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” Estimated Effects on the Supplemental Nutrition Assistance Program of Eliminating California’s SSI Cash-Out Policy Final Report February 12, 2010 Karen Cunnyngham Page is left intentionally blank to allow for double-sided copying Mathematica Reference Number: 06499 Submitted to: California Food Policy Advocates 116 New Montgomery St., Suite 633 San Francisco, CA 94105 Project Officer: George Manalo-LeClair Submitted by: Mathematica Policy Research 600 Maryland Avenue, SW Suite 550 Washington, DC 20024-2512 Telephone: (202) 484-9220 Facsimile: (202) 863-1763 Project Director: Karen Cunnyngham Estimated Effects on the Supplemental Nutrition Assistance Program of Eliminating California’s SSI Cash-Out Policy Final Report February 12, 2010 Karen Cunnyngham Mathematica Policy Research ii ACKNOWLEDGMENTS This work benefited from the contributions of a number of people at Mathematica. Bruce Schechter conducted the majority of the computer programming for this project, and Joel Smith assisted with the microsimulation model development. Jackie Kauff reviewed the draft report, Carole Trippe and Andrew Gothro reviewed the final report, and Jane Retter and Lisa Walls assisted with editing and formatting. George Manalo-LeClair and Cathy Hsu at the California Food Policy Advocates developed the policy scenarios simulated in the research, and Mr. Manalo-LeClair reviewed the draft report. The microsimulation model used in this research is based on a model developed by Mathematica for the U.S. Department of Agriculture’s Food and Nutrition Service (FNS). The most recent update of the model used by FNS was conducted by a Mathematica team led by Carole Trippe. Mathematica Policy Research iii ABSTRACT For this research project, Mathematica Policy Research used a computer model that simulates the Supplemental Nutrition Assistance Program (SNAP) to estimate the effects on SNAP eligibility and benefit amounts of eliminating California’s Supplemental Security Income (SSI) cash-out policy. When the state implemented the SSI cash-out policy in 1974, many SSI recipients qualified only for the minimum SNAP benefit of $10. By making SSI recipients ineligible for SNAP while simultaneously raising the SSI state supplemental payment (SSP) by $10, California was able to save on SNAP administrative costs without reducing benefits for most recipients. Furthermore, a study conducted by Mathematica for the California Food Policy Advocates (CFPA) in 2002 found that ending SSI cash-out in 2000 would have reduced the total amount of SNAP benefits for which Californians qualified. Changes to SNAP, California’s SSP, and the economy since 2000 mean that many SSI recipients who are living alone or only with other SSI recipients would now qualify for larger SNAP benefits. Consequently, CFPA asked Mathematica to reassess the effect on SNAP eligibility and benefit amounts of eliminating California’s SSI cash-out policy. Mathematica did this by simulating the elimination of SSI cash-out under three scenarios. Under the first, we simulated ending SSI cash-out using the current SSP. Under the second, we first simulated a reduction in the maximum combined SSI\/SSP for single SSI recipients and then simulated ending SSI cash-out for all SSI recipients. The third scenario simulates ending SSI cash-out only for one-person households and includes several other policy changes. Based on our research, we estimate that ending California’s SSI cash-out policy under the current regulatory environment would increase the number of California households eligible for SNAP. However, we also estimate that total SNAP benefits flowing into the state would decrease. Further, we estimate that under both the second and third scenarios, total California SNAP benefits for which eligible households would qualify would rise along with the number of eligible households. Under all three scenarios, ending SSI cash-out would substantially increase the percentage of eligible households qualifying for the minimum benefit. Mathematica Policy Research iv Mathematica Policy Research v CONTENTS I. INTRODUCTION ………………………………………………………………………………………….. 1 II. RESEARCH OBJECTIVES ………………………………………………………………………………… 3 III. METHODOLOGY ………………………………………………………………………………………… 4 A. SNAP Unit Formation …………………………………………………………………………… 5 B. Determining SNAP Eligibility …………………………………………………………………. 6 C. Simulating SNAP Participation ……………………………………………………………….. 8 D. Four Simulation Scenarios ……………………………………………………………………. 8 IV. FINDINGS 10 A. Estimated Effects of Eliminating SSI Cash-out Under Current Regulatory Environment …………………………………………………………………………………….. 12 B. Estimated Effects of Eliminating SSI Cash-out After Lowering the Maximum Combined SSI\/SSP for Single People …………………………………………………….. 16 C. Estimated Effects of Eliminating SSI Cash-out for One-Person Households with 100 Percent Participation by Newly Eligible Households, Implementing a Standard Medical Deduction, and Lowering the Standard Utility Allowance ………………………………………………………………………………. 20 D. Summary …………………………………………………………………………………………. 25 APPENDIX A DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT UNDER CURRENT REGULATORY ENVIRONMENT ………………..A.1 APPENDIX B DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT AFTER LOWERING THE MAXIMUM COMBINED SSI\/SSP FOR SINGLE PEOPLE ………………………………………………………………………… B.1 APPENDIX C DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT FOR ONE-PERSON HOUSEHOLDS WITH 100 PERCENT PARTICIPATION BY NEWLY ELIGIBLE HOUSEHOLDS, IMPLEMENTING A STANDARD MEDICAL DEDUCTION, AND LOWERING THE STANDARD UTILITY ALLOWANCE ………………………………………………………………….C.1 Mathematica Policy Research vi TABLES 1 Estimated Percentage Change in California SNAP Eligibility, Participation, and Benefits Under Three Reform Simulations ………………………………………….. 10 2 Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out ………………………………………………………………………………………. 13 3 Estimated Numbers and Characteristics of California SNAP Households in an Average Month Under Simulation to Eliminate SSI Cash-Out, by Change in Eligibility Status and Potential Benefit ………………………………………………….. 15 4 Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out After Lowering the SSI\/SSP for Single People ………………………….. 17 5 Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out After Lowering the SSI\/SSP for Single People, by Change in Eligibility Status and Potential Benefit …………………………………………………….. 19 6 Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out for One-Person Households, Implement a Standard Medical Deduction, and Lower the SUA ………………………………………………………………. 22 7 Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out for One-Person Households, Implement a Standard Medical Deduction, and Lower the SUA by Change in Eligibility Status and Potential Benefit ………………………………………………………………………………………………. 24 8 Summary of Estimated Effects of Simulations to Eliminate SSI Cash-Out on Eligible Households, Individuals, and Benefits and Percentage of Eligible Households Qualifying for the Minimum Benefit ……………………………………….. 26 Mathematica Policy Research 1 I. INTRODUCTION In work for the California Food Policy Advocates (CFPA), Mathematica Policy Research used a computer model that simulates the Supplemental Nutrition Assistance Program (SNAP, formerly the Food Stamp Program) to estimate the effects on SNAP eligibility and benefit amounts of eliminating California’s Supplemental Security Income (SSI) cash-out policy. Under the SSI cash-out policy, California SSI recipients are ineligible for SNAP. When this policy was implemented in 1974, California increased the SSI State Supplementary Payment (SSP) by $10, the amount of SNAP benefits for which many SSI recipients qualified at the time. By providing cash through the SSP instead of SNAP benefits, the state was able to save on SNAP administrative costs without reducing benefits for most recipients. A study conducted by Mathematica for CFPA in 2002 found that ending SSI cash-out in 2000 would have reduced the total amount of SNAP benefits for which Californians qualified.1 However, because of changes to SNAP, California’s SSP, and the economy, many SSI recipients who are living alone or only with other SSI recipients would now qualify for larger SNAP benefits. This has raised questions about whether the results from the 2002 study are still valid. In response, CFPA asked Mathematica to reassess the effect on SNAP eligibility and benefit amounts of eliminating California’s SSI cash-out policy. Mathematica examined the effects of ending SSI cash-out under three scenarios specified by CFPA. Under the first scenario, we simulated ending SSI cash-out using the current SSP. Under the second scenario, we simulated the reduction in the maximum combined SSI\/SSP for single SSI recipients included in the California Governor’s proposed budget for 2010-11. This simulation reduces the maximum SSI\/SSP to the minimum required by federal law (the maximum SSI\/SSP for 1 Cunnyngham, Karen. \u2015Modeling the Impact of Eliminating SSI Cash-out in California.\u2016 Memorandum submitted to the California Food Policy Advocates. Washington, DC: Mathematica Policy Research, December 2002. Mathematica Policy Research 2 married SSI recipients is already at the federal minimum) and then ends SSI cash-out for all SSI recipients. The third scenario incorporates several policy changes and is designed to estimate the effects of a best-case simulation. Under this scenario, we simulated ending SSI cash-out only for one-person households and required all newly eligible SNAP households to participate. Limiting the population for which SSI cash-out is eliminated removes the possibility of currently eligible people losing eligibility or benefits when household members receiving SSI join the SNAP filing unit. We also simulated implementing a Standard Medical Deduction, which increases the SNAP benefit for which some households qualify. Finally, because FNS requires that states maintain cost-neutrality when implementing a Standard Medical Deduction, we simulated a slight reduction in the Standard Utility Allowance (SUA). Based on our research, we estimate that ending California’s SSI cash-out policy under the current regulatory environment would increase the number of California households and individuals eligible for and participating in SNAP. However, we also estimate that both the average monthly SNAP benefit for California SNAP households and total SNAP benefits flowing into the state would decrease. Further, we estimate that under both the second and third scenarios, total California SNAP benefits would rise along with the number of eligible and participating SNAP households and individuals. The largest increase in total benefits would be for households participating under the third scenario. However, the average monthly SNAP benefit would still decrease under these scenarios. In this paper, we describe our research objectives and methodology and provide a detailed discussion of our conclusions. Mathematica Policy Research 3 II. RESEARCH OBJECTIVES In the earlier work for CFPA, Mathematica used a Current Population Survey (CPS)-based microsimulation model to estimate the effect of eliminating the SSI cash-out policy in 2000. We found that doing so would have increased the number of Californians eligible for SNAP but reduced the total amount of SNAP benefits coming into the state. Households that would have gained under the policy change include those consisting solely of SSI recipients (pure SSI households) that would have become newly eligible for SNAP. However, these households would have qualified for a relatively small average benefit of $16. Conversely, some households consisting of both SSI recipients and nonrecipients (mixed SSI households) would have lost benefits under the policy change. Overall, Mathematica estimated a 12 percent net loss in SNAP benefits to Californians if the SSI cash-out policy had been eliminated in 2000. Several important changes have been made to SNAP since 2000, both nationally and in California. For example, SNAP maximum and minimum benefits were increased, noncitizen eligibility was expanded, and California eliminated the SNAP asset test for households with children. In addition, the amount of California’s SSP was reduced. The objective of the research presented here is to provide information to help determine whether, given these changes, California’s SSI cash- out policy should be reconsidered. Specifically, Mathematica addressed the following questions: Under fiscal year 2009 SNAP rules, would ending California’s SSI cash-out policy result in a net increase or decrease in California SNAP benefits? What are the characteristics of households that would gain benefits or lose benefits under the policy change? Are there policy scenarios under which the elimination of SSI cash-out would result in a net increase in SNAP benefits to California households? Mathematica Policy Research 4 III. METHODOLOGY Mathematica addressed these questions with a computer model\u2014the 2009 Baseline of the 2005 MATH\u00ae SIPP+. The model was developed by Mathematica for FNS, who uses it to estimate the effects of potential changes to SNAP during preparation of the President’s budget submission and in response to policy changes proposed by Congress. The model is also the basis for reports and memoranda detailing the characteristics of the SNAP eligible and participating populations. Like other microsimulation models, the MATH SIPP+ has two components\u2014an underlying database and a series of computer programs. The database consists of individual household records that contain detailed information about household income, assets, expenses, and demographics. The computer programs, acting as an \u2015electronic caseworker,\u2016 apply SNAP eligiblity rules to each household in the database to determine whether the household would be eligible for SNAP and, if so, the benefit to which it would be entitled. The model also predicts which eligible households participate in SNAP. For the model’s baseline, the predicted participant population is calibrated to match participant totals and characteristics from SNAP administrative data. The MATH SIPP+ model is based on data from both the Survey of Income and Program Participation (SIPP) and the CPS Annual Social and Economic Supplement (ASEC). The SIPP serves as the model’s underlying database because it contains the data on household income, assets, and expenses needed to determine SNAP eligiblity and benefit amounts. However, the SIPP sample is relatively small and is not representative at the state level. To overcome these weakenesses, the MATH SIPP+ model also incorporates CPS ASEC data. While not containing information on assets and expenses, CPS ASEC data provides a larger sample than the SIPP and is representative at the state level. The CPS data is used to reweight the SIPP data in such a way that the MATH SIPP+ model can be used for state-level simulations. In brief, each household in the underlying SIPP database is assigned a set of state weights\u2014one for each state\u2014that are derived from the original SIPP weight and are based on state demographic and economic household characteristics from the Mathematica Policy Research 5 CPS ASEC. Through these state weights, the MATH SIPP+ model uses data on all households in the sample, regardless of their state of residence, to simulate SNAP eligibility in each state. The 2009 Baseline of the 2005 MATH SIPP+ model uses September 2005 SIPP data, 2005 and 2006 CPS ASEC data, and fiscal year 2008 SNAP administrative data. The September 2005 SIPP data was chosen because it is the most recent data available that includes the information on household assets and expenses necessary to simulate SNAP eligibility. The 2005 and 2006 CPS ASEC data was selected to be consistent with the SIPP data. Finally, the 2008 SNAP administrative data is most recent data of its type available. The SNAP administrative data is used to calibrate the 2005 SIPP data so the characteristics of the simulated SNAP population resemble those of the actual SNAP population in 2008. The version of the model used in this research simulates SNAP eligibility rules in California in fiscal year 2009 and incorporates policy changes included in the 2009 American Reinvestment and Recovery Act (ARRA), California’s SNAP asset and categorical eligibility policies, and California’s current SSP amounts. Below we describe some important aspects of the model. For more information on the 2009 Baseline of the MATH SIPP+ model, please see Smith (forthcoming).2 A. SNAP Unit Formation An important step in determining SNAP eligibility is identifying which household members would be required to apply for SNAP together as a unit. SNAP applicants are more likely to be eligible and to qualify for a larger benefit if their filing unit does not include household members with relatively high assets and\/or income. However, regulations require that the assets and income of certain household members be considered together when determining SNAP eligibility. 2 Smith, Joel. \u2015Technical Working Paper: Creation of the September 2009 Baseline of the 2005 MATH SIPP+ Model and Database.\u2016 Washington, DC: Mathematica Policy Research, forthcoming. Mathematica Policy Research 6 A SNAP unit generally comprises everyone who lives in the same household and purchases and prepares meals together. Immediate family members, such as spouses or people under age 22 living with their parents, are almost always part of the same SNAP unit, even if they purchase and prepare meals separately. On the other hand, people who are both elderly and disabled and share meals with other household members may form a separate SNAP unit, either alone or with a spouse, under certain circumstances. The MATH SIPP+ model uses these unit formation rules to assign individuals to a SNAP unit. If a household reports receipt of SNAP benefits in the SIPP, data on the composition of the reported SNAP units are used to form simulated SNAP units. For households that do not report receiving SNAP benefits, other information on the SIPP, such as family relationships and those in the household sharing food expenses, is used to assign individuals to simulated SNAP units. California SSI recipients are assigned to a SNAP unit but are excluded from eligibility. As a result, their assets and income are not considered in the simulated SNAP eligibility and benefit determinations. B. Determining SNAP Eligibility To be asset-eligible for SNAP under federal rules, most SNAP units that contain an elderly or disabled person can have no more than $3,000 in countable assets and other SNAP units can have no more than $2,000 in countable assets. Pure public assistance households\u2014those in which every member receives income from SSI, Temporary Assistance for Needy Families (TANF), or General Assistance\u2014are categorically eligible for SNAP, meaning they are not subject to the asset or income tests. The MATH SIPP+ model uses asset information reported on the SIPP to determine a SNAP unit’s countable assets. Most financial assets are counted toward the SNAP asset limit, although tax- preferred retirement and education accounts are excluded. The assets of TANF and SSI recipients are also excluded from countable assets. In addition to these federal exclusions, California has not Mathematica Policy Research 7 included the value of vehicles in SNAP countable assets since 2004, and recently passed legislation that exempts households with children from the SNAP asset test entirely. To be income-eligible for SNAP, units that are not pure public assistance must have a combined gross income under 130 percent of the federal poverty guideline and net income under 100 percent of the federal poverty guideline. SNAP units that contain an elderly or disabled person are exempt from the gross income test. Net income is calculated by subtracting certain deductions from gross income. Every SNAP unit is allowed a standard deduction, the amount of which is based on geographic location and household size. In addition, a unit may deduct shelter costs that exceed 50 percent of the unit’s countable income after subtracting all other deductions. Although units with an elderly person are not subject to a cap on this deduction, in fiscal year 2010 other units cannot claim an excess shelter deduction of greater than $459. Households may also deduct out-of-pocket medical expenses incurred by elderly or disabled members in excess of $35 per month. Finally, households may deduct 20 percent of household earnings; the cost of dependent care incurred while other household members work, seek employment, or attend school; and legally obligated child support expenses. Most of the income amounts used by the MATH SIPP+ model to determine SNAP income- eligibility are reported on the SIPP. However, receipt of both SSI and TANF benefits is underreported in most surveys, including the SIPP, so the model simulates eligibility, participation, and benefit amount for these programs. The SIPP also includes the information on shelter, medical, dependent care, and child support expenses needed to determine income deductions. The benefit amount for which an eligible SNAP unit qualifies is determined by subtracting 30 percent of its net income from the maximum benefit for its unit size. Eligible SNAP units that contain only one or two people are entitled to a minimum benefit, currently $16. Mathematica Policy Research 8 C. Simulating SNAP Participation After SNAP eligibility is determined for each household in the database, the MATH SIPP+ model selects certain eligible SNAP households to be simulated SNAP participants. The model uses a complex selection process to ensure that the state totals and characteristics of the simulated SNAP participant population in the model baseline are similar to those seen in SNAP administrative data. The version of the MATH SIPP+ model used in this analysis was calibrated to match 2008 SNAP totals and characteristics, the most recent data available at the time. This model can be used to estimate the effects of a policy change on SNAP eligibility, participation, and benefit levels by modifying the rules that are simulated. For instance, as part of this research, the model simulated an elimination of SSI cash-out by adding SSI recipients’ income to their SNAP units’ income totals and re-determining the SNAP units’ eligibility and benefit amounts. For units that became newly eligible for SNAP under the new simulation, the MATH SIPP+ model predicted whether the unit would participate by using the unit’s characteristics and an equation based on the characteristics of current SNAP participants. In addition, the model predicted whether eligible units that qualified for a different benefit amount under the new simulation would change their participation decisions. For instance, some eligible units that did not participate in the baseline simulation but qualified for a larger benefit under a new scenario were simulated to newly participate. D. Four Simulation Scenarios For this research, we first simulated a California \u2015baseline,\u2016 which incorporates post-ARRA federal SNAP rules and California’s new policy of exempting households with children from the SNAP asset test. The simulation uses a maximum combined federal and state SSI\/SSP benefit amount of $845 for single people and $1,407 for couples. We used this baseline to conduct three \u2015reform\u2016 simulations that estimate the effect on California SNAP eligibility, participation, and benefits of changing SNAP policies and, in one case, Mathematica Policy Research 9 California’s SSP. For the first reform simulation, we ended SSI cash-out for all California households. In the second reform simulation, we first created a new baseline by lowering the maximum combined SSI\/SSP for single people from $845 to $830, the minimum allowed by federal law, and then ended SSI cash-out for all households. For the final \u2017best-case scenario’ reform simulation, we ended SSI cash-out only for one-person households and required participation by all newly eligible households. This reform simulation also implemented a standard medical deduction of $124 for households with an elderly or disabled member with qualifying medical expenses of $36 $159 and, to maintain federally-required cost-neutrality, a $6 reduction in the SUA for all households with utility expenses. (The medical deduction of households with medical expenses of $160 or more remained unchanged at the amount of the medical expenses minus a threshold of $35.) The results of the three reform simulations are described below. In the tables that show the characteristics of households eligible for and participating in SNAP under the three reform scenarios, the characteristics displayed are of households after SSI cash-out has been ended (Tables 2, 4, and 6). In the tables that show the characteristics of households gaining or losing eligibility or benefits under the three simulations, the characteristics of newly eligible households are, again, of households after SSI cash-out is eliminated (Tables 3, 5, and 7). However, the characteristics of households losing eligibility, with higher benefits, or with lower benefits are of households before SSI cash-out is eliminated. This is to capture the effects on currently eligible households of ending SSI cash-out. Mathematica Policy Research 10 IV. FINDINGS The estimated number of eligible and participating California households and individuals increases under all three reform simulations (Table 1). Under the first reform simulation, which ends SSI cash- out for all California households, the estimated number of SNAP eligible and participating households increases by 17 and 5 percent, respectively, and the number of eligible and participating individuals increases by 11 and 8 percent, respectively. The second reform simulation, which differs from the first only in the maximum SSI\/SSP payment to single people (in both the baseline and the reform simulations), produces results very similar to the first. The third simulation, which ends SSI cash-out for only one-person households and simultaneously makes other programmatic changes, has a much larger effect on the estimated number of SNAP participants\u2014a 48 percent increase for households and a 20 percent increase for individuals. All of these estimates are statistically significant at the 99-percent confidence level. Table 1. Estimated Percentage Change in California SNAP Eligibility, Participation, and Benefits Under Three Reform Simulations Percentage Change from Baseline Under Reform Simulation First Reform Second Reform Third Reform Eligible Participating Eligible Participating Eligible Participating Total households 17 5 17 6 17 48 Total individuals 11 8 11 8 7 20 Total benefits -0.3 -1 2 -0.4 3 7 Average benefit -15 -7 -13 -6 -12 -27 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: The first reform eliminates SSI cash-out. The second reform lowers the maximum SSI\/SSP for singles and eliminates SSI cash-out. The third reform eliminates SSI cash-out for one-person households, implements a Standard Medical Deduction, and lowers the Standard Utility Allowance. The effects of the reform simulations on total California SNAP benefits differ substantially across the reforms. Under the first reform simulation, the total amount of SNAP benefits for which Mathematica Policy Research 11 eligible households qualify remains essentially unchanged, but the total amount of SNAP benefits received by SNAP participants decreases by one percent (statistically significant at the 90-percent confidence level). The benefit decrease is the result of some current SNAP households becoming ineligible and others qualifying for lower SNAP benefits when the income of an SSI recipient in the household is considered in the SNAP eligibility and benefit determinations. These decreases offset the increased benefits to newly eligible SNAP households and to some current SNAP households qualifying for higher SNAP benefits under the simulation. If a smaller California SSP benefit were in place when SSI cash-out is eliminated, households containing SSI recipients would more likely be eligible for SNAP and, if eligible, would qualify for larger SNAP benefits. This is seen in the results of the second reform simulation, which simulates this scenario: total SNAP benefits for eligible households rise by two percent (statistically significant at the 99-percent confidence level) and hold constant for participating households. Under the third reform simulation, only one-person SSI households become eligible for SNAP, a policy that ensures currently eligible households will not lose eligibility when SSI cash-out is eliminated. In addition, all newly eligible households are simulated to participate in SNAP, so the maximum amount of newly possible benefits are delivered. The Standard Medical Deduction simulated in the third reform is set up similarly so that no household will lose SNAP eligibility or benefits due to its implementation. Conversely, the small simulated reduction in the SUA results in a very few households losing eligibility and a slight benefit reduction for households with a shelter deduction that are not already receiving the minimum or maximum benefit. Under this reform simulation, estimated total benefits increase by three and seven percent for eligible and participating SNAP households, respectively. The estimated average SNAP benefit for eligible and participating California households decreases under all three reform simulations. The percentage decrease in average SNAP benefits for eligible households is similar across the three reform simulations, ranging between 12 and 15 Mathematica Policy Research 12 percent. For participating households, however, the decrease in the average SNAP benefit under the third reform simulation (27 percent) is substantially greater than the decrease under the first and second reform simulations (7 and 6 percent, respectively). These decreases are all statistically significant at the 99-percent confidence level. We discuss the results from each reform simulation, including the characteristics of \u2015gainers\u2016 and \u2015losers,\u2016 in more detail in the sections below. A. Estimated Effects of Eliminating SSI Cash-out Under Current Regulatory Environment This section summarizes the major effects of the first reform simulation, which eliminates SSI cash-out. More detailed results can be found in the tables in Appendix A. Table 2 presents estimated numbers of eligible and participating households and individuals after SSI cash-out is eliminated, the total benefits for which they qualify, and percentage changes from the baseline simulation. The table also shows the percentage of households with selected socioeconomic characteristics after SSI cash- out is eliminated along with average benefit and income amounts. For instance, Table 2 shows that when SSI cash-out is eliminated, an estimated 23 percent of eligible households and 17 percent of participating households contain an SSI recipient. As mentioned, under the simulation the estimated number of eligible and participating SNAP households increases by 17 and 5 percent, respectively. However, some socioeconomic subgroups experience a disproportionally large increase relative to the overall increase. For instance, the number of eligible SNAP households qualifying for the minimum benefit increases by over 100 percent and the number of participating households receiving the minimum benefit increases by over 200 percent. This group comprises an estimated 21 and 4 percent of the eligible and participating populations, respectively. In contrast, the number of eligible and participating households receiving the maximum benefit decreases by eight and five percent, respectively. However, this group forms a much larger share of Mathematica Policy Research 13 the participating population (37 percent) than households receiving the minimum benefit. Among eligible households, an estimated 19 percent qualify for the maximum benefit\u2014about the same percentage as qualify for the minimum benefit. Table 2. Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out All California Households Eligible for SNAP Percent Change a Participating in SNAP Percent Change a Total households (number in 000s) 2,678 17 *** 938 5 *** Total individuals (number in 000s) 6,193 11 *** 2,407 8 *** Total benefits (dollars in 000s) 597,040 0 301,370 -1 * Percentage of Total Households With income from 1-100 percent of poverty 56 27 *** 67 3 With earnings 45 -1 33 3 * With TANF 15 -2 *** 32 -2 * With SSI 23 *** 17 *** Qualifying for minimum benefit 21 134 *** 4 232 *** Qualifying for maximum benefit 19 -8 *** 37 -5 *** Claiming shelter deduction 50 10 *** 72 5 *** Claiming medical deduction 11 51 *** 4 68 *** In one-person SNAP household 44 31 *** 31 4 In two-person SNAP household 21 22 *** 25 4 In larger SNAP household 35 2 44 7 *** With elderly members 23 89 *** 10 88 *** With disabled nonelderly adults 13 201 *** 9 423 *** With children 52 -2 *** 67 0 Average Amounts (Dollars) Monthly benefit 223 -15 *** 321 -7 *** Monthly gross income 1,056 2 * 828 16 *** Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics are of the SNAP unit after SSI cash-out is eliminated. a Percent change from numbers, total benefits, or average amounts under baseline rules. * Change is statistically different from zero at a 90 percent level of significance. ** Change is statistically different from zero at a 95 percent level of significance. *** Change is statistically different from zero at a 99 percent level of significance. Mathematica Policy Research 14 The number of eligible households with children decreases by two percent and the number of participating households with children remains unchanged. Despite the reduced or unchanged numbers, over half of all eligible households and two-thirds of all participating households contain at least one child. The number of eligible and participating households with earnings or with TANF does not change by more than three percent. The average monthly benefit decreases by 15 percent to $223 for eligible households and by 7 percent to $321 for participating households. Average monthly gross income increases by 2 percent to $1,056 for eligible households and by 16 percent to $828 for participating households. Characteristics of Households Gaining or Losing Under the First Reform Simulation. Under the simulation to end SSI cash-out, 455,000 households become newly eligible, 61,000 become newly ineligible, and 160,000 remain eligible but qualify for higher (26,000 households) or lower (134,000 households) benefits. Table 3 shows the estimated numbers of households and individuals and total benefits for these four types of households as well as selected socioeconomic characteristics and average benefit and income amounts. While the characteristics of newly eligible households are after SSI cash-out is eliminated, as in Table 2, the characteristics of the other three groups are from before SSI cash-out is eliminated and thus do not include SSI recipients. The average monthly benefit and total benefits for which these four types of households qualify under the first reform simulation explain why total benefits for eligible households do not increase under the simulation even though the number of eligible households and individuals does increase. Under the first reform simulation, newly eligible households, which have an average benefit of $39, qualify for a total of almost $18 million in SNAP benefits per month, and eligible households qualifying for higher benefits (with an average benefit of $336) qualify for an additional $2 million per month. However, eligible households qualifying for lower benefits (with an average benefit of $314) lose over $13 million per month, and newly ineligible households, which have an average benefit of $136, lose over $8 million per month. Because the amount of lost benefits is greater than Mathematica Policy Research 15 the amount of gained benefits, the net change in total benefits under the simulation is slightly negative. (The change is not statistically significant at the 90-percent confidence level.) Table 3. Estimated Numbers and Characteristics of California SNAP Households in an Average Month Under Simulation to Eliminate SSI Cash-Out, by Change in Eligibility Status and Potential Benefit California Households Affected by Simulation Newly Eligible for SNAP Newly Ineligible for SNAP Still Eligible for SNAP With Higher Benefit With Lower Benefit Total households (number in 000s) 455 61 26 134 Total individuals (number in 000s) 542 129 40 318 Total benefits (dollars in 000s) 17,939 8,300 1,972 a -13,208 a Percentage of Total Households In poverty 78 46 90 98 With earnings 5 73 14 18 With TANF 0 17 9 53 With SSI 100 0 0 0 Qualifying for minimum benefit 73 15 1 0 Qualifying for maximum benefit 3 5 77 29 Claiming shelter deduction 27 12 39 29 Claiming medical deduction 21 7 16 3 In one-person SNAP household 81 37 71 39 In two-person SNAP household 18 27 12 22 In larger SNAP household 0 36 16 38 With elderly members 60 13 18 7 With disabled nonelderly adults 34 13 6 5 With children 1 56 35 79 Average Amounts (Dollars) Monthly benefit 39 136 336 314 Monthly gross income 938 1,135 1,134 673 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics of newly eligible households are after SSI cash-out is eliminated. Characteristics of households losing eligibility, with higher benefits, or with lower benefits are before SSI cash-out is eliminated. a Total increase or decrease in benefits. Mathematica Policy Research 16 Not surprisingly, the characteristics of these four types of households differ substantially from each other. Of the households that become newly eligible under the simulation, 81 percent are one- person SNAP households, 60 percent contain an elderly member, and only 6 percent contain a child. By contrast, among households that become ineligible under the simulation, before they became ineligible, 37 percent were one-person SNAP households, 13 percent contained an elderly member, and 34 percent contained a child. Among eligible households that qualify for higher benefits, before SSI cash-out was eliminated, 77 percent qualified for the maximum benefit for their household size, 71 percent were one-person SNAP households, and 35 percent contained children. Among eligible households that qualified for lower benefits, before SSI cash-out was eliminated, 29 percent were eligible for the maximum benefit, 39 percent were one-person SNAP households, and 79 percent contained children. B. Estimated Effects of Eliminating SSI Cash-out After Lowering the Maximum Combined SSI\/SSP for Single People This section summarizes the major effects of the second reform simulation, which ends SSI cash-out after the maximum combined SSI\/SSP for single people is lowered from $845 to $830. More detailed results can be found in the tables presented in Appendix B. The results of the second reform simulation are similar, although not identical, to the results of the first reform simulation. For instance, under the second reform simulation, an estimated 22 percent of eligible households and 17 percent of participating households contain an SSI recipient, similar to the corresponding percentages under the first reform simulation (Table 4). Slightly more households and individuals are eligible under the second reform simulation than under the first, and slightly more households and individuals are simulated to participate. In addition, households eligible and participating under the second reform simulation have slightly lower gross incomes ($1,047 for eligible households, $824 for participating households) than under Mathematica Policy Research 17 Table 4. Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out After Lowering the SSI\/SSP for Single People All California Households Eligible for SNAP Percent Change a Participating in SNAP Percent Change a Total households (number in 000s) 2,706 17 *** 955 6 *** Total individuals (number in 000s) 6,291 11 *** 2,448 8 *** Total benefits (dollars in 000s) 614,322 2 *** 307,780 0 Percentage of Total Households With income from 1 100 percent of poverty 58 31 *** 69 6 *** With earnings 46 1 * 33 2 ** With TANF 15 -1 ** 32 -1 With SSI 22 *** 17 *** Qualifying for minimum benefit 20 109 *** 4 158 *** Qualifying for maximum benefit 20 -7 *** 36 -4 *** Claiming shelter deduction 51 11 *** 72 6 *** Claiming medical deduction 11 41 *** 5 70 *** In one-person SNAP household 43 31 *** 31 3 In two-person SNAP household 21 18 *** 26 8 * In larger SNAP household 36 4 *** 43 7 *** With elderly members 23 75 *** 11 79 *** With disabled nonelderly adults 13 189 *** 10 431 *** With children 53 0 66 0 Average Amounts (Dollars) Monthly benefit 227 -13 *** 322 -6 *** Monthly gross income 1,047 0 824 15 *** Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics are of the SNAP unit after SSI cash-out is eliminated. a Percent change from numbers, total benefits, or average amounts under revised baseline rules. * Change is statistically different from zero at a 90 percent level of significance. ** Change is statistically different from zero at a 95 percent level of significance. *** Change is statistically different from zero at a 99 percent level of significance. the first reform simulation and qualify for slightly higher average benefits ($227 for eligible households, $322 for participating households). As a result, total benefits for which eligible Mathematica Policy Research 18 households qualify under the second simulation increase by two percent and total benefits for participating households remain constant. This contrasts to no change in eligible benefits under the first reform simulation and a one percent decrease in participating benefits. As under the first reform simulation, the number of eligible and participating households qualifying for the minimum benefit increases disproportionately under the second reform simulation, although to a slightly lesser extent than under the first\u2014109 percent for eligible households and 158 percent for participating households. Similarly, the number of eligible and participating households with a disabled nonelderly member or with an elderly member also increases substantially under the second reform simulation. The number of eligible and participating households qualifying for the maximum benefit decreases under the second reform simulation, although the decreases were slightly less than under the first reform simulation. Unlike under the first reform simulation, the number of eligible and participating households with children remains unchanged under the second reform simulation. Characteristics of Households Gaining or Losing Under the Second Reform Simulation. Under the second reform simulation, fewer households become newly eligible (435,000), newly ineligible (37,000), and remain eligible but qualify for lower benefits (128,000) than under the first reform simulation (Table 5). However, more households remain eligible but qualify for higher benefits (54,000). Although fewer households become newly eligible when SSI cash-out is eliminated, more households are already eligible before SSI cash-out is ended then under the first reform simulation. This is because the lower combined SSI\/SSP payment for single people under this simulation means that slightly fewer people are eligible for SSI and thus ineligible for SNAP. The average monthly benefit and total benefits for which these types of households qualify under the second reform simulation also differ from the average and total benefits under the first reform simulation. Newly eligible households have a higher average benefit ($58) and higher total Mathematica Policy Research 19 Table 5. Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out After Lowering the SSI\/SSP for Single People, by Change in Eligibility Status and Potential Benefit California Households Affected by Simulation Newly Eligible for SNAP Newly Ineligible for SNAP Still Eligible for SNAP With Higher Benefit With Lower Benefit Total households (number in 000s) 435 37 54 128 Total individuals (number in 000s) 520 70 101 310 Total benefits (dollars in 000s) 25,107 3,871 2,810 a -11,560 a Percentage of Total Households In poverty 89 37 79 96 With earnings 7 61 36 22 With TANF 0 16 19 49 With SSI 100 0 0 0 Qualifying for minimum benefit 65 23 0 0 Qualifying for maximum benefit 4 5 39 28 Claiming shelter deduction 30 15 39 32 Claiming medical deduction 19 9 8 4 In one-person SNAP household 82 47 51 38 In two-person SNAP household 16 26 21 23 In larger SNAP household 1 27 28 39 With elderly members 57 15 14 6 With disabled nonelderly adults 36 25 6 7 With children 2 44 50 79 Average Amounts (Dollars) Monthly benefit 58 105 294 312 Monthly gross income 872 1,105 1,104 729 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics of newly eligible households are after SSI cash-out is eliminated. Characteristics of households losing eligibility, with higher benefits, or with lower benefits are before SSI cash-out is eliminated. a Total increase or decrease in benefits. benefits ($25 million). Eligible households qualifying for a higher benefit have a lower average monthly benefit ($294) but still qualify for more total additional benefits ($3 million) than under the first reform simulation. Households that become newly ineligible have an average benefit of $105 Mathematica Policy Research 20 and lose $4 million in total benefits, both less than under the first reform simulation. Finally, eligible households qualifying for lower benefits have an average benefit of $312, about the same as under the first reform simulation but lose fewer total benefits ($12 million). Of the households that become newly eligible under the second reform simulation, 82 percent are one-person households, 57 percent contain an elderly member, and only 2 percent contain a child. Among newly ineligible households, before they became ineligible, 47 percent were one- person households, 15 percent contained an elderly member, and 44 percent contained a child. These percentages differ by one to 10 percentage points from the corresponding percentages under the first reform simulation. The differences between the first and second reform simulations in household composition among eligible households that qualify for higher benefits are pronounced. Before SSI cash-out was eliminated under the second reform simulation, 39 percent qualified for the maximum benefit, 51 percent were in one-person SNAP households, and 50 percent contained children. On the other hand, the characteristics of eligible households that qualified for lower benefits are similar under the two simulations. Before SSI cash-out was eliminated under the second reform simulation, 28 percent were eligible for the maximum benefit, 38 percent were in one-person SNAP households, and 79 percent contained children. C. Estimated Effects of Eliminating SSI Cash-out for One-Person Households with 100 Percent Participation by Newly Eligible Households, Implementing a Standard Medical Deduction, and Lowering the Standard Utility Allowance This section summarizes the major effects of the third reform simulation, which eliminates SSI cash-out for one-person households with 100 percent participation by newly eligible households, implements a Standard Medical Deduction, and slightly lowers the SUA. More detailed results from the third reform simulation can be found in the tables presented in Appendix C. Mathematica Policy Research 21 The net increase in the number of eligible households under the third reform simulation is similar to the net increases in eligible households under the first two reform simulations, 17 percent (Table 6). However, the estimated number of participating households increases by almost 50 percent under the third reform simulation. This increase is much higher than under the first two reform simulations because, under the third reform simulation, all newly eligible households are simulated to participate. The total benefits for which eligible and participating households qualify increase by three and seven percent, respectively. The seven percent increase in benefits to participants is in contrast to net decreases under the first two simulations. However, the average monthly benefit for which both eligible and participating households qualify decreases by 12 percent to $230 and 27 percent to $249, respectively. Fourteen percent of eligible households contain an SSI recipient as do 28 percent of participating households. Although the characteristics of households eligible under the third reform simulation are relatively similar to those under the first reform simulation, the characteristics of participating households differ substantially. For example, the number of eligible households qualifying for the minimum benefit increases by just over 100 percent under the third reform simulation and comprises 19 percent of the eligible population, similar to corresponding results under the first reform simulation. The number of participating households qualifying for the minimum benefit under the third reform simulation, however, increases dramatically to comprise 22 percent of the participating population as opposed to 4 percent under the first reform simulation. The number of participating households with disabled nonelderly adults or with elderly members also increases substantially. Under the third reform simulation, these groups comprise 21 and 12 percent, respectively, of participating households. Mathematica Policy Research 22 Table 6. Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out for One- Person Households, Implement a Standard Medical Deduction, and Lower the SUA All California Households Eligible for SNAP Percent Change a Participating in SNAP Percent Change a Total households (number in 000s) 2,673 17 *** 1,314 48 *** Total individuals (number in 000s) 5,999 7 *** 2,693 20 *** Total benefits (dollars in 000s) 613,851 3 *** 327,842 7 *** Percentage of Total Households With income from 1 100 percent of poverty 57 30 *** 75 60 *** With earnings 47 2 26 12 *** With TANF 16 0 23 0 With SSI 14 *** 28 *** Qualifying for minimum benefit 19 105 *** 22 2,421 *** Qualifying for maximum benefit 22 2 *** 30 7 ** Claiming shelter deduction 49 8 *** 57 18 *** Claiming medical deduction 10 43 *** 8 360 *** In one-person SNAP household 48 43 *** 53 143 *** In two-person SNAP household 18 1 18 4 ** In larger SNAP household 35 0 30 2 ** With elderly members 20 68 *** 21 482 *** With disabled nonelderly adults 9 119 *** 12 806 *** With children 54 0 ** 49 2 ** Average Amounts (Dollars) Monthly benefit 230 -12 *** 249 -27 *** Monthly gross income 1,007 -3 *** 761 7 *** Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics are of the SNAP unit after SSI cash-out is eliminated. a Percent change from numbers, total benefits, or average amounts under revised baseline rules. * Change is statistically different from zero at a 90 percent level of significance. ** Change is statistically different from zero at a 95 percent level of significance. *** Change is statistically different from zero at a 99 percent level of significance. Other groups experiencing large increases under the third reform simulation include participating households claiming a medical deduction or containing just one person. The first group Mathematica Policy Research 23 more than triples in size and encompasses eight percent of participating households compared to four percent under the first reform simulation. Over half of all participating households fall into the second group, their number increasing by over 100 percent under the third reform simulation. The number of participating households with children increases very slightly under the third reform simulation, but since the subgroup increase is much less than the overall increase, the percentage of participating households with children drops to 49 percent. Characteristics of Households Gaining or Losing Under the Third Reform Simulation. Although the 17 percent increase in the number of eligible households under the third reform simulation is similar to the percent increases under the first two reform simulations, the dynamics of the increase under the third one are quite different. Because SSI cash-out is only eliminated for one- person households, currently eligible households do not lose eligibility as the result of an SSI recipient joining their SNAP filing unit as some do in the first two reform simulations. As a result, only a negligible number of households (less than 500) becomes newly ineligible (Table 7). However, two-person pure SSI households, a group that would automatically be eligible for SNAP in the absence of SSI cash-out, remain ineligible for SNAP under the third reform simulation, reducing the number of newly eligible households (389,000). Almost all of the newly eligible households are single SSI recipients, although a small number are households qualifying for a larger medical expense deduction. Some already-eligible households also qualify for a larger medical expense deduction and therefore a larger benefit (43,000). While all the newly ineligible households lose eligibility because they qualify for a smaller shelter expense deduction due to a slightly smaller SUA, most eligible households with a shelter expense deduction qualify for a slightly smaller benefit rather than lose eligibility (481,000 households). Mathematica Policy Research 24 Table 7. Estimated Numbers and Characteristics of Eligible and Participating California Households in an Average Month Under Simulation to Eliminate SSI Cash-Out for One- Person Households, Implement a Standard Medical Deduction, and Lower the SUA by Change in Eligibility Status and Potential Benefit California Households Affected by Simulation Newly Eligible for SNAP Newly Ineligible for SNAP Still Eligible for SNAP With Higher Benefit With Lower Benefit Total households (number in 000s) 389 * 43 481 Total individuals (number in 000s) 396 * 93 1,332 Total benefits (dollars in 000s) 14,775 8 1,227 a -779 a Percentage of Total Households In poverty 90 0 44 60 With earnings 5 0 30 72 With TANF 0 0 4 19 With SSI 95 0 0 0 Qualifying for minimum benefit 69 100 15 0 Qualifying for maximum benefit 4 0 0 0 Claiming shelter deduction 27 100 68 100 Claiming medical deduction 22 100 100 7 In one-person SNAP household 99 100 46 29 In two-person SNAP household 1 0 27 23 In larger SNAP household 0 0 26 48 With elderly members 57 0 75 16 With disabled nonelderly adults 34 100 26 5 With children 1 0 27 73 Average Amounts (Dollars) Monthly benefit 38 16 196 276 Monthly gross income 848 2,411 1,154 1,152 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. Note: Characteristics of newly eligible households are after SSI cash-out is eliminated. Characteristics of households losing eligibility, with higher benefits, or with lower benefits are before SSI cash-out is eliminated. a Total increase or decrease in benefits. * Less than 500. Newly eligible households, with an average monthly benefit of $38, qualify for total monthly benefits of $15 million while newly ineligible households, with an average monthly benefit of $16, Mathematica Policy Research 25 lose benefits totaling only $8,000. The amount of total benefits gained by households qualifying for higher benefits is just over $1 million and the amount of total benefits lost by households qualifying for lower benefits is just under $1 million. Before the third reform scenario was simulated, these groups of gainers and losers had average benefits of $196 and $276, respectively. Among households newly eligible under the third reform simulation, 69 percent qualify for the minimum benefit, 57 percent contain an elderly member, and 34 percent contain a disabled nonelderly adult. Only one percent contains a child. All of the households qualifying for higher benefits under the third reform simulation claim a medical expense deduction. Sixty eight percent also claim a shelter expense deduction. Among these households, only 15 percent qualify for the minimum benefit, 46 percent are one-person households, 75 percent contain an elderly member, 26 percent contain a disabled nonelderly person, and 27 percent contain a child. By contrast, all of the households qualifying for lower benefits claim a shelter expense deduction, but only 7 percent claim a medical expense deduction. Furthermore, 73 percent of these households contain a child, while only 16 percent contain an elderly person and 5 percent contain a disabled nonelderly person. D. Summary We estimate that the number of California households eligible for SNAP increases under a simulated elimination of SSI cash-out, as does the number of eligible individuals (Table 8). However, total benefits for which eligible households qualify remain constant and the percentage of households qualifying for the minimum benefit increases from 11 percent to 21 percent. Pure SSI households gain SNAP benefits under this policy change, while some mixed SSI households lose benefits. While most of the households losing benefits qualify for a lower SNAP benefit, others lose eligibility entirely. If California’s SSI SSP payment were reduced, SSI households would be slightly worse off. As a result, a simulated elimination of SSI cash-out under this scenario results in slightly more households Mathematica Policy Research 26 and individuals becoming eligible for SNAP than under the first simulation. Because SNAP benefits are slightly higher under this scenario, eligible households also qualify for more total benefits than before SSI cash-out is eliminated or under the first simulation. Under this scenario, fewer households lose SNAP eligibility or qualify for lower SNAP benefits and 20 percent of eligible households qualify for the minimum benefit. Table 8. Summary of Estimated Effects of Simulations to Eliminate SSI Cash-Out on Eligible Households, Individuals, and Benefits and Percentage of Eligible Households Qualifying for the Minimum Benefit All Currently Eligible California Households California Households Eligible for SNAP under Three Simulations to Eliminate SSI Cash-Out With Current SSI SSP (First Simulation) With Lower SSI SSP (Second Simulation) For One-Person Households (Third Simulation) Total households (number in 000s) 2,284 2,678 2,706 2,673 Total individuals (number in 000s) 5,604 6,193 6,291 5,999 Total benefits (dollars in 000s) 598,636 597,040 614,322 613,851 Percentage of households qualifying for minimum benefit 11 21 20 19 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update. The final policy scenario eliminates SSI cash-out for most households but does not cause currently eligible SNAP households to lose eligibility. The estimated number of eligible households and individuals increases under this simulation, although not as much as under the first two simulations. The increase in total benefits is similar to the increase under the second simulation, as is the percentage of eligible households qualifying for the minimum benefit (19 percent.) While some households lose benefits under this scenario, the per-household benefit decrease is small. Furthermore, some households, all of which contain an elderly or disabled person, qualify for higher benefits under this scenario. Mathematica Policy Research APPENDIX A DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT UNDER CURRENT REGULATORY ENVIRONMENT Page is left intentionally blank to allow for double-sided copying Total California Households 2,284 100.0 889 100.0 Gross Income as a Percentage of Poverty Level No income 334 14.6 205 23.0 1-100% 1,184 51.9 611 68.7 101-130% 623 27.3 61 6.8 131% or greater 143 6.3 13 1.4 Households with Income from Earnings 1,224 53.6 301 33.9 Temporary Assistance for Needy Families 424 18.6 309 34.7 Social Security 376 16.5 48 5.4 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 246 10.8 11 1.3 Eligible for maximum benefit 568 24.9 361 40.6 Eligible for other benefit 1,470 64.4 516 58.1 Households with Deductions Excess shelter deduction 1,222 53.5 641 72.1 Medical deduction 196 8.6 24 2.7 Dependent care deduction 75 3.3 23 2.6 Child support expense deduction 40 1.8 21 2.4 Household Size One person 891 39.0 285 32.0 Two people 471 20.6 223 25.1 More than two people 923 40.4 382 42.9 Household Composition Households with elderly adults 324 14.2 48 5.4 Households with disabled nonelderly adults 112 4.9 17 1.9 Households with children 1,428 62.5 627 70.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table A.1. Characteristics of Eligible and Participating California Households, FY 2009 Participating (000s) of Total Households (000s) of Total Eligible Number Percent Number Percent A.3 Total California Individuals 5,604 100.0 2,237 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 609 10.9 441 19.7 1-100% 3,224 57.5 1,625 72.6 101-130% 1,532 27.3 144 6.5 131% or greater 238 4.3 26 1.2 Individuals in Households with Income from Earnings 3,482 62.1 773 34.6 Temporary Assistance for Needy Families 1,173 20.9 887 39.7 Social Security 632 11.3 121 5.4 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 268 4.8 16 0.7 Eligible for maximum benefit 1,096 19.6 784 35.1 Eligible for other benefit 4,240 75.7 1,437 64.3 Individuals in Households with Deductions Excess shelter deduction 3,092 55.2 1,622 72.5 Medical deduction 284 5.1 35 1.6 Dependent care deduction 214 3.8 63 2.8 Child support expense deduction 93 1.7 44 2.0 Individuals by Household Size One person 891 15.9 285 12.7 Two people 941 16.8 446 19.9 More than two people 3,772 67.3 1,507 67.3 Individuals by Household Composition Households with elderly adults 445 7.9 75 3.4 Households with disabled nonelderly adults 229 4.1 47 2.1 Households with children 4,584 81.8 1,923 86.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. (000s) of Total(000s) of Total Table A.2. Characteristics of Individuals in Eligible and Participating California Households by Household Characteristics, FY 2009 Individuals in Households ParticipatingEligible Number Percent Number Percent A.4 Total California Benefits 598,636 262 305,799 344 Benefits by Household Gross Income as a Percentage of Poverty Level No income 109,930 329 77,857 380 1-100% 389,714 329 216,839 355 101-130% 90,562 145 10,640 175 131% or greater 8,431 59 463 36 Benefits in Households with Income from Earnings 323,186 264 94,130 312 Temporary Assistance for Needy Families 111,157 262 96,137 311 Social Security 42,212 112 12,165 256 Supplemental Security Income 0 0 0 0 Benefits by Household Benefit Level Eligible for minimum benefit 3,977 16 182 16 Eligible for maximum benefit 196,539 346 138,482 383 Eligible for other benefit 398,121 271 167,134 324 Benefits in Households with Deductions Excess shelter deduction 382,261 313 232,062 362 Medical deduction 21,892 112 5,569 230 Dependent care deduction 22,681 303 8,451 370 Child support expense deduction 12,486 310 7,143 341 Benefits by Household Size One person 101,881 114 47,389 167 Two people 102,203 217 60,946 273 More than two people 394,552 428 197,463 517 Benefits by Household Composition Households with elderly adults 34,957 108 10,730 225 Households with disabled nonelderly adults 18,229 162 6,236 371 Households with children 479,495 336 250,589 399 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Total ($000s) Total ($000s) Table A.3. Benefits for Eligible and Participating California Households by Household Characteristic, FY 2009 Benefits for Households ParticipatingEligible Benefit ($) Benefit ($) Average Average A.5 Monthly Benefit 262 344 Monthly Gross Income among Households with Positive Income 1,039 713 Monthly Net Income among Households with Positive Net Income 710 494 Monthly Amount of Income Type among Households with Income Type Earnings 1,060 720 Temporary Assistance for Needy Families 510 535 Supplemental Security Income 0 0 Social Security 862 654 Amount of Deduction among Households with Deduction Excess shelter deduction 276 280 Medical deduction 206 203 Dependent care deduction 211 285 Child support expense deduction 360 427 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Participating Average Value for Households ($) Eligible Table A.4 Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households, FY 2009 A.6 Total California Households 2,678 100.0 17.2 0 938 100.0 5.5 ## Gross Income as a Percentage of Poverty Level No income 280 10.5 -16.0 0 184 19.7 -9.9 ## 1-100% 1,503 56.1 26.9 0 631 67.3 3.4 101-130% 707 26.4 13.5 0 102 10.9 68.3 ## 131% or greater 187 7.0 30.6 0 20 2.1 55.7 ## Households with Income from Earnings 1,212 45.2 -1.0 309 33.0 2.6 ## Temporary Assistance for Needy Families 413 15.4 -2.5 0 303 32.3 -1.8 ## Social Security 639 23.9 69.8 0 98 10.4 105.1 ## Supplemental Security Income 615 23.0 0 158 16.8 ## Benefit Level Eligible for minimum benefit 575 21.5 133.5 0 37 4.0 232.1 ## Eligible for maximum benefit 522 19.5 -8.1 0 343 36.6 -5.1 ## Eligible for other benefit 1,581 59.0 7.6 0 558 59.5 8.0 ## Households with Deductions Excess shelter deduction 1,343 50.1 9.9 0 674 71.8 5.1 ## Medical deduction 297 11.1 51.3 0 41 4.3 68.1 ## Dependent care deduction 77 2.9 3.5 0 23 2.5 1.7 Child support expense deduction 46 1.7 14.5 0 24 2.6 16.5 Household Size One person 1,166 43.5 30.9 0 295 31.5 3.8 Two people 573 21.4 21.7 0 232 24.8 4.2 More than two people 939 35.1 1.8 410 43.7 7.5 ## Household Composition Households with elderly adults 612 22.9 89.1 0 89 9.5 87.5 ## Households with disabled nonelderly adults 338 12.6 200.9 0 88 9.4 423.2 ## Households with children 1,404 52.4 -1.7 0 625 66.6 -0.4 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance a Percent change from number eligible and number participating under baseline rules (see Table A.1) (000s) of Total Change a (000s) Table A.5. Characteristics of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Percent Percent of Total Change a Households Eligible under Simulation to Eliminate SSI Cash-Out Eligible Participating Number Percent Percent Number A.7 Total California Individuals 6,193 100.0 10.5 # 2,407 100.0 7.6 ## Individuals by Household Gross Income as a Percentage of Poverty Level No income 531 8.6 -12.8 # 409 17.0 -7.3 ## 1-100% 3,588 57.9 11.3 # 1,682 69.9 3.5 101-130% 1,745 28.2 13.9 # 269 11.2 86.2 ## 131% or greater 329 5.3 38.2 # 47 2.0 80.0 ## Individuals in Households with Income from Earnings 3,456 55.8 -0.8 810 33.7 4.8 ## Temporary Assistance for Needy Families 1,229 19.9 4.8 # 957 39.8 7.9 ## Social Security 1,027 16.6 62.6 # 227 9.4 87.2 ## Supplemental Security Income 1,073 17.3 # 418 17.4 ## Individuals by Household Benefit Level Eligible for minimum benefit 658 10.6 145.8 # 45 1.9 192.2 ## Eligible for maximum benefit 1,028 16.6 -6.2 # 751 31.2 -4.2 ## Eligible for other benefit 4,508 72.8 6.3 # 1,610 66.9 12.0 ## Individuals in Households with Deductions Excess shelter deduction 3,296 53.2 6.6 # 1,697 70.5 4.6 ## Medical deduction 438 7.1 54.3 # 61 2.5 71.8 ## Dependent care deduction 223 3.6 4.3 # 67 2.8 6.4 Child support expense deduction 111 1.8 19.8 # 58 2.4 31.6 Individuals by Household Size One person 1,166 18.8 30.9 # 295 12.3 3.8 Two people 1,145 18.5 21.7 # 465 19.3 4.2 More than two people 3,882 62.7 2.9 1,647 68.4 9.3 ## Individuals by Household Composition Households with elderly adults 854 13.8 91.8 # 143 5.9 90.6 ## Households with disabled nonelderly adults 654 10.6 185.8 # 238 9.9 407.4 ## Households with children 4,640 74.9 1.2 # 2,027 84.2 5.4 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance PercentPercent Change a Table A.6. Characteristics of Individuals in Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Individuals in Households Eligible under Simulation Eligible Participating Number Percent Percent Number to Eliminate SSI Cash-Out a Percent change from number eligible and number participating under baseline rules (see Table A.2) (000s) of Change a (000s) of A.8 Total California Benefits 597,040 -0.3 223 301,370 -1.4 ## 321 Benefits by Household Gross Income as a Percentage of Poverty Level No income 95,253 -13.4 0 340 71,838 -7.7 ## 389 1-100% 393,685 1.0 262 212,793 -1.9 337 101-130% 97,220 7.4 0 138 15,729 47.8 ## 154 131% or greater 10,881 29.1 0 58 1,009 117.9 ## 51 Benefits in Households with Income from Earnings 316,035 -2.2 0 261 95,159 1.1 308 Temporary Assistance for Needy Families 101,660 -8.5 0 246 87,762 -8.7 ## 290 Social Security 58,255 38.0 0 91 18,463 51.8 ## 189 Supplemental Security Income 55,099 0 90 28,551 ## 181 Benefits by Household Benefit Level Eligible for minimum benefit 9,286 133.5 0 16 604 232.1 ## 16 Eligible for maximum benefit 183,663 -6.6 0 352 132,443 -4.4 ## 386 Eligible for other benefit 404,090 1.5 0 256 168,323 0.7 302 Benefits in Households with Deductions Excess shelter deduction 394,125 3.1 0 293 236,114 1.7 ## 350 Medical deduction 29,776 36.0 0 100 7,600 36.5 ## 187 Dependent care deduction 22,627 -0.2 292 8,251 -2.4 355 Child support expense deduction 13,655 9.4 296 8,067 12.9 331 Benefits by Household Size One person 101,864 0.0 87 44,930 -5.2 ## 152 Two people 103,669 1.4 181 57,456 -5.7 247 More than two people 391,507 -0.8 417 198,983 0.8 485 Benefits by Household Composition Households with elderly adults 49,425 41.4 0 81 14,984 39.6 ## 167 Households with disabled nonelderly adults 40,112 120.0 0 119 17,385 178.8 ## 198 Households with children 463,087 -3.4 0 330 242,296 -3.3 ## 388 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Percent Average Total to Eliminate SSI Cash-Out Table A.7. Benefits for Eligible and Participating California Households Under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 Percent Average Benefits for Households Eligible under Simulation Eligible Participating Total a Percent change from benefits for eligible and participating households under baseline rules (see ($000s) Change a Benefit ($000s) Change a Benefit A.9 Monthly Benefit 223 -14.9 0 321 -6.6 0 Monthly Gross Income among Households with Positive Income 1,056 1.6 0 828 16.2 0 Monthly Net Income among Households with Positive Net Income 744 4.8 0 613 24.1 0 Monthly Amount of Income Type among Households with Income Type Earnings 1,059 -0.1 722 0.2 Temporary Assistance for Needy Families 514 0.8 0 538 0.6 Supplemental Security Income 571 0 592 0 Social Security 740 -14.2 0 613 -6.2 Amount of Deduction among Households with Deduction Excess shelter deduction 289 4.5 0 296 5.6 0 Medical deduction 186 -9.5 0 193 -5.0 Dependent care deduction 212 0.3 288 0.9 Child support expense deduction 331 -8.1 379 -11.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Table A.8. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Average Value for California a Percent change from average values under baseline rules (see Table A.4) Eligible Participating Average ($) Average ($) Percent Change a Percent Change a to Eliminate SSI Cash-Out Households Eligible under Simulation A.10 Total California Households 455 100.0 54 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 353 77.6 53 97.8 101-130% 66 14.6 1 2.0 131% or greater 36 7.8 * 0.2 Households with Income from Earnings 24 5.3 1 2.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 236 51.8 24 44.7 Supplemental Security Income 455 100.0 54 100.0 Benefit Level Eligible for minimum benefit 334 73.5 22 41.0 Eligible for maximum benefit 14 3.0 7 13.2 Eligible for other benefit 107 23.5 25 45.8 Households with Deductions Excess shelter deduction 123 26.9 36 65.9 Medical deduction 94 20.6 13 23.4 Dependent care deduction 2 0.4 * 0.9 Child support expense deduction 2 0.5 * 0.6 Household Size One person 370 81.3 53 97.5 Two people 84 18.5 1 2.5 More than two people 1 0.3 0 0.0 Household Composition Households with elderly adults 275 60.4 30 55.7 Households with disabled nonelderly adults 154 33.7 17 30.7 Households with children 6 1.3 * 0.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Number Percent Number Percent (000s) of Total (000s) of Total Table A.9A. Characteristics of California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out, FY 2009 Households Newly Eligible under Newly Eligible and ParticipatingAll Newly Eligible Simulation to Eliminate SSI Cash-Out A.11 Total Calfornia Households 58 100.0 4 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 56 96.8 3 83.4 101-130% 1 2.3 * 5.3 131% or greater 1 0.9 * 11.3 Households with Income from Earnings 4 7.4 3 79.9 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 25 42.7 1 16.6 Supplemental Security Income 54 93.3 * 3.5 Benefit Level Eligible for minimum benefit 23 39.3 1 16.6 Eligible for maximum benefit 7 12.3 0 0.0 Eligible for other benefit 28 48.5 3 83.4 Households with Deductions Excess shelter deduction 39 66.9 3 79.9 Medical deduction 13 22.5 * 11.3 Dependent care deduction * 0.8 0 0.0 Child support expense deduction * 0.5 0 0.0 Household Size One person 53 91.8 1 16.6 Two people 1 2.6 * 3.5 More than two people 3 5.6 3 79.9 Household Composition Households with elderly adults 31 52.9 1 16.6 Households with disabled nonelderly adults 17 28.8 * 3.5 Households with children 4 6.6 3 83.4 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Households Newly Participating under All Newly Participating Previously Eligible and Newly Participating Simulation to Eliminate SSI Cash-Out Table A.9B. Characteristics of California Households Newly Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.12 Total Calfornia Households 26 100.0 12 100.0 Gross Income as a Percentage of Poverty Level No income 15 56.6 5 40.4 1-100% 9 33.0 6 55.9 101-130% 1 4.0 * 2.7 131% or greater 2 6.4 * 0.9 Households with Income from Earnings 4 14.4 1 7.5 Temporary Assistance for Needy Families 2 9.3 2 21.0 Social Security 3 12.7 1 8.4 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit * 0.9 * 0.9 Eligible for maximum benefit 20 77.0 9 77.4 Eligible for other benefit 6 22.0 3 21.7 Households with Deductions Excess shelter deduction 10 38.6 7 59.0 Medical deduction 4 16.2 1 8.6 Dependent care deduction 1 2.8 1 6.4 Child support expense deduction 1 3.1 * 3.6 Household Size One person 19 71.2 7 59.3 Two people 3 12.5 2 18.8 More than two people 4 16.3 3 21.8 Household Composition Households with elderly adults 5 18.2 1 8.8 Households with disabled nonelderly adults 1 5.6 1 8.4 Households with children 9 35.3 6 49.8 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table A.9C. Characteristics of Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.13 Total California Households 61 100.0 9 100.0 Gross Income as a Percentage of Poverty Level No income 3 4.5 1 9.8 1-100% 25 41.3 7 84.5 101-130% 30 48.6 * 5.6 131% or greater 3 5.6 0 0.0 Households with Income from Earnings 45 73.0 3 39.1 Temporary Assistance for Needy Families 11 17.2 5 59.2 Social Security 15 24.2 * 2.8 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 9 15.0 * 1.1 Eligible for maximum benefit 3 4.7 1 11.5 Eligible for other benefit 49 80.3 8 87.4 Households with Deductions Excess shelter deduction 7 11.6 3 29.4 Medical deduction 4 6.6 1 6.1 Dependent care deduction * 0.1 * 0.7 Child support expense deduction 0 0.0 0 0.0 Household Size One person 22 36.6 5 53.5 Two people 17 27.1 2 23.9 More than two people 22 36.3 2 22.6 Household Composition Households with elderly adults 8 13.0 1 7.1 Households with disabled nonelderly adults 8 13.5 * 0.8 Households with children 34 56.1 7 76.7 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table A.10A. Characteristics of California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Households Losing Eligibility under All Newly Ineligible Participating in Baselaw Number Percent Number Percent Simulation to Eliminate SSI Cash-Out A.14 Total Calfornia Households 9 100.0 * 100.0 Gross Income as a Percentage of Poverty Level No income 1 9.3 0 0.0 1-100% 8 85.4 * 100.0 101-130% * 5.3 0 0.0 131% or greater 0 0.0 0 0.0 Households with Income from Earnings 3 37.0 0 0.0 Temporary Assistance for Needy Families 6 61.4 * 100.0 Social Security * 2.7 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit * 1.0 0 0.0 Eligible for maximum benefit 1 10.9 0 0.0 Eligible for other benefit 8 88.1 * 100.0 Households with Deductions Excess shelter deduction 3 32.7 * 91.6 Medical deduction 1 5.7 0 0.0 Dependent care deduction * 0.7 0 0.0 Child support expense deduction 0 0.0 0 0.0 Household Size One person 5 54.6 * 72.8 Two people 2 22.6 0 0.0 More than two people 2 22.8 * 27.2 Household Composition Households with elderly adults 1 6.8 0 0.0 Households with disabled nonelderly adults * 0.7 0 0.0 Households with children 7 78.0 * 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households Newly Not Participating under All Newly Not Participating Still Eligible But No Longer Participating Simulation to Eliminate SSI Cash-Out Table A.10B. Characteristics of California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.15 Total Calfornia Households 134 100.0 92 100.0 Gross Income as a Percentage of Poverty Level No income 36 26.8 15 16.0 1-100% 96 71.3 77 84.0 101-130% 2 1.9 0 0.0 131% or greater * 0.1 0 0.0 Households with Income from Earnings 24 17.7 8 8.8 Temporary Assistance for Needy Families 71 53.2 67 72.6 Social Security 6 4.6 1 1.6 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 39 29.3 16 17.8 Eligible for other benefit 95 70.7 76 82.2 Households with Deductions Excess shelter deduction 39 29.4 30 32.3 Medical deduction 4 2.7 1 1.6 Dependent care deduction 3 2.5 3 3.2 Child support expense deduction * 0.3 * 0.2 Household Size One person 53 39.3 31 33.1 Two people 30 22.3 24 25.5 More than two people 52 38.5 38 41.4 Household Composition Households with elderly adults 9 6.7 2 2.7 Households with disabled nonelderly adults 7 5.0 3 3.2 Households with children 105 78.6 83 89.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households With Lower Benefits under Eligible under Simulation Participating under Simulation Simulation to Eliminate SSI Cash-Out Table A.10C. Characteristics of Eligible and Participating California Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.16 Total California Individuals 542 100.0 55 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 355 65.4 53 96.5 101-130% 127 23.4 2 3.3 131% or greater 61 11.3 * 0.2 Individuals in Households with Income from Earnings 32 5.8 2 3.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 291 53.7 24 44.2 Supplemental Security Income 542 100.0 55 100.0 Individuals by Household Benefit Level Eligible for minimum benefit 391 72.1 22 40.2 Eligible for maximum benefit 15 2.8 8 14.0 Eligible for other benefit 136 25.1 25 45.8 Individuals in Households with Deductions Excess shelter deduction 151 27.8 37 66.2 Medical deduction 123 22.8 13 24.3 Dependent care deduction 4 0.7 * 0.8 Child support expense deduction 3 0.5 * 0.6 Individuals by Household Size One person 370 68.2 53 95.1 Two people 168 31.0 3 4.9 More than two people 4 0.8 0 0.0 Individuals by Household Composition Households with elderly adults 345 63.6 31 56.7 Households with disabled nonelderly adults 178 32.8 17 29.9 Households with children 13 2.3 * 0.8 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Table A.11A. Characteristics of Individuals in California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Number Percent Number Percent Simulation to Eliminate SSI Cash-Out A.17 Total California Individuals 69 100.0 14 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 67 96.3 13 95.2 101-130% 2 2.9 * 1.5 131% or greater 1 0.8 * 3.3 Individuals in Households with Income from Earnings 15 21.1 13 93.1 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 25 36.3 1 4.8 Supplemental Security Income 56 80.3 * 2.1 Individuals by Household Benefit Level Eligible for minimum benefit 23 33.1 1 4.8 Eligible for maximum benefit 8 11.2 0 0.0 Eligible for other benefit 39 55.7 13 95.2 Individuals in Households with Deductions Excess shelter deduction 50 71.6 13 93.1 Medical deduction 14 20.1 0 3.3 Dependent care deduction * 0.7 0 0.0 Child support expense deduction * 0.4 0 0.0 Individuals by Household Size One person 53 77.0 1 4.8 Two people 3 4.3 * 2.1 More than two people 13 18.7 13 93.1 Individuals by Household Composition Households with elderly adults 32 46.3 1 4.8 Households with disabled nonelderly adults 17 24.3 * 2.1 Households with children 14 19.8 13 95.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Individuals in Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table A.11B. Characteristics of Individuals in California Households Newly Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.18 Total California Individuals 40 100.0 19 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 25 61.0 9 46.8 1-100% 12 29.9 9 47.2 101-130% 2 5.0 1 5.4 131% or greater 2 4.2 * 0.5 Individuals in Households with Income from Earnings 5 12.6 2 9.9 Temporary Assistance for Needy Families 4 10.6 4 22.2 Social Security 5 13.0 2 9.7 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit * 0.6 * 0.5 Eligible for maximum benefit 32 79.2 15 79.4 Eligible for other benefit 8 20.2 4 20.1 Individuals in Households with Deductions Excess shelter deduction 13 33.4 10 52.8 Medical deduction 6 14.8 2 8.9 Dependent care deduction 2 5.2 2 10.9 Child support expense deduction 1 3.3 1 4.9 Individuals by Household Size One person 19 46.3 7 35.7 Two people 7 16.2 4 22.7 More than two people 15 37.4 8 41.6 Individuals by Household Composition Households with elderly adults 6 13.9 1 6.2 Households with disabled nonelderly adults 3 7.7 2 11.6 Households with children 22 55.7 13 67.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Individuals in Households With Higher Benefits Eligible in Baselaw Participating in Baselaw under Simulation to Eliminate SSI Cash-Out Table A.11C. Individuals in Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.19 Total California Individuals 129 100.0 15 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 4 3.2 1 8.1 1-100% 50 38.3 13 88.7 101-130% 66 50.8 * 3.3 131% or greater 10 7.8 0 0.0 Individuals in Households with Income from Earnings 109 84.3 8 56.0 Temporary Assistance for Needy Families 28 21.3 10 65.6 Social Security 25 19.7 1 4.2 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 9 7.2 * 0.6 Eligible for maximum benefit 4 3.4 1 9.5 Eligible for other benefit 116 89.4 13 89.9 Individuals in Households with Deductions Excess shelter deduction 10 7.5 4 26.1 Medical deduction 6 4.4 2 10.5 Dependent care deduction * 0.1 * 0.8 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person 22 17.3 5 30.9 Two people 33 25.6 4 27.5 More than two people 74 57.0 6 41.6 Individuals by Household Composition Households with elderly adults 11 8.4 2 11.1 Households with disabled nonelderly adults 17 13.0 * 1.4 Households with children 95 73.3 13 86.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table A.12A. Characteristics of Individuals in California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Losing Eligibility All Newly Ineligible Participating in Baselaw Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out A.20 Total California Individuals 16 100.0 1 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 1 7.7 0 0.0 1-100% 14 89.2 1 100.0 101-130% * 3.1 0 0.0 131% or greater 0 0.0 0 0.0 Individuals in Households with Income from Earnings 8 53.3 0 0.0 Temporary Assistance for Needy Families 11 67.2 1 100.0 Social Security 1 4.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit * 0.6 0 0.0 Eligible for maximum benefit 1 9.0 0 0.0 Eligible for other benefit 14 90.4 1 100.0 Individuals in Households with Deductions Excess shelter deduction 5 28.8 1 83.7 Medical deduction 2 10.0 0 0.0 Dependent care deduction * 0.8 0 0.0 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person 5 31.6 * 47.1 Two people 4 26.2 0 0.0 More than two people 7 42.2 * 52.9 Individuals by Household Composition Households with elderly adults 2 10.6 0 0.0 Households with disabled nonelderly adults 0 1.3 0 0.0 Households with children 14 87.2 1 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table A.12B. Characteristics of Individuals in California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out A.21 Total California Individuals 318 100.0 227 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 49 15.5 22 9.7 1-100% 261 82.1 205 90.3 101-130% 7 2.3 0 0.0 131% or greater * 0.1 0 0.0 Individuals in Households with Income from Earnings 73 23.0 24 10.4 Temporary Assistance for Needy Families 186 58.4 174 76.9 Social Security 20 6.3 4 1.7 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 55 17.4 26 11.3 Eligible for other benefit 263 82.6 201 88.7 Individuals in Households with Deductions Excess shelter deduction 108 34.0 81 35.7 Medical deduction 8 2.6 4 1.7 Dependent care deduction 10 3.2 9 4.1 Child support expense deduction 1 0.4 * 0.2 Individuals by Household Size One person 53 16.5 31 13.5 Two people 60 18.7 47 20.7 More than two people 206 64.7 149 65.8 Individuals by Household Composition Households with elderly adults 12 3.9 6 2.5 Households with disabled nonelderly adults 27 8.4 16 7.1 Households with children 287 90.2 217 95.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Individuals in Households With Lower Benefits Eligible under Simulation Participating under Simulation under Simulation to Eliminate SSI Cash-Out Table A.12C. Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent A.22 Total Benefits 17,939 100.0 4,614 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 13,865 77.3 4,520 98.0 101-130% 3,002 16.7 93 2.0 131% or greater 1,072 6.0 1 0.0 Benefits in Households with Income from Earnings 946 5.3 243 5.3 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 9,654 53.8 2,117 45.9 Supplemental Security Income 17,939 100.0 4,614 100.0 Benefits by Household Benefit Level Eligible for minimum benefit 5,398 30.1 356 7.7 Eligible for maximum benefit 3,013 16.8 1,528 33.1 Eligible for other benefit 9,528 53.1 2,730 59.2 Benefits in Households with Deductions Excess shelter deduction 11,732 65.4 4,314 93.5 Medical deduction 5,958 33.2 1,665 36.1 Dependent care deduction 192 1.1 92 2.0 Child support expense deduction 200 1.1 59 1.3 Benefits by Household Size One person 13,762 76.7 4,309 93.4 Two people 4,007 22.3 305 6.6 More than two people 170 0.9 0 0.0 Benefits by Household Composition Households with elderly adults 11,469 63.9 2,864 62.1 Households with disabled nonelderly adults 5,503 30.7 1,137 24.6 Households with children 491 2.7 92 2.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Table A.13A. Benefits for Eligible California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Total Percent Total Percent Simulation to Eliminate SSI Cash-Out A.23 Total Benefits 6,531 100.0 1,917 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 6,426 98.4 1,907 99.4 101-130% 97 1.5 3 0.2 131% or greater 9 0.1 7 0.4 Benefits in Households with Income from Earnings 2,129 32.6 1,886 98.4 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 2,128 32.6 11 0.6 Supplemental Security Income 4,635 71.0 21 1.1 Benefits by Household Benefit Level Eligible for minimum benefit 367 5.6 11 0.6 Eligible for maximum benefit 1,528 23.4 0 0.0 Eligible for other benefit 4,636 71.0 1,907 99.4 Benefits in Households with Deductions Excess shelter deduction 6,200 94.9 1,886 98.4 Medical deduction 1,673 25.6 7 0.4 Dependent care deduction 92 1.4 0 0.0 Child support expense deduction 59 0.9 0 0.0 Benefits by Household Size One person 4,320 66.1 11 0.6 Two people 325 5.0 21 1.1 More than two people 1,886 28.9 1,886 98.4 Benefits by Household Composition Households with elderly adults 2,875 44.0 11 0.6 Households with disabled nonelderly adults 1,158 17.7 21 1.1 Households with children 1,998 30.6 1,907 99.4 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Benefits for Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table A.13B. Benefits for Eligible California Households Newly Participating under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Total Percent Total Percent A.24 Total Benefits 6,813 1,972 100.0 3,320 776 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 4,515 1,111 66.3 1,647 354 49.6 1-100% 2,029 573 29.8 1,612 387 48.6 101-130% 137 158 2.0 59 35 1.8 131% or greater 132 130 1.9 2 * 0.1 Benefits in Households with Income from Earnings 626 332 9.2 326 61 9.8 Temporary Assistance for Needy Families 585 87 8.6 585 87 17.6 Social Security 529 305 7.8 182 110 5.5 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 4 18 0.1 2 0 0.1 Eligible for maximum benefit 5,908 1,532 86.7 2,829 674 85.2 Eligible for other benefit 901 422 13.2 489 102 14.7 Benefits in Households with Deductions Excess shelter deduction 2,037 739 29.9 1,665 420 50.1 Medical deduction 703 333 10.3 197 103 5.9 Dependent care deduction 370 64 5.4 370 64 11.1 Child support expense deduction 230 46 3.4 171 7 5.1 Benefits by Household Size One person 3,331 1,404 48.9 1,288 441 38.8 Two people 1,108 235 16.3 773 159 23.3 More than two people 2,374 333 34.8 1,259 176 37.9 Benefits by Household Composition Households with elderly adults 824 333 12.1 212 101 6.4 Households with disabled nonelderly adults 367 38 5.4 268 24 8.1 Households with children 3,640 694 53.4 2,118 320 63.8 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Total Percent Total Percent ($000s) Increase ($000s) Increase Increase ($000s) Increase ($000s) Benefits for Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table A.13C. Benefits for Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 A.25 Total Benefits 8,300 100.0 1,815 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 778 9.4 230 12.7 1-100% 4,498 54.2 1,571 86.5 101-130% 2,745 33.1 14 0.8 131% or greater 280 3.4 0 0.0 Benefits in Households with Income from Earnings 6,551 78.9 937 51.6 Temporary Assistance for Needy Families 1,688 20.3 1,037 57.1 Social Security 672 8.1 47 2.6 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 148 1.8 1 0.1 Eligible for maximum benefit 817 9.8 270 14.8 Eligible for other benefit 7,335 88.4 1,544 85.1 Benefits in Households with Deductions Excess shelter deduction 713 8.6 388 21.4 Medical deduction 275 3.3 110 6.1 Dependent care deduction 23 0.3 23 1.3 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 1,492 18.0 608 33.5 Two people 2,389 28.8 654 36.0 More than two people 4,419 53.2 553 30.5 Benefits by Household Composition Households with elderly adults 480 5.8 112 6.2 Households with disabled nonelderly adults 384 4.6 16 0.9 Households with children 6,748 81.3 1,600 88.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table A.14A. Benefits for Eligible California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Losing Eligibility All Newly Ineligible Participating in Baselaw Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out A.26 Total Benefits 1,915 100.0 99 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 230 12.0 0 0.0 1-100% 1,670 87.2 99 100.0 101-130% 14 0.7 0 0.0 131% or greater 0 0.0 0 0.0 Benefits in Households with Income from Earnings 937 49.0 0 0.0 Temporary Assistance for Needy Families 1,137 59.4 99 100.0 Social Security 47 2.4 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 1 0.1 0 0.0 Eligible for maximum benefit 270 14.1 0 0.0 Eligible for other benefit 1,644 85.8 99 100.0 Benefits in Households with Deductions Excess shelter deduction 472 24.7 84 84.6 Medical deduction 110 5.8 0 0.0 Dependent care deduction 23 1.2 0 0.0 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 659 34.4 51 51.4 Two people 654 34.1 0 0.0 More than two people 601 31.4 48 48.6 Benefits by Household Composition Households with elderly adults 112 5.8 0 0.0 Households with disabled nonelderly adults 16 0.8 0 0.0 Households with children 1,700 88.8 99 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table A.14B. Benefits for Eligible California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out A.27 Total Benefits 42,041 13,208 100.0 29,642 9,822 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 9,384 2,199 22.3 4,142 1,120 14.0 1-100% 31,944 10,893 76.0 25,501 8,702 86.0 101-130% 712 116 1.7 0 0 0.0 131% or greater 2 0 0.0 0 0 0.0 Benefits in Households with Income from Earnings 8,742 2,889 20.8 3,174 1,053 10.7 Temporary Assistance for Needy Families 22,451 7,896 53.4 21,192 7,325 71.5 Social Security 2,096 573 5.0 423 134 1.4 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 0 0 0.0 0 0 0.0 Eligible for maximum benefit 10,471 2,521 24.9 4,808 1,307 16.2 Eligible for other benefit 31,571 10,687 75.1 24,834 8,515 83.8 Benefits in Households with Deductions Excess shelter deduction 13,603 4,157 32.4 10,451 3,113 35.3 Medical deduction 1,057 435 2.5 562 292 1.9 Dependent care deduction 1,346 367 3.2 1,223 334 4.1 Child support expense deduction 176 59 0.4 59 22 0.2 Benefits by Household Size One person 8,942 3,542 21.3 4,832 2,440 16.3 Two people 8,222 3,234 19.6 6,403 2,714 21.6 More than two people 24,878 6,432 59.2 18,407 4,668 62.1 Benefits by Household Composition Households with elderly adults 2,131 690 5.1 879 389 3.0 Households with disabled nonelderly adults 3,201 599 7.6 2,083 313 7.0 Households with children 36,359 11,684 86.5 27,800 9,236 93.8 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Decrease Percent Simulation to Eliminate SSI Cash-Out Table A.14C. Benefits for Eligible and Participating California Households With Lower Benefits under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 Decrease Benefits for Households With Lower Benefits under Eligible under Simulation Participating under Simulation Total Decrease ($000s) ($000s) Decrease ($000s) ($000s) Percent Total A.28 Potential Monthly Benefit 39 113 336 354 Monthly Gross Income among Households with Positive Income 938 793 1,134 1,027 Monthly Net Income among Households with Positive Net Income 707 452 429 385 Monthly Amount of Income Type among Households with Income Type Earnings 920 463 1,024 383 Temporary Assistance for Needy Families 0 0 422 422 Supplemental Security Income 551 476 585 573 Social Security 584 651 528 592 Amount of Deduction among Households with Deduction Excess shelter deduction 326 383 465 466 Medical deduction 136 172 351 270 Dependent care deduction 248 200 358 358 Child support expense deduction 223 403 359 387 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Newly Participating Still Participating with Higher Table A.15. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Gaining under Simulation to Eliminate SSI Cash-Out, FY 2009 Average Value for California Households Gaining under Simulation to Eliminate SSI Cash-Out ($) Newly Eligible or Participating Eligible or Participating in Baselaw Newly Eligible Still Eligible with Higher A.29 Potential Monthly Benefit 136 210 314 322 Monthly Gross Income among Households with Positive Income 1,135 581 673 608 Monthly Net Income among Households with Positive Net Income 813 376 440 402 Monthly Amount of Income Type among Households with Income Type Earnings 1,011 455 749 603 Temporary Assistance for Needy Families 352 373 525 537 Supplemental Security Income 0 0 0 0 Social Security 875 728 541 289 Amount of Deduction among Households with Deduction Excess shelter deduction 175 106 145 133 Medical deduction 187 9 68 116 Dependent care deduction 544 544 248 274 Child support expense deduction 0 0 325 290 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table A.16. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Losing under Simulation to Eliminate SSI Cash-Out, FY 2009 Newly Ineligible Newly Not Participating Still Eligible with Lower Still Participating with Lower Average Value for California Households Losing under Simulation to Eliminate SSI Cash-Out ($) Newly Ineligible or Not Participating Eligible or Participating under Simulation A.30 Total California Households 455 100.0 334 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 353 77.6 260 77.8 101-130% 66 14.6 43 13.0 131% or greater 36 7.8 31 9.2 Households with Income from Earnings 24 5.3 20 6.1 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 236 51.8 166 49.5 Supplemental Security Income 455 100.0 334 100.0 Benefit Level Eligible for minimum benefit 334 73.5 334 100.0 Eligible for maximum benefit 14 3.0 0 0.0 Eligible for other benefit 107 23.5 0 0.0 Households with Deductions Excess shelter deduction 123 26.9 23 6.8 Medical deduction 94 20.6 40 12.0 Dependent care deduction 2 0.4 1 0.2 Child support expense deduction 2 0.5 1 0.4 Household Size One person 370 81.3 278 83.1 Two people 84 18.5 56 16.9 More than two people 1 0.3 0 0.0 Household Composition Households with elderly adults 275 60.4 194 57.9 Households with disabled nonelderly adults 154 33.7 119 35.5 Households with children 6 1.3 4 1.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Number Percent Number Percent (000s) of Total (000s) of Total Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table A.17. Characteristics of California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out, FY 2009 A.31 Total California Households 455 100.0 334 100.0 Countable Earned Income $0 431 94.7 314 93.9 1-499 9 2.0 8 2.5 500-999 4 1.0 4 1.1 1,000 or greater 10 2.3 8 2.5 Countable Social Security $0 219 48.2 169 50.5 1-199 22 4.7 13 4.0 200-399 24 5.3 19 5.8 400-599 66 14.6 43 12.9 600-799 103 22.6 77 22.9 800-999 10 2.2 6 1.9 1,000 or greater 12 2.5 7 2.1 Countable Supplemental Security Income $0 0 0.0 0 0.0 1-199 114 25.0 82 24.4 200-399 76 16.6 50 15.0 400-599 31 6.9 24 7.2 600-799 180 39.5 139 41.7 800-999 13 2.8 9 2.7 1,000 or greater 41 9.1 30 9.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Number Percent Number Percent (000s) of Total (000s) of Total Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table A.18. Income Distribution for California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out, FY 2009 A.32 Mathematica Policy Research APPENDIX B DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT AFTER LOWERING THE MAXIMUM COMBINED SSI\/SSP FOR SINGLE PEOPLE Page is left intentionally blank to allow for double-sided copying Total California Households 2,308 100.0 901 100.0 Gross Income as a Percentage of Poverty Level No income 331 14.4 205 22.7 1-100% 1,197 51.8 621 68.9 101-130% 636 27.5 62 6.9 131% or greater 144 6.3 13 1.5 Households with Income from Earnings 1,222 52.9 305 33.9 Temporary Assistance for Needy Families 422 18.3 309 34.3 Social Security 412 17.9 57 6.3 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 254 11.0 15 1.6 Eligible for maximum benefit 567 24.6 363 40.3 Eligible for other benefit 1,487 64.4 523 58.0 Households with Deductions Excess shelter deduction 1,239 53.7 652 72.4 Medical deduction 214 9.3 28 3.1 Dependent care deduction 75 3.3 23 2.5 Child support expense deduction 40 1.8 21 2.3 Household Size One person 893 38.7 288 32.0 Two people 492 21.3 227 25.2 More than two people 924 40.0 386 42.8 Household Composition Households with elderly adults 351 15.2 57 6.3 Households with disabled nonelderly adults 122 5.3 17 1.9 Households with children 1,425 61.7 631 70.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table B.1. Characteristics of Eligible and Participating California Households, FY 2009 Participating (000s) of Total Households (000s) of Total Eligible Number Percent Number Percent B.3 Total California Individuals 5,660 100.0 2,270 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 606 10.7 441 19.4 1-100% 3,246 57.4 1,654 72.9 101-130% 1,566 27.7 147 6.5 131% or greater 242 4.3 27 1.2 Individuals in Households with Income from Earnings 3,486 61.6 788 34.7 Temporary Assistance for Needy Families 1,176 20.8 895 39.4 Social Security 703 12.4 136 6.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 275 4.9 19 0.8 Eligible for maximum benefit 1,097 19.4 787 34.7 Eligible for other benefit 4,288 75.8 1,464 64.5 Individuals in Households with Deductions Excess shelter deduction 3,143 55.5 1,661 73.2 Medical deduction 325 5.7 42 1.9 Dependent care deduction 215 3.8 63 2.8 Child support expense deduction 93 1.7 44 1.9 Individuals by Household Size One person 893 15.8 288 12.7 Two people 983 17.4 453 20.0 More than two people 3,783 66.8 1,528 67.3 Individuals by Household Composition Households with elderly adults 498 8.8 90 4.0 Households with disabled nonelderly adults 253 4.5 48 2.1 Households with children 4,589 81.1 1,944 85.7 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. (000s) of Total(000s) of Total Table B.2. Characteristics of Individuals in Eligible and Participating California Households by Household Characteristics, FY 2009 Individuals in Households ParticipatingEligible Number Percent Number Percent B.4 Total California Benefits 601,835 261 309,040 343 Benefits by Household Gross Income as a Percentage of Poverty Level No income 109,262 330 77,857 380 1-100% 391,025 327 219,897 354 101-130% 92,475 145 10,763 174 131% or greater 9,073 63 523 40 Benefits in Households with Income from Earnings 323,446 265 96,104 315 Temporary Assistance for Needy Families 111,243 264 96,317 312 Social Security 47,264 115 13,436 237 Supplemental Security Income 0 0 0 0 Benefits by Household Benefit Level Eligible for minimum benefit 4,092 16 234 16 Eligible for maximum benefit 196,662 347 139,068 383 Eligible for other benefit 401,081 270 169,738 325 Benefits in Households with Deductions Excess shelter deduction 387,224 313 236,626 363 Medical deduction 25,095 117 6,269 224 Dependent care deduction 22,734 303 8,428 370 Child support expense deduction 12,540 310 7,143 341 Benefits by Household Size One person 101,229 113 47,574 165 Two people 105,617 215 61,773 272 More than two people 394,989 428 199,693 518 Benefits by Household Composition Households with elderly adults 38,746 110 12,001 211 Households with disabled nonelderly adults 19,514 160 6,305 367 Households with children 479,364 336 252,675 401 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Total ($000s) Total ($000s) Table B.3. Benefits for Eligible and Participating California Households by Household Characteristic, FY 2009 Benefits for Households ParticipatingEligible Benefit ($) Benefit ($) Average Average B.5 Monthly Benefit 261 343 Monthly Gross Income among Households with Positive Income 1,043 720 Monthly Net Income among Households with Positive Net Income 712 500 Monthly Amount of Income Type among Households with Income Type Earnings 1,061 717 Temporary Assistance for Needy Families 511 535 Supplemental Security Income 0 0 Social Security 857 661 Amount of Deduction among Households with Deduction Excess shelter deduction 278 281 Medical deduction 208 199 Dependent care deduction 211 285 Child support expense deduction 359 427 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Participating Average Value for Households ($) Eligible Table B.4 Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households, FY 2009 B.6 Total California Households 2,706 100.0 17.2 *** 955 100.0 6.1 *** Gross Income as a Percentage of Poverty Level No income 280 10.4 -15.3 *** 184 19.3 -9.9 *** 1-100% 1,568 57.9 31.0 *** 655 68.6 5.6 *** 101-130% 672 24.8 5.6 *** 98 10.2 57.9 *** 131% or greater 186 6.9 28.6 *** 18 1.9 34.7 ** Households with Income from Earnings 1,237 45.7 1.2 * 313 32.8 2.4 ** Temporary Assistance for Needy Families 417 15.4 -1.3 ** 306 32.0 -0.9 Social Security 642 23.7 55.8 *** 108 11.3 90.0 *** Supplemental Security Income 600 22.2 *** 163 17.0 *** Benefit Level Eligible for minimum benefit 531 19.6 109.3 *** 37 3.9 157.9 *** Eligible for maximum benefit 530 19.6 -6.6 *** 348 36.4 -4.3 *** Eligible for other benefit 1,645 60.8 10.6 *** 570 59.7 9.1 *** Households with Deductions Excess shelter deduction 1,371 50.7 10.7 *** 692 72.4 6.1 *** Medical deduction 302 11.2 41.4 *** 47 5.0 69.8 *** Dependent care deduction 77 2.9 3.2 * 23 2.4 2.0 Child support expense deduction 47 1.7 17.1 ** 25 2.6 17.6 Household Size One person 1,165 43.1 30.5 *** 298 31.2 3.3 Two people 578 21.4 17.6 *** 244 25.6 7.8 * More than two people 962 35.6 4.2 *** 413 43.3 7.2 *** Household Composition Households with elderly adults 614 22.7 75.1 *** 102 10.6 79.1 *** Households with disabled nonelderly adults 352 13.0 189.0 *** 91 9.6 430.9 *** Households with children 1,421 52.5 -0.3 628 65.7 -0.4 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Table B.5. Characteristics of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Percent Percent of Total Change a Households Eligible under Simulation to Eliminate SSI Cash-Out Eligible Participating Number Percent Percent Number a Percent change from number eligible and number participating under baseline rules (see Table B.1) (000s) of Total Change a (000s) B.7 Total California Individuals 6,291 100.0 11.2 *** 2,448 100.0 7.9 *** Individuals by Household Gross Income as a Percentage of Poverty Level No income 531 8.4 -12.3 *** 409 16.7 -7.3 *** 1-100% 3,737 59.4 15.1 *** 1,744 71.2 5.4 *** 101-130% 1,697 27.0 8.4 *** 256 10.5 73.8 *** 131% or greater 326 5.2 35.0 *** 39 1.6 44.3 ** Individuals in Households with Income from Earnings 3,545 56.4 1.7 * 825 33.7 4.7 ** Temporary Assistance for Needy Families 1,245 19.8 5.8 ** 971 39.6 8.5 Social Security 1,042 16.6 48.2 *** 248 10.1 81.6 *** Supplemental Security Income 1,074 17.1 *** 425 17.4 *** Individuals by Household Benefit Level Eligible for minimum benefit 572 9.1 108.4 *** 45 1.8 141.1 *** Eligible for maximum benefit 1,045 16.6 -4.7 *** 761 31.1 -3.3 *** Eligible for other benefit 4,673 74.3 9.0 *** 1,642 67.1 12.2 *** Individuals in Households with Deductions Excess shelter deduction 3,371 53.6 7.3 *** 1,743 71.2 4.9 *** Medical deduction 456 7.3 40.2 *** 74 3.0 75.7 *** Dependent care deduction 223 3.6 4.1 * 67 2.7 6.7 Child support expense deduction 115 1.8 22.8 ** 58 2.4 33.2 Individuals by Household Size One person 1,165 18.5 30.5 *** 298 12.2 3.3 Two people 1,157 18.4 17.6 *** 489 20.0 7.8 * More than two people 3,969 63.1 4.9 *** 1,662 67.9 8.7 *** Individuals by Household Composition Households with elderly adults 859 13.7 72.7 *** 167 6.8 86.7 *** Households with disabled nonelderly adults 703 11.2 178.1 *** 247 10.1 417.5 *** Households with children 4,709 74.9 2.6 2,041 83.4 5.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance a Percent change from number eligible and number participating under baseline rules (see Table B.2) (000s) of Change a (000s) of PercentPercent Change a Table B.6. Characteristics of Individuals in Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Individuals in Households Eligible under Simulation Eligible Participating Number Percent Percent Number to Eliminate SSI Cash-Out B.8 Total California Benefits 614,322 2.1 227 307,780 -0.4 322 Benefits by Household Gross Income as a Percentage of Poverty Level No income 95,253 -12.8 *** 340 71,838 -7.7 *** 389 1-100% 409,906 4.8 *** 261 219,844 0.0 335 101-130% 97,874 5.8 *** 146 15,182 41.1 *** 155 131% or greater 11,288 24.4 *** 61 915 75.1 * 52 Benefits in Households with Income from Earnings 321,302 -0.7 * 260 96,172 0.1 307 Temporary Assistance for Needy Families 104,197 -6.3 *** 250 90,182 -6.4 *** 295 Social Security 65,995 39.6 *** 103 22,099 64.5 *** 205 Supplemental Security Income 65,273 *** 109 31,955 *** 197 Benefits by Household Benefit Level Eligible for minimum benefit 8,566 109.3 *** 16 604 157.9 *** 16 Eligible for maximum benefit 186,774 -5.0 *** 353 134,227 -3.5 *** 386 Eligible for other benefit 418,982 4.5 *** 255 172,949 1.9 303 Benefits in Households with Deductions Excess shelter deduction 404,702 4.5 *** 295 241,898 2.2 *** 350 Medical deduction 34,977 39.4 *** 116 9,385 49.7 *** 198 Dependent care deduction 22,720 -0.1 293 8,270 -1.9 356 Child support expense deduction 13,966 11.4 295 8,092 13.3 329 Benefits by Household Size One person 102,413 1.2 88 45,348 -4.7 * 152 Two people 113,700 7.7 ** 197 60,848 -1.5 249 More than two people 398,209 0.8 * 414 201,584 0.9 488 Benefits by Household Composition Households with elderly adults 58,679 51.4 *** 96 18,579 54.8 *** 183 Households with disabled nonelderly adults 45,168 131.5 *** 128 19,047 202.1 *** 209 Households with children 469,170 -2.1 *** 330 244,933 -3.1 *** 390 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance a Percent change from benefits for eligible and participating households under baseline rules (see ($000s) Change a Benefit ($000s) Change a Benefit Percent Average Total to Eliminate SSI Cash-Out Table B.7. Benefits for Eligible and Participating California Households Under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 Percent Average Benefits for Households Eligible under Simulation Eligible Participating Total B.9 Monthly Benefit 227 -12.9 *** 322 -6.1 *** Monthly Gross Income among Households with Positive Income 1,047 0.4 824 14.5 *** Monthly Net Income among Households with Positive Net Income 732 2.8 ** 604 20.9 *** Monthly Amount of Income Type among Households with Income Type Earnings 1,063 0.2 726 1.2 Temporary Assistance for Needy Families 512 0.3 536 0.2 Supplemental Security Income 537 *** 578 *** Social Security 739 -13.9 *** 590 -10.7 *** Amount of Deduction among Households with Deduction Excess shelter deduction 290 4.1 *** 296 5.5 *** Medical deduction 186 -10.5 *** 205 2.9 Dependent care deduction 212 0.3 288 1.2 Child support expense deduction 328 -8.5 379 -11.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Table B.8. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out, FY 2009 Average Value for California a Percent change from average values under baseline rules (see Table A.4) Eligible Participating Average ($) Average ($) Percent Change a Percent Change a to Eliminate SSI Cash-Out Households Eligible under Simulation B.10 Total California Households 435 100.0 60 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 386 88.7 59 98.7 101-130% 14 3.2 1 1.1 131% or greater 35 8.1 * 0.1 Households with Income from Earnings 29 6.7 1 2.3 Temporary Assistance for Needy Families * 0.1 0 0.0 Social Security 207 47.7 26 43.0 Supplemental Security Income 435 100.0 60 100.0 Benefit Level Eligible for minimum benefit 282 64.8 19 31.2 Eligible for maximum benefit 18 4.1 9 15.5 Eligible for other benefit 135 31.1 32 53.3 Households with Deductions Excess shelter deduction 129 29.6 43 72.5 Medical deduction 82 18.9 16 26.8 Dependent care deduction 2 0.4 * 0.8 Child support expense deduction 2 0.6 * 0.5 Household Size One person 358 82.4 50 83.5 Two people 70 16.1 10 16.3 More than two people 6 1.4 * 0.2 Household Composition Households with elderly adults 250 57.4 34 56.3 Households with disabled nonelderly adults 156 36.0 18 30.4 Households with children 7 1.7 1 0.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Table B.9A. Characteristics of California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out, FY 2009 Households Newly Eligible under Newly Eligible and ParticipatingAll Newly Eligible Simulation to Eliminate SSI Cash-Out Number Percent Number Percent (000s) of Total (000s) of Total B.11 Total Calfornia Households 62 100.0 2 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 59 95.6 * 5.1 101-130% 2 3.6 2 73.2 131% or greater 1 0.9 * 21.8 Households with Income from Earnings 3 4.3 1 61.1 Temporary Assistance for Needy Families 1 1.9 1 54.7 Social Security 27 42.9 1 38.9 Supplemental Security Income 61 98.7 1 61.1 Benefit Level Eligible for minimum benefit 19 31.4 1 38.9 Eligible for maximum benefit 9 15.0 0 0.0 Eligible for other benefit 33 53.6 1 61.1 Households with Deductions Excess shelter deduction 44 70.2 * 5.1 Medical deduction 17 26.9 1 30.1 Dependent care deduction * 0.7 0 0.0 Child support expense deduction * 0.5 0 0.0 Household Size One person 51 82.0 1 38.9 Two people 10 15.8 0 0.0 More than two people 1 2.2 1 61.1 Household Composition Households with elderly adults 35 55.9 1 45.3 Households with disabled nonelderly adults 18 29.6 * 6.4 Households with children 2 2.8 1 54.7 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Households Newly Participating under All Newly Participating Previously Eligible and Newly Participating Simulation to Eliminate SSI Cash-Out Table B.9B. Characteristics of California Households Newly Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 B.12 Total Calfornia Households 54 100.0 26 100.0 Gross Income as a Percentage of Poverty Level No income 16 29.4 5 18.6 1-100% 26 49.4 21 78.3 101-130% 9 17.6 1 2.7 131% or greater 2 3.6 * 0.4 Households with Income from Earnings 19 35.8 7 25.6 Temporary Assistance for Needy Families 10 19.2 9 34.8 Social Security 7 13.7 4 14.3 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit * 0.3 * 0.4 Eligible for maximum benefit 21 39.5 9 36.2 Eligible for other benefit 32 60.3 17 63.5 Households with Deductions Excess shelter deduction 21 39.4 14 53.3 Medical deduction 4 7.9 2 6.2 Dependent care deduction 1 1.9 1 2.8 Child support expense deduction 1 1.3 * 1.6 Household Size One person 27 50.7 12 47.6 Two people 11 21.3 7 26.2 More than two people 15 28.0 7 26.2 Household Composition Households with elderly adults 8 14.3 3 12.4 Households with disabled nonelderly adults 3 5.8 1 5.2 Households with children 27 50.0 16 59.3 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table B.9C. Characteristics of Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 B.13 Total California Households 37 100.0 7 100.0 Gross Income as a Percentage of Poverty Level No income 2 4.6 1 11.5 1-100% 12 32.4 5 81.2 101-130% 22 60.6 * 7.2 131% or greater 1 2.4 0 0.0 Households with Income from Earnings 23 60.8 2 30.7 Temporary Assistance for Needy Families 6 15.9 3 51.7 Social Security 14 37.1 * 3.6 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 8 22.6 * 1.4 Eligible for maximum benefit 2 4.9 1 12.7 Eligible for other benefit 27 72.6 6 85.9 Households with Deductions Excess shelter deduction 6 15.2 2 32.8 Medical deduction 3 8.8 1 7.8 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Household Size One person 17 47.1 4 61.1 Two people 10 25.7 2 26.5 More than two people 10 27.2 1 12.4 Household Composition Households with elderly adults 6 14.9 1 9.1 Households with disabled nonelderly adults 9 25.0 * 1.0 Households with children 16 43.8 5 72.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table B.10A. Characteristics of California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Households Losing Eligibility under All Newly Ineligible Participating in Baselaw Number Percent Number Percent Simulation to Eliminate SSI Cash-Out B.14 Total Calfornia Households 7 100.0 * 100.0 Gross Income as a Percentage of Poverty Level No income 1 10.8 0 0.0 1-100% 6 82.4 * 100.0 101-130% * 6.8 0 0.0 131% or greater 0 0.0 0 0.0 Households with Income from Earnings 2 28.8 0 0.0 Temporary Assistance for Needy Families 4 54.7 * 100.0 Social Security * 3.4 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit * 1.3 0 0.0 Eligible for maximum benefit 1 12.0 0 0.0 Eligible for other benefit 6 86.8 * 100.0 Households with Deductions Excess shelter deduction 3 37.0 * 100.0 Medical deduction 1 7.3 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Household Size One person 4 62.2 * 79.5 Two people 2 24.9 0 0.0 More than two people 1 12.9 * 20.5 Household Composition Households with elderly adults 1 8.6 0 0.0 Households with disabled nonelderly adults * 0.9 0 0.0 Households with children 5 73.9 * 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Households Newly Not Participating under All Newly Not Participating Still Eligible But No Longer Participating Simulation to Eliminate SSI Cash-Out Table B.10B. Characteristics of California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 B.15 Total Calfornia Households 128 100.0 84 100.0 Gross Income as a Percentage of Poverty Level No income 33 26.1 15 17.5 1-100% 90 70.2 69 82.5 101-130% 5 3.7 0 0.0 131% or greater 0 0.0 0 0.0 Households with Income from Earnings 28 21.8 8 9.5 Temporary Assistance for Needy Families 63 49.5 59 70.1 Social Security 9 7.1 2 2.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 36 28.2 16 19.2 Eligible for other benefit 92 71.8 68 80.8 Households with Deductions Excess shelter deduction 40 31.6 29 35.2 Medical deduction 6 4.4 1 1.7 Dependent care deduction 3 2.6 3 3.6 Child support expense deduction * 0.3 * 0.2 Household Size One person 48 37.6 28 34.1 Two people 29 23.0 21 25.1 More than two people 50 39.4 34 40.8 Household Composition Households with elderly adults 8 6.4 3 3.3 Households with disabled nonelderly adults 9 7.0 3 3.5 Households with children 101 79.2 74 88.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Households With Lower Benefits under Eligible under Simulation Participating under Simulation Simulation to Eliminate SSI Cash-Out Table B.10C. Characteristics of Eligible and Participating California Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 B.16 Total California Individuals 520 100.0 70 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 430 82.7 69 98.3 101-130% 27 5.2 1 1.5 131% or greater 63 12.1 * 0.1 Individuals in Households with Income from Earnings 47 9.0 2 3.4 Temporary Assistance for Needy Families 1 0.2 0 0.0 Social Security 245 47.1 32 45.1 Supplemental Security Income 520 100.0 70 100.0 Individuals by Household Benefit Level Eligible for minimum benefit 297 57.2 19 26.7 Eligible for maximum benefit 23 4.4 12 17.1 Eligible for other benefit 199 38.4 39 56.2 Individuals in Households with Deductions Excess shelter deduction 165 31.7 52 74.2 Medical deduction 103 19.8 21 29.9 Dependent care deduction 3 0.6 * 0.7 Child support expense deduction 3 0.6 * 0.4 Individuals by Household Size One person 358 68.9 50 71.6 Two people 140 27.0 20 28.0 More than two people 22 4.2 * 0.4 Individuals by Household Composition Households with elderly adults 304 58.4 43 61.8 Households with disabled nonelderly adults 189 36.3 19 26.5 Households with children 19 3.7 1 1.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Table B.11A. Characteristics of Individuals in California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Number Percent Number Percent Simulation to Eliminate SSI Cash-Out B.17 Total California Individuals 77 100.0 7 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 69 89.8 * 4.6 101-130% 7 9.5 6 88.9 131% or greater 1 0.7 * 6.6 Individuals in Households with Income from Earnings 9 11.1 6 88.3 Temporary Assistance for Needy Families 6 7.5 6 82.5 Social Security 32 42.1 1 11.7 Supplemental Security Income 76 98.9 6 88.3 Individuals by Household Benefit Level Eligible for minimum benefit 19 25.4 1 11.7 Eligible for maximum benefit 12 15.5 0 0.0 Eligible for other benefit 45 59.1 6 88.3 Individuals in Households with Deductions Excess shelter deduction 52 67.9 0 4.6 Medical deduction 22 28.1 1 9.9 Dependent care deduction * 0.6 0 0.0 Child support expense deduction * 0.4 0 0.0 Individuals by Household Size One person 51 66.2 1 11.7 Two people 20 25.4 0 0.0 More than two people 6 8.4 6 88.3 Individuals by Household Composition Households with elderly adults 44 57.8 1 17.5 Households with disabled nonelderly adults 19 24.6 * 5.8 Households with children 7 8.5 6 82.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Individuals in Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table B.11B. Characteristics of Individuals in California Households Newly Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 B.18 Total California Individuals 101 100.0 50 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 26 25.3 9 18.6 1-100% 49 48.0 39 78.4 101-130% 21 21.2 1 2.8 131% or greater 6 5.5 * 0.2 Individuals in Households with Income from Earnings 45 44.6 16 32.8 Temporary Assistance for Needy Families 25 24.5 20 40.3 Social Security 11 10.5 5 9.7 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit * 0.1 * 0.2 Eligible for maximum benefit 33 32.5 16 31.7 Eligible for other benefit 68 67.3 34 68.1 Individuals in Households with Deductions Excess shelter deduction 37 36.6 27 53.2 Medical deduction 7 6.4 2 4.7 Dependent care deduction 3 2.6 2 4.2 Child support expense deduction 1 1.2 1 1.9 Individuals by Household Size One person 27 26.7 12 24.8 Two people 23 22.5 14 27.3 More than two people 51 50.7 24 47.9 Individuals by Household Composition Households with elderly adults 9 9.0 3 6.8 Households with disabled nonelderly adults 6 5.7 3 5.2 Households with children 71 69.7 39 77.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Individuals in Households With Higher Benefits Eligible in Baselaw Participating in Baselaw under Simulation to Eliminate SSI Cash-Out Table B.11C. Individuals in Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 B.19 Total California Individuals 70 100.0 10 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 2 3.1 1 10.3 1-100% 19 27.4 9 85.0 101-130% 47 67.6 * 4.7 131% or greater 1 1.9 0 0.0 Individuals in Households with Income from Earnings 53 76.2 5 44.3 Temporary Assistance for Needy Families 13 18.6 6 54.3 Social Security 23 33.5 1 6.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 8 11.9 * 0.9 Eligible for maximum benefit 2 3.2 1 11.1 Eligible for other benefit 59 84.8 9 88.0 Individuals in Households with Deductions Excess shelter deduction 8 10.9 4 33.8 Medical deduction 5 6.9 2 15.1 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person 17 24.9 4 39.6 Two people 19 27.1 4 34.4 More than two people 34 48.0 3 26.1 Individuals by Household Composition Households with elderly adults 8 11.0 2 16.0 Households with disabled nonelderly adults 18 25.8 * 2.0 Households with children 43 61.4 9 82.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table B.12A. Characteristics of Individuals in California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Losing Eligibility All Newly Ineligible Participating in Baselaw Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out B.20 Total California Individuals 11 100.0 1 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 1 9.7 0 0.0 1-100% 9 85.9 1 100.0 101-130% * 4.4 0 0.0 131% or greater 0 0.0 0 0.0 Individuals in Households with Income from Earnings 5 41.7 0 0.0 Temporary Assistance for Needy Families 6 56.9 1 100.0 Social Security 1 5.7 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit * 0.8 0 0.0 Eligible for maximum benefit 1 10.5 0 0.0 Eligible for other benefit 10 88.7 1 100.0 Individuals in Households with Deductions Excess shelter deduction 4 37.6 1 100.0 Medical deduction 2 14.2 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person 4 40.5 * 56.3 Two people 4 32.4 0 0.0 More than two people 3 27.1 * 43.7 Individuals by Household Composition Households with elderly adults 2 15.1 0 0.0 Households with disabled nonelderly adults 0 1.8 0 0.0 Households with children 9 83.0 1 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table B.12B. Characteristics of Individuals in California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out B.21 Total California Individuals 310 100.0 204 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 47 15.0 22 10.7 1-100% 247 79.6 183 89.3 101-130% 17 5.4 0 0.0 131% or greater 0 0.0 0 0.0 Individuals in Households with Income from Earnings 90 28.9 24 11.6 Temporary Assistance for Needy Families 165 53.3 153 74.6 Social Security 29 9.5 4 2.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 52 16.7 25 12.3 Eligible for other benefit 258 83.3 179 87.7 Individuals in Households with Deductions Excess shelter deduction 115 37.1 80 39.3 Medical deduction 16 5.2 4 1.9 Dependent care deduction 10 3.3 9 4.5 Child support expense deduction 1 0.4 * 0.2 Individuals by Household Size One person 48 15.5 28 13.9 Two people 59 19.0 42 20.5 More than two people 203 65.6 134 65.6 Individuals by Household Composition Households with elderly adults 12 3.8 6 3.1 Households with disabled nonelderly adults 35 11.4 16 7.8 Households with children 281 90.5 194 95.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 (000s) of Total (000s) of Total Number Percent Number Percent Individuals in Households With Lower Benefits Eligible under Simulation Participating under Simulation under Simulation to Eliminate SSI Cash-Out Table B.12C. Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out, FY 2009 B.22 Total Benefits 25,107 100.0 6,986 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 23,097 92.0 6,874 98.4 101-130% 898 3.6 111 1.6 131% or greater 1,112 4.4 1 0.0 Benefits in Households with Income from Earnings 1,531 6.1 339 4.8 Temporary Assistance for Needy Families 32 0.1 0 0.0 Social Security 11,901 47.4 3,509 50.2 Supplemental Security Income 25,107 100.0 6,986 100.0 Benefits by Household Benefit Level Eligible for minimum benefit 4,548 18.1 301 4.3 Eligible for maximum benefit 4,431 17.6 2,298 32.9 Eligible for other benefit 16,128 64.2 4,387 62.8 Benefits in Households with Deductions Excess shelter deduction 15,964 63.6 6,516 93.3 Medical deduction 7,997 31.9 2,723 39.0 Dependent care deduction 179 0.7 92 1.3 Child support expense deduction 249 1.0 60 0.9 Benefits by Household Size One person 13,795 54.9 4,380 62.7 Two people 10,469 41.7 2,592 37.1 More than two people 842 3.4 15 0.2 Benefits by Household Composition Households with elderly adults 16,529 65.8 4,912 70.3 Households with disabled nonelderly adults 7,382 29.4 1,390 19.9 Households with children 837 3.3 107 1.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Table B.13A. Benefits for Eligible California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Total Percent Total Percent Simulation to Eliminate SSI Cash-Out B.23 Total Benefits 7,224 100.0 238 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 6,910 95.7 35 14.9 101-130% 305 4.2 195 82.0 131% or greater 9 0.1 7 3.1 Benefits in Households with Income from Earnings 563 7.8 224 94.4 Temporary Assistance for Needy Families 184 2.5 184 77.2 Social Security 3,522 48.8 13 5.6 Supplemental Security Income 7,211 99.8 224 94.4 Benefits by Household Benefit Level Eligible for minimum benefit 315 4.4 13 5.6 Eligible for maximum benefit 2,298 31.8 0 0.0 Eligible for other benefit 4,611 63.8 224 94.4 Benefits in Households with Deductions Excess shelter deduction 6,552 90.7 35 14.9 Medical deduction 2,738 37.9 15 6.4 Dependent care deduction 92 1.3 0 0.0 Child support expense deduction 60 0.8 0 0.0 Benefits by Household Size One person 4,393 60.8 13 5.6 Two people 2,592 35.9 0 0.0 More than two people 239 3.3 224 94.4 Benefits by Household Composition Households with elderly adults 4,966 68.7 54 22.8 Households with disabled nonelderly adults 1,431 19.8 41 17.2 Households with children 290 4.0 184 77.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. ($000s) of Total ($000s) of Total Total Percent Total Percent Benefits for Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table B.13B. Benefits for Eligible California Households Newly Participating under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 B.24 Total Benefits 12,941 2,810 100.0 7,315 1,258 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 4,741 1,259 36.6 1,709 399 23.4 1-100% 6,544 1,236 50.6 5,508 821 75.3 101-130% 1,429 285 11.0 96 38 1.3 131% or greater 227 30 1.8 2 * 0.0 Benefits in Households with Income from Earnings 4,263 545 32.9 2,321 148 31.7 Temporary Assistance for Needy Families 2,626 429 20.3 2,465 407 33.7 Social Security 1,036 348 8.0 445 132 6.1 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 2 3 0.0 2 1 0.0 Eligible for maximum benefit 6,142 1,765 47.5 2,957 807 40.4 Eligible for other benefit 6,796 1,042 52.5 4,356 451 59.6 Benefits in Households with Deductions Excess shelter deduction 4,944 801 38.2 3,931 551 53.7 Medical deduction 739 343 5.7 265 121 3.6 Dependent care deduction 445 73 3.4 370 67 5.1 Child support expense deduction 225 44 1.7 171 10 2.3 Benefits by Household Size One person 4,240 1,569 32.8 1,947 651 26.6 Two people 3,091 696 23.9 1,979 329 27.1 More than two people 5,610 546 43.4 3,390 278 46.3 Benefits by Household Composition Households with elderly adults 1,146 348 8.9 412 123 5.6 Households with disabled nonelderly adults 634 64 4.9 322 29 4.4 Households with children 8,496 1,418 65.7 5,559 688 76.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Benefits for Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table B.13C. Benefits for Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 Total Percent Total Percent ($000s) Increase ($000s) Increase Increase ($000s) Increase ($000s) B.25 Total Benefits 3,871 100.0 1,321 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 421 10.9 205 15.5 1-100% 1,741 45.0 1,102 83.4 101-130% 1,681 43.4 14 1.1 131% or greater 28 0.7 0 0.0 Benefits in Households with Income from Earnings 2,651 68.5 554 42.0 Temporary Assistance for Needy Families 919 23.7 613 46.4 Social Security 568 14.7 47 3.5 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 135 3.5 1 0.1 Eligible for maximum benefit 437 11.3 221 16.7 Eligible for other benefit 3,298 85.2 1,099 83.2 Benefits in Households with Deductions Excess shelter deduction 455 11.8 326 24.7 Medical deduction 211 5.5 110 8.4 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 1,082 28.0 539 40.8 Two people 979 25.3 568 43.0 More than two people 1,809 46.7 214 16.2 Benefits by Household Composition Households with elderly adults 304 7.8 112 8.5 Households with disabled nonelderly adults 397 10.3 16 1.2 Households with children 2,989 77.2 1,127 85.3 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table B.14A. Benefits for Eligible California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Losing Eligibility All Newly Ineligible Participating in Baselaw Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out B.26 Total Benefits 1,405 100.0 84 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 205 14.6 0 0.0 1-100% 1,186 84.4 84 100.0 101-130% 14 1.0 0 0.0 131% or greater 0 0.0 0 0.0 Benefits in Households with Income from Earnings 554 39.5 0 0.0 Temporary Assistance for Needy Families 697 49.6 84 100.0 Social Security 47 3.3 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 1 0.1 0 0.0 Eligible for maximum benefit 221 15.7 0 0.0 Eligible for other benefit 1,183 84.2 84 100.0 Benefits in Households with Deductions Excess shelter deduction 411 29.2 84 100.0 Medical deduction 110 7.9 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 590 42.0 51 60.7 Two people 568 40.4 0 0.0 More than two people 247 17.6 33 39.3 Benefits by Household Composition Households with elderly adults 112 8.0 0 0.0 Households with disabled nonelderly adults 16 1.1 0 0.0 Households with children 1,211 86.2 84 100.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table B.14B. Benefits for Eligible California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out B.27 Total Benefits 39,832 11,560 100.0 26,897 8,338 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 8,847 1,944 22.2 4,105 1,050 15.3 1-100% 29,758 9,466 74.7 22,792 7,287 84.7 101-130% 1,227 150 3.1 0 0 0.0 131% or greater 0 0 0.0 0 0 0.0 Benefits in Households with Income from Earnings 9,804 2,845 24.6 3,150 964 11.7 Temporary Assistance for Needy Families 19,894 6,589 49.9 18,561 6,028 69.0 Social Security 2,541 570 6.4 412 118 1.5 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 0 0 0.0 0 0 0.0 Eligible for maximum benefit 9,785 2,171 24.6 4,705 1,182 17.5 Eligible for other benefit 30,047 9,389 75.4 22,191 7,155 82.5 Benefits in Households with Deductions Excess shelter deduction 13,726 3,819 34.5 10,317 2,872 38.4 Medical deduction 1,482 448 3.7 562 283 2.1 Dependent care deduction 1,346 350 3.4 1,223 317 4.5 Child support expense deduction 176 56 0.4 59 21 0.2 Benefits by Household Size One person 8,013 2,923 20.1 4,535 2,120 16.9 Two people 7,920 2,896 19.9 5,694 2,227 21.2 More than two people 23,899 5,740 60.0 16,667 3,990 62.0 Benefits by Household Composition Households with elderly adults 1,864 538 4.7 916 376 3.4 Households with disabled nonelderly adults 3,626 592 9.1 2,083 301 7.7 Households with children 34,744 10,391 87.2 25,083 7,839 93.3 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Total Decrease Percent Simulation to Eliminate SSI Cash-Out Table B.14C. Benefits for Eligible and Participating California Households With Lower Benefits under Simulation to Eliminate SSI Cash-Out by Household Characteristic, FY 2009 Decrease Benefits for Households With Lower Benefits under Eligible under Simulation Participating under Simulation Total Decrease ($000s) ($000s) Decrease ($000s) ($000s) Percent B.28 Potential Monthly Benefit 58 117 294 327 Monthly Gross Income among Households with Positive Income 872 821 1,104 938 Monthly Net Income among Households with Positive Net Income 640 469 661 537 Monthly Amount of Income Type among Households with Income Type Earnings 1,034 1069 913 462 Temporary Assistance for Needy Families 121 276 444 466 Supplemental Security Income 514 509 520 508 Social Security 547 538 566 522 Amount of Deduction among Households with Deduction Excess shelter deduction 326 380 344 305 Medical deduction 125 211 228 257 Dependent care deduction 194 200 422 358 Child support expense deduction 216 403 363 387 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Newly Participating Still Participating with Higher Table B.15. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Gaining under Simulation to Eliminate SSI Cash-Out, FY 2009 Average Value for California Households Gaining under Simulation to Eliminate SSI Cash-Out ($) Newly Eligible or Participating Eligible or Participating in Baselaw Newly Eligible Still Eligible with Higher B.29 Potential Monthly Benefit 105 196 312 322 Monthly Gross Income among Households with Positive Income 1,105 525 729 614 Monthly Net Income among Households with Positive Net Income 810 326 475 398 Monthly Amount of Income Type among Households with Income Type Earnings 906 373 830 608 Temporary Assistance for Needy Families 382 359 518 533 Supplemental Security Income 0 0 0 0 Social Security 882 728 597 211 Amount of Deduction among Households with Deduction Excess shelter deduction 199 108 138 133 Medical deduction 169 9 114 116 Dependent care deduction 0 0 248 274 Child support expense deduction 0 0 325 290 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table B.16. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Losing under Simulation to Eliminate SSI Cash-Out, FY 2009 Newly Ineligible Newly Not Participating Still Eligible with Lower Still Participating with Lower Average Value for California Households Losing under Simulation to Eliminate SSI Cash-Out ($) Newly Ineligible or Not Participating Eligible or Participating under Simulation B.30 Total California Households 435 100.0 282 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 386 88.7 250 88.9 101-130% 14 3.2 6 2.2 131% or greater 35 8.1 25 8.9 Households with Income from Earnings 29 6.7 18 6.3 Temporary Assistance for Needy Families 0 0.1 0 0.0 Social Security 207 47.7 133 47.3 Supplemental Security Income 435 100.0 282 100.0 Benefit Level Eligible for minimum benefit 282 64.8 282 100.0 Eligible for maximum benefit 18 4.1 0 0.0 Eligible for other benefit 135 31.1 0 0.0 Households with Deductions Excess shelter deduction 129 29.6 15 5.3 Medical deduction 82 18.9 30 10.5 Dependent care deduction 2 0.4 1 0.3 Child support expense deduction 2 0.6 1 0.4 Household Size One person 358 82.4 266 94.4 Two people 70 16.1 16 5.6 More than two people 6 1.4 0 0.0 Household Composition Households with elderly adults 250 57.4 149 53.1 Households with disabled nonelderly adults 156 36.0 110 39.1 Households with children 7 1.7 3 1.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table B.17. Characteristics of California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out, FY 2009 Number Percent Number Percent (000s) of Total (000s) of Total B.31 Total California Households 435 100.0 282 100.0 Countable Earned Income $0 406 93.3 264 93.7 1-499 9 2.0 7 2.5 500-999 4 0.9 3 1.1 1,000 or greater 16 3.7 8 2.8 Countable Social Security $0 227 52.3 148 52.7 1-199 19 4.3 5 1.7 200-399 24 5.5 17 6.1 400-599 65 15.1 41 14.6 600-799 96 22.1 68 24.0 800-999 1 0.2 1 0.2 1,000 or greater 2 0.4 2 0.7 Countable Supplemental Security Income $0 0 0.0 0 0.0 1-199 111 25.6 73 26.0 200-399 70 16.1 44 15.5 400-599 31 7.1 22 7.9 600-799 206 47.4 133 47.2 800-999 5 1.1 4 1.5 1,000 or greater 12 2.7 5 1.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$830 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table B.18. Income Distribution for California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out, FY 2009 Number Percent Number Percent (000s) of Total (000s) of Total B.32 Mathematica Policy Research APPENDIX C DETAILED TABLES SHOWING ESTIMATED EFFECTS OF ELIMINATING SSI CASH-OUT FOR ONE-PERSON HOUSEHOLDS WITH 100 PERCENT PARTICIPATION BY NEWLY ELIGIBLE HOUSEHOLDS, IMPLEMENTING A STANDARD MEDICAL DEDUCTION, AND LOWERING THE STANDARD UTILITY ALLOWANCE Page is left intentionally blank to allow for double-sided copying Total California Households 2,284 100.0 889 100.0 Gross Income as a Percentage of Poverty Level No income 334 14.6 205 23.0 1-100% 1,184 51.9 611 68.7 101-130% 623 27.3 61 6.8 131% or greater 143 6.3 13 1.4 Households with Income from Earnings 1,224 53.6 301 33.9 Temporary Assistance for Needy Families 424 18.6 309 34.7 Social Security 376 16.5 48 5.4 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 246 10.8 11 1.3 Eligible for maximum benefit 568 24.9 361 40.6 Eligible for other benefit 1,470 64.4 516 58.1 Households with Deductions Excess shelter deduction 1,222 53.5 641 72.1 Medical deduction 196 8.6 24 2.7 Dependent care deduction 75 3.3 23 2.6 Child support expense deduction 40 1.8 21 2.4 Household Size One person 891 39.0 285 32.0 Two people 471 20.6 223 25.1 More than two people 923 40.4 382 42.9 Household Composition Households with elderly adults 324 14.2 48 5.4 Households with disabled nonelderly adults 112 4.9 17 1.9 Households with children 1,428 62.5 627 70.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table C.1. Characteristics of Eligible and Participating California Households, FY 2009 Participating (000s) of Total Households (000s) of Total Eligible Number Percent Number Percent C.3 Total California Individuals 5,604 100.0 2,237 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 609 10.9 441 19.7 1-100% 3,224 57.5 1,625 72.6 101-130% 1,532 27.3 144 6.5 131% or greater 238 4.3 26 1.2 Individuals in Households with Income from Earnings 3,482 62.1 773 34.6 Temporary Assistance for Needy Families 1,173 20.9 887 39.7 Social Security 632 11.3 121 5.4 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 268 4.8 16 0.7 Eligible for maximum benefit 1,096 19.6 784 35.1 Eligible for other benefit 4,240 75.7 1,437 64.3 Individuals in Households with Deductions Excess shelter deduction 3,092 55.2 1,622 72.5 Medical deduction 284 5.1 35 1.6 Dependent care deduction 214 3.8 63 2.8 Child support expense deduction 93 1.7 44 2.0 Individuals by Household Size One person 891 15.9 285 12.7 Two people 941 16.8 446 19.9 More than two people 3,772 67.3 1,507 67.3 Individuals by Household Composition Households with elderly adults 445 7.9 75 3.4 Households with disabled nonelderly adults 229 4.1 47 2.1 Households with children 4,584 81.8 1,923 86.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. (000s) of Total(000s) of Total Table C.2. Characteristics of Individuals in Eligible and Participating California Households by Household Characteristics, FY 2009 Individuals in Households ParticipatingEligible Number Percent Number Percent C.4 Total California Benefits 598,636 262 305,799 344 Benefits by Household Gross Income as a Percentage of Poverty Level No income 109,930 329 77,857 380 1-100% 389,714 329 216,839 355 101-130% 90,562 145 10,640 175 131% or greater 8,431 59 463 36 Benefits in Households with Income from Earnings 323,186 264 94,130 312 Temporary Assistance for Needy Families 111,157 262 96,137 311 Social Security 42,212 112 12,165 256 Supplemental Security Income 0 0 0 0 Benefits by Household Benefit Level Eligible for minimum benefit 3,977 16 182 16 Eligible for maximum benefit 196,539 346 138,482 383 Eligible for other benefit 398,121 271 167,134 324 Benefits in Households with Deductions Excess shelter deduction 382,261 313 232,062 362 Medical deduction 21,892 112 5,569 230 Dependent care deduction 22,681 303 8,451 370 Child support expense deduction 12,486 310 7,143 341 Benefits by Household Size One person 101,881 114 47,389 167 Two people 102,203 217 60,946 273 More than two people 394,552 428 197,463 517 Benefits by Household Composition Households with elderly adults 34,957 108 10,730 225 Households with disabled nonelderly adults 18,229 162 6,236 371 Households with children 479,495 336 250,589 399 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Total ($000s) Total ($000s) Table C.3. Benefits for Eligible and Participating California Households by Household Characteristic, FY 2009 Benefits for Households ParticipatingEligible Benefit ($) Benefit ($) Average Average C.5 Monthly Benefit 262 344 Monthly Gross Income among Households with Positive Income 1,039 713 Monthly Net Income among Households with Positive Net Income 710 494 Monthly Amount of Income Type among Households with Income Type Earnings 1,060 720 Temporary Assistance for Needy Families 510 535 Supplemental Security Income 0 0 Social Security 862 654 Amount of Deduction among Households with Deduction Excess shelter deduction 276 280 Medical deduction 206 203 Dependent care deduction 211 285 Child support expense deduction 360 427 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Participating Average Value for Households ($) Eligible Table C.4 Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households, FY 2009 C.6 Total California Households 2,673 100.0 17.0 *** 1,314 100.0 47.8 *** Gross Income as a Percentage of Poverty Level No income 334 12.5 0.0 215 16.3 4.9 1-100% 1,536 57.5 29.7 *** 980 74.6 60.4 *** 101-130% 638 23.9 2.5 *** 84 6.4 37.8 *** 131% or greater 165 6.2 14.9 *** 36 2.7 180.9 *** Households with Income from Earnings 1,244 46.5 1.6 338 25.7 12.1 *** Temporary Assistance for Needy Families 424 15.9 0.0 309 23.5 0.0 Social Security 576 21.5 52.9 *** 256 19.5 438.4 *** Supplemental Security Income 370 13.8 *** 370 28.1 *** Benefit Level Eligible for minimum benefit 506 18.9 105.5 *** 284 21.6 2,420.7 *** Eligible for maximum benefit 582 21.8 2.5 *** 388 29.5 7.3 ** Eligible for other benefit 1,585 59.3 7.8 *** 642 48.9 24.4 *** Households with Deductions Excess shelter deduction 1,316 49.2 7.6 *** 754 57.4 17.6 *** Medical deduction 280 10.5 42.6 *** 111 8.5 360.4 *** Dependent care deduction 76 2.8 1.3 24 1.8 4.1 Child support expense deduction 42 1.6 5.0 * 23 1.8 10.4 ** Household Size One person 1,274 47.7 43.1 *** 692 52.7 143.2 *** Two people 475 17.8 0.8 232 17.6 3.9 ** More than two people 924 34.6 0.1 391 29.7 2.4 ** Household Composition Households with elderly adults 545 20.4 68.3 *** 278 21.1 482.2 *** Households with disabled nonelderly adults 246 9.2 118.8 *** 152 11.6 805.7 *** Households with children 1,430 53.5 0.1 ** 639 48.6 1.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance a Percent change from number eligible and number participating under baseline rules (see Table C.1) (000s) of Total Change a (000s) Table C.5. Characteristics of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Percent Percent of Total Change a Households Eligible under Simulation to Eliminate SSI Cash-Out Eligible Participating Number Percent Percent Number C.7 Total California Individuals 5,999 100.0 7.1 *** 2,693 100.0 20.4 *** Individuals by Household Gross Income as a Percentage of Poverty Level No income 609 10.2 0.0 453 16.8 2.6 1-100% 3,576 59.6 10.9 *** 2,015 74.8 24.0 *** 101-130% 1,549 25.8 1.1 *** 170 6.3 17.7 *** 131% or greater 265 4.4 11.2 *** 55 2.0 110.6 *** Individuals in Households with Income from Earnings 3,504 58.4 0.6 834 31.0 7.9 *** Temporary Assistance for Needy Families 1,173 19.6 0.0 887 33.0 0.0 Social Security 836 13.9 32.2 *** 336 12.5 176.8 *** Supplemental Security Income 370 6.2 *** 370 13.7 *** Individuals by Household Benefit Level Eligible for minimum benefit 527 8.8 97.1 *** 288 10.7 1,754.5 *** Eligible for maximum benefit 1,110 18.5 1.2 *** 814 30.2 3.8 ** Eligible for other benefit 4,362 72.7 2.9 *** 1,591 59.1 10.7 *** Individuals in Households with Deductions Excess shelter deduction 3,175 52.9 2.7 *** 1,748 64.9 7.7 *** Medical deduction 374 6.2 31.9 *** 130 4.8 266.1 *** Dependent care deduction 215 3.6 0.4 64 2.4 1.5 Child support expense deduction 95 1.6 2.2 * 46 1.7 4.9 ** Individuals by Household Size One person 1,274 21.2 43.1 *** 692 25.7 143.2 *** Two people 949 15.8 0.8 463 17.2 3.9 ** More than two people 3,776 62.9 0.1 1,538 57.1 2.1 ** Individuals by Household Composition Households with elderly adults 672 11.2 50.9 *** 312 11.6 316.6 *** Households with disabled nonelderly adults 363 6.1 58.7 *** 183 6.8 291.4 *** Households with children 4,589 76.5 0.1 ** 1,959 72.7 1.8 ** Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance PercentPercent Change a Table C.6. Characteristics of Individuals in Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Individuals in Households Eligible under Simulation Eligible Participating Number Percent Percent Number to Eliminate SSI Cash-Out a Percent change from number eligible and number participating under baseline rules (see Table C.2) (000s) of Change a (000s) of C.8 Total California Benefits 613,851 2.5 230 327,842 7.2 *** 249 Benefits by Household Gross Income as a Percentage of Poverty Level No income 109,930 0.0 329 80,107 2.9 373 1-100% 403,777 3.6 *** 263 235,493 8.6 *** 240 101-130% 90,917 0.4 ** 143 11,144 4.7 ** 133 131% or greater 9,227 9.5 *** 56 1,099 137.2 *** 31 Benefits in Households with Income from Earnings 323,532 0.1 260 99,308 5.5 ** 294 Temporary Assistance for Needy Families 111,065 -0.1 262 96,037 -0.1 311 Social Security 50,785 20.3 *** 88 20,295 66.8 *** 79 Supplemental Security Income 14,246 *** 39 14,246 *** 39 Benefits by Household Benefit Level Eligible for minimum benefit 8,172 105.5 *** 16 4,586 2,420.7 *** 16 Eligible for maximum benefit 199,283 1.4 *** 343 144,355 4.2 ** 372 Eligible for other benefit 406,397 2.1 *** 256 178,902 7.0 *** 279 Benefits in Households with Deductions Excess shelter deduction 390,015 2.0 *** 296 243,982 5.1 *** 324 Medical deduction 28,176 28.7 *** 101 10,955 96.7 *** 98 Dependent care deduction 22,777 0.4 300 8,565 1.3 360 Child support expense deduction 12,711 1.8 ** 300 7,373 3.2 ** 319 Benefits by Household Size One person 116,601 14.4 *** 92 64,625 36.4 *** 93 Two people 102,589 0.4 216 62,306 2.2 269 More than two people 394,661 0.0 427 200,912 1.7 * 514 Benefits by Household Composition Households with elderly adults 44,309 26.8 *** 81 19,902 85.5 *** 72 Households with disabled nonelderly adults 23,489 28.9 *** 96 11,243 80.3 *** 74 Households with children 479,622 0.0 335 254,506 1.6 * 398 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Percent Average Total to Eliminate SSI Cash-Out Table C.7. Benefits for Eligible and Participating California Households Under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 Percent Average Benefits for Households Eligible under Simulation Eligible Participating Total a Percent change from benefits for eligible and participating households under baseline rules (see Table C.3) ($000s) Change a Benefit ($000s) Change a Benefit C.9 Monthly Benefit 230 -12.4 *** 249 -27.5 *** Monthly Gross Income among Households with Positive Income 1,007 -3.1 *** 761 6.7 *** Monthly Net Income among Households with Positive Net Income 692 -2.6 *** 545 10.2 *** Monthly Amount of Income Type among Households with Income Type Earnings 1,059 -0.1 728 1.2 Temporary Assistance for Needy Families 510 0.0 535 0.0 Supplemental Security Income 470 *** 470 *** Social Security 783 -9.1 *** 645 -1.3 Amount of Deduction among Households with Deduction Excess shelter deduction 280 1.3 ** 281 0.5 Medical deduction 212 2.9 175 -13.9 Dependent care deduction 211 -0.1 281 -1.4 Child support expense deduction 354 -1.5 409 -4.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Change is statistically different from zero at a 90% level of significance ** Change is statistically different from zero at a 95% level of significance *** Change is statistically different from zero at a 99% level of significance Table C.8. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Average Value for California a Percent change from average values under baseline rules (see Table C.4) Eligible Participating Average ($) Average ($) Percent Change a Percent Change a to Eliminate SSI Cash-Out Households Eligible under Simulation C.10 Total California Households 389 100.0 389 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 352 90.5 352 90.5 101-130% 15 3.9 15 3.9 131% or greater 22 5.6 22 5.6 Households with Income from Earnings 20 5.1 20 5.1 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 200 51.3 200 51.3 Supplemental Security Income 370 95.0 370 95.0 Benefit Level Eligible for minimum benefit 267 68.5 267 68.5 Eligible for maximum benefit 14 3.6 14 3.6 Eligible for other benefit 109 27.9 109 27.9 Households with Deductions Excess shelter deduction 104 26.7 104 26.7 Medical deduction 84 21.6 84 21.6 Dependent care deduction 1 0.2 1 0.2 Child support expense deduction 2 0.5 2 0.5 Household Size One person 384 98.7 384 98.7 Two people 4 1.0 4 1.0 More than two people 1 0.3 1 0.3 Household Composition Households with elderly adults 221 56.8 221 56.8 Households with disabled nonelderly adults 134 34.4 134 34.4 Households with children 2 0.5 2 0.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Number Percent Number Percent (000s) of Total (000s) of Total Table C.9A. Characteristics of California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Households Newly Eligible under Newly Eligible and ParticipatingAll Newly Eligible Simulation to Eliminate SSI Cash-Out C.11 Total Calfornia Households 425 100.0 36 100.0 Gross Income as a Percentage of Poverty Level No income 10 2.4 10 28.0 1-100% 369 86.8 17 47.1 101-130% 23 5.4 8 21.2 131% or greater 23 5.4 1 3.6 Households with Income from Earnings 37 8.6 17 46.8 Temporary Assistance for Needy Families 0 0.0 * 0.3 Social Security 209 49.1 9 25.0 Supplemental Security Income 370 87.0 0 0.0 Benefit Level Eligible for minimum benefit 273 64.2 6 17.3 Eligible for maximum benefit 27 6.2 13 35.2 Eligible for other benefit 126 29.6 17 47.5 Households with Deductions Excess shelter deduction 114 26.9 10 29.2 Medical deduction 87 20.5 3 8.5 Dependent care deduction 1 0.2 0 0.0 Child support expense deduction 2 0.5 0 0.4 Household Size One person 407 95.8 23 65.2 Two people 9 2.0 5 13.0 More than two people 9 2.1 8 21.8 Household Composition Households with elderly adults 230 54.1 9 24.9 Households with disabled nonelderly adults 135 31.9 2 4.3 Households with children 12 2.7 10 26.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Households Newly Participating under All Newly Participating Previously Eligible and Newly Participating Simulation to Eliminate SSI Cash-Out Table C.9B. Characteristics of California Households Newly Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.12 Total Calfornia Households 43 100.0 3 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 19 43.6 2 81.5 101-130% 14 32.2 1 18.5 131% or greater 11 24.2 0 0.0 Households with Income from Earnings 13 29.8 2 54.4 Temporary Assistance for Needy Families 2 4.1 1 29.5 Social Security 36 83.8 1 45.6 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 7 15.2 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 37 84.8 3 100.0 Households with Deductions Excess shelter deduction 30 68.2 3 92.7 Medical deduction 43 100.0 3 100.0 Dependent care deduction * 0.1 0 0.0 Child support expense deduction * 0.6 0 0.0 Household Size One person 20 46.2 * 17.0 Two people 12 27.3 * 12.0 More than two people 11 26.5 2 70.9 Household Composition Households with elderly adults 32 74.6 2 72.3 Households with disabled nonelderly adults 11 25.8 1 27.7 Households with children 12 27.1 2 77.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table C.9C. Characteristics of Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.13 Total California Households * 100.0 0 0.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater * 100.0 0 0.0 Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security * 100.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit * 100.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Households with Deductions Excess shelter deduction * 100.0 0 0.0 Medical deduction * 100.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Household Size One person * 100.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults * 100.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table C.10A. Characteristics of California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Households Losing Eligibility under All Newly Ineligible Participating in Baselaw Number Percent Number Percent Simulation to Eliminate SSI Cash-Out C.14 Total Calfornia Households 0 0.0 0 0.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater 0 0.0 0 0.0 Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 0 0.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Households with Deductions Excess shelter deduction 0 0.0 0 0.0 Medical deduction 0 0.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Household Size One person 0 0.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults 0 0.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households Newly Not Participating under All Newly Not Participating Still Eligible But No Longer Participating Simulation to Eliminate SSI Cash-Out Table C.10B. Characteristics of California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.15 Total Calfornia Households 481 100.0 197 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 291 60.5 158 80.5 101-130% 156 32.5 32 16.1 131% or greater 34 7.0 7 3.5 Households with Income from Earnings 346 71.8 120 61.0 Temporary Assistance for Needy Families 92 19.0 90 45.6 Social Security 86 17.8 20 10.0 Supplemental Security Income 0 0.0 0 0.0 Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 1 0.2 * 0.2 Eligible for other benefit 480 99.8 196 99.8 Households with Deductions Excess shelter deduction 481 100.0 197 100.0 Medical deduction 33 6.8 3 1.4 Dependent care deduction 21 4.3 7 3.4 Child support expense deduction 7 1.5 2 1.3 Household Size One person 139 28.9 49 24.9 Two people 109 22.7 51 26.1 More than two people 233 48.4 96 49.0 Household Composition Households with elderly adults 75 15.7 18 9.1 Households with disabled nonelderly adults 24 5.0 4 2.0 Households with children 351 73.0 166 84.5 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Households With Lower Benefits under Eligible under Simulation Participating under Simulation Simulation to Eliminate SSI Cash-Out Table C.10C. Characteristics of Eligible and Participating California Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.16 Total California Individuals 396 100.0 396 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 352 88.9 352 88.9 101-130% 17 4.2 17 4.2 131% or greater 27 6.9 27 6.9 Individuals in Households with Income from Earnings 22 5.5 22 5.5 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 204 51.5 204 51.5 Supplemental Security Income 370 93.4 370 93.4 Individuals by Household Benefit Level Eligible for minimum benefit 267 67.3 267 67.3 Eligible for maximum benefit 14 3.5 14 3.5 Eligible for other benefit 115 29.2 115 29.2 Individuals in Households with Deductions Excess shelter deduction 109 27.6 109 27.6 Medical deduction 91 22.9 91 22.9 Dependent care deduction 1 0.2 1 0.2 Child support expense deduction 2 0.5 2 0.5 Individuals by Household Size One person 384 97.0 384 97.0 Two people 8 2.0 8 2.0 More than two people 4 1.0 4 1.0 Individuals by Household Composition Households with elderly adults 227 57.3 227 57.3 Households with disabled nonelderly adults 135 34.1 135 34.1 Households with children 5 1.3 5 1.3 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Table C.11A. Characteristics of Individuals in California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Number Percent Number Percent Simulation to Eliminate SSI Cash-Out C.17 Total California Individuals 456 100.0 60 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 11 2.5 11 19.1 1-100% 390 85.6 38 63.5 101-130% 25 5.6 9 14.7 131% or greater 29 6.3 2 2.7 Individuals in Households with Income from Earnings 61 13.3 39 64.7 Temporary Assistance for Needy Families 0 0.0 * 0.3 Social Security 215 47.1 11 17.7 Supplemental Security Income 370 81.1 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 273 59.8 6 10.4 Eligible for maximum benefit 31 6.7 17 28.0 Eligible for other benefit 152 33.4 37 61.6 Individuals in Households with Deductions Excess shelter deduction 133 29.1 24 39.2 Medical deduction 94 20.7 3 5.7 Dependent care deduction 1 0.2 0 0.0 Child support expense deduction 2 0.5 * 0.2 Individuals by Household Size One person 407 89.3 23 39.1 Two people 17 3.8 9 15.5 More than two people 31 6.9 27 45.4 Individuals by Household Composition Households with elderly adults 237 52.1 11 17.5 Households with disabled nonelderly adults 136 29.9 2 2.7 Households with children 36 7.8 30 50.6 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. * Less than 500 Individuals in Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table C.11B. Characteristics of Individuals in California Households Newly Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.18 Total California Individuals 93 100.0 8 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 55 58.8 6 81.2 101-130% 21 22.2 1 18.8 131% or greater 18 19.1 0 0.0 Individuals in Households with Income from Earnings 42 45.1 5 61.2 Temporary Assistance for Needy Families 7 7.2 3 37.9 Social Security 79 84.3 3 38.8 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 7 7.3 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 86 92.7 8 100.0 Individuals in Households with Deductions Excess shelter deduction 55 59.2 7 92.7 Medical deduction 93 100.0 8 100.0 Dependent care deduction * 0.1 0 0.0 Child support expense deduction * 0.4 0 0.0 Individuals by Household Size One person 20 21.5 * 6.4 Two people 24 25.5 1 9.0 More than two people 49 53.0 6 84.6 Individuals by Household Composition Households with elderly adults 62 66.4 5 71.6 Households with disabled nonelderly adults 32 34.1 2 28.4 Households with children 49 53.0 7 89.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Individuals in Households With Higher Benefits Eligible in Baselaw Participating in Baselaw under Simulation to Eliminate SSI Cash-Out Table C.11C. Individuals in Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.19 Total California Individuals * 100.0 0 0.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater * 100.0 0 0.0 Individuals in Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security * 100.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit * 100.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Individuals in Households with Deductions Excess shelter deduction * 100.0 0 0.0 Medical deduction * 100.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person * 100.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Individuals by Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults * 100.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table C.12A. Characteristics of Individuals in California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Individuals in Households Losing Eligibility All Newly Ineligible Participating in Baselaw Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out C.20 Total California Individuals 0 0.0 0 0.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater 0 0.0 0 0.0 Individuals in Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 0 0.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Individuals in Households with Deductions Excess shelter deduction 0 0.0 0 0.0 Medical deduction 0 0.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Individuals by Household Size One person 0 0.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Individuals by Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults 0 0.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Table C.12B. Characteristics of Individuals in California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Individuals in Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Number Percent Number Percent under Simulation to Eliminate SSI Cash-Out C.21 Total California Individuals 1,332 100.0 536 100.0 Individuals by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 836 62.8 435 81.1 101-130% 434 32.5 86 16.0 131% or greater 62 4.6 15 2.9 Individuals in Households with Income from Earnings 1,053 79.1 335 62.5 Temporary Assistance for Needy Families 268 20.1 262 48.9 Social Security 144 10.8 42 7.9 Supplemental Security Income 0 0.0 0 0.0 Individuals by Household Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 2 0.2 1 0.3 Eligible for other benefit 1,330 99.8 535 99.7 Individuals in Households with Deductions Excess shelter deduction 1,332 100.0 536 100.0 Medical deduction 46 3.5 3 0.6 Dependent care deduction 55 4.2 18 3.4 Child support expense deduction 22 1.7 8 1.5 Individuals by Household Size One person 139 10.4 49 9.1 Two people 219 16.4 103 19.2 More than two people 974 73.1 384 71.7 Individuals by Household Composition Households with elderly adults 120 9.0 30 5.5 Households with disabled nonelderly adults 52 3.9 11 2.0 Households with children 1,160 87.1 497 92.7 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Individuals in Households With Lower Benefits Eligible under Simulation Participating under Simulation under Simulation to Eliminate SSI Cash-Out Table C.12C. Households with Lower Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 (000s) of Total (000s) of Total Number Percent Number Percent C.22 Total Benefits 14,775 100.0 14,775 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 13,912 94.2 13,912 94.2 101-130% 298 2.0 298 2.0 131% or greater 565 3.8 565 3.8 Benefits in Households with Income from Earnings 454 3.1 454 3.1 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 7,729 52.3 7,729 52.3 Supplemental Security Income 14,246 96.4 14,246 96.4 Benefits by Household Benefit Level Eligible for minimum benefit 4,303 29.1 4,303 29.1 Eligible for maximum benefit 2,779 18.8 2,779 18.8 Eligible for other benefit 7,692 52.1 7,692 52.1 Benefits in Households with Deductions Excess shelter deduction 9,653 65.3 9,653 65.3 Medical deduction 5,127 34.7 5,127 34.7 Dependent care deduction 125 0.8 125 0.8 Child support expense deduction 229 1.5 229 1.5 Benefits by Household Size One person 14,474 98.0 14,474 98.0 Two people 162 1.1 162 1.1 More than two people 139 0.9 139 0.9 Benefits by Household Composition Households with elderly adults 8,623 58.4 8,623 58.4 Households with disabled nonelderly adults 4,944 33.5 4,944 33.5 Households with children 283 1.9 283 1.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Table C.13A. Benefits for Eligible California Households Newly Eligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Eligible under All Newly Eligible Newly Eligible and Participating Total Percent Total Percent Simulation to Eliminate SSI Cash-Out C.23 Total Benefits 22,247 100.0 7,472 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 2,250 10.1 2,250 30.1 1-100% 18,805 84.5 4,893 65.5 101-130% 549 2.5 251 3.4 131% or greater 643 2.9 78 1.0 Benefits in Households with Income from Earnings 5,285 23.8 4,831 64.6 Temporary Assistance for Needy Families 5 0.0 5 0.1 Social Security 8,136 36.6 408 5.5 Supplemental Security Income 14,246 64.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 4,404 19.8 100 1.3 Eligible for maximum benefit 6,004 27.0 3,225 43.2 Eligible for other benefit 11,839 53.2 4,147 55.5 Benefits in Households with Deductions Excess shelter deduction 12,956 58.2 3,303 44.2 Medical deduction 5,299 23.8 172 2.3 Dependent care deduction 125 0.6 0 0.0 Child support expense deduction 234 1.1 6 0.1 Benefits by Household Size One person 17,282 77.7 2,808 37.6 Two people 1,431 6.4 1,270 17.0 More than two people 3,533 15.9 3,394 45.4 Benefits by Household Composition Households with elderly adults 9,125 41.0 502 6.7 Households with disabled nonelderly adults 4,995 22.5 51 0.7 Households with children 4,090 18.4 3,806 50.9 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Benefits for Households Newly Participating All Newly Participating Previously Eligible and Newly Participating under Simulation to Eliminate SSI Cash-Out Table C.13B. Benefits for Eligible California Households Newly Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Total Percent Total Percent C.24 Total Benefits 7,295 1,227 100.0 840 92 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0 0.0 0 0 0.0 1-100% 5,303 593 72.7 768 83 91.5 101-130% 1,143 334 15.7 71 8 8.5 131% or greater 850 301 11.6 0 0 0.0 Benefits in Households with Income from Earnings 3,957 435 54.2 574 65 68.3 Temporary Assistance for Needy Families 327 54 4.5 178 36 21.2 Social Security 6,010 1,012 82.4 266 26 31.7 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 106 98 1.5 0 0 0.0 Eligible for maximum benefit 0 0 0.0 0 0 0.0 Eligible for other benefit 7,189 1,129 98.5 840 92 100.0 Benefits in Households with Deductions Excess shelter deduction 4,511 883 61.8 801 84 95.5 Medical deduction 7,295 1,227 100.0 840 92 100.0 Dependent care deduction 14 1 0.2 0 0 0.0 Child support expense deduction 12 10 0.2 0 0 0.0 Benefits by Household Size One person 1,183 459 16.2 58 8 6.9 Two people 1,613 389 22.1 65 5 7.8 More than two people 4,500 379 61.7 716 79 85.3 Benefits by Household Composition Households with elderly adults 4,548 861 62.3 663 71 79.0 Households with disabled nonelderly adults 2,756 371 37.8 176 21 21.0 Households with children 4,552 402 62.4 740 82 88.1 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. * Less than 500 Total Percent Total Percent ($000s) Increase ($000s) Increase Increase ($000s) Increase ($000s) Benefits for Households With Higher Benefits under Eligible in Baselaw Participating in Baselaw Simulation to Eliminate SSI Cash-Out Table C.13C. Benefits for Eligible and Participating California Households with Higher Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 C.25 Total Benefits 8 100.0 0 0.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater 8 100.0 0 0.0 Benefits in Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 8 100.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 8 100.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Benefits in Households with Deductions Excess shelter deduction 8 100.0 0 0.0 Medical deduction 8 100.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 8 100.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Benefits by Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults 8 100.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table C.14A. Benefits for Eligible California Households Newly Ineligible under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Losing Eligibility All Newly Ineligible Participating in Baselaw Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out C.26 Total Benefits 0 0.0 0 0.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 0 0.0 0 0.0 101-130% 0 0.0 0 0.0 131% or greater 0 0.0 0 0.0 Benefits in Households with Income from Earnings 0 0.0 0 0.0 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 0 0.0 0 0.0 Supplemental Security Income 0 0.0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 0 0.0 0 0.0 Eligible for maximum benefit 0 0.0 0 0.0 Eligible for other benefit 0 0.0 0 0.0 Benefits in Households with Deductions Excess shelter deduction 0 0.0 0 0.0 Medical deduction 0 0.0 0 0.0 Dependent care deduction 0 0.0 0 0.0 Child support expense deduction 0 0.0 0 0.0 Benefits by Household Size One person 0 0.0 0 0.0 Two people 0 0.0 0 0.0 More than two people 0 0.0 0 0.0 Benefits by Household Composition Households with elderly adults 0 0.0 0 0.0 Households with disabled nonelderly adults 0 0.0 0 0.0 Households with children 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table C.14B. Benefits for Eligible California Households Newly Not Participating under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 ($000s) of Total ($000s) of Total Benefits for Households Newly Not Participating All Newly Not Participating Still Eligible But No Longer Participating Total Percent Total Percent under Simulation to Eliminate SSI Cash-Out C.27 Total Benefits 132,975 779 100.0 61,084 299 100.0 Benefits by Household Gross Income as a Percentage of Poverty Level No income 0 0 0.0 0 0 0.0 1-100% 98,248 441 73.9 54,746 236 89.6 101-130% 31,414 277 23.6 6,070 55 9.9 131% or greater 3,313 61 2.5 268 8 0.4 Benefits in Households with Income from Earnings 101,804 543 76.6 36,055 175 59.0 Temporary Assistance for Needy Families 27,875 145 21.0 27,577 141 45.1 Social Security 11,057 161 8.3 3,434 34 5.6 Supplemental Security Income 0 0 0.0 0 0 0.0 Benefits by Household Benefit Level Eligible for minimum benefit 0 0 0.0 0 0 0.0 Eligible for maximum benefit 362 1 0.3 226 0 0.4 Eligible for other benefit 132,614 778 99.7 60,859 299 99.6 Benefits in Households with Deductions Excess shelter deduction 132,975 779 100.0 61,084 299 100.0 Medical deduction 4,080 62 3.1 525 5 0.9 Dependent care deduction 5,893 29 4.4 2,022 11 3.3 Child support expense deduction 2,445 14 1.8 993 5 1.6 Benefits by Household Size One person 13,680 205 10.3 5,739 58 9.4 Two people 22,759 165 17.1 11,862 78 19.4 More than two people 96,536 408 72.6 43,484 163 71.2 Benefits by Household Composition Households with elderly adults 10,240 133 7.7 2,959 27 4.8 Households with disabled nonelderly adults 4,450 47 3.3 1,377 8 2.3 Households with children 116,527 558 87.6 56,316 255 92.2 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Decrease Benefits for Households With Lower Benefits under Eligible under Simulation Participating under Simulation Total Decrease ($000s) ($000s) Decrease ($000s) ($000s) Percent Total Decrease Percent Simulation to Eliminate SSI Cash-Out Table C.14C. Benefits for Eligible and Participating California Households With Lower Benefits under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, by Household Characteristic, FY 2009 C.28 Potential Monthly Benefit 38 52 196 325 Monthly Gross Income among Households with Positive Income 848 840 1,154 1,010 Monthly Net Income among Households with Positive Net Income 616 610 576 479 Monthly Amount of Income Type among Households with Income Type Earnings 972 797 836 801 Temporary Assistance for Needy Families 0 371 328 413 Supplemental Security Income 470 470 0 0 Social Security 636 644 833 838 Amount of Deduction among Households with Deduction Excess shelter deduction 316 296 399 241 Medical deduction 153 156 124 124 Dependent care deduction 186 186 214 0 Child support expense deduction 246 237 113 0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Newly Participating Still Participating with Higher Table C.15. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Gaining under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Average Value for California Households Gaining under Simulation to Eliminate SSI Cash-Out ($) Newly Eligible or Participating Eligible or Participating in Baselaw Newly Eligible Still Eligible with Higher C.29 Potential Monthly Benefit 16 0 276 311 Monthly Gross Income among Households with Positive Income 2,411 0 1,152 921 Monthly Net Income among Households with Positive Net Income 803 0 615 495 Monthly Amount of Income Type among Households with Income Type Earnings 0 0 1,121 818 Temporary Assistance for Needy Families 0 0 531 533 Supplemental Security Income 0 0 0 0 Social Security 1,278 0 871 701 Amount of Deduction among Households with Deduction Excess shelter deduction 990 0 200 176 Medical deduction 484 0 359 319 Dependent care deduction 0 0 148 129 Child support expense deduction 0 0 267 232 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the baseline SNAP unit. Table C.16. Average Monthly Benefit, Income, and Deductions of Eligible and Participating California Households Losing under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 Newly Ineligible Newly Not Participating Still Eligible with Lower Still Participating with Lower Average Value for California Households Losing under Simulation to Eliminate SSI Cash-Out ($) Newly Ineligible or Not Participating Eligible or Participating under Simulation C.30 Total California Households 389 100.0 267 100.0 Gross Income as a Percentage of Poverty Level No income 0 0.0 0 0.0 1-100% 352 90.5 236 88.5 101-130% 15 3.9 14 5.3 131% or greater 22 5.6 17 6.2 Households with Income from Earnings 20 5.1 17 6.5 Temporary Assistance for Needy Families 0 0.0 0 0.0 Social Security 200 51.3 125 46.8 Supplemental Security Income 370 95.0 252 94.7 Benefit Level Eligible for minimum benefit 267 68.5 267 100.0 Eligible for maximum benefit 14 3.6 0 0.0 Eligible for other benefit 109 27.9 0 0.0 Households with Deductions Excess shelter deduction 104 26.7 16 5.9 Medical deduction 84 21.6 16 6.1 Dependent care deduction 1 0.2 0 0.1 Child support expense deduction 2 0.5 0 0.1 Household Size One person 384 98.7 267 100.0 Two people 4 1.0 0 0.0 More than two people 1 0.3 0 0.0 Household Composition Households with elderly adults 221 56.8 140 52.6 Households with disabled nonelderly adults 134 34.4 99 37.2 Households with children 2 0.5 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Number Percent Number Percent (000s) of Total (000s) of Total Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table C.17. Characteristics of California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 C.31 Total California Households 389 100.0 267 100.0 Countable Earned Income $0 369 94.9 249 93.5 1-499 8 2.0 8 2.9 500-999 2 0.6 2 0.9 1,000 or greater 9 2.4 7 2.7 Countable Social Security $0 190 48.7 142 53.2 1-199 4 1.2 2 0.8 200-399 19 4.9 13 5.0 400-599 61 15.6 36 13.6 600-799 92 23.7 55 20.7 800-999 9 2.3 8 3.0 1,000 or greater 14 3.6 10 3.7 Countable Supplemental Security Income $0 19 5.0 14 5.3 1-199 104 26.8 64 23.9 200-399 68 17.4 40 15.2 400-599 26 6.7 18 6.9 600-799 171 44.0 130 48.6 800-999 0 0.1 0 0.1 1,000 or greater 0 0.0 0 0.0 Source: 2009 Baseline of 2005 MATH SIPP+ model, California update (No asset test for households with children; SSI+SSP=$845 singles, $1,407 couples) Note: Characteristics are of the SNAP unit after SSI Cash-out is eliminated. Number Percent Number Percent (000s) of Total (000s) of Total Households Newly Eligible under Simulation to Eliminate SSI Cash-Out All Newly Eligible Eligible for the Minimum Benefit Table C.18. Income Distribution for California Households Newly Eligible for the Minimum Benefit under Simulation to Eliminate SSI Cash-Out for One Person Units, Add a Standard Medical Deduction, and Lower the SUA, FY 2009 C.32 Page is left intentionally blank to allow for double-sided copying www.mathematica-mpr.com Improving public well-being by conducting high-quality, objective research and surveys Princeton, NJ \u25a0 Ann Arbor, MI \u25a0 Cambridge, MA \u25a0 Chicago, IL \u25a0 Oakland, CA \u25a0 Washington, DC Mathematica\u00ae is a registered trademark of Mathematica Policy Research ”

” Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings Final Report Authors: Kathleeen Keefe Emily Sama-Miller Laura Castner Maura Bardos Elizabeth Clary Sarah Wissel Larry Vittoriano Submitted by: Submitted to: Mathematica Policy Research Office of Research and Analysis 1100 1st Street, NE, 12th Floor Food and Nutrition Service Washington, DC 20002-4221 3101 Park Center Drive Telephone: (202) 484-9220 Alexandria, VA 22302-1500 Facsimile: (202) 863-1763 Project Director: Project Officer: Laura Castner Rosemarie Downer This study was conducted under Contract number AG-3198-D-08-0105 with the Food and Nutrition Service. This report is available on the Food and Nutrition Service website: http:\/\/www.fns.usda.gov Suggested Citation: U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings, by Kathleeen Keefe, Emily Sama- Miller, Laura Castner, Maura Bardos, Elizabeth Clary, Sarah Wissel, and Larry Vittoriano, Project Officer: Rosemarie Downer, Alexandria, VA: 2012. United States Food and Department of Nutrition Agriculture Service Family Programs Report December 2012 http:\/\/www.fns.usda.gov\/ A.18 Profile: California State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 4 Number of Partners Interviewed: 5 Initiatives Active in State: Call Center, Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) None ONLINE SYSTEM (Regionally) Number of Applications Downloaded Locally Not reported Not reported Not reported Number of Online Applications Submitted per Month Locally Not reported No No Number of Multiple Applications Locally Not reported No No Percent of Applicants with Hardship Reason for Requesting Phone Interviews Locally Not reported Not reported Not reported Average Level of Benefits Locally Not reported Not reported Not reported Number of First-Time Applications Denied Locally Not reported Not reported Not reported Number of Clients Requesting Help to Apply Online Locally Not reported Not reported Not reported Average Number of Changes Submitted per Month Locally Not reported Not reported Not reported Number of Changes Started Locally Not reported Not reported Not reported Number of Changes Submitted Locally Not reported Not reported Not reported Number of Applicants who did not Receive Help to Apply Online Locally Not reported Not reported Not reported Percent of Applications Received Locally Not reported No No Number of Applications Started Locally Not reported Not reported Not reported Number of First-Time Applications Approved Locally Not reported Not reported Not reported Average Number of Accounts Created per Month Locally Not reported Not reported Not reported California (continued) A.19 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Log-ins Locally Not reported Not reported Not reported Average Number of Screenings Started: Online Locally Not reported Not reported Not reported Average Number of Screenings Completed: Online Locally Not reported Not reported Not reported Percent of Users Selecting Spanish Language Locally Not reported Not reported Not reported Percent of Screenings Resulting in Application Submission: Online Locally Not reported Not reported Not reported Number of Online Screenings Started: Online Locally Not reported Not reported Not reported Number of Online Screenings Completed: Online Locally Not reported Not reported Not reported Percent of Applicants Who Received Help to Apply Online Locally Not reported Not reported Not reported Average Number Started per Month Locally Not reported No No Average Number Submitted per Month Locally Not reported No No Number of One- page\/Requests for Assistance Submitted Locally Not reported Not reported Not reported Number of Applications with Filing Date Only Locally Not reported Not reported Not reported Number of Applications Submitted With All Application Questions Answered Locally Not reported Not reported Not reported Number of Applicants who Received Help to Apply Online Locally Not reported Not reported Not reported DOCUMENT IMAGING (Regionally) Number of Documents Received Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Number of Documents Scanned Locally Not reported No No California (continued) A.20 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Amount of Days in Queue to be Indexed Locally Not reported No No Number of Documents in Error Queue Locally Not reported No No Number of Documents Pending Indexing Locally Not reported Not reported Not reported Number of Barcode Errors Locally Not reported Not reported Not reported Number of Queues with Over 1,000 Documents Locally Not reported Not reported Not reported PARTNERING (Regionally) Percent of Partners Providing Application Assistance Locally Not reported Not reported Not reported Number of Partners Locally Not reported Not reported Not reported Number Accepting Applications Locally Not reported Not reported Not reported Number Providing Application Assistance Locally Not reported Not reported Not reported Number Clients Assisted per Partner Locally Not reported Not reported Not reported Number of Applications Received per Partner Locally Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Regionally) Number of Redetermination Interviews Locally Not reported Not reported Not reported Number of Face-to-Face Interviews Locally Not reported Not reported Not reported Number of Telephone Interviews Locally Not reported Not reported Not reported Percent of Interviews Conducted by Telephone Locally Not reported No No Percent of Interviews Conducted Face-to-Face Locally Not reported No No Percent of Telephone Interview Requests Honored Locally Not reported Not reported Not reported Total Number of Interviews Locally Not reported Not reported Not reported Number of Home Visit Interviews Locally Not reported Not reported Not reported California (continued) A.21 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Missed Interviews Locally Not reported Not reported Not reported Notice of Missed Interview Mailed Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Applicants Requesting an In-Person Interview Locally Not reported Not reported Not reported Number of Applicants who Did Not Answer to Type of Interview Requested Locally Not reported Not reported Not reported Percent that are Missed and have Notice Mailed Locally Not reported No No ONLINE EXPEDITED APPLICATIONS (Regionally) Percent of Applications Approved: Online Expedited Locally Not reported Not reported Not reported Percent of Applications Approved: Online All Locally Not reported Not reported Not reported Number of Applications Approved: Online All Locally Not reported Not reported Not reported Number of Expedited Applications Received Online Locally Not reported Not reported Not reported Number of Applications Approved: Online Expedited Locally Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide None No No Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Online Locally Not reported Not reported Not reported California (continued) A.22 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Faxed Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Percent of Online Recertifications Approved Locally Not reported Not reported Not reported Number of Recertifications Approved: Online Locally Not reported Not reported Not reported Number of Applications Approved: Faxed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Approved: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Percent of Online Applications Approved Locally Not reported Not reported Not reported Percent of Applications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported California (continued) A.23 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Community Partner Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Applications Denied: Online Locally Not reported Not reported Not reported Percent of Online Recertifications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported Number of Recertifications Denied: Online Locally Not reported Not reported Not reported Percent of Online Applications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported California (continued) A.24 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of One- page\/Requests for Assistance Denied Locally Not reported Not reported Not reported Number of Applications Denied: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Denied: Community Partner Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Total Number of Applications Completed Statewide Program Access, Efficiency, Customer Service Not reported No Total Number of Applications To Be Processed Statewide Program Access, Efficiency, Customer Service Not reported No Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Online Locally Not reported Not reported Not reported Percent of Applications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Applications: Faxed Locally Not reported Not reported Not reported Number of Recertifications: Faxed Locally Not reported Not reported Not reported California (continued) A.25 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Percent of Applications: Online Locally Not reported No No Number of Applications: Online Locally Not reported Not reported Not reported Percent of Recertifications: Community Partner Locally Not reported Not reported Not reported Percent of Applications: Faxed Locally Not reported Not reported Not reported Percent of Recertifications: Faxed Locally Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Online Locally Not reported Not reported Not reported Number of Applications: Community Partner Locally Not reported Not reported Not reported Number of Recertifications: Community Partner Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Applications: Community Partner Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported California (continued) A.26 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications Approved Timely Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service State: All applications should be approved timelyLocal: Internal performance measures track whether individual workers approve 90 to 95 percent of applications timely. No Percent of Recertifications Approved Timely Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service All recertifications should be approved timely No Average Processing Time of Application Decision Locally Not reported Within 15 days\u2014applies to all applications. No Average Processing Time of Recertification Decision Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: California counties are responsible for administering SNAP with state oversight (typically, counties work in consortia to purchase and maintain eligibility systems). As a result, modernization and measurement are implemented variably across the state. The state office collects reports from the counties on the status of their application and recertification processes. It also allocates funding to the counties for its major initiatives. California local offices have faced a few challenges with capturing and reporting data accurately during the development and refinement of their systems. Offices facing these problems have addressed them through system reprogramming or manual data counts. Measurement Goals: A few of California’s performance measures touch on all FNS goals for modernization. Counties also pursued performance measurement in order to: meet FNS and grant requirements, meet a legal services agreement, identify trends, maximize programs, measure the success of outreach efforts, determine needed staff and equipment, and track the outreach provided. California (continued) A.27 Call Center: The state office reported that, while there is no statewide call center, some county offices have call centers of their own. However, none of the county offices we interviewed for the study had a call center in place. Online System: The presence or absence of an online application system varies by county. Each consortium with an online application has its own vendor to operate it. As such, functionality of the system and the measures collected differ among offices. All California local offices surveyed that have an online application system track the percent of total applications received online. Document Imaging: A few California local offices we interviewed have established document imaging. These offices track aggregate data only. Kiosks: Neither the state nor local offices interviewed have implemented kiosks. Waiver of Face-to-Face Interview: Two California counties interviewed have a waiver of face-to- face interviews in place. They both track performance measures and data on the volume and type of interview provided (telephone interview or face-to-face interview) and on notices of missed interviews. Shortened Interviews: No counties participating in the study have implemented a shortened interview process. Online Expedited Applications: Some California county offices interviewed review the percentage and the number of online expedited applications approved. County offices report the number of expedited applications processed to the state office on a quarterly basis. Further reporting capabilities, such as summarizing demographic or other characteristics of online expedited applications, vary by county. Application Tracking: State staff reported that application tracking typically occurs at the local level, as no applications are delivered to the state office. Most local offices responding to the survey focus on application accuracy, application approvals\/denials, and application receipt (though other areas of application tracking are monitored by some local offices). Changes Over Time: Some counties reported they have redesigned or implemented new initiatives within the past ten years, such as a call center, document imaging, or an online application system. They are working on developing data and adding measures or reports. Desired or Planned Future Measures: State and local offices expressed a desire to collect more information. Specifically, they would like to track: percent of applications approved and denied (by online versus paper submission), accuracy measures on phone versus face-to-face recertifications, measures that compare the current approval rate of recertifications to the rate prior to the implementation of a waiver of face-to-face interviews, number of people completing their Partnering: California’s partners work on outreach, screening, and application assistance. Some partners operate under an interagency agreement (M.O.U.) with the California Department of Public Health, and some partners are compensated for their services. One office we surveyed has specified standards on the number of applications and screenings their partner must meet per month. Two local offices we surveyed reported that they collect performance data on partnerships. They monitor data, such as the percent of partners providing application assistance and some aggregate data. Measures Collected by Partners: One county we surveyed stated that the purpose of tracking performance measure data for their partnering initiative is to provide the data to their partner. The county provides the partner the information required to submit grant applications and the partner provides the county with the number of applicants they assisted. Another county’s partner also tracks the number of applications submitted to the county office. Partners also collect numerous measures on outreach, trainings, volume and efficiency of application assistance. California (continued) A.28 recertification, number of people submitting their quarterly report online, number of abandoned applications, number of people submitting their application from a particular screen of the online application, and additional data on the online application system. Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Acknowledgments Executive Summary Diversity in State Measures Challenges of Comparing Measures Data Collection I. Study Background, objectives, and Analytical Approach A. Overview of Data Collection 1. Preliminary Assessment and Instrument Development 2. Respondent Selection and Data Collection 3. Results of Data Collection Efforts B. Data Analysis Approach 1. Constructing State Profiles 2. Identifying Challenges and Performance Across States II. How are States Performing? A. Observed Results on Measures Across States 1. Call Centers 2. Online Systems 3. Document Imaging 4. Kiosks 5. Partnering 6. Interview Initiatives 7. Application Tracking B. Setting Standards and Benchmarks 1. Preventing Corrective Action 2. Encouraging Staff Productivity 3. Monitoring and Sustaining Performance 4. Responding to Legal Action C. Conclusion III. Limitations to use of measures and standards A. Contextual Limitations 1. Initiative Scope and Features 2. System Limitations 3. Terminology Differences 4. Varying Measurement Motivations B. Data Limitations 1. Accuracy 2. Validity 3. Reliability C. Conclusion References Glossary Modernization Initiatives Measurement Terminology California SNAP Modernization Profiles .pdf Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Acknowledgments Executive Summary Diversity in State Measures Challenges of Comparing Measures Data Collection I. Study Background, objectives, and Analytical Approach A. Overview of Data Collection 1. Preliminary Assessment and Instrument Development 2. Respondent Selection and Data Collection 3. Results of Data Collection Efforts B. Data Analysis Approach 1. Constructing State Profiles 2. Identifying Challenges and Performance Across States II. How are States Performing? A. Observed Results on Measures Across States 1. Call Centers 2. Online Systems 3. Document Imaging 4. Kiosks 5. Partnering 6. Interview Initiatives 7. Application Tracking B. Setting Standards and Benchmarks 1. Preventing Corrective Action 2. Encouraging Staff Productivity 3. Monitoring and Sustaining Performance 4. Responding to Legal Action C. Conclusion III. Limitations to use of measures and standards A. Contextual Limitations 1. Initiative Scope and Features 2. System Limitations 3. Terminology Differences 4. Varying Measurement Motivations B. Data Limitations 1. Accuracy 2. Validity 3. Reliability C. Conclusion References Glossary Modernization Initiatives Measurement Terminology ”

” Background States have implemented a variety of modernization initiatives to improve access and delivery of the Supplemental Nutrition Assistance Program (SNAP) in order to manage increasing caseloads under budgetary constraints. Modernization initiatives can include the following types of activities: policy simplification, restructuring organizational and administrative functions, partnering with other organizations and implementing new technology. As these efforts have multiplied and expanded, so has the Food and Nutrition Service’s (FNS) interest in how States implement and monitor their efforts. Similarly, States have an interest in seeing how other States are performing. This exploratory study was conducted to determine the measures States have in place across eight modernization initiatives, including call centers, online systems, document imaging, kiosks, partnering, waiving the face-to-face interview, shortened interviews and online expedited applications. A review of SNAP performance standards and reporting requirements as they pertain to these modernization initiatives was conducted. The effort resulted in two reports. The first report integrates and summarizes findings across the 45 study States (44 states plus the District of Columbia) on how they monitor and measure performance. It also includes suggestions for performance measures and standards for FNS and States to consider. The second report delves into details on how each of the 45 States measures performance and describes the performance standards in use. Methods The study was conducted in two-phases. In the first phase, a broad group of stakeholders were interviewed for their perspectives on performance measurement activities in the States. During the second phase, data were collected from the 45 study States, more than 100 local agencies within those States, and more than 50 community and business partners who work with the States and local agencies. Findings States and local offices are collecting a large number of measures. Across the 8 modernization initiatives that were examined, States and local offices reported using 89 different performance measures to assess their activities (Table1). Measures are most commonly used for technology-related initiatives. Table 1: Number of States and Number of Measures for the Eight Initiatives Initiative Number of States With Initiative Number of Different Measures for Initiative Call Center 28 34 Online System 33 27 Document Imaging 24 8 Kiosks 14 1 Partnering 34 3 Waiver of Face-to- Face Interview 40 12 Shortened Interviews 12 2 Online Expedited Applications 20 2 Total 89 Data were collected between August 2010 and April 2011 from the 45 study States States do not always establish standards for the performance measures they collect. Of the 89 measures collected, States developed PERFORMANCE MEASUREMENT FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM MODERNIZATION INITIATIVES Office of Research and Analysis December 2012 Nutrition Assistance Program Report Series Office of Research and Analysis Family Nutrition Programs Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings Final Report United States Food and Department of Nutrition Agriculture Service December 2012 Non-Discrimination Policy The U.S. Department of Agriculture (USDA) prohibits discrimination in all of its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, political beliefs, genetic information, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write: USDA, Director, Office of Adjudication, 1400 Independence Ave., SW, Washington, DC 20250-9410 or call (866) 632-9992 (Toll-free Customer Service), (800) 877-8339 (Local or Federal relay), (866) 377-8642 (Relay voice users). USDA is an equal opportunity provider and employer. Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings Final Report Authors: Kathleeen Keefe Emily Sama-Miller Laura Castner Maura Bardos Elizabeth Clary Sarah Wissel Larry Vittoriano Submitted by: Submitted to: Mathematica Policy Research Office of Research and Analysis 1100 1st Street, NE, 12th Floor Food and Nutrition Service Washington, DC 20002-4221 3101 Park Center Drive Telephone: (202) 484-9220 Alexandria, VA 22302-1500 Facsimile: (202) 863-1763 Project Director: Project Officer: Laura Castner Rosemarie Downer This study was conducted under Contract number AG-3198-D-08-0105 with the Food and Nutrition Service. This report is available on the Food and Nutrition Service website: http:\/\/www.fns.usda.gov Suggested Citation: U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings, by Kathleeen Keefe, Emily Sama- Miller, Laura Castner, Maura Bardos, Elizabeth Clary, Sarah Wissel, and Larry Vittoriano, Project Officer: Rosemarie Downer, Alexandria, VA: 2012. United States Food and Department of Nutrition Agriculture Service Family Programs Report December 2012 http:\/\/www.fns.usda.gov\/ iii ACKNOWLEDGMENTS This report was prepared by Kathleen Keefe, Emily Sama-Miller, Laura Castner, Maura Bardos, Elizabeth Clary, Sarah Wissel, and Larry Vittoriano of Mathematica Policy Research under contract to the U.S. Department of Agriculture, Food and Nutrition Service. Additional staff played a critical role in collecting data and conducting interviews during telephone interviews and site visits: Lauren Akers, Kevin Conway, Elizabeth Laird, Alexander Millar, Antoniya Owens, and Amy Wodarek O’Reilly. We thank Scott Cody for thoroughly reviewing each portion of this report. Bea Jones and other database programmers were instrumental in retrieving and reporting the extensive survey data used to produce the appendices. Alfreda Holmes carefully prepared the manuscript and adjusted the formatting on hundreds of pages of appendix tables, and Molly and Jim Cameron provided editorial assistance to optimize the text. We also extend our gratitude to the many individuals outside of Mathematica that contributed to the success of this report. Project Officer Rosemarie Downer provided helpful comments on report drafts and invaluable guidance throughout the duration of the study. State, local, and partner offices that participated in this study shared their staff time and resources during data collection and site visits. This report would not have been possible without their cooperation. v CONTENTS EXECUTIVE SUMMARY …………………………………………………………………………………….. xi I STUDY BACKGROUND, OBJECTIVES, AND ANALYTICAL APPROACH ……………… 1 A. Overview of Data Collection …………………………………………………………… 2 1. Preliminary Assessment and Instrument Development ………………….. 2 2. Respondent Selection and Data Collection ………………………………….. 3 3. Results of Data Collection Efforts ……………………………………………… 5 B. Data Analysis Approach ………………………………………………………………… 6 1. Constructing State Profiles ………………………………………………………. 6 2. Identifying Challenges and Performance Across States …………………. 6 II HOW ARE STATES PERFORMING? ………………………………………………………….. 9 A. Observed Results on Measures Across States ……………………………………. 9 1. Call Centers ………………………………………………………………………… 10 2. Online Systems ……………………………………………………………………. 12 3. Document Imaging ……………………………………………………………….. 14 4. Kiosks ………………………………………………………………………………… 16 5. Partnering …………………………………………………………………………… 17 6. Interview Initiatives ………………………………………………………………. 19 7. Application Tracking …………………………………………………………….. 20 B. Setting Standards and Benchmarks ……………………………………………….. 21 1. Preventing Corrective Action ………………………………………………….. 21 2. Encouraging Staff Productivity ………………………………………………… 22 3. Monitoring and Sustaining Performance …………………………………… 22 4. Responding to Legal Action ……………………………………………………. 23 C. Conclusion ……………………………………………………………………………….. 23 III LIMITATIONS TO USE OF MEASURES AND STANDARDS ……………………………. 25 A. Contextual Limitations ……………………………………………………………….. 26 1. Initiative Scope and Features ………………………………………………….. 26 2. System Limitations ……………………………………………………………….. 31 3. Terminology Differences ……………………………………………………….. 33 4. Varying Measurement Motivations …………………………………………… 37 Contents Mathematica Policy Research vi III (continued) B. Data Limitations ………………………………………………………………………… 38 1. Accuracy …………………………………………………………………………….. 38 2. Validity ……………………………………………………………………………….. 42 3 Reliability ……………………………………………………………………………. 44 C. Conclusion ……………………………………………………………………………….. 46 REFERENCES ………………………………………………………………………………………………… 47 GLOSSARY …………………………………………………………………………………………………… 49 APPENDIX A: STATE PROFILES vii TABLES I.1 Modes of Data Collection for Each Respondent Type ……………………………….. 3 II.1 Average Wait Time and Abandonment for Selected States ………………………. 11 II.2 Measures of Online Systems for Application Tracking for an Illustrative Sample of States ………………………………………………………………. 14 II.3 Quantity of Documents Imaged and Averages for Selected States …………….. 15 II.4 Document Imaging Approach and Time Measures for Selected States ……………………………………………………………………………………………. 16 II.5 Measures of Partnering for an Illustrative Sample of States …………………….. 18 II.6 Reported Performance Measures for All States with Application Tracking Efforts ………………………………………………………………………………. 20 III.1 Variations in Reported Call Center Functions, by Call Center Reach and Number of Functions …………………………………………………………………. 27 III.2 Variations in Reported Online System Functions …………………………………… 29 III.3 Sample of Partners’ Service Variation in Selected States …………………………. 30 III.4 Terminology Variations for Selected Performance Measure Calculations ……………………………………………………………………………………. 34 III.5 Selected State and Local Office Performance Measure Data Entry Methods ………………………………………………………………………………………… 39 III.6 Selected Reports of Methods to Ensure Data Accuracy …………………………… 41 III.7 Validity Concerns for Selected Performance Measures Across Initiatives ……………………………………………………………………………………….. 43 III.8 Selected States and Localities Reporting Standards or Benchmarks on Measures Viewed as Possibly Being Invalid ………………………………………. 44 III.9 Sample of Changes to Performance Measures Affecting Data Reliability ………………………………………………………………………………………. 45 ix FIGURES I.1 Number and Combination of Respondents, by State ………………………………… 5 xi EXECUTIVE SUMMARY The number and breadth of efforts across federal and state agencies to improve technology and streamline service delivery supporting access to the U.S. Department of Agriculture Food and Nutrition Service’s (FNS) Supplemental Nutrition Assistance Program (SNAP) and other public benefits have risen over the last decade. Technology and policy changes often operate together in the states to offer clients new ways to access benefits; such changes also offer staff and partner organizations improved procedures for conducting business. As modernization efforts have multiplied and expanded, so has FNS’s interest in how states implement and monitor their efforts in an environment of increased demand and restricted resources. States, too, have an interest in seeing how well other states are performing. This report is second that stem from the same data collection effort. That effort sought the participation of all states and the District of Columbia, and the reports are based on the responses of the 45 that were able to participate. This report specifically delves into states’ experiences with measuring their modernization initiatives, while the other report focuses more broadly on experiences across the nation. The overall effort focused on a subset of eight modernization initiatives of greatest interest to FNS: call centers, online applications, document imaging, kiosks for application submission, partnering with non-SNAP organizations, online expedited applications, waiver of face-to-face interviews, and shortened interviews. This report (1) describes each state’s performance measures and standards in detail (particularly in state-specific appendices that constitute most of this report), and (2) explains how these measures are implemented and how states use the results. For this report, we sought specific examples of the situations that lead to varied performance measurement approaches by examining the information that states, localities, and SNAP partner organizations provided us in surveys, interviews, and on-site observations. (Throughout, we use performance measures to refer to measures, as well as the aggregate data and data elements that make up the measures (see box).) Diversity in State Measures States track a wide range of performance measures, and how staff use those measures also varies considerably (as the detailed appendices to this report illustrate). No specific performance measurement activities are undertaken uniformly across those states implementing a given modernization initiative. Even performance metrics that track application receipt and processing vary; some states differentiate between applications and recertifications while others do not. However, some similar approaches to measurement exist across states. Except for the shortened interview procedure and kiosks, the states are involved in notable efforts to measure their performance on the modernization initiatives. Most of the common measures across initiatives relate Performance Measurement Terminology 1. Data Element is a field in a database that stores an instance of an activity or characteristic and is the basis of aggregate data and performance measure calculations. 2. Aggregate Data are counts of data elements, such as the number of observations. 3. Performance Measures are calculations using related pieces of aggregate data to assess an activity and typically are displayed as percentages and averages. 4. Performance Standard includes a standard and a benchmark. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes, while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. Executive Summary Mathematica Policy Research xii to the proportion of an activity completed and the time taken to complete a given task, although the specific variable definitions and calculations states use to measure them tend to vary. Some common measures for each modernization initiative exist across the states interviewed, except for the shortened interview protocol and kiosks. However, within these common measures, we found a variety of measure names and definitions. While the measures could be used to track a state’s performance over time and identify anomalies, the variations across measures and initiatives prevent many specific cross-state comparisons. Challenges of Comparing Measures Due to the variation in the structure of the states’ modernization initiatives and measurement needs, comparing outcomes or even measurement activities across states is difficult and, in some cases, inappropriate. Two aspects commonly affect cross-state performance measure comparisons: contextual limitations and data limitations. Contextual limitations, such as differences in what the initiatives do and who they serve, affect the calculation and comparability of performance measures. Data limitations (specifically those that affect the accuracy, validity, and reliability of data) influence calculations of performance measures, and perhaps their utility and comparability. Meaningful comparisons of performance outcomes across states require an understanding of the contextual and data limitations that each state faces. In addition to cross-state comparison limitations, within-state variations in context and data quality may also be present. Local areas serve different populations with special sets of services, face unique system limitations, and have different reasons for measuring select aspects of performance. In some cases, state and local offices reported different methods of calculating performance measures and setting standards. So, we can expect to see a range in data quality across local offices within a state, and across states. (An exception to this is states where all decisions about data entry systems and training are made at the state level and strictly observed at each local office.) Data Collection Our two-phase research approach began with interviews of a broad group of stakeholders to obtain their perspectives on state performance measurement activities. We refined the number of modernization initiatives to include in the study and developed the data collection instruments, building from an inventory of initiatives and measures that we knew to be active in some core states. The second phase built on the first phase interviews by soliciting survey and interview input from all states and a range of local SNAP offices and partner organizations. 1 The information in this report is the result of an analysis and synthesis of the data collected in that second phase. We first collected data from state SNAP agencies (asking them to respond to a survey, participate in a telephone interview, and submit 12 months of data on their performance measures). Then, with their assistance, we identified and contacted local staff to approach for additional interviews (using the same procedures we used with the state). Finally, using feedback from both state and local SNAP staff, we constructed a list of partner organizations to approach 1 Additional details regarding the methods employed during the study can be found in the companion report: Castner, Laura, Amy Wodarek O’Reilly, Kevin Conway, Maura Bardos, and Emily Sama-Miller. Performance Measures for Supplemental Nutrition Assistance Program Modernization Initiatives. Washington, DC: Mathematica Policy Research, 2012. Executive Summary Mathematica Policy Research xiii about telephone interviews (and request 12 months of performance data, if available). We specifically focused on those doing a wide variety of measurement or participating in unique partnering arrangements (for example, contracting out portions of services, such as document imaging, that SNAP staff would otherwise perform). Staff from some states also participated in site visits from Mathematica staff to explain their measurement activities in greater depth. During the nine-month data collection period, from August 2010 to April 2011, we received feedback from 217 SNAP offices or community organizations representing the 45 states (including the District of Columbia) that were able to participate. In total, we completed a survey, telephone interview, or both with 45 state and 117 local SNAP offices, and completed telephone interviews with 55 partners. In 15 states, respondents included the state and local SNAP offices and partner organizations, and site visits with state staff occurred in 10 states. In 19 states, both the state and local offices responded; in the remaining 11, the state office was the only respondent. 1 I. STUDY BACKGROUND, OBJECTIVES, AND ANALYTICAL APPROACH Modernization of public services, including the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) Supplemental Nutrition Assistance Program (SNAP), involves implementing technological advancements in service delivery and changes in program policy intended to streamline the application and recertification processes. Technology and policy changes (sometimes in the context of reorganized business processes) often operate together in states to offer clients new ways to access benefits, and improve staff and partner organizations’ procedures for conducting business. The number and breadth of such modernization efforts have risen over the last decade in response to several interrelated factors. For example, increased economic need among applicants, increased participation, decreased resources (including staff availability), and monetary incentives related to quality have motivated states to find ways to improve the efficiency of their service delivery without affecting the accuracy of benefit determination. Monetary incentives to increase program participation have encouraged states to improve their customer service and program access. Flexibility in setting policies, paired with technological improvements, has given states many options in exactly how to achieve their goals. As modernization efforts have multiplied and expanded, so has FNS’s interest in how states implement and monitor their efforts, as has the interest of states in how other states are performing in the current environment of increased demand and restricted resources. As a result, FNS contracted with Mathematica Policy Research to conduct an exploratory study that captures how states are measuring the performance of their modernization activities. This report is the second that stems from the same data collection effort. While the first report presents findings integrated across states to examine themes and promising approaches for specific modernization efforts, this report delves more deeply into specific states’ experiences. In examining the information that states, localities, and SNAP partner organizations provided us in surveys, interviews, and on-site observations, we sought specific examples of the situations that lead to cross-state variance in performance and performance measurement. In both reports, we typically use the term performance measures to refer to measures, as well as the aggregate data and data elements that constitute them (see box). The broader project has four research objectives, two of which we address specifically in this report: (1) describe each state’s performance measures and standards in detail; and (2) explain how these measures are implemented, the observed results, and how states use the results. In the remainder of this chapter, we provide an overview of how we collected the data used for the study and discuss our approaches to constructing profiles of each state and examining results across states. Performance Measurement Terminology 1. Data Element is a field in a database that stores an instance of an activity or characteristic and is the basis of aggregate data and performance measure calculations. 2. Aggregate Data are counts of data elements, such as the number of observations. 3. Performance Measures are calculations using related pieces of aggregate data to assess an activity and typically are displayed as percentages and averages. 4. Performance Standard includes a standard and a benchmark. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes, while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. Background Mathematica Policy Research 2 A. Overview of Data Collection A two-phase approach comprised the core of our data collection effort, with results of the first phase informing the second. First, we interviewed a broad group of stakeholders (including SNAP staff at the national, regional, and state levels, and advocates) to obtain their perspectives on state performance measurement activities, refined the number of modernization initiatives to include in the study, and developed the data collection instruments. We then solicited survey and interview input from all states and a range of local SNAP offices and partner organizations. In this section, we provide a brief description of the specific activities and respondents in both phases, and summarize the response to our data collection effort.2 1. Preliminary Assessment and Instrument Development Before constructing a survey instrument for this exploratory study, it was essential for us to better understand the basics, especially how some states with prominent modernization efforts measure their performance for SNAP. We began with telephone interviews of stakeholders from FNS, national human services organizations, state SNAP agencies, and community-based organizations and business partners. These respondents were selected specifically for their perspectives on state modernization and measurement activities. We asked them about their knowledge of ongoing modernization initiatives and their measurements and standards, as well as their perceptions of performance measurement gaps. Along with these calls, we conducted a targeted document review of sample performance measurement reports provided by our respondents, as well as relevant earlier reports on modernization efforts (Cody et al. 2008; Rowe et al. 2010). Using the findings from the interviews and document analysis, we drafted a preliminary inventory of state performance measurement activities. The inventory helped us assess the extent of measurement activities for all activities that FNS classified under the heading of modernization. Upon consultation with FNS, we then identified a subset of eight initiatives, based on their wide use across states and importance to FNS. Limiting the number of initiatives was important to balance the time required for state and local staff to participate in the data collection with FNS’s need for thoughtful and thorough answers to questions. The eight initiatives that became the focus of the remainder of the project fall into the following three categories: Technology – Call centers, including their computer phone systems, change centers, interviews, and application processing – Online systems, including the online screening tools, online applications, and online accounts – Document imaging – Kiosks used for application access and submission 2 Additional details regarding the methods employed during the study can be found in the companion report: Castner, Laura, Amy Wodarek O’Reilly, Kevin Conway, Maura Bardos, and Emily Sama-Miller. Performance Measures for Supplemental Nutrition Assistance Program Modernization Initiatives. Washington, DC: Mathematica Policy Research, 2012. Background Mathematica Policy Research 3 Partnering with Other Organizations Policy Simplification – The waiver of face-to-face interviews – A shortened interview process – The capacity for clients to complete expedited applications online We developed a survey that included a module for each of the eight initiatives. Due to the emphasis that states place on existing FNS measures and the centrality of application processing to SNAP operations, we developed an additional survey module dedicated to performance measures around the receipt and processing of applications and recertifications. This module expanded upon the FNS-required performance measures regarding application approvals and denials by including measures related to the source of the application or recertification. To support our second phase (data collection), we designed instruments for surveys, phone interviews, and in-person interviews and observations to collect detailed information and provide states with an interactive response approach to describe and demonstrate their use of performance measures. We designed an electronic survey for state and local SNAP agencies, and created a secure file transfer protocol (FTP) site through which they could return performance data after completing the survey. We also developed structured interview protocols for use during follow-up telephone interviews with state and local staff and for targeted interviews (with no preliminary survey) with partner organization staff. A final data collection tool was a semi-structured interview guide to support site visits to a smaller number of states. Mathematica data collectors participated in a full day of training to learn about the purpose of the project in general and the data collection in particular, and review and practice using the data collection instruments. 2. Respondent Selection and Data Collection Once we developed the instruments, we collected data from state SNAP agencies. Then, with their assistance, we identified and contacted local staff and partner organizations to approach for data collection. Using feedback from both state and local SNAP staff, we also constructed a list of partner organizations to approach about telephone interviews. Staff from some states also participated in site visits made by the Mathematica team to explain their state’s measurement activities in greater depth. Table I.1 displays the data collection mode used for each type of respondent, with further details on the data collection efforts described in the remainder of the section. Table I.1. Modes of Data Collection for Each Respondent Type Respondent Type Electronic Survey Telephone Interview Performance Data Site Visit (Selected States) State SNAP Offices X X X X County\/Local SNAP Offices X X X X Partner Organizations X X X Background Mathematica Policy Research 4 All state SNAP agencies received an invitation to participate in the study and, in most states, a subset of their county and local SNAP offices and partner organizations received a subsequent invitation (once we had background information from the state survey). We selected local offices across multiple states in an effort to represent the breadth of local-level measurement activities occurring (see Castner et al. 2011 for details). Responses collected from selected county or other local SNAP offices supplemented the state-level picture by determining the extent to which additional performance measurement activity is being conducted at local levels, as well as giving a front-line perspective on performance data generation and usage. At both levels, the electronic survey provided us with information about the presence and functionality of any focal modernization initiatives in a state as well as application tracking, and solicited basic information (such as definition, importance, frequency of collection) about the performance measures the state collects and the standards and incentives it uses. We then followed up with phone interviews to clarify a small number of survey responses and obtain more details about selected performance measures. SNAP office respondents also received a request to submit 12 months of performance data for each of the measures the office calculates. In addition to our efforts to survey and interview SNAP staff, we collected information on the specific activities and performance measurements of three types of SNAP partner organizations\u2014 national businesses, local businesses, and community-based organizations. To contact these organizations, we selected among the outreach partners and contractors providing services that respondents in SNAP offices discussed during their telephone interviews. We specifically focused on those who were doing a wide variety of measurements or participating in unique partnering arrangements. To collect information from partner organizations, we interviewed them about their partnering activities with the state or local SNAP agencies as well as their performance measurement activities, and also requested that they submit 12 months of performance data for each measure they calculate. Finally, our team undertook site visits to 10 states we identified as leaders in their implementation of modernization initiatives and most likely to have developed a wide range of performance measures. After completing surveys and interviews in these states, we visited them to conduct in-person interviews with state and local staff and partners, and observe their use of performance measures. We sought participation from all 50 states and the District of Columbia, but found that 6 said they did not have time available to respond. We accommodated the schedules of respondents so that the request was as minimally burdensome as possible; this included allowing states to complete an interview only and extending the data collection period. However, despite our best attempts, some state and local office respondents still were unable to participate due to their administrative responsibilities. As data collection progressed, we revised our approach to collecting data from local offices. Our initial plan was to conduct surveys and interviews in 19 states\u2014those we identified as having a relatively high number of the key initiatives that together covered the range of initiative functionalities and regions of the country. In county-administered\/state-supervised states, we requested contact information from the state for 13 local offices; in state-administered states, we requested it for 7. During data collection, however, we often found little variation among the local offices in state-administered states regarding their measurement of modernization initiatives because they primarily followed direction from the state. As a result, to enhance the data collection effort, we modified our approach and requested contact information for local offices in all states, as opposed Background Mathematica Policy Research 5 to just the subset of states. The target numbers changed from 13 to 5 for county-administered states and from 7 to 2 for state-administered states. 3. Results of Data Collection Efforts During the nine-month data collection period from August 2010 to April 2011, we received feedback from 217 offices or organizations representing 45 states, including the District of Columbia (Figure I.1). In 15 states, respondents included the state and local SNAP offices and partner organizations, and in 10 of these states, state staff also participated in site visits. In 19 states, both the state and local offices responded; in the remaining 11, the state office was the only respondent. We completed a survey, telephone interview, or both a survey and telephone interview with 117 offices out of 137 originally contacted. Finally, although we collected contact information for numerous partner organizations, it would not have been fruitful to interview all of them. This was because many partner activities involved conducting SNAP outreach and providing application assistance. After conducting a substantial number of interviews with these types of partners and identifying their typical measurement activities, we chose to continue interviewing organizations with activities going beyond outreach and application assistance. We sent participation requests to 71 partners and interviewed 55. Figure I.1. Number and Combination of Respondents, by State Background Mathematica Policy Research 6 B. Data Analysis Approach Having accumulated a great deal of survey and interview information, as well as some details on performance from reports that respondents sent us, we then undertook two analysis efforts to distill the information into a usable form. First, we created a profile of each state that listed the set of measures and aggregate data, along with any performance standards, benchmarks, or incentives each had in place, and a brief narrative description of the state’s activities. Then, using these profiles, the interview responses, and performance reports, we summarized states’ use of these measures (which we report in Chapter II) and identified several common challenges they faced in performance measurement (as reported in Chapter III). We present the results of these two analysis activities in the remainder of the report. 1. Constructing State Profiles For each of the 45 states responding to the study in any form, we created a specific profile that details that state’s measurement activities. These profiles, arranged alphabetically, form the appendices to this report. Each profile opens with key facts about the state: how SNAP is administered, the number and types of respondents contributing, and the initiatives active in the state. Next, we present a table that lists the performance measures and aggregate data each state or its localities or partners reported to us. The table is arranged by modernization initiative and describes the area in which a given initiative is active, specifies whether a given measure is implemented statewide or locally, and the goals the state or locality is trying to meet through use of the measure. Finally, we provide any standards, benchmarks, or incentives the state or locality applies to the measure. Following the table, we supply a brief narrative giving an overview of the initiatives active in each state to provide context for how the performance measures are implemented. In developing these appendices, we strove to report exactly what respondents told us, within reason. For some measures, additional refinement was necessary. For example, if a respondent reported in the survey that no standard was in place, but during their interview described a standard, we added this information as an update to our database and reported it in the appendix. We renamed some measures across states for the sake of continuity\u2014for example, if a state chose to write in a measure of its own and its definition was similar to a measure we had supplied. In cases for which one or more local offices in a state-administered state reported using a measure from reports provided by the state office, we listed the measure as being implemented statewide even if the state had not indicated this to be the case in its survey. That is, we assumed as long as any local offices were using the data from the state, it is accurate to say that statewide data are available, even if not all local offices choose to use the data in this way. 2. Identifying Challenges and Performance Across States We analyzed how states are using the measures they employ and, to a degree, how they report their performance on these measures. In Chapter II, we discuss our findings on these aspects. For each initiative, we report information on how selected states are implementing and using key measures, drawing attention to specific examples that illustrate why cross-state comparisons may be difficult or inappropriate. In some cases, we report the performance of a small number of states on select measures although, as we describe, it is difficult to do so in a more comprehensive fashion because of the complex contextual factors that limit generalizability. The chapter closes with a discussion of approaches states take to setting benchmarks and standards for themselves on the Background Mathematica Policy Research 7 measures they value most, which may be of interest to states or stakeholders seeking to replicate certain modernization initiatives in new locations. Reviewing respondents’ information within and across states revealed some clear challenges that SNAP offices and their partners face when dealing with performance measurement. In Chapter III, we discuss these limitations more specifically. They include contextual limitations (such as varied functionality of modernization initiatives across states, differences in how states refer to similar concepts), and data limitations (that affect the accuracy, reliability, and validity of data in a way that impairs the generalizability of findings). The data limitations may prove particularly cumbersome for state users of data. While they also affect readers who want to understand these data across states, those readers who are interested in applying this information on measures to their states may be most concerned with the contextual limitations that could complicate their interpretation of the data that respondents provided in the course of this study. Throughout this report, we offer examples of individual states’ experiences with performance measurement. Readers seeking greater detail on a specific state’s situation and measures will find this information in the state profile appendices. 9 II. HOW ARE STATES PERFORMING? As state agencies and FNS seek to identify appropriate performance measures for SNAP, information on how all states are measuring their modernization initiatives and performing with respect to those measures is valuable. For each initiative, a number of performance measures could be useful and informative, but we found that only a few are actually in use\u2014and even fewer are used broadly. In some cases, states are using several similar measures to address the same concept. In this chapter, we explore how states are measuring their modernization initiatives, what standards they are setting for those measures, and how these vary across the states. We provide the details on each state’s modernization initiatives and measures in the appendices. Performance on 175 different measures is being recorded by at least one state or local office (89 are tied specifically to the eight modernization initiatives we examined, and 86 relate to application tracking, accuracy, and approval\/denial rates). With the exception of the quality control measures required by FNS, no performance measures are being collected in all states. Among the more common measures, the method of calculation is not always consistent, so they are not entirely comparable (as we discuss in Chapter III). To further complicate attempts at cross-state comparisons, differences in the nature and maturity of modernization activities, state and local priorities, and business process change efforts shape how the states view and use the measures and what performance levels they find acceptable. We begin this chapter with a review of the results we observed across states, handling each modernization initiative in turn (see the glossary for descriptions). The discussions describe the reach of each initiative, performance on frequently reported metrics for illustrative subgroups of states, sources of variation in those metrics, and the situations in which performance measures are reported on less frequently. In the second section, we focus on setting benchmarks, examining how and why states have set benchmarks and standards, and what some have done to incentivize their staff, despite severe fiscal limitations. A. Observed Results on Measures Across States Information in this chapter is based on what state and county or local SNAP offices reported to us through the survey and interview (or, in some states, site visits). After collecting information about their initiatives, we asked specific questions about the performance measures and benchmarks related to those initiatives. As discussed earlier, this is an exploratory study\u2014we focused on gathering a wide range of information, then verifying the details for a subset of the information. Verifying all of the information we received would have placed too much of a burden on SNAP and partner staff. No performance measures, other than those federally mandated for quality control reviews, are being calculated by all of the states implementing a given initiative. We found several common measures across states, although many were calculated in various ways (as a result, this report often looks at measure families, grouping differently named but similarly calculated measures together). Some states also discussed novel measures they have developed around one or more of their modernization initiatives. This section discusses these common performance measures reported for each modernization initiative in turn, beginning with call centers.3 3 Throughout this report, we refer to performance measures by the names listed in the survey or directly provided by the states. How Are States Performing? Mathematica Policy Research 10 1. Call Centers Among the 28 states4 with call centers, a state or local office in 23 states5 reported that they calculate two key types of measures of clients’ access to telephone services: (1) wait time and (2) volume of calls addressed by the call center. This includes states that operate call centers statewide, regionally, or that operate a combination of regional and statewide call centers, and those for which a performance measure may be reported statewide, by a local or county office, or both. Performance measures addressing how long clients must wait to have their concerns addressed include: Average Hold Time Average Waiting Time (to Speak to Agent) Average Queue Time Average Answer Speed Average Time to De-Queue Measures of the portion of calls addressed by the call center include: Percent Calls Abandoned Percent of Total Calls Handled Percent of Queued Calls Handled No measures from either of these groups were reported for the five other states with call centers (however, the District of Columbia does track the number, but not percent, of calls abandoned). Table II.1 displays the benchmark and performance data for selected states for measures of wait time and rate of calls abandoned, as well as key features of their call center(s). As we describe in Chapter III, the challenge in reviewing data from call centers is that many of them serve clients from multiple programs (such as medical assistance and Temporary Assistance for Needy Families (TANF)) and they do not differentiate callers by program in their databases. Arizona was unique in reporting that their call center metrics are differentiated by public benefit program. Table II.1 shows substantial variation in the standards and benchmarks of selected states and their actual results. Some variation can be explained by how a state’s call center fits into other initiatives and how it is operated. For example, due to increasing SNAP applications and resource constraints, Florida cannot fully staff its call centers without compromising the timeliness and accuracy of processing applications, so it reported prioritizing application processing over allocating additional resources to the call centers. Operational capacity within the call centers also impacts these figures. Arizona’s call center serves the entire state and its staff also process changes that come through its 4 Arizona, California, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Louisiana, Massachusetts, Minnesota, Missouri, Nebraska, Nevada, New York, North Carolina, Ohio, Pennsylvania, South Carolina, Texas, Utah, Virginia, Washington, West Virginia, and Wisconsin. 5 Arizona, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Louisiana, Minnesota, Nebraska, Nevada, New York, North Carolina, Ohio, Pennsylvania, South Carolina, Texas, Utah, Virginia, Washington, West Virginia, and Wisconsin. How Are States Performing? Mathematica Policy Research 11 Table II.1. Average Wait Time and Abandonment for Selected States State Call Center Features Measure Benchmark or Standard Monthly Average Arizona Statewide Automated response unit Change center Average waiting time (to speak to agent) None 16:43 minutes Percent of total calls handled None Not reported Florida Regional Automated response unit Change center Average answer speed 3 minutes 12:52 minutes a Percent calls abandoned 12 percent 17.1 percent a Georgia Statewide Automated response unit Change center Average answer speed <1 minute 8:57 minutes Percent calls abandoned <9 percent 40.38 percent Indiana Regional Operated by a contractor Automated response unit Cannot transfer to agents Change center Average hold time \u22643 minutes 4:14 minutes Percent calls abandoned \u22645 or 7 percentb 6.53 percent Pennsylvania Multiple areas Automated response unit Change center Average answer speed None 9:23 minutes Percent of queued calls handled 80 percent 12.45 percent (abandoned)c South Carolina Automated response unit Change center Average answer speed 5 minutesd Not reported Percent calls abandoned None Not reported Texas Multiple areas Operated by a contractor Automated response unit Change center Real-time work management system Average answer speed 180 seconds 0:56 minutes Percent calls abandoned 10 percent or lesse 4.0 percent a This represents one circuit (Florida regional SNAP office) only. b Local offices in Indiana use one of several models. Those using a hybrid model have benchmarks of 7 percent. Modern offices have a benchmark of 5 percent. See the Indiana appendix for more information. c Performance data submitted showed [percent] of calls abandoned of calls entered. d The South Carolina respondent reported that this is the industry standard for call center wait times. e Texas offices are fined per percentage point by which their rate of abandonment exceeds 10 percent. online system. Supervisors, however, do not have a tool that allows them to assess immediate staffing and support needs and reassign staff across tasks if needed. This lack of resource could result in longer wait times for callers. Some call centers also are limited by system capacities; calls are abandoned automatically either after some designated wait time (25 minutes in Arizona) or when the queue exceeds a certain number of callers (120 in Pennsylvania). Even for states that use the same measure, such as Percent Calls Abandoned, we cannot compare performance across states, as they do not include or exclude these system-abandoned calls uniformly. States also apply different minimum call lengths in labeling a call abandoned in an effort to exclude misdials. Average wait times and call abandonment rates typically are correlated, as indicated by the monthly averages shown in Table II.1. Of the four states in the table reporting average abandonment rates and wait times by month, the peak rates for both measures occurred during the same months for Georgia, Indiana, and Texas (for example, both measures were highest in May for Georgia and How Are States Performing? Mathematica Policy Research 12 Indiana and in September for Texas). For Pennsylvania, the month with the highest wait times had the second highest monthly abandonment rate. The rates of call abandonment in Pennsylvania and Indiana were higher than in Texas, at median monthly averages of 12.45 percent, 6.53 percent, and 4.0 percent, respectively. This is not surprising, given the differences in average hold time, as people are more likely to abandon calls when faced with longer hold times, such as the median monthly averages of 9:23 (Pennsylvania) and 4:14 (Indiana), than when calls are answered in less than a minute, as in Texas. We observed the same pattern when looking at performance data within states. Texas shows the highest call volume of these three states, averaging more than 300,000 calls per month for the 12-month period for which performance data were submitted. Texas and Indiana, which have the lowest wait times and abandonment rates of those states that submitted performance data, employ contractors to operate their call centers. Texas's answer speeds and abandonment rates may be related to how the state penalizes its call center contractor for rates in excess of the benchmark. (For more information, see Section B on Setting Standards and Benchmarks.) Some additional measures are used in call centers, although primarily for staff and task management. For example, Pennsylvania tracks the Average After-Call Work Time by Staff and Average Calls Handled, a per-hour, per-employee measure. Supervisors monitor call length and intervene when calls become excessively long. Such measures were cited by staff in several states as efforts to increase efficiency. 2. Online Systems States' online systems vary and can include simple websites, in which clients can populate and submit an application, as well as more elaborate sites in which data from a screening tool pre- populates an application that can be signed and submitted electronically. Clients in some states can create online accounts to monitor benefit amounts and submit changes. Online submission for SNAP applications is available in 33 states.6 Of these, 23 states reported that the application source is recorded, either through the eligibility determination systems or another system for tracking application receipts, such as clerical logs.7 Workers in some other states may be able to identify the source for individual applications by searching for markers on the applications themselves, such as Uniform Resource Locators (URL) and printer codes, but could not reasonably determine the number of applications received through the online system using aggregate data collected in an automated way. States in which the eligibility systems can differentiate application sources often can report the percentage of applications received through the online system and the percentage of online applications approved; this enables them to document the initiative's impact on clients' program access and staff workloads without any manual counting. None of the states reported tracking submissions of online applications by demographic subgroup. In theory, online application capability should increase program access, as it provides potential clients with an additional means to learn about their eligibility and submit an application. However, this may depend upon the states' communication efforts. New Jersey used radio advertisements to 6 Arizona, California, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Louisiana, Maine, Maryland, Massachusetts, Michigan, Montana, Nebraska, New Hampshire, New Jersey, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Carolina, Texas, Utah, Virginia, Washington, West Virginia, and Wisconsin. Alaska has an online screening too, but the online system cannot submit applications. 7 Arizona, some California offices, Delaware, Florida, Georgia, Illinois, one Kansas local office, one Louisiana local office, Maryland, Massachusetts, Michigan, some local offices in Montana, Nebraska, New York, Ohio, Pennsylvania, Rhode Island, South Carolina, Texas, Utah, one local office in Virginia, Washington, and Wisconsin. How Are States Performing? Mathematica Policy Research 13 notify potential clients about its online system and recorded the number of online applications to measure success and determine when it was appropriate to discontinue the advertisements. States also expect that the approval rates for online applications may be lower than for paper applications, due to the demographics of the clientele to which an online application might appeal. For example, Massachusetts uses a benchmark of 50 percent approval for online applications, which is lower than the state's benchmark for approval of all applications (70 percent). Several states reported that they calculate the approval rates specific to applications received through their online systems, but we received minimal performance data for this measure. Without these data, we cannot confirm that online application systems attract applicants less likely to be eligible. Two of the states that calculate the approval rates for online applications\u2014New York and Utah\u2014implemented their online systems within the past five years. The third state using this measure\u2014Massachusetts\u2014implemented its online system in 2004. Two early adopters, Arizona (2002) and Pennsylvania (2001), are not measuring approval rates for applications received online. SNAP offices also reported tracking the quantity of online applications and their approval rates to indicate the workload impact of the initiative. All of the states listed in Table II.2 have screening tools available on their websites so that potential clients can gauge their eligibility before applying for programs. Some states8 reported having online systems without screening tools, but they did not report calculating either of the performance measures highlighted in Table II.2. Screening tools also may save staff time, as those potential clients whom the screening tool shows to be ineligible may be less likely to apply. Because so few states reported calculating the approval rates for applications submitted through their online systems, all of which include an online screening tool, we cannot speak to variation in the approval ratings for online applications based on this tool. Maryland, Pennsylvania, and North Carolina track the use of their online screening tool differently. Maryland reports the number of screenings started and completed (34,783 screenings were started and 27,591 completed); Pennsylvania reports that they use it to determine the percent of potentially eligible screenings resulting in application submissions (results not provided by the state); and North Carolina computes a monthly average (results not provided by the state). A few states track online client account activity, although the type of data they track is not consistent across states. Michigan, Utah, and Florida track the number of online accounts created and the number of changes submitted. Florida also tracks the number of customer log-ins. Michigan's online account measures inform its outreach activities. Specifically, Michigan analyzes online account creation to determine how much time field staff should devote to community outreach and whether they should educate community partners about the online system. Other states may be using their measures similarly but were not as explicit as to their intent. A few states employ unique performance measures for their online systems. Six states\u2014or local offices within those states\u2014reported measuring the volume of clients who received help to apply online.9 Several of these states also track the number of clients who did not receive help to apply online or the number who requested assistance. North Carolina has an online application, but applications must be printed and submitted as hard copies. It uses monthly data about the number of hits on the application site as a proxy for the number of clients applying through the online system. Arizona posts a customer service survey on its website. 8 New Hampshire, Oregon. 9 California, Florida, Maryland, New York, Virginia, and Wisconsin. How Are States Performing? Mathematica Policy Research 14 Table II.2. Measures of Online Systems for Application Tracking for an Illustrative Sample of States State Online System Features Percent of Applications Received Online (associated benchmark) Percent of Online Applications Approved (associated benchmark) Arizona Client accounts Change reporting Integrated screening tool E-signature X (none) Indiana Client accounts Change reporting Integrated screening tool E-signature X (none) Massachusetts Client accounts Screening tool E-signature X (40 percent) X (50 percent) Nebraska Client accounts Change reporting Screening tool E-signature X (none) New York Client accounts Integrated screening tool E-signature X (20 percent) X (none) Pennsylvania Client accounts Change reporting Integrated screening tool E-signature Unsigned submission X (none) Utah Client accounts Online chats Integrated screening tool E-signature Unsigned submission X (none) X (none) 3. Document Imaging States' measurement of document imaging activities focuses on the percentage of documents imaged and timeliness of imaging activities. For most of these offices, case files are available only electronically and must be remotely accessed; thus, quick and comprehensive document imaging is critical to the success of their application processing. Offices in eight states10 reported tracking the Percent of Documents Scanned and an additional twelve11 collect the Number of Documents Scanned. Table II.3 does not include performance data for the sample, as very few states submitted data for this measure. SNAP offices in an additional four12 states do document imaging but did not 10 Delaware, Minnesota, Mississippi, Nebraska, New Hampshire, Ohio, Washington, and Wisconsin. 11 Arizona, California, Florida, Idaho, Indiana, New York, North Carolina, Pennsylvania, Rhode Island, South Carolina, Texas, and Utah. 12 District of Columbia (planned but not yet implemented at time of interview), Iowa, South Dakota, and Virginia. How Are States Performing? Mathematica Policy Research 15 Table II.3. Quantity of Documents Imaged and Averages for Selected States State Data Collected by the State, Regional, or Local Offices? Who Images Documents? Percent of Documents Scanned Delaware State Documents are imaged at the local offices Mississippi Local Counties scan documents, and states collect imaging system data Nebraska Regional Imaging is done by two central offices New York State Documents are sent to a central location, although some local offices have their own imaging systems Ohio Local Counties have their own locally developed systems Washington State Documents are sent to one of four statewide indexing sites Wisconsin Local Documents are imaged by the local offices and attached to the case files in the eligibility system Number of Documents Scanneda Arizona State Documents used to be imaged by a contractor, but now are handled by local office staff in a state-run system California Local Documents are imaged by those local offices that implement the initiative Florida State State has a central document imaging center, although some local offices image their own documents Indiana State Documents are imaged by a contractor and performance metrics are outlined in the contract North Carolina Local Local office staff image documents and attach them to case files Pennsylvania State Imaging done by county offices into a state system, although some smaller offices send documents to larger offices Texas State A contractor at a statewide office does the scanning Utah State Documents are sent to a main processing center, although some local offices can image documents into the online system Wisconsin State Documents are imaged by the local offices and attached to the case files in the eligibility system aStates and local offices that track performance measures are noted in the Percent of Documents Scanned section only. report measuring the volume or percentage of documents imaged. The offices report these metrics for documents across multiple programs and generally cannot differentiate those documents specific to SNAP, although Arizona did report this capability. A few offices also track documents by source (such as by mail or fax). An office's performance data may vary by the maturity of the document imaging initiative, particularly the approach to documents that predate implementation. For example, an office in Delaware recently had initiated document imaging and was working to image older documents at the time of the interview. Until the office finished imaging all older documents into the system, its performance on the percentage of documents imaged or average time to image documents would misrepresent its normal capacity and probably would lag behind offices with similar procedures and resources. In such cases, an apparent performance gap should not be misconstrued as reflecting poorly on the office. Other offices may opt not to image documents predating the initiative or may image those obtained only within a certain period prior to the implementation date. How Are States Performing? Mathematica Policy Research 16 Offices' approaches to document imaging vary, and these approaches impact the time required to image documents. In some cases, scanning occurs after case workers have used the hard copies to make an eligibility determination. In others, a scan first model is used, in which all documents are scanned before being made available for caseworkers. Some states may set different standards for scanning time, depending on when the document is used, if both approaches exist within the same state. For example, Washington set a standard that documents should be imaged within one day if the contents of the document have not been used already to update the client file, but set a standard of three business days if the client file already has been updated or worked. Imaging also may take longer when documents must be packaged and sent to central processing sites or to larger local offices. In the case of the scan first models, offices expect documents to be scanned in a very short time period so the scanning process does not delay the application decision timeline. Table II.4 shows the processing time measures for select offices that reported tracking it. Because each state operates in a unique context and may vary as to which records it counts and how it measures processing time, performance over 12 months cannot be compared, and so is not shown. Table II.4. Document Imaging Approach and Time Measures for Selected States State Scans Pre- or Post-Processing? Performance Measure Indiana Pre Average Processing Time Nebraska Pre Average Processing Time Pennsylvania Pre Percent of Documents Attached in a Timely Manner Texas Post Percent of Documents Imaged Same- Day Washington Pre\/Post Percent of Documents Scanned within Standard of Promptness Regardless of the degree to which a state integrates document imaging into the eligibility determination process, staff in multiple states reported that the initiative has obvious benefits. In Utah, document imaging enables its call center both to address a wider range of client questions and allow staff to work remotely. An Arizona respondent stated that, I honestly believe that imaging has saved staff time. And the proof is that we were able to survive even after a 600-person cut [in staff over two years]. While Missouri does not use document imaging, a respondent explained that it would be much simpler if they had document imaging because it would reduce the likelihood of lost case files and save time otherwise spent digging through case records. The larger counties can never find 100 percent of their cases. Missouri indicated that it is exploring options to fund a document imaging initiative. 4. Kiosks SNAP offices in 14 states reported having computer stations or kiosks in their lobbies or elsewhere to enable clients to access online applications or accounts.13 In general, when discussing their kiosks, respondents reported minimal use by clients. They said that clients interested in applying online or accessing their online accounts do so from their own homes, libraries, or other convenient 13 Arizona, Florida, Indiana, Louisiana, Michigan, Nebraska, New York, North Carolina, Ohio, Pennsylvania, Utah, Virginia, Washington, and Wisconsin. How Are States Performing? Mathematica Policy Research 17 spaces. The states are doing little to measure kiosk use. Washington does track the number of applications submitted from a kiosk. A field in the online application allows clients to indicate that they are using a kiosk station to complete and submit the application. The state cannot identify which kiosk was used, nor verify that the client used a kiosk. 5. Partnering The extent to which SNAP offices work with partners to help potential clients access the system varies. Partners are engaged in a range of activities, under formal and informal agreements, and may or may not be compensated for their efforts. In a few cases, to be discussed in this section, the partners' compensation is dependent to a degree on their performance. Some states report data on their partnering arrangements, although most of these performance measures track the nature and cost of the partnering arrangements, not the quantity or quality of services provided; the percent of partner applications approved was the only reported partnering measure to address the success of the partnering initiative in reaching potential clients. States reported minimal or no performance reporting requirements for their partners. In a few cases, noted in Table II.5, states do track and report on the number of clients assisted by partners, the number of applications submitted through them, and the approval rate for applications submitted by them. Performance measurement activities vary, but the states that do the most reporting on their partnering initiatives are those with contractual partners. For example, among the states included in case study site visits, those that have been engaged longest in partnering for application assistance (Arizona, Pennsylvania, and Washington) are all states where partnering arrangements are governed by Memoranda of Understanding (MOUs). Arizona does not appear in Table II.5, as it did not report measuring its partnering activities. Washington, whose partnering is the oldest of these three, dating to the 1990s, reported only a few measures, and at least one of the partners interviewed for this study indicated that it submits performance data to the state. Pennsylvania calculates performance data about its partners, and at least one partner reported submitting data to the state. Table II.5 does not include information on partnering in California, Delaware, Florida, Louisiana, or Ohio. Partnering in these states varies significantly at the county level, and there are no consistent measures at the state level. Within each of these states, counties are engaged in partnering arrangements\u2014some through formal contracts or MOUs\u2014and collecting and reporting performance data on these partners. Counties in other states, including New York and North Carolina, may be engaged in partnering activities beyond those reported by the state. It is also important to note the unique partnering arrangements in Utah. The state outsources its staff to locations such as hospitals and medical clinics, where they assist clients with applications. These staff report to the state office but are exempt from some typical eligibility worker responsibilities, such as fielding calls through the call center, so they can focus their attention on the How Are States Performing? Mathematica Policy Research 18 Table II.5. Measures of Partnering for an Illustrative Sample of States Measures Percent or Number of Partners Providing Application Assistance Percent of Partners Providing Access to Kiosks Percent of Partner Applications Approved or Denied Aggregate Data on Client Services: Number of Partners Track Performance on Additional Measures?a States with Contractual Partnersb Alabama X Applications received per partner No Kansas X Clients assisted per partner, Applications received per partner No Maryland X Yes Massachusetts X X Clients assisted per partner, Applications received per partner Yes Michigan Applications received per partner Yes Nebraska X X No Rhode Island X No Texas X Clients educated, Clients assisted per partner, Applications received per partner Yes States with Partners by MOU Georgia X Clients assisted per partner, Applications received per partner, Outreach events, Clients served No Nevada X X Clients assisted per partner, Applications received per partner No Pennsylvania X Applications received per partner Yes Washington X Yes States with Informal Partners Illinois X Applications received per partner Yes Wisconsin X Clients assisted per partner, Applications received per partner Yes Note: Indiana relies on contractors to operate its call center, mail service, and document imaging but does not partner for application assistance. Indiana's measurement of its call center is reported in the Call Center section. California, Delaware, Florida, Louisiana, Ohio, and Utah also are omitted from the table and will be discussed later. Other states reported having community partners but did not report any performance measurement of their partnering. a According to partner reports of what state or local SNAP offices require. Project staff did not interview partners in all states, nor all partners in a state. States may be requiring data from partners with whom we did not speak. bStates listed as having contractual partners also may have partners by MOUs or no agreements. States are listed only once, based on the most formal arrangement noted. How Are States Performing? Mathematica Policy Research 19 on-site clients. These arrangements were initiated in 2007 and constitute an alternative approach to the partner staff application assistance we observed in other states. A few states, such as Washington and Pennsylvania, have established performance-based contracts with their partners. Washington reimburses partners for their application assistance, but at least half of all of their submitted applications must be approved, with a further incentive that payment for approved applications exceeds that for denied applications. For each of its partners, Pennsylvania sets standards for the number of applications submitted monthly, based on the partner's size and service area demographics. Beginning in the second quarter of the year, Pennsylvania's quarterly payments are dependent upon the partner showing progress towards its specific annual goals. Partners that assist with client applications have special access to the SNAP eligibility determination system (COMPASS) so they can check the eligibility status of submitted applications. This enables them to calculate the percent of submitted applications that are eligible, which sometimes is required by their MOU. Partners' reporting capacities often exceed state requirements. They may track other data based on requirements from their stakeholders, or to manage their own workload. For example, one Illinois SNAP partner was compensated by funds available through the American Recovery and Reinvestment Act (ARRA) of 2009. Based on the requirements of that funding source, the partner collected information about applicant demographics, particularly poverty status. When the period of ARRA funding ended, so did the requirement to submit this data to the SNAP office. The partner still collects it for its own use, however. 6. Interview Initiatives Of the state and local SNAP office staff interviewed, staff in all but five14 states we spoke to reported using or planning to use a waiver of face-to-face interviews. Maine and the District of Columbia had not yet implemented the policy waiver at the time of the interviews but had it in place during a later phase of the data collection. SNAP is county administered in Ohio and California, so the waiver is not implemented universally. A few states applied for a waiver for recertification interviews only, and continue to conduct in-person interviews for initial applicants. Others use the waiver to allow for client choice; many states default to a telephone interview unless the client requests to meet face to face. Most offices record the interview type in the case notes or use some other method not conducive to automated reporting. Ten offices use systems that enable them to determine how many interviews were conducted over the phone versus in person; half of these states do not regularly report the percentage of interviews by method. Other states do report information about interview methods, although some is pulled from quality control reports on case samples (and so may not be available for the entire caseload). The error rate by interview source is another common measure related to the waiver of face-to-face interviews. Again, much of these data reflect a sample of cases. The counts of telephone interviews that contribute to these statistics include some clients who would have been eligible under the hardship waiver; states did not specifically report on the number of interviews conducted over the phone using the policy waiver. States also reported the percentage of requests for telephone interviews honored and the percentage of interviews conducted via the automated phone system, although the latter was employed 14 Iowa, Mississippi, Missouri, Montana, and South Carolina. How Are States Performing? Mathematica Policy Research 20 only in Illinois. None of the states were able to report on the eligibility determination by interview type or the demographics of those who elected one interview type over another. 7. Application Tracking Not surprisingly, the most common performance measures relate to tracking the progress and outcomes of initial and recertification applications, a task undertaken by all states. Thirty-six states, listed in Table II.6, reported tracking approval and denial rates. Tables II.6 indicates which states report on approval and denial rates separately, or have only a single overall measures for total applications. (States often declined to define their total application measure, so it is not clear whether the total number sums applications and recertifications, applications only but from all sources, or something else.) Table II.6. Reported Performance Measures for All States with Application Tracking Efforts Percent Approved Percent Denied State Total Applications Applications, Recertifications Differentiated Total Applications Applications, Recertifications Differentiated Alabama X X Arizona X X Alaskaa X X California X X Connecticut X Delaware a X X District of Columbia X X Georgia X X Hawaii X Idaho X Indiana X Iowa X X Kansas a X Kentucky a X Louisiana X X Maryland X Massachusetts X X Michigan X X Minnesota X X Missouri X X Mississippi X X Nebraska X Nevada X X New Hampshire X X New Mexico X X New York X North Carolina X Ohio X X Pennsylvania X X Rhode Island X Texas X X Utah X X Virginia X X Washington X X Wisconsin X Wyoming X X aMeasurement reported at the local level only. How Are States Performing? Mathematica Policy Research 21 States measure application processing time in one of two key ways: the percentage of applications processed within a certain timeframe, and the average processing time for those completed within the reporting period. Most states reporting the percentage processed timely use the federal guidelines that applications and recertifications be processed within 30 days. Some states, however, expect applications to be processed more quickly. Massachusetts, for example, set a target that applications be processed within 17 days, and Idaho set a benchmark that 70 percent be processed on the day of receipt. Kansas and Missouri also have benchmarks stating an aim that 95 percent of applications be processed on time. Indiana is in a unique situation. Due to a lawsuit, the state must process 90 percent of applications and recertifications timely, higher than the internal goals of 80 percent and 85 percent, respectively. However, the state operates under a waiver that enables it to extend the processing time to 60 days in cases in which the client has not submitted sufficient documentation during the first 30 days to make an eligibility decision. While most states would close out the application as ineligible due to incomplete information, Indiana can keep it open for an additional 30 days, in the interest of collecting the missing information without requiring the client to resubmit the entire application. A respondent from Indiana noted that the state's timeliness has improved since it increased efforts to track application processing. Several other application processing measures were common or addressed particular concerns: applications by source, average benefit amount, percent outside of business hours, and the percent of duplicate applications. A few states track reasons for application denial, but each office does so differently. More than half of states calculate the average benefit amount.15 A California respondent explained this as a way to assess program costs, particularly the impact and feasibility of proposed policy changes. States that can report the average benefit amount by household characteristics, such as New Mexico, also use this measure to indicate whether certain populations might be underserved. In tracking the number of applications received, some states reported being able to differentiate by source or isolate one or more sources, such as the percentage submitted through their online systems or postal mail. New York and Illinois monitor the percent of online applications received outside of normal business hours. Illinois explained this as an effort to identify and investigate anomalies when comparing across its local SNAP offices. Some local offices in California also track the average number of online applications submitted and the number of repeat or duplicate online applications. Massachusetts occasionally reviews the percentage of duplicate online applications and is working with its vendor to screen out duplicate cases. B. Setting Standards and Benchmarks States did not report extensive use of performance benchmarks and standards, and several states indicated a deliberate choice not to set them. State and local offices reported setting performance benchmarks or standards for several reasons: (1) to help prevent the need for corrective actions, (2) to encourage staff productivity, (3) to monitor and maintain output levels during periods of modernization, and (4) in response to legislative and judicial decisions. 1. Preventing Corrective Action States performing below the national average for timeliness and accuracy risk are being required to create a Corrective Action Plan. In an effort to avoid this, states may carefully monitor their 15 Alabama, Alaska, Arizona, California, Connecticut, District of Columbia, Delaware, Georgia, Hawaii, Iowa, Louisiana, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nevada, New Hampshire, New Mexico, New York, North Carolina, Ohio, Rhode Island, Texas, Utah, Virginia, Washington, and Wisconsin. How Are States Performing? Mathematica Policy Research 22 performance on timeliness or quality measures. In some cases, states established guidelines more stringent than the FNS guidelines, such as the benchmark in Idaho that 70 percent of applications be processed the day of receipt. In an effort to improve performance and discontinue a Corrective Action Plan, Oregon instituted a similar policy that the counties' error rates with telephone interviews must be below the state average or the local office would be required to submit a Corrective Action Plan. Since implementing this program, Oregon's staff reported that the error rate has improved; it is the lowest in 10 years, and is below the national average. Oregon also conducts a quality assurance review to look at agency-caused error rates and cites the counties with best accuracy rates in a monthly newsletter. It issues certificates each month to workers whose reviewed cases all were found to be accurate. 2. Encouraging Staff Productivity Incentives for meeting benchmarks have been used in some states and local offices to push staff to continually improve performance. These incentives also reward high performers and foster friendly competition both within and between offices. As one respondent in Florida explained it, We benchmark against ourselves in terms of what's possible, where we can push the envelope. In some cases, benchmarks and standards are established with input from office staff, as one local office in Minnesota reported. For example, in setting a 15-day processing standard for all applications, one of California's county offices determined that this standard would be challenging but realistic, given its historical data on processing time. Pennsylvania increased its goal for Number of Calls Handled after meeting its previous goal. The Oregon example cited in the section above also illustrates the use of staff rewards for accuracy. In many cases, initiatives meant to reward staff for their performance on certain measures have been discontinued due to financial strain. A number of states provided examples of fiscally neutral awards for strong performance: Governor's Awards are given to call centers when any of the center's standards are met, including a one-minute average answer speed, less than a nine-percent rate of call abandonment, or an average call time between four and six minutes (Georgia) Top-performing staff are offered special assignments or advisory roles (New York, Washington) Executive Directors of the local office(s) with top performance, once adjusted for rudeness complaints and positive feedback, are recognized monthly (Pennsylvania) Despite an inability to offer monetary rewards, at least one respondent noted that the recognition and praise still benefit staff morale and have some positive impacts on office performance. 3. Monitoring and Sustaining Performance As SNAP offices modernize or merge, they use performance data to monitor how well they are integrating new and existing activities and workloads, or even to justify a change in processes. In these cases, standards set to the performance levels prior to the change can help an office ensure that its clients are not adversely affected by this process. After Illinois implemented its online application system, it noticed that applications were still submitted during normal office hours, with low volume outside of those hours. It began to track the percent of online applications that clients submitted outside of normal hours while initiating a campaign to educate clients about the new opportunity to submit applications at their convenience. They reported that the campaign was a success, noting an increase in Percent [of online applications] Completed After Hours (at 27.3 percent during the year How Are States Performing? Mathematica Policy Research 23 from February 2009 to January 2010). Once the performance reached an acceptable level, the state discontinued use of the measure. Two county offices in Wisconsin undergoing changes in their workflow design provided additional examples of how SNAP offices can use performance measures and standards during the transition. The first office, after an initial transition period, plans to establish performance benchmarks slightly higher than the levels met prior to the redesign. The second office had achieved and Average Answer Speed of 30 seconds or less for 95 percent of its calls, so it established this as a benchmark as it expanded to serve callers from several additional counties. Other state and local SNAP offices reported similar uses of performance measurement to maintain or increase client services while implementing new or expanded initiatives. Arizona's decision to operate its document imaging center internally, rather than continue to employ a contractor, relied on establishing and maintaining benchmarks for a performance level comparable to or better than that of the contractor, and at a lower cost. This proof of concept benchmarking in Arizona represents a use of benchmarks and standards to justify and initiate a change in process. 4. Responding to Legal Action Benchmarks and standards also have been set through legislative or judicial action, typically as a result of notably poor performance. Lawsuits resulting from lost mail have led to benchmarks for prompt and comprehensive document imaging. Cases of significantly delayed benefits also have led to stricter standards for average processing time or benchmarks for percentage of applications processed on time. Maryland must process 96 percent of applications in a timely manner, per a court order resulting from the Thompson v. Donald case. Similarly, the Nevada legislature imposed standards for call center wait times in response to complaints of extremely lengthy wait times. Not all states set standards or benchmarks. In many cases, respondents described their decision not to set them as central to maintaining high levels of customer service and program access. For this reason, Michigan chose not to establish any performance standards or benchmarks beyond those required by FNS. More often, however, the states identified certain measures as inappropriate for benchmarking. For example, a respondent in Rhode Island indicated that setting standards for the application source\u2014online, delivery to local office, partner submission, or other methods\u2014would limit client choice. Similarly, Alaska and Delaware, which can calculate the percentage of interviews conducted over the phone, have not set benchmarks in the interest of protecting client choice. For these states, the telephone interviews are seen as an option to increase program access, rather than as replacing the traditional in-person interviews as a means of increasing efficiency. Arizona noted that call center traffic peaks shortly after Notices of Missed Interview are sent, so establishing an appropriate standard for wait time would be difficult, given the variability in call volume. C. Conclusion No performance measurement activities are undertaken uniformly across the states implementing a given modernization initiative. Even performance metrics that track application receipt and processing vary, with some states differentiating between applications and recertifications while others do not. With the exception of the shortened interview procedure and kiosks, states are involved in notable efforts to measure their performance and do so in similar ways. Most of the common measures across initiatives relate to the proportion of an activity completed and the time taken to complete a given task. However, within these common measures, we found variety in measure names How Are States Performing? Mathematica Policy Research 24 and definitions. While the measures could be used to track a state's performance over time and identify anomalies, the variations across measures and initiatives prevent many specific cross-state comparisons. States' reasons for reporting\u2014or not reporting\u2014specific measures also vary. In general, states do not record the characteristics of the clients benefitting from or served by the modernization initiatives, nor do they collect other information to assess how well a given initiative or activity is improving service to a given clientele. States' use of performance benchmarks and standards also vary, with some abstaining entirely. Benchmarks and standards are applied to performance metrics for four reasons: (1) to prevent against low performance that would warrant corrective action, (2) to encourage staff productivity, (3) to monitor performance levels during periods of change and sustain customer service, and (4) in response to judicial or legislative requirements. In the current fiscal climate, states are very limited in giving monetary rewards to high-performing staff or local offices, but they reported other efforts to help encourage staff productivity and reward high achievers who meet benchmarks. 25 III. LIMITATIONS TO USE OF MEASURES AND STANDARDS States face an array of challenges in collecting data and calculating performance measures, many of which affect data quality and hinder efforts to compare existing measures across states. In this chapter, we address two aspects that commonly affect cross-state performance measure comparisons: contextual limitations and data limitations. Contextual limitations, such as differences in what initiatives do and who they serve, affect the calculation and comparability of performance measures. Data limitations (specifically those that affect the accuracy, validity, and reliability of data) influence calculations of performance measures, and perhaps their utility and comparability. An awareness of the challenges inherent in collecting and interpreting performance measures supports a firm understanding of how states use their performance measures and standards. National performance measures and standards may face the same contextual and data limitations and similarly may create challenges to measuring performance of modernization initiatives. While we examine the challenges and limitations of calculating performance measures that states reported to us, our own analysis also encountered the following four main challenges: 1. This is an exploratory study\u2014the first to seek any information on how states are measuring their initiatives. Our focus was on obtaining a wide range of information, which limited our ability to collect some details related to the measures. 2. Information was reported by staff in state and local SNAP offices and partner agencies during our surveys and interviews. We asked respondents what they do measure\u2014not what they can measure\u2014but some respondents nonetheless reported things they could (but do not yet) measure. In some cases, we identified their answers as prospective by clarifying aspects of their responses during interviews. However, to seek that detailed level of clarification on each measure would have required more time from the states than we could reasonably request. 3. We asked local offices how certain measures are calculated and, in instances in which they are collected for the state office, respondents gave us the best information they had available, although they may inadvertently have given us incorrect information. 4. We requested additional information about certain measures and standards from some states and localities, based on educated guesses about the measures most important to them. However, due to our need to limit the details for which we asked, we have little information on performance standards, which is reflected by the unequal treatment they receive in this chapter. We have tried to convey the information obtained in a manner consistent with how it was reported to us and to represent the information as accurately as possible, but some unexplained inconsistencies remain for exploration in more focused studies. Here we address limitations in two parts. In the first section of the chapter, we discuss the contextual limitations that impact states' use of specific performance measures and standards, including (1) the scope of initiatives, (2) system limitations, (3) terminology differences, and (4) varying measurement motivations. The second section addresses the challenges reported in collecting data for these measures and standards, including the data's accuracy, validity, and reliability. Limitations Mathematica Policy Research 26 A. Contextual Limitations State and local offices operate and implement modernization initiatives in different contexts, which influence their choice of performance measures and standards. This also affects which outcomes can be observed and complicates cross-state comparisons. Common contextual limitations include the following: Initiative Scope and Features. Initiatives differ in their size and breadth, especially whether they serve the entire state or just a region, and what services are provided through them. System Limitations. Eligibility and reporting systems are limited in their ability to capture and report measures of interest to each state. Terminology Differences. Variations in measure wording and definitions across states mean that states are measuring different performance aspects. Varying Measurement Motivations. Motivations for using measures and standards also vary across states, with some choosing measures to manage staff workloads and others setting standards to comply with legislative or other mandates. 1. Initiative Scope and Features An initiative's scope (its size, breadth, and functionality) plays a role in determining performance measures and their associated outcomes, and likewise affects the performance standards that guide an initiative. It may be misleading to compare two states' initiatives if one serves an entire state and the other serves just a local area. For instance, states that run statewide call centers may set different standards for Average Number of Calls Handled than do local call centers. Functionality also matters, as call change reporting centers may have different measures and standards than call centers through which customers call in for interviews. In this section, we highlight the variation in scope across states, by initiative, and illustrate the limitations of cross-state performance measure and standard comparisons. Call Centers. Call centers are particularly prone to comparison limitations because of the diversity of their functions and the breadth of their service areas across states. Even when call centers serve the same area, they may provide different amounts and types of services (Table III.1). Seven states reported serving multiple areas through their call center initiatives. For example, Pennsylvania has a statewide call center used in all but one county that we interviewed\u2014that county established its own regional call center. New York reported multiple call centers, some of which are county based and one is a regional call center in New York City. Service area, functionality, and the interview waivers a state may have in place all affect performance outcomes for call centers. For example, results for Average Number of Calls Handled will be different in small, mostly rural areas than in a call center covering an urban, multicounty area. In terms of service features, some call centers share a phone line that rings at multiple desks, while more complex centers have software to queue and assign calls to agents. These features impact how many people can be served, regardless of the number of staff available. Also, outcomes for measures such as Average Answer Speed will differ by call centers' service features. Phone systems' ability to route calls to specific geographic locations (such as in Pennsylvania) or the use of specialized teams to handle certain types of calls (Utah), or to suggest that clients seek services online (Arizona) also influence outcomes. Limitations Mathematica Policy Research 27 Table III.1. Variations in Reported Call Center Functions, by Call Center Reach and Number of Functions State Has Computer Phone System Transfer to Agent Tele-phone Screening Change Center Accept Change Reports Initial Application or Interview Recertification Application or Interview Number of Functions Statewide Missouri Xa 1 Louisiana Xa 1 Georgia X X 2 Delaware X X X 3 District of Columbia X X X 3 Illinois X X X 3 Nevada X X X 3 South Carolina X X X 3 West Virginia X X X X 4 Idaho X X X X 4 Iowa X X X X 4 North Carolina X a X X X X X 5 Pennsylvaniab X X X X X 5 Texas X X X X X X 6 Arizona X X X X X X X 7 Utah X X X X X X X 7 Washington X X X X X X X 7 Wisconsinc X X X X X X X 7 Regional or Local Minnesota X a X 2 Virginia X X 2 Connecticut X X X 3 California X a X X X 4 New York X X X X X 5 Massachusetts X X X X X X 6 Nebraska X a X X X X X 6 Florida X X X X X X X 7 Indiana Xa X X X X X X 7 Ohio X X X X X X X 7 Number 23 21 14 22 17 13 15 Percent of Call Centers with Functionality 82 75 50 79 61 46 54 aIndicates that the phone center is totally automated, with no option to transfer to an agent. bThe Pennsylvania state office operates a call center staffed by state staff and used in all but one county interviewed. cWisconsin has established locally-run call centers in each county office. The state and county offices collect data on the local call centers. Additionally, whether a state or locality has a waiver of face-to-face interviews and a call center that handles these interviews has an impact on the data that feed into performance measures. The time a caller waits to speak to a staff member and the length of the call may differ in states that conduct phone interviews (Arizona, Pennsylvania, Utah, and Washington) than in those that have more limited services available by phone (District of Columbia, Iowa, Nevada, and Virginia). There may be further variation among states according to the type of waiver they have in place. For example, Idaho's and Utah's call centers accept telephone applications or interviews at both initial application and recertification, while Illinois's and West Virginia's accept only recertification applications or interviews by phone. Variations in call center scope also impact performance standards. The reported performance standard for the Average Calls Handled is 40 calls per day per worker in West Virginia, where the call center provides four functions, while for Utah, the standard is within five percent of a team Limitations Mathematica Policy Research 28 average for a call center that provides seven functions. The New York City call center, which places outgoing calls only for interviews, did not report a performance standard for Average Calls Handled, but if it did, it would reflect the number of interviews it desired a worker to complete in a day, regardless of the size of the area served. Average Answer Speed standards may be impacted by scope, but not always. States and localities reported performance standards for Average Answer Speed that ranged from 95 percent of calls answered within 30 seconds in a Wisconsin local office (six service functions) to 5 minutes in South Carolina (three service functions), Washington (seven functions), and a Minnesota local office (two functions). A local Washington office reported having an informal standard of approximately 25 minutes for Average Answer Speed for people who call the office directly, to parallel the wait times experienced in the lobby. (This is separate from the state's call center and its more formal standards, as described above.) Online Systems. Service offerings through online systems also vary and affect both access and state performance and standards. Online systems, with their open access nature, vary little in their service areas, but the services states offer through this initiative do vary (Table III.2), thus affecting the aspects of performance states choose to measure and their outcomes on those measures. For example, states with integrated online screening tools may have a lower count of Number of Applications: Online each month if, before submitting their application, prospective applicants can discover that they are not eligible or will receive only a small benefit amount. The ability to submit applications online and to print applications and mail them could affect states' performance on other measures of application submission, such as Percent of Applications: Paper Submission to Local Office, and Percent of Applications: Mailed, and could increase the number of duplicate applications if people choose to submit both ways. Interpretations of online systems' outcomes across states thus should consider any variations in available services. Although few states reported setting performance standards for their online system measures, these variations in service provision also could limit the comparability of standards. Document Imaging. The services provided by a document imaging initiative, including whether some tasks are automated, affects states' choices about performance measures and standards. How SNAP offices perform document imaging tasks once the initiatives are in place also affect these measures and standards. Barcodes facilitate automated linking of images to case files in some offices but not in others, and this may affect measures of document imaging volume and speed. Where barcodes are absent or manual indexing otherwise is needed, systems setup and worker cooperation may impact performance. For example, in one Nebraska office, so many index categories exist that workers reported using just those few codes easiest to remember so they can work more quickly than if they had to look up a specific code from a list of more than 300. Measures such as Average Processing Time, Percent of Documents Imaged Same-Day, or Percent of Documents Imaged Next Business Day (the latter two measures are used in Texas) rely on dedicated staff being responsible for imaging documents, although the staff members that are responsible for these tasks vary by office and can impact the measures. Document imaging measures also are impacted by other initiatives. States that employ online systems allowing users to scan and upload their own documents online could see a decrease in the Percent of Documents Submitted through mail or fax. If this system is used heavily, less scanning would be required but indexing and attaching documents to cases still would be necessary. 29 Table III.2. Variations in Reported Online System Functions State Screener Integrated Online Screening Tool and Application Application Download and Paper Submission Online Unsigned Sub-mission Online Signed Sub- mission Application Integrated with SNAP Eligibility System Check Account History or Benefit Status Report Changes Partner Access Alaska Xa Xa Xa X Arizona X X Xa Xa X X X X X California Xa X Xa X Xa Xa X Xa Delaware X X X X X X Florida X Xa Xa Xa X X X X X Georgia X X X X X X Illinois X X X X X X Indiana X X X X X X Iowa X X X X Kansas X X X X Xa X Louisiana Xa Xa X X Xa Xa Maine X X X X X Maryland X X X X X X X X Massachusetts X Xa Xa Xa X X X Xa X Michigan X X X Xa X X X X X Missouri X Xa Xa Xa X X Montana Xa Xa Xa Xa Xa Xa Nebraska X Xa X X X X New Hampshire X X New Jersey X X X X X New York X X X Xa X X X Xa X North Carolina X Xa X Ohio Xa Xa Xa Xa Xa Xa Xa Xa Xa Oregon Xa Xa Xa Pennsylvania X X X X X Xa X X X Rhode Island X X X X South Carolina X X Texas X X X X Xa Xa Utah X X X X X X X Xa Xa Virginia X X X X X X X X Washington X Xa X Xa X X X X West Virginia X X X X X X Wisconsin X X X X X X Number 29 25 30 17 30 25 20 17 15 Percent of States with Online Systems 88 76 91 52 91 76 61 52 45 aReported at the local level only. Limitations Mathematica Policy Research 30 Kiosks. The comparability of performance measures for kiosks is particularly vulnerable to limitations based on the prevalence of these tools, as well as the availability of other initiatives designed to increase access to applications. However, of the 14 states that reported providing kiosks, most did not report measuring their performance. Partnering. Partnering initiatives vary considerably by location, even within a state (for example, partners may be clustered in urban areas rather than being spread equally around a state). This leaves the initiative's measures susceptible to comparability limitations. For example, Feeding Illinois (a core outreach partner that subcontracts with other partners, each of which reports on its performance) reported that the performance standards of its subcontracted partners vary according to their location (urban or rural) and clientele (especially ethnicity). In another instance, a Delaware partner operates a statewide prisoner re-entry program, which obviously targets a limited population of the state. Each state's partnering performance measures reflect the unique contexts in which their partners operate. The types and amounts of services partners provide also vary considerably (Table III.3), which can result in misleading performance outcomes. Partners reported providing services ranging from application assistance to hosting online systems, scanning and submitting documents, and making kiosks available. Although many partners reported some level of application assistance and outreach, the type and amount varied, ranging from helping people fill out and submit paper applications to collecting and copying verification documentation and providing ongoing case management support. For example, Utah's YWCA partner stations an eligibility worker onsite to provide application assistance to the YWCA clientele. While some partners reported providing computers for submitting online applications, few (Utah's Crossroads Urban Center, for example) monitor them to see how frequently the computers are used. The measure Percent of Partners Providing Access to Terminals\/Kiosks may reflect the availability of these machines, but not usage or accessibility. Table III.3. Sample of Partners' Service Variation in Selected States State Application Assistance SNAP- Related Outreach Call Center Online System Document Imaging Kiosks Arizona X X X X California X X X Delaware X X Florida X Illinois X X X X Indiana X X Maryland X X X Massachusetts X X X X Michigan X X Nebraska X X New York X Pennsylvania X X X X X Texas X X X Utah X X X X Washington X X X X Wisconsin X X Number 14 11 8 8 3 2 Note: Not all states have partnering arrangements, and we did not speak with every partner in each state. This table includes services that partners we interviewed reported providing. Thus, this table may under-represent the services available through partners in these states. (Alabama, Alaska, Connecticut, Georgia, Kansas, Kentucky, Maine, Minnesota, Missouri, Nevada, New Hampshire, North Carolina, Ohio, Oregon, South Carolina, Rhode Island, and Wyoming also had partnering arrangements, although we did not speak with partners in those states.) Limitations Mathematica Policy Research 31 Interview Initiatives. The cross-state comparability of performance measures for the Waiver of Face-to-Face Interview initiative is limited both by area served and services provided through that initiative. In states with this waiver, it is possible that it is implemented locally, and not throughout the state. A comparison of performance measures that track the percentage of interviews conducted face to face versus by telephone will yield different results in states where this initiative is implemented statewide versus in only a few localities. Even comparing these measures at the local level raises concerns: (1) rural areas with limited transportation may have higher rates of hardship interviews conducted by telephone, and (2) urban areas with multiple easily accessible offices may have lower rates of telephone interviews but serve more people overall. Finally, as mentioned in the call center section above, variation exists in the waivers themselves, with allowances for interviews at application, recertification, or both. Such differences may affect interview initiative outcomes just as they do call center outcomes. Very few performance standards were reported for this waiver, but any attempt to compare states' performance standards should be cautious due to the underlying regional and service variations. Application Tracking. States' ability to gauge their performance on measures of application tracking is impacted by the presence and variation of all of the initiatives discussed so far. Multiple methods for receiving applications through different initiatives affect how those applications are tracked, what states choose to measure, and where they set their performance standards. The variations in the presence of initiatives and their scope in a state limits cross-state comparisons because of the complexities involved. Controlling for regional variation and service provision for each measure would be necessary to complete a fair assessment of state performance. 2. System Limitations The efficacy of comparing performance measures across states also is impacted by the eligibility and reporting systems the states use. Respondents reported three main limitations to these systems: reporting capacity, system reliability, and capability. Each affects states differently and may be a problem for some states more than others. In this section, we discuss each of these limitations individually, rather than by modernization initiative, because each has potential impacts across initiatives and their performance measures. Reporting Capacity. Performance measures' utility may be limited by a state's reporting capacity. Some states' systems do not have the capacity to report aggregate data or generate reports that can be manipulated by users, while others only produce reports months after data were collected. These systems produce reports on performance measures that are not useful for states and local offices. Also, system-generated reports may not be formatted in a way that answers questions interesting to their readers or may not be dynamic and capable of being manipulated so users can find those answers themselves. Examples of systems that lack useful reporting capacity for states include the following: States do not all track performance measures by program. Indiana tracks the performance measure Average Waiting Time (to Speak to Agent) for all calls that come into its call center, but cannot track performance on SNAP cases versus calls for other benefits. The same is true for its online system and application tracking measures. Some measures available at a point in time are not aggregated to show trends or longer-term performance. Delaware's call center reports are not aggregated at the most useful level for their users. The system calculates Percent of Total Calls Handled based on a point-in-time data collection, but when the staff want to see these data more Limitations Mathematica Policy Research 32 broadly (for instance, for performance reviews), they must aggregate the statistic they need manually. Data may capture only one piece of a broader measure. Alaska SNAP officials reported that they can track only those clients who were approved for SNAP benefits through their food bank partners, not those that applied and were rejected. One county in Wisconsin, which is served by a regional call center, is unable to extract performance measures for itself only, limiting the county's use of any performance measures for that initiative. A local Wyoming office reported receiving aggregate data from the state that did not allow it to locate the data needed to calculate performance measures for its office. In these situations, reports may not address the questions of interest to users or may be too cumbersome to be useful. Data reporting lags also can limit effective responsiveness to performance outcomes. Minnesota's eligibility system requires manual entry before data are transferred to a warehouse. Not all data that Minnesota collects can be entered into this system because the state does not have the resources to add fields to the data warehouse. Its system can produce point-in-time reports of all pending cases by worker and the number of days pending, but not whether the application is new, repeat, or recertification; denial reason; or program. Respondents in Minnesota reported that the system also has a lag of a few months for these data, but did not explain further. System Reliability. Unreliable systems encountering periodic outages limit the usefulness of the data provided through those systems. Arizona staff described an eligibility system that stops working so frequently that caseworkers must keep back-up paper files. A Maryland partner reported a month-long server problem that kept it from logging into the eligibility system as a community partner, limiting the state's ability to track the partner's activities (the partner could assist people with applying but the activities were not credited to the partner). In one New York City office, a machine broke, forcing staff to code documents manually as they were imaged. Even when states and local areas can create manual workarounds for their unreliable systems, such changes introduce the possibility of errors in the data systems. Comparing states' performance on measures relying on data systems that fail regularly could be misleading if all the data are not captured, or are captured inaccurately. System Capacity. States all may report they are implementing an initiative, but varying system abilities can affect what states either can or choose to measure as well as how those outcomes appear, which limits performance measure comparability across states. These types of limitations may apply across all modernization initiatives, including these three examples: The West Virginia computer phone system only records information regarding calls received, requiring caseworkers to self-report outbound calls. Staff reported that this was less accurate than automated computer phone system reports. Pennsylvania's call center capability is limited because the queue capacity cuts off when 120 calls are waiting and does not allow callers into the queue after 4:15 p.m. so as to allow staff to answer all calls remaining in the queue before their workday ends. In Washington, paper applications received from partners around the state come with a barcode attached at the bottom of each so that partners' cases can be tracked and they can be reimbursed for their efforts. However, state scanners are programmed not to scan the bottom margin of the page (where the barcodes are applied), thus forcing Limitations Mathematica Policy Research 33 partners to track their application assistance manually and reconcile each missing case with the state in a process that takes two rounds of review each month to resolve. Given this lengthy reconciliation process, comparing Washington's partner performance in a recent month against that of other states could give the impression that Washington's partners submitted fewer applications than they actually did. 3. Terminology Differences An absence of standardized terminology limits cross-state performance comparisons. For example, multiple states may count the Percent of Documents Scanned, but how they define imaging and what tasks are involved in the imaging process can vary, from making an image of a document to the act of scanning a document, assigning a code, and attaching the document to the proper case. This lack of standardization reflects the differences in service provision and data system functionality, described earlier, and could hinder our ability to compare outcomes across states. Table III.4 shows the variation in how states report defining and calculating selected performance measures. While these differences often are subtle, recognizing them is crucial to accurate cross-state comparisons. Two issues emerge when examining limitations that stem from terminology differences. One is that states measure performance over different time periods (for example 12 months versus one day), which could result in different performance outcomes. The second is that some states provided general descriptions of their measures rather than precise definitions of how to calculate them. In the same way that terminology variations limit cross-state performance comparisons, they also limit cross-state comparisons of performance standards tied to the measures. This does not imply that one method of calculation is better than another, just that the differences can impact the observed values and interpretation of reported performance measures. Call Centers. Call centers vary in several ways in how they define and calculate measures, making it difficult to compare one state's performance against another without recognizing these differences. Where states seem to have similar numerators for their performance measures, differences in denominators and numbers excluded from the calculation reflect varying activities. Georgia and Pennsylvania calculate Average Answer Speed using a common numerator but use vastly different denominators and exclusions. Pennsylvania excludes abandoned calls, but these are included in the same calculation in Georgia, perhaps lowering its Average Answer Speed. Because we were able to collect only limited information about many measures, it sometimes is difficult to tell how certain data are treated from state to state. For example, we cannot always identify how abandoned calls are treated. If the state's queue times are very long, or if it provides a similar service through another avenue, its abandoned call rate could be high, thus potentially skewing the state's Average Call Duration if it includes abandoned calls either in the numerator or denominator, or excludes these calls from the calculation entirely. Broad definitions of certain measures make them particularly difficult to compare against each other. In Arizona and Georgia, for example, Average Call Duration reflects the amount of time a caseworker spends on the telephone with a person, in Indiana it includes the after-call work time spent by caseworkers, and in Pennsylvania it is a factor of all of the time staff were logged into the system and not on breaks. Thus, the results of this calculation could appear higher in states that include more activities in the definition, as in Indiana and Pennsylvania. Limitations Mathematica Policy Research 34 Table III.4. Terminology Variations for Selected Performance Measure Calculations Selected Performance Measure Calculations State Description Exclusions Call Centers Average Answer Speed Georgia Total time from start of queue to answer time divided by total number of calls. Time starts once customer is in queue at the start of greeting, and time ends when the customer comes off the queue, either by the agent picking up the phone or the customer hanging up. Noneb Pennsylvania Total accumulated time to answer for all entered calls divided by total number of calls answered by an agent or calls receiving some treatment (such as cancel, route, or transfer to a voice mailbox). Abandoned calls and queue full excluded Washington Total time calls waited in queue and ringing before an agent answered divided by all calls that get routed to the queue. Excludes abandoned and other dropped calls and direct agent calls Wisconsina Total speed of answer divided by total answered calls. Noneb Average Call Duration Arizona Total number of minutes during which the client speaks to an agent divided by total number of calls answered. Noneb Georgia Total time on the phone with a client post queue divided by total number of answered calls. Noneb Indiana Total talk time plus total after-call work time divided by total calls handled. Noneb Pennsylvania Total login time for day and talk time for the day divided by total number of calls. Time when people are not receiving calls (such as breaks) are excluded Utah Total number of minutes and seconds spent from time of answer to disconnect for all calls in the universe divided by total number of answered calls. Noneb Average After-Call Work Time by Staff Pennsylvania Total system-calculated after-call work time divided by total number of calls handled. Non-handled calls (queue full and abandoned) excluded South Carolina Total amount of time agent is in after call status (after caller hangs up) divided by total number of calls answered. Noneb Utah Total time the phone is set to \"After-Call Work\" mode divided by total number of calls resulting in after-call work. Noneb Average Calls Handled Florida Total number of calls answered divided by total number of workdays. Noneb Limitations Mathematica Policy Research Table III.4 (continued) 35 Selected Performance Measure Calculations State Description Exclusions Ohio a Total number of calls answered by staff in customer service center divided by total number of staff handling calls that day. One local office: Includes all calls: incoming, voicemail, outgoing calls, and when a worker accesses personal voicemail. One local office: Every call that comes in is recorded, including hang-ups\/voicemails. One local office: Wrong numbers and hang ups are screened out by the receptionist before they can reach the customer service center Pennsylvania Total number of calls a worker answered within an hour divided by total amount of time a worker is logged in within an hour. Dropped calls and outbound calls (if the call is dropped and the agent has to call the client back) excluded Utah Total number of calls answered from a call center queue divided by total number of agents answering calls from a call center queue. Dropped\/abandoned calls are excluded Online Systems Percent of Applications Received Massachu-setts Total number of online applications that generated an application in BEACON (the online application system) divided by total number of applications, including all sources (walk-in, mail-in, etc.). Noneb Nebraska Total number of program applications submitted online divided by total number of program applications submitted. System change in July 2010 allows for better count of paper submissions Utah Total number of applications submitted online divided by total number of applications submitted by any means. Applications for programs that closed less than 30 days prior (churners) are excluded from the denominator Percent of Applicants Who Received Help to Apply Online Florida Total number of applicants who answered survey that they needed help divided by total number of applicants who completed the survey. Applicants who chose not to take the satisfaction survey are not included New York Total facilitated e-applications divided by total SNAP applications received. Noneb Virginia Total number who reported receiving help online divided by total number submitting online applications. The calculation excludes all who do not respond to the item Limitations Mathematica Policy Research Table III.4 (continued) 36 Selected Performance Measure Calculations State Description Exclusions Document Imaging Percent of Documents Received by Fax Indiana Total number of documents shown as coming from a fax divided by total number of documents received. Noneb Utah Total number of documents received to a centralized fax line for imaging divided by total number of documents received and imaged. Noneb Interview Initiatives Percent of Interviews Conducted Face-to-Face Alaska Number of face-to-face interviews conducted in the month for approved cases divided by total number of interviews conducted for approved cases. Interviews that result in denials are not part of the performance measure Massachu-setts Total number of face-to-face interviews conducted in a period of time divided by total number of certifications\/recertifications conducted during same period. Noneb Virginia Total number of face-to-face interviews divided by total number of interviews completed. Excludes those with no interview Percent of Interviews Conducted by Telephone California Total number of interviews conducted by phone divided by total number of redetermination interviews. Noneb Michigan Total number of SNAP applications where a worker conducted a telephone interview divided by total number of all SNAP interviews. Interviews for non-SNAP applications are excluded New Mexico Total number of telephone interviews divided by the total number of interviews. Noneb West Virginia Number of cases eligible for telephone interview divided by the number of cases due for redetermination. Excludes any cases not due for redetermination. aDescription was provided by a local office in that state. bEither there are no elements excluded from the calculation, or states did not report any exclusions. Online Systems. Online systems are susceptible to the same cross-state comparison limitations due to their lack of uniform definitions and calculations. Massachusetts calculates its measure Percent of Applications Received by dividing all applications received online by all applications received through any means, but Utah excludes churners (applications from a household whose assistance case was closed less than 30 days before) from the denominator. Document Imaging. Comparing states across document imaging performance also is problematic because of the different ways states define and calculate the data for these measures. Limitations Mathematica Policy Research 37 Indiana and Utah calculate Average Number of Documents Received by Fax in similar ways, but Indiana's denominator includes only documents received, while Utah's includes documents received and imaged. If different types of documents are imaged in each office, this measure may inflate performance differences. Partnering. While states reported calculating fewer performance measures for partnering than some other initiatives, the differences in terminology around those measures still impact measure calculation. For example, the Percent of Partners Providing Application Assistance is calculated differently in three states. Florida calculates the number of partners that provide this type of assistance and divides by the total number of partners. Massachusetts calculates only the number of formal partners (excluding the informal partners that may provide the same assistance) that have submitted active applications during a particular timeframe. Rhode Island calculates the percentage of agencies in the state that provide application assistance through its web application. Across states, the types of agencies, the types of application assistance the agencies provide, and the method of providing that assistance (web applications, paper, etc.) are all variables that introduce limitations to cross-site comparisons of this measure. Interview Initiatives. Three states reported different ways of defining and calculating the Percent of Interviews Conducted Face to Face. Alaska's numerator for this measure is the number of face-to-face interviews for approved cases, excluding all denied cases. Massachusetts's numerator is the number of face-to-face interviews at initial application and recertification during a specific timeframe. Finally, Virginia looks at the number of face-to-face interviews and divides by all cases, including not just those that received telephone interviews, but also those not interviewed at all. 4. Varying Measurement Motivations States may calculate and use the same performance measures and standards, but their motivations for doing so may vary. A performance measure designed to meet a legislative mandate in one state could be calculated differently from one used primarily for staffing purposes, and any performance standards associated with those measures likely will differ as well. This is not problematic in and of itself, but it can complicate comparisons of multiple states because these varying motivations affect the priority that measures receive within an office. As one respondent said, Where you measure is where you get results. Broadly speaking, states have three main rationales for setting and calculating performance measures and standards across any initiative: (1) managing staff, (2) gauging program access, and (3) adhering to requirements dictated by lawsuits or legislative action. Performance measures are valuable tools for managing staff and workloads. Numerous local offices reported calculating and using performance measures across initiatives for staffing purposes. In call centers, measures such as the Average Call Duration, Percent of Total Calls Handled, and Average Answer Speed help staff to monitor workflow and make adjustments as needed. Offices in Nebraska, Washington, and Wisconsin use Average Call Duration for workload management purposes. In Delaware, this measure is used to identify program and technical knowledge deficits among staff. In Wisconsin, the Percent of Total Calls Handled by the Spanish-speaking eligibility worker identifies which times of day and days of week are busiest. Texas and Florida also reported using online systems measures to monitor performance because they had the potential to be more efficient than processing face-to-face or telephone applications. Wisconsin reported using several measures of document imaging for staffing purposes, including Average Processing Time and Percent of Documents Scanned. The challenge for most offices is managing staff workloads with the resources available, and the performance measures on which they focus are those from which Limitations Mathematica Policy Research 38 they tend to see useful results. This may mean that other performance outcomes suffer if they are not considered valuable. Several states and local offices reported using measures across modernization initiatives to estimate clients' accessibility to programs. A Washington office uses Average Answer Speed in its call centers to ensure that these clients do not have longer waits for service than those who walk into its centers. Florida, Pennsylvania, Washington, and Utah use the online system measures Average Number [of online applications] Submitted per Month and Number of Changes Submitted per Month to assess whether clients are using online application systems to apply for and manage their benefits. Performance on these measures is client driven, and it may be more accurate to compare states' outreach and promotion strategies for directing clients to one service or another. Performance measures and standards also can be inspired by lawsuits and legislative mandates. Indiana and Maryland track their performance on certain measures for these reasons, setting performance standards around Average Processing Time of Applications and Recertifications because of a lawsuit and court order, respectively. States involved with lawsuits and court orders may face penalties for failing to meet certain outcomes, and thus have strong incentives to ensure compliance. B. Data Limitations While contextual limitations impact cross-state analysis, the data used in these calculations also pose limits to performance evaluations and can jeopardize interpretations of individual performance measures. Performance measures are subject to three main types of data limitations: (1) accuracy, meaning whether data are entered and measures are calculated correctly; (2) validity, or whether states actually measure what they intend to measure; and (3) reliability, defined as stability of performance measures and their calculations over time. Limitations to the accuracy, validity, or reliability of measures hinder cross-state comparability and performance analyses. To gauge these limitations, we analyzed survey responses that identified limitations and asked staff for their impressions of measure accuracy. 1. Accuracy When data are used to calculate performance measures, how they are entered impacts the quality of the measure. Procedures to ensure that data are entered correctly also influence the dependability of measures. Table III.5 describes whether states and local offices entered data manually, automatically, or by both methods across an illustrative sample of performance measures. Data entered automatically are likely subject to fewer errors and subjectivity (assuming the systems automatically generating those data were programmed correctly). Overall, state and local offices often reported using automatic data entry performance measures, leading to a higher degree of accuracy. However, this tended to be true more often at the state than at the local level, where staff typically have less control over generating reports. Also, little consistency was reported between states and local offices regarding which measures use data that are entered manually versus automatically, even among initiatives with performance measures that lend themselves to automated calculations (such as call centers and Limitations Mathematica Policy Research 39 Table III.5. Selected State and Local Office Performance Measure Data Entry Methods Data Entry Method Measure Manual Automatic Both Call Center Average After-Call Work Time OH a DE, SC Average Answer Speed GA, IN, MN, a SC, UT, WA, WI, a WY Average Call Duration OH, a WI a FL, GA, NC, WI a Average Calls Handled OH, a WI a DE, NY, a SC, WI Average Hold Time IL, IN, OH, a WY Average Waiting Time WI a FL, OH, a SC, WI a Percentage of Calls Abandoned GA, IN, MN, a NE, NC, OH, a UT Percentage of Total Calls Handled OH a DE, VA, a WI a Online Systems Average Number of Accounts Created FL, MI, UT Average Number Started per Month MI, a RI, VA Average Number Submitted per Month CA, a OH a CA, a MA, PA WA a Percent of Applications Received GA a MA, UT, WA CA, a WA a Document Imaging Average Processing Time WI a MN, a NY a DE, a IN, WA, WI a Percent of Documents Received by Fax MN, a OH, a UT Percent of Documents Scanned OH a DE, a MN, a OH, a WI a WA Partnering Percent of Partners Providing Access to Terminals\/Kiosks CA a MI FL a Interview Initiatives Percent of Interviews Conducted by Telephone AK, CA, a OH, a OR, WI a CA,a DE, IL, MA WI a Percent of Interviews Conducted Face-to- Face AK, CA, a OH, a VA NM Percent that are Missed and have Notices Mailed OH, a OR CA, a VA, WI a Application Tracking Average Benefit Amount CA, MN, OH a CA, a DC, UT, WA a MT, NV, NM, NC Average Processing Time DE, a MN a Average Processing Time of Application Decision DC, KS, WA a AK, CA, a DC, RI, WA, a WI a MD Percent of Applications Approved GA, a LA, a MA, a VA a CA, a GA, a LA, a MN,a NYb AZ, CT, a GA,a MA, PA, UT, WA a aLocal office reported. bLocal and state offices reported. online systems, which tend to have data systems that automatically capture a great deal of aggregate data). These factors influenced whether staff thought their data were entered correctly. To help us identify the limitations of these measures, we asked staff to report their level of satisfaction with the accuracy of each measure. In general, respondents reported high levels of satisfaction with the accuracy of their performance measures. Out of 114 performance measures in the survey, respondents reported dissatisfaction with only 31. Some of this satisfaction may be explained by the steps in place to ensure accuracy. Part of ensuring data accuracy is instituting procedures to guarantee that data are entered correctly. In general, states and local offices reported Limitations Mathematica Policy Research 40 three types of procedures to ensure data accuracy: (1) staff training, (2) monitoring and quality assurance, and (3) built-in system prompts (Table III.6). Numerous offices reported training staff as their mechanism for ensuring data accuracy. For example, an office in Wisconsin said that it instituted a training session for call center staff on Average After-Call Work Time by Staff, because staff were not entering all data into the database that calculates this measure, resulting in inaccurate results. Several offices reported using training in conjunction with monitoring and quality control procedures to ensure accuracy. An Ohio office reported concerns that workers were taking calls but not recording them in the phone log, so it held a staff training, and taught supervisors to monitor this activity more closely. In New York, partners of one office are intensely trained on correct data entry procedures and a team of staff conduct site visits to ensure compliance. One California office created program documents to instruct staff on data entry, and its case reviewers check worker input against these regulations. If they find that the processes are not being followed, they conduct special trainings or send announcements reminding staff to follow the formal procedures. A few offices reported creating built-in system prompts for workers to ensure regular and accurate data entry. Massachusetts trains workers to use on-screen drop-down menus to indicate whether interviews are conducted over the telephone or face to face (rather than their having to remember to enter this information in a uniform way). A Wisconsin office has a similar check box but reported no special procedures or training for workers to use this feature. Pennsylvania's eligibility system generates a report on Percent of Total Applications Approved; as long as cases are entered into the eligibility system, no other human intervention is required. Rhode Island created a mandatory field in its screener to indicate which cases are eligible for expedited benefits. A Wisconsin office has a similar field in its online application system that automatically tells staff if a case is eligible for expedited benefits. New Mexico uses a web-based client tracking system to prevent multiple workers from accessing or working on more than one case at a time. All of these different system checks contribute to data accuracy but may not impact every initiative and performance measure uniformly. Call Centers. Call center measures received the highest dissatisfaction ratings among staff we surveyed, spread across nine different performance measures. Utah, Washington, and Wisconsin reported some dissatisfaction with Average After-Call Work Time because they could not determine call outcomes (which affect the amount of after-call work time), and because the measure is related directly to worker action, which is not always carried out under standardized procedure and may be prone to manipulation. For example, one office was concerned that the amount of time may be skewed by workers switching in and out of after-call work time, a manual process that relies on worker judgment. Online Systems. Most dissatisfaction with performance measure accuracy among online system measures stemmed from the ways in which systems capture and generate data. Reports of dissatisfaction with online systems were spread across six performance measures, with only seven state and local offices reporting their dissatisfaction with respect to this initiative. Massachusetts reported concern with its online system's ability to stop duplicate cases from being submitted and so was dissatisfied with its Percent of Multiple Applications measure. Document Imaging. Only one office reported not being satisfied with a document imaging measure. A local Wisconsin office said that workers forget to close out of cases, which can generate inaccurate data for the calculation of Average Processing Time. Limitations Mathematica Policy Research 41 Table III.6. Selected Reports of Methods to Ensure Data Accuracy Performance Measure Training Monitoring\/ Quality Control Built-In System Prompts Call Center Percent of Changes Processed NY, OH NY, OH Average Waiting Time (to Speak to Agent) WI Average Queue Time WI Average Calls Handled OH OH Call Response (percent of time agents are available to take calls) NC Average After-Call Work Time by Staff WI Online Systems Average Number Submitted per Month CA Document Imaging Average Processing Time NY NY Partnering Number of Partners Providing Application Assistance NY Waiver of Face-to-Face Interview Percent of Interviews Conducted by Telephone MA, NY NY MA, WI Percent of Interviews Conducted Face-to-Face MA MA Error Rate for Cases with Telephone Interviews MA MA Percentage of Interviews Conducted by Phone Without Documented Hardship Reason WI Application Tracking Percent of Agency Caused Errors AK, MD Percent of Errors where Policy Incorrectly Applied AK Average Processing Time of Application Decision CA CA Percent of Applications Approved CA CA PA Percent of Applications Approved: Online All NY NY Percentage of Applicants that Appear Eligible for Expedited Benefits RI, WI Note: As reported by a state or local office, or both. Application Tracking. Across all performance measures under application tracking, there were only eight for which states reported any dissatisfaction. These were clustered around performance measures dealing with agency-caused errors, and percents of applications denied. Respondents indicated their concern regarding the ability to determine the fault for errors and distinguish new applications from recertifications or duplicates. All of these data accuracy issues illustrate how difficult it is to ensure that high-quality data are used to calculate performance measures. If data are inaccurate, then measures are poor reflections of state performance and not good bases for comparison. While states have enacted measures to ensure the accuracy of their data, these processes vary from state to state, and even within initiative, further complicating the ability to make useful cross-site comparisons. Setting standards for these measures can create incentives for workers to perform better or force them to find workarounds that may compromise data accuracy further. Limitations Mathematica Policy Research 42 2. Validity Validity refers to whether states actually are measuring what they intend to measure, or if their measures include data they do not intend to capture. Ascertaining the validity of a measure requires a firm understanding of the data that go into each performance measure calculation, as well as the data excluded. Table III.7 shows selected state reports of performance measure validity concerns. We do not have detailed information on the concerns that states and localities have about the validity of each measure. Numerous respondents indicated validity concerns on their survey submissions without specifying the reason for their concern, and it would have been too burdensome to request this information from each respondent. Call Centers. States reported more concerns about their call centers' ability to capture what they intended to measure relative to other initiatives. This could reflect the high number of states with call center initiatives, the tendency to create more performance measures for this initiative, or could be a factor of how states perform calculations for these measures. It also may reflect some of the contextual limitations described earlier in this chapter. For example, South Carolina respondents said they were concerned about the validity of the Average Call Duration because the measure failed to consider the nature of the call, which tends to dictate its length. Overall, eight states reported validity concerns with call center measures, and some states had recurring concerns (for example, West Virginia had concerns about four measures, and Pennsylvania, Wisconsin, and Utah each had concerns about two). Online Systems. Perhaps because online system performance measures tend to be generated automatically by the systems themselves, there were fewer reports of validity concerns with these measures. The concerns reported clustered around two measures related to online applications: Average Number Started per Month and Average Number Submitted per Month. In addition, Michigan reported that the Average Number of Accounts Created per Month did not capture the number of individuals who view their own cases and thus likely underestimates the use of this function. Virginia staff were concerned with their measure of the number of online applications submitted because they thought people might be starting online applications but not submitting them that way. They also reported that, because applicants can submit applications with only a name, address, and signature, users may not get far enough into the application to indicate whether they received help to apply online. Document Imaging. States reported very few validity concerns for document imaging performance measures. Delaware expressed concern that local offices that retroactively scan in old documents and case files show better monthly performance on Percent of Documents Scanned, thus invalidating the accuracy of this measure. Partnering. Three states\u2014Massachusetts, Nebraska, and Rhode Island\u2014reported validity concerns with partnering performance measures on their survey. Although they did not report the nature of their concerns, several logical conclusions can be drawn based on what we learned about those states' circumstances. For example, the length of time the initiative has been in place and how much time the state had to create and test their measures may influence whether states reported validity concerns with partnering. Rhode Island, for instance, had implemented a new partnering arrangement that was still being reviewed when the data were reported to us. Additionally, the variety and quantity of partners in a state may introduce validity concerns for performance measures covering partnering. Massachusetts also voiced concern about the validity of partnering measures. It has both formal and informal partnership agreements, with different understandings of compensation and expected performance for each partner. Limitations Mathematica Policy Research 43 Interview Initiatives. The bulk of the validity concerns around interview initiative measures came from respondents in Ohio, although we do not know the specific nature of their concerns. It is not surprising that a state would be concerned about more than one measure for an initiative because if it doubts the data going into one calculation, that same data could impact other calculations as well. Additionally, we surveyed numerous local offices in Ohio, so this state had more opportunity to express validity concerns than other states. Also, the state initiatives are county administered and so may have atypically high within-state variation. Table III.7. Validity Concerns for Selected Performance Measures Across Initiatives Measure States with Validity Concernsa Call Center Average Call Duration PA, SC, UT, WV, WI Average Answer Speed PA, WI Average Calls Handled UT, WV Average Hold Time GA, PA, UT, WV Percent of Changes Processed DE Online Systems Average Number of Accounts Created per Month MI, UT Percent of Applicants Who Received Help to Apply Online VA Average Number (of Applications) Started Per Month FL, MA, VA Average Number (of Applications) Submitted Per Month SC, UT Document Imaging Percent of Documents Scanned DE Percent of Documents Received by Fax UT Partnering Percent of Partners Providing Access to Terminals\/Kiosks NE Percent of Partners Providing Application Assistance MA, NE Waiver of Face-to-Face Interview Error Rate for Cases with Face-to-Face Interviews and Telephone Interviews OH Percent of Interviews Conducted by Telephone OH Percent of Interviews Conducted Face-to-Face MA, OH, WI Application Tracking Percent Client Caused Errors LA Percent of Applicants that Appear Eligible for Expedited Benefits PA, UT Percent of Applications: Online MA, UT, TX Average Processing Time of Application\/Recertification Decision CA, MN, PA, UT, VA a When asked if they thought the measure truly captured the measure of performance or efficiency it was intended to measure, respondents in state or local offices indicated either no or that it had some limitations. Standards and Benchmarks. Across initiatives, most states with performance standards or benchmarks associated with their measures do think their measures reflect the aspects of program performance or efficiency they were intended to measure. However, some states think they have based performance standards or benchmarks on measures that do not truly reflect the aspects of program performance they were intended to capture. Table III.8 shows selected states and localities Limitations Mathematica Policy Research 44 that reported having benchmarks based on performance measures they viewed as having some16 validity limitations. When reviewing these data, it is important to consider that some standards and benchmarks may be informal or internal and used by local offices, not applied across the state. Some states also may set standards to motivate workers, such as those shown in Table III.8, thus tying standards to measures even though those measures are not perfect representations of what they are trying to gauge. Although we do not know why states and local offices chose to implement performance standards and benchmarks on data they felt might be invalid, the fact that they did so limits the comparability of these standards with those of states that based theirs on data they believed to be valid. Table III.8. Selected States and Localities Reporting Standards or Benchmarks on Measures Viewed as Possibly Being Invalid Measure State or Locality Standard or Benchmark Call Center Average After-Call Work Time by Staff UT 20 minutes (one local office) Average Calls Handled UT Within 5 percent of the team average for number of calls WV Minimum of 40 calls per day per worker Average Number of Calls per Case FL 1.57 calls Average Waiting Time (to Speak to Agent) WV Less than 5-7 minutes Interview Initiatives Percent of Interviews Conducted Face-to-Face WI At least 50 percent completed face-to-face Note: This illustrative sample of state or local offices reporting a benchmark on a performance measure they considered invalid does not represent every office reporting validity concerns and benchmarks. 3. Reliability Data reliability addresses the consistency of calculating performance measures over time. Reliable measures are those that have not been changed recently\u2014either in how they are defined or calculated. Changes to how performance measures are calculated or defined are not inherently bad but may indicate that a measure was not calculated in the best way prior to the change, so impairing comparability over time. Conducting cross-state comparisons when some measures are less reliable than others can over- or underestimate the difference between states in performance changes over time. Offices change their performance measure calculations for three main reasons: (1) computer system changes, (2) changing business practices, and (3) shifting programmatic requirements (Table III.9). Changes to software or computer systems can force changes in calculations. These types of system changes happened recently in part of Wisconsin, which obtained new call center software, and in Utah, when its online systems were combined across three programs. Other changes occurred because of changing business practices. Illinois's call center measures changed when a staff reduction forced the office to limit the queue capacity. Similarly, the conversion to a new office 16 States or local offices reported either some limitations or no [this does not reflect what it is intended to]. Limitations Mathematica Policy Research 45 Table III.9. Sample of Changes to Performance Measures Affecting Data Reliability State Measure(s) Change(s) in past year Call Center Illinois Average Waiting Time (to Speak to Agent) Average Hold Time Average Queue Time The measure has not changed, but a system change has affected the review of the data results. Due to a staff reduction, a business decision was made to decrease the number of calls allowed in the queue by approximately 40 percent, impacting all of these measures. Indiana Percent Calls Abandoned Some offices are converting to a new office model. For the new model, the standard will be 5 percent or less. For the old model, it was 7 percent or less. Wisconsina Number of Calls Answered\/Handled New phone system software. Wisconsina Average Time to Process Change New phone system software. Online System Utah Percent of Applications Received Average Number of Changes Submitted per Month The online system was consolidated from three applications into one. No information. Document Imaging Wisconsina Percent of Documents Scanned Developed a new scanning procedure. Partnering Massachusetts Percent of Partners Providing Application Assistance No information. Interview Initiatives Californiaa Percent of Interviews Conducted by Telephone Added a drop-down box to record how interview was conducted. Also including a place for clients to request a telephone interview. Massachusetts Percent of Interviews Conducted Face-to-Face\/by Telephone Error Rate for Cases with Telephone Interviews Now has a systematic way to collect these data and track them; used only quality control review data before. No information. Application Tracking New Mexico Average Benefit Amount Constantly changing eligibility system. Pennsylvania Percent of Community Partner Applications Approved Added a requirement that partners use online system. Before, partners also could use paper applications. An online application is easier for the state to manage. Rhode Island Average Processing Time of Application Decision Driven in part by a federal lawsuit, data are now entered up front using the application panel. aLocal office provided this information. model in some Indiana offices means an expectation of increased efficiency. In California, one office added a drop-down box to its system to capture data on rates of telephone versus face-to-face interviews. Pennsylvania began requiring partners to use their online systems to provide application assistance, thereby allowing the state to track the Percent of Community Partner Applications Limitations Mathematica Policy Research 46 Approved through the online system. Finally, shifting programmatic requirements led some offices to change their performance measure calculations. In Massachusetts, a move to reimburse partners for providing application assistance led to new calculations of the Average Cost of Partner Arrangements and the Percent of Partners Providing Application Assistance. Despite these examples, most states did not report recent changes in how they calculated their performance measures. Respondents reported two main reasons for not changing measures within the past year. The first and most common reason was that the measure or initiative was so new it had not been in place for a full year. The second was that the state or local office reported using the measure either rarely or never. C. Conclusion States implement and operate their modernization initiatives in complex circumstances unique to their areas and populations. They must carefully select performance measures and standards based on their service environment, the other initiatives in use, and their individual goals. Meaningful comparisons of performance outcomes across states require understanding the contextual and data limitations that each state faces. In this chapter, we focused on cross-state comparison limitations, but within-state variations in context and data quality also may be present. Not enough data are available from this study to systematically compare local office performance within states, but we can assume that they face similar limitations with their data. Local areas serve different populations with a special set of services, face unique system limitations, and have different reasons for measuring select aspects of performance. In addition, we uncovered instances in which state and local offices reported different methods of calculating performance measures and setting different standards. Except in states where all decisions about data entry\u2014from systems used to staff training on those systems\u2014are made at the state level and strictly followed at each local office, we can expect to see various data quality issues as well. Thus, within-state comparisons may encounter the same challenges described above. Future research could investigate within-state data variations, which might help states set common performance measures and standards using high-quality data. 47 REFERENCES Castner, Laura, Amy Wodarek O'Reilly, Kevin Conway, Maura Bardos, and Emily Sama-Miller. Performance Measures for Supplemental Nutrition Assistance Program Modernization Initiatives. Washington, DC: Mathematica Policy Research, 2012. Cody, Scott D., Ren\u00e9e Nogales, and Emily Sama Martin. Modernization of the Food Stamp Program in Florida. Washington, DC: Mathematica Policy Research, February 2008. Rowe, Gretchen, Sam Hall, Carolyn O'Brien, Nancy Pindus, Robin Koralek. Enhancing Supplemental Nutrition Assistance Program (SNAP) Certification: SNAP Modernization Efforts Interim Report Volume 1. The Urban Institute: Washington, DC, April 2010. 49 GLOSSARY Modernization Initiatives Call Center: A point of access through which individuals place a call to obtain information or some other service by listening to a recording, talking to a person, and\/or interacting with a computer. Within a state, call centers may operate statewide or regionally and place calls, receive calls, or both. Each call center may employ a different combination of functions, including answering basic questions about a program or a specific case, change reporting, screening for potential eligibility, and taking applications. Caseworkers at call centers also may process the information they receive, including faxes or reported changes. Online System: Internet sites with which individuals may access and use to submit or receive information about either their potential eligibility or existing SNAP case. (This does not include websites that provide only general information about a program.) Online systems may allow users to screen for potential eligibility, submit applications online, or check the status of\/report changes to an existing case. Some online applications integrate directly with state eligibility determination software, while others are separate tools. In some states, partners (see below) have special levels of access to the online system enabling them to serve the applicants they assist. Document Imaging: A system or a process through which states or local offices scan paper documents and create and store an electronic version for future access. Kiosks: A computer terminal located in the community or an office (but not in a home) through which an individual may access one or more functions of an online system. Partnering: Formal relationships or services that the SNAP agency solicits from nongovernmental groups. The solicitation may be in the form of a contract, memorandum of understanding, or another type of request. Waiver of Face-to-Face Interview: Formal approval received from FNS to perform interviews for application, recertification, or both by telephone rather than in person. Shortened Interviews: Use of an abbreviated interview protocol for certain types of households, based on their characteristics. Measurement Terminology Data Element: An instance of an activity or characteristic that forms the basis of aggregate data and performance measure calculations. Aggregate Data: Counts of data elements, such as the number of observations. Performance Measure: Calculation used to assess an activity, typically displayed as a percentage or average. Performance Standards: These include both standards and benchmarks. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes, while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. A.1 APPENDIX A STATE PROFILES This appendix contains, in alphabetical order, the profiles of SNAP modernization initiatives and their performance measures for the 45 states (including the District of Columbia) that participated in the study through surveys, interviews, and sharing of performance data. Each profile opens with key facts about the state: how SNAP is administered, the number and types of respondents contributing, and the initiatives active in the state. Next, we present a table that lists the performance measures and aggregate data each state or its localities or partners reported to us. Each table is arranged by modernization initiative, describing the area in which a given initiative is active, specifying whether a given measure is implemented statewide or locally, and listing the goals the state or locality is trying to attain through use of the measure. Finally, we provide any standards, benchmarks, or incentives the state or locality applies to the measure. Following the table, we supply a brief narrative, giving an overview of the initiatives active in each state to provide context for how the performance measures are implemented. In developing these appendices, we strove to report as exactly as possible what respondents had told us, within reason. For some measures, additional refinement was needed. For example, if a respondent reported on the survey that no standard was in place, but during their interview he or she described a standard, we made this update to our database and reported it in the appendix. We also renamed some measures for the sake of consistency across states. If one or more local offices in a state-administered state specified that they use a measure from reports the state office gave them, even if the state had not indicated doing so on its survey, we reported the measure as being implemented statewide. Across states, some acronyms appear frequently: \uf0b7 ARRA the American Recovery and Reinvestment Act, which provided some funds for development and implementation of new SNAP modernization initiatives in some states. \uf0b7 AVR and ARU Automated Voice Response and Automated Response Unit are two names typically given to the computer systems that run call centers; these work to answer calls and route and queue them according to an algorithm the call center establishes. \uf0b7 QC FNS Quality Control regulations and procedures that seek to maximize the accuracy and integrity of SNAP. Some responses also appear frequently, as a result of the structure of the survey we used to collect the data: \uf0b7 Not reported survey respondents did not enter any information about a question \uf0b7 No survey respondents answered no \uf0b7 Not sure survey respondent was unsure of the answer to a question \uf0b7 None no FNS goals were noted as a focus for a given measure \uf0b7 Yes, not specified survey respondent answered yes to say that a benchmark, standard, or incentive existed for a measure, but did not provide further detail A.3 Profile: Alabama State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Partnering, Waiver of Face\u2010to\u2010Face Interview, Shortened Interviews, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives PARTNERING (Statewide) Number of Applications Received per Partner Statewide Program Access, Efficiency, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent that are Missed and have Notice Mailed Locally Not reported Not reported Not reported Total Number of Interviews Locally Not reported Not reported Not reported Number of Redetermination Interviews Locally Not reported Not reported Not reported Number of Missed Interviews Locally Not reported Not reported Not reported SHORTENED INTERVIEWS (Statewide) Number of Shortened Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Percent of Community Partner Applications Approved Statewide Program Access No No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity No No Percent of Total Recertifications Approved Statewide Program Access No No Average Benefit Amount (for those eligible) Statewide None No No Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Customer Service No No Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity No No Alabama (continued) A.4 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity No No Total Number of Applications Completed Locally Not reported No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Applications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Alabama runs a demonstration in three counties, called the Elderly Simplified Application Demonstration. For this demonstration, they have a waiver for face-to-face interviews. Recently, Alabama began working with two community partners that conduct outreach and assist individuals with applying for SNAP. Alabama's computer system is at least 30 years old and can limit their ability to collect information. Measurement Goals: Alabama primarily measures performance to ensure customer service, accuracy and integrity, and program access. Call Center: Alabama does not have a call center. Online System: Alabama does not have an online system. Document Imaging: Alabama does not have a document imaging initiative in place. Kiosks: Alabama does not have kiosks available for application access and submission. Waiver of Face-to-Face Interview: Alabama has a waiver of the face-to-face interview at both application and recertification. State staff reported that Alabama's mainframe system is old and is not able to distinguish between cases that had telephone versus face-to-face interviews. Local staff reported that Alabama (continued) A.5 they track the number of clients that miss the interview and the percentage that were mailed a notice after an interview were missed. Shortened Interviews: Alabama has a shortened interview demonstration, according to state staff, but did not provide additional detail. They track the number of shortened interviews and the result of each one (benefit amount and disposition). Online Expedited Applications: Alabama does not have online expedited applications. Application Tracking: Alabama tracks a wide range of measures and aggregate data related to applications and recertifications, including the percentage completed, approved, and denied, and the average benefit of those who are approved. Administrators in state regions examine the results of the percentage of applications approved every three to six months for their particular group of counties. Their reviews may be adjusted if the county is under corrective action. Alabama also tracks the accuracy measures required by FNS. Changes Over Time: Alabama has been collecting the application measures for the last 30 years without any changes. Desired or Planned Future Measures: Alabama is currently building the capacity to measure the percentage of applications approved and the percentage denied. Staff reported that they anticipate this will provide them with information on the quality of applications received. Partnering: Alabama works with two community partners and has formal arrangements with both. One partner is paid for each submitted application. Because their computer system is so old, Alabama is unable to automatically track the number of applications submitted through the partner and can only do so manually by matching names from the partner with names in the state data. Alabama pays their second partner a fee for outreach and limited application assistance. The fee is not contingent on the number of applications submitted, so the state does not track the number submitted from this partner. Measures Collected by Partners: We did not contact either of Alabama's partners as part of this study. A.6 Profile: Alaska State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) None PARTNERING (Regionally) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Number of Telephone Interviews Statewide Program Access, Efficiency, Customer Service No No Total Number of Interviews Statewide Program Access, Efficiency, Customer Service No No Number of Face-to-Face Interviews Statewide Program Access, Efficiency, Customer Service No No Percent of Interviews Conducted by Telephone Statewide Program Access, Efficiency, Customer Service No No Percent of Interviews Conducted Face-to-Face Statewide Program Access, Efficiency, Customer Service No No Error Rate for Cases with Telephone Interviews Locally Not reported Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Locally Not reported Not reported Not reported Number of Home Visit Interviews Locally Not reported Not reported Not reported Number of Missed Interviews Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Applicants Requesting an In-Person Interview Locally Not reported Not reported Not reported Percent that are Missed and have Notice Mailed Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Average Benefit Amount (for those eligible) Statewide Program Access Not reported Not reported Alaska (continued) A.7 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Application Decision Statewide Accuracy & Integrity, Efficiency, Customer Service Performance benchmark is an average processing time of 17 days. No Percent of Applications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Percent of Total Applications Approved Locally Not reported Not reported Not reported Percent of Total Recertifications Approved Locally Not reported Not reported Not reported Number of Applications Approved: Faxed Locally Not reported Not reported Not reported Number of Recertifications Approved: Faxed Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Alaska (continued) A.8 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Faxed Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Applications: Faxed Locally Not reported Not reported Not reported Percent of Recertifications: Faxed Locally Not reported Not reported Not reported Percent of Applications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Mailed Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications: Faxed Locally Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Alaska (continued) A.9 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Complete Applications Denied Locally Not reported Not reported Not reported Percent of Complete Recertifications Denied Locally Not reported Not reported Not reported Percent of One- page\/Requests for Assistance Denied Locally Not reported Not reported Not reported Percent of Initial Applications Denied Locally Not reported Not reported Not reported Percent of Recertifications Denied Locally Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC review. The table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: In Alaska, SNAP is state-administered, and the state's administration is divided into four regional offices. According to state staff, Alaska's population is not homogenous and this complicates introducing any statewide standards. Specifically, some areas are so rural that face-to-face interviews are Alaska (continued) A.10 difficult. The state reports they are less concerned with a set standard and more concerned with appropriately meeting the needs of their diverse population. Measurement Goals: Alaska primarily measures performance to ensure customer service, accuracy and integrity, and program access. Call Center: Alaska does not have a call center. Online System: Alaska has an online screening tool, but not an online application system. There are no measures in place for this initiative. Document Imaging: Alaska does not have document imaging. Kiosks: Alaska does not have kiosks. Waiver of Face-to-Face Interview: Measures of this initiative are produced automatically in a monthly state report. Alaska primarily uses this measure as a reference point when assessing approaches to program accessibility. The local offices we interviewed reported that they look at the state-level data and reports for tracking all measures. Shortened Interviews: Alaska does not have a shortened interview initiative. Online Expedited Applications: Alaska does not have online expedited applications. Application Tracking: For the case review system, Alaska intends to start issuing monthly reports (as they had done in the past). On a monthly basis, Alaska reports and reviews the average \"cycle time,\" or the average number of days between the application submission and the application decision. Alaska does not use the results of this measure on the state level, but reported that the four regional managers and district\/local supervisors assess their performance using these data and may make changes accordingly. The state can calculate approval rates and measures, but does not currently do so. Alaska samples the required number of cases for the FNS quality control sample. The state also uses a separate case review system to track information recorded, especially about agency-caused errors, during supervisory reviews. Reviews in that system are sampled by the supervisors at will, but are not a representative sample and are not related to the QC sample. For the first few months of employment, 100 percent of a new employee's cases are reviewed by their supervisor. The case review system also includes regional reviewers and some peer reviewers. Alaska has a monthly reporting system that identifies error trends from the case review system data. Changes Over Time: Alaska used to have a case numbering system that reported statistics by caseload (the cases a single employee was responsible to manage). However, with a new business process in place, work is pooled across staff under a specific supervisor. So, Alaska's caseload number no longer refers to a particular employee, but rather to a set of employees under a specific supervisor. Partnering: There is no statewide initiative for partnering, but one local office in the state has some partnerships. Their partners have paper applications available (for all benefit types, not only SNAP) and they offer application assistance. The local office also partners with a food bank to operate a Summer Feeding Program that distributes non-perishable meals to pregnant women and children. The local office staff trains the food bank staff on safe handling of the meals and asks them to count the number of meals and snacks distributed (for food inventory purposes), but does not track any measures related to SNAP. Local staff indicated that this may progress to statewide partnering arrangements and any performance measures would be established on the state-level at that time. Measures Collected by Partners: Not applicable. Alaska (continued) A.11 Desired or Planned Future Measures: Alaska is considering several modernization initiatives, including document imaging and an integrated online eligibility and application system. State staff said an integrated online system could improve the efficiency of data collection and data entry. But, they are cautious because they believe systems and procedures that would be appropriate for another state that had a primarily urban population or a population that was very well connected with the Internet and very technologically savvy would not necessarily work in Alaska. A.12 Profile: Arizona State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 6 Number of Partners Interviewed: 4 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Waiting Time (to Speak to Agent) Statewide Program Access, Customer Service No No Average Calls Handled Statewide Accuracy & Integrity, Efficiency Yes, not specified Yes, not specified Percent of Total Calls Handled Statewide Accuracy & Integrity There is a standard on only the agent level. The incentive is for agents to reach a certain number of calls per day. Agents are ranked based on the number of calls they have per day. Staff use this ranking for performance reviews. Average Staff on Phones Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Queue Time Statewide Efficiency No No Percent of Queued Calls Handled Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls (in flow) Statewide Program Access, Customer Service Not sure Not sure Number of Calls Abandoned Statewide Program Access, Efficiency, Customer Service No No Number of Calls Queued Statewide Efficiency Not sure Not sure Number of Calls Answered\/Handled Statewide Efficiency, Customer Service Not sure Not sure Number of Agents Assigned to Phones Statewide Efficiency, Customer Service Not sure Not sure Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Program Access, Customer Service No No Arizona (continued) A.13 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Time to Process Change Statewide Accuracy & Integrity, Efficiency Staff set the standards based on a time study. This time study was part of the initial review of call centers. Staff do not look at this measure now. High performance rankings. Number of Changes Received Statewide Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Changes Processed Statewide Accuracy & Integrity, Efficiency Not sure Not sure Average Hold Time Statewide Program Access, Customer Service No No Percent Calls Abandoned Statewide Customer Service No No Average Call Duration Statewide Efficiency, Customer Service Yes, not specified Yes, not specified Number of Clients Accessing Computer Phone System Data Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Calls Received Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Hang-ups Statewide Accuracy & Integrity, Customer Service No No Number of Changes Received Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Not Completed in Computer Phone System Statewide Program Access, Customer Service No No Percent of Calls Completed in the Computer Phone System Statewide Program Access, Efficiency, Customer Service Yes, not specified Yes, not specified Percent of Changes Processed Statewide Accuracy & Integrity, Efficiency Yes, not specified Yes, not specified Number of Calls Completed in Computer Phone System Statewide Efficiency, Customer Service No No Number of Calls Transferred to Agent Statewide Program Access, Customer Service Not sure Not sure ONLINE SYSTEM (Statewide) Number of Online Screenings Started: Online Statewide Program Access No No Arizona (continued) A.14 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Online Screenings Completed: Online Statewide Program Access No No Number of Applications Started Statewide Program Access No No Number of Abandoned Applications Statewide Program Access No No DOCUMENT IMAGING (Statewide) Number of Documents Scanned Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Tasks Completed Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Alerts Processed Statewide Accuracy & Integrity, Efficiency, Customer Service No No KIOSKS (Statewide) None PARTNERING (Statewide) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None SHORTENED INTERVIEWS (Statewide) None ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Program Access, Efficiency, Customer Service No No Percent of Applications Approved: Online All Statewide Program Access, Efficiency, Customer Service No No Number of Expedited Applications Received Online Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Applications Approved: Online Expedited Statewide Program Access, Efficiency, Customer Service No No Number of Applications Approved: Online All Statewide Program Access, Efficiency, Customer Service No No Arizona (continued) A.15 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives APPLICATION TRACKING (Statewide) Average Benefit Amount (for those eligible) Statewide None No No Percent of Complete Applications Denied Statewide Program Access No No Percent of Complete Recertifications Denied Statewide Program Access No No Percent of Initial Applications Denied Statewide Program Access No No Percent of Recertifications Denied Statewide Program Access No No Number of Applications Denied: Paper Submissions to Local Office Statewide Efficiency, Customer Service No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Efficiency, Customer Service No No Number of Applications Denied: Online Statewide Efficiency, Customer Service No No Number of Recertifications Denied: Online Statewide Efficiency, Customer Service No No Percent of Applications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Total Applications Approved Statewide Customer Service No No Percent of Total Recertifications Approved Statewide Customer Service No No Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Online Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Recertifications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service N o No Average Processing Time of Application Decision Statewide Efficiency, Customer Service No No Arizona (continued) A.16 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Recertification Decision Statewide Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Arizona actively collects and reports performance measures on their modernization initiatives. All modernization efforts and performance measures are state-initiated and are standardized statewide. The state office distributes their data to local offices on a weekly and monthly basis and local offices can pull reports from the statewide mainframe system. Arizona reported that workforce management could be used to improve some data collection processes. Staff must currently compile many different reports to obtain certain performance measure data. Recently, SNAP caseloads in Arizona have increased dramatically and staffing has decreased. Based on this, some offices we interviewed reflected that they are less focused on performance measurement than handling a greater workload with fewer staff and a restricted budget. Measurement Goals: Arizona's performance measures touch on all four FNS goals. They have also designed and use performance measures to produce cost savings, increase timeliness and accuracy, track staffing needs, and for management purposes during performance reviews. Call Center: Arizona tracks numerous performance measures and sets of aggregate data through the state-run call center in Phoenix. This information is used to determine the appropriate level of call center staffing, analyze incoming call volumes, and support application activity such as change processing. Staff interviewed noted that the current system in place is inefficient and out-dated. Standards in place were developed from case studies conducted before developing the cal center. Online System: Arizona collects several sets of aggregate data that are distributed in reports for community partners and the general public. At the time of the interview, Arizona collected no performance measures on the online system. They were holding discussions to determine which performance measures to focus on, based on the measures required for the Arizona Medicaid program. One respondent interviewed noted recent problems with the transfer of information from the online system into the eligibility determination system, which may have skewed the approval\/denial rate and number of days for timeliness. They are working to resolve this issue. Partnering: Although Arizona participates in both formal (subscription based) and informal partnering arrangements, they do not track any measures under this initiative. Arizona partners help with outreach and application assistance. Some partners provide kiosks or a workspace for Department of Economic Security employees to help clients directly within the community. Measures Collected by Partners: Partners reported collecting data on the Arizona online system, the Arizona online system registration failures, percent of applications approved, percent of applications denied, and percent of applications pending. Arizona (continued) A.17 Document Imaging: Arizona collects the number of documents scanned, the number of tasks completed, and the number of alerts processed. They are working toward a more efficient document imaging system and currently have five pilot sites. Kiosks: Arizona reported the presence of two kiosks. One is part of a new initiative and is not yet widely used by the public. Rather, staff and customers have been using it together as a training start-up. A local office reported that they have a computer set up for online application submission, but it is not currently functioning. Waiver of Face-to-Face Interview: Arizona records the type of interview (face-to-face or telephone) conducted and would be able to produce ad-hoc reports, but they do not regularly track any measures under this initiative. Shortened Interviews: Arizona did not have a separate shortened interview statewide at the time of our data collection, but one local office reported they had implemented a shortened interview protocol in their area, and do not track any measures for this initiative. Online Expedited Applications: Arizona monitors approval rates for online applications and online expedited applications, as well as related aggregate data sets. Staff interviewed in one office indicated concern over the quality of these data, due to the system marking applications as expedites that are not truly expedites. Application Tracking: Arizona distinguishes between applications that were delivered online and applications that were not delivered online. Online applications can be further differentiated by their source. The general public uses a different model of the online system than partners (subscribers), who have assigned log-in information. This means the state can track partner versus non-partner applications as well as their outcomes. Arizona collects many measure related to a few areas of application tracking: approvals, accuracy, denials, and timely processing. Changes Over Time: The online application system became available to the public in 2009, and in late 2010 the state was in the process of improving the alignment between their document imaging system and the online application. Desired or Planned Future Measures: Most Arizona offices reported that they are satisfied with the performance measures they are calculating at this time. Some staff expressed an interest in seeing online application rates (by disposition) from other states in order to better understand the reasons clients are applying online and the characteristics of those applicants. Some staff are also interested in seeing performance measures and aggregate data from call centers in other states. One local office would like to see measures of case quality for individual workers (because they have no time to case read) and more detailed aggregate data on numbers of applications by their origin. A.18 Profile: California State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 4 Number of Partners Interviewed: 5 Initiatives Active in State: Call Center, Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) None ONLINE SYSTEM (Regionally) Number of Applications Downloaded Locally Not reported Not reported Not reported Number of Online Applications Submitted per Month Locally Not reported No No Number of Multiple Applications Locally Not reported No No Percent of Applicants with Hardship Reason for Requesting Phone Interviews Locally Not reported Not reported Not reported Average Level of Benefits Locally Not reported Not reported Not reported Number of First-Time Applications Denied Locally Not reported Not reported Not reported Number of Clients Requesting Help to Apply Online Locally Not reported Not reported Not reported Average Number of Changes Submitted per Month Locally Not reported Not reported Not reported Number of Changes Started Locally Not reported Not reported Not reported Number of Changes Submitted Locally Not reported Not reported Not reported Number of Applicants who did not Receive Help to Apply Online Locally Not reported Not reported Not reported Percent of Applications Received Locally Not reported No No Number of Applications Started Locally Not reported Not reported Not reported Number of First-Time Applications Approved Locally Not reported Not reported Not reported Average Number of Accounts Created per Month Locally Not reported Not reported Not reported California (continued) A.19 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Log-ins Locally Not reported Not reported Not reported Average Number of Screenings Started: Online Locally Not reported Not reported Not reported Average Number of Screenings Completed: Online Locally Not reported Not reported Not reported Percent of Users Selecting Spanish Language Locally Not reported Not reported Not reported Percent of Screenings Resulting in Application Submission: Online Locally Not reported Not reported Not reported Number of Online Screenings Started: Online Locally Not reported Not reported Not reported Number of Online Screenings Completed: Online Locally Not reported Not reported Not reported Percent of Applicants Who Received Help to Apply Online Locally Not reported Not reported Not reported Average Number Started per Month Locally Not reported No No Average Number Submitted per Month Locally Not reported No No Number of One- page\/Requests for Assistance Submitted Locally Not reported Not reported Not reported Number of Applications with Filing Date Only Locally Not reported Not reported Not reported Number of Applications Submitted With All Application Questions Answered Locally Not reported Not reported Not reported Number of Applicants who Received Help to Apply Online Locally Not reported Not reported Not reported DOCUMENT IMAGING (Regionally) Number of Documents Received Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Number of Documents Scanned Locally Not reported No No California (continued) A.20 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Amount of Days in Queue to be Indexed Locally Not reported No No Number of Documents in Error Queue Locally Not reported No No Number of Documents Pending Indexing Locally Not reported Not reported Not reported Number of Barcode Errors Locally Not reported Not reported Not reported Number of Queues with Over 1,000 Documents Locally Not reported Not reported Not reported PARTNERING (Regionally) Percent of Partners Providing Application Assistance Locally Not reported Not reported Not reported Number of Partners Locally Not reported Not reported Not reported Number Accepting Applications Locally Not reported Not reported Not reported Number Providing Application Assistance Locally Not reported Not reported Not reported Number Clients Assisted per Partner Locally Not reported Not reported Not reported Number of Applications Received per Partner Locally Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Regionally) Number of Redetermination Interviews Locally Not reported Not reported Not reported Number of Face-to-Face Interviews Locally Not reported Not reported Not reported Number of Telephone Interviews Locally Not reported Not reported Not reported Percent of Interviews Conducted by Telephone Locally Not reported No No Percent of Interviews Conducted Face-to-Face Locally Not reported No No Percent of Telephone Interview Requests Honored Locally Not reported Not reported Not reported Total Number of Interviews Locally Not reported Not reported Not reported Number of Home Visit Interviews Locally Not reported Not reported Not reported California (continued) A.21 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Missed Interviews Locally Not reported Not reported Not reported Notice of Missed Interview Mailed Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Applicants Requesting an In-Person Interview Locally Not reported Not reported Not reported Number of Applicants who Did Not Answer to Type of Interview Requested Locally Not reported Not reported Not reported Percent that are Missed and have Notice Mailed Locally Not reported No No ONLINE EXPEDITED APPLICATIONS (Regionally) Percent of Applications Approved: Online Expedited Locally Not reported Not reported Not reported Percent of Applications Approved: Online All Locally Not reported Not reported Not reported Number of Applications Approved: Online All Locally Not reported Not reported Not reported Number of Expedited Applications Received Online Locally Not reported Not reported Not reported Number of Applications Approved: Online Expedited Locally Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide None No No Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Online Locally Not reported Not reported Not reported California (continued) A.22 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Faxed Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Percent of Online Recertifications Approved Locally Not reported Not reported Not reported Number of Recertifications Approved: Online Locally Not reported Not reported Not reported Number of Applications Approved: Faxed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Approved: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Percent of Online Applications Approved Locally Not reported Not reported Not reported Percent of Applications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported California (continued) A.23 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Community Partner Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Applications Denied: Online Locally Not reported Not reported Not reported Percent of Online Recertifications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported Number of Recertifications Denied: Online Locally Not reported Not reported Not reported Percent of Online Applications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported California (continued) A.24 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of One- page\/Requests for Assistance Denied Locally Not reported Not reported Not reported Number of Applications Denied: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Denied: Community Partner Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Total Number of Applications Completed Statewide Program Access, Efficiency, Customer Service Not reported No Total Number of Applications To Be Processed Statewide Program Access, Efficiency, Customer Service Not reported No Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Online Locally Not reported Not reported Not reported Percent of Applications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Applications: Faxed Locally Not reported Not reported Not reported Number of Recertifications: Faxed Locally Not reported Not reported Not reported California (continued) A.25 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Percent of Applications: Online Locally Not reported No No Number of Applications: Online Locally Not reported Not reported Not reported Percent of Recertifications: Community Partner Locally Not reported Not reported Not reported Percent of Applications: Faxed Locally Not reported Not reported Not reported Percent of Recertifications: Faxed Locally Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Online Locally Not reported Not reported Not reported Number of Applications: Community Partner Locally Not reported Not reported Not reported Number of Recertifications: Community Partner Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Applications: Community Partner Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported California (continued) A.26 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications Approved Timely Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service State: All applications should be approved timelyLocal: Internal performance measures track whether individual workers approve 90 to 95 percent of applications timely. No Percent of Recertifications Approved Timely Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service All recertifications should be approved timely No Average Processing Time of Application Decision Locally Not reported Within 15 days\u2014applies to all applications. No Average Processing Time of Recertification Decision Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: California counties are responsible for administering SNAP with state oversight (typically, counties work in consortia to purchase and maintain eligibility systems). As a result, modernization and measurement are implemented variably across the state. The state office collects reports from the counties on the status of their application and recertification processes. It also allocates funding to the counties for its major initiatives. California local offices have faced a few challenges with capturing and reporting data accurately during the development and refinement of their systems. Offices facing these problems have addressed them through system reprogramming or manual data counts. Measurement Goals: A few of California's performance measures touch on all FNS goals for modernization. Counties also pursued performance measurement in order to: meet FNS and grant requirements, meet a legal services agreement, identify trends, maximize programs, measure the success of outreach efforts, determine needed staff and equipment, and track the outreach provided. California (continued) A.27 Call Center: The state office reported that, while there is no statewide call center, some county offices have call centers of their own. However, none of the county offices we interviewed for the study had a call center in place. Online System: The presence or absence of an online application system varies by county. Each consortium with an online application has its own vendor to operate it. As such, functionality of the system and the measures collected differ among offices. All California local offices surveyed that have an online application system track the percent of total applications received online. Document Imaging: A few California local offices we interviewed have established document imaging. These offices track aggregate data only. Kiosks: Neither the state nor local offices interviewed have implemented kiosks. Waiver of Face-to-Face Interview: Two California counties interviewed have a waiver of face-to- face interviews in place. They both track performance measures and data on the volume and type of interview provided (telephone interview or face-to-face interview) and on notices of missed interviews. Shortened Interviews: No counties participating in the study have implemented a shortened interview process. Online Expedited Applications: Some California county offices interviewed review the percentage and the number of online expedited applications approved. County offices report the number of expedited applications processed to the state office on a quarterly basis. Further reporting capabilities, such as summarizing demographic or other characteristics of online expedited applications, vary by county. Application Tracking: State staff reported that application tracking typically occurs at the local level, as no applications are delivered to the state office. Most local offices responding to the survey focus on application accuracy, application approvals\/denials, and application receipt (though other areas of application tracking are monitored by some local offices). Changes Over Time: Some counties reported they have redesigned or implemented new initiatives within the past ten years, such as a call center, document imaging, or an online application system. They are working on developing data and adding measures or reports. Desired or Planned Future Measures: State and local offices expressed a desire to collect more information. Specifically, they would like to track: percent of applications approved and denied (by online versus paper submission), accuracy measures on phone versus face-to-face recertifications, measures that compare the current approval rate of recertifications to the rate prior to the implementation of a waiver of face-to-face interviews, number of people completing their Partnering: California's partners work on outreach, screening, and application assistance. Some partners operate under an interagency agreement (M.O.U.) with the California Department of Public Health, and some partners are compensated for their services. One office we surveyed has specified standards on the number of applications and screenings their partner must meet per month. Two local offices we surveyed reported that they collect performance data on partnerships. They monitor data, such as the percent of partners providing application assistance and some aggregate data. Measures Collected by Partners: One county we surveyed stated that the purpose of tracking performance measure data for their partnering initiative is to provide the data to their partner. The county provides the partner the information required to submit grant applications and the partner provides the county with the number of applicants they assisted. Another county's partner also tracks the number of applications submitted to the county office. Partners also collect numerous measures on outreach, trainings, volume and efficiency of application assistance. California (continued) A.28 recertification, number of people submitting their quarterly report online, number of abandoned applications, number of people submitting their application from a particular screen of the online application, and additional data on the online application system. A.29 Profile: Connecticut State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) None PARTNERING (Statewide) Number of Partners Statewide Program Access, Customer Service No No Number Accepting Applications Statewide Program Access, Customer Service No No Number Providing Application Assistance Statewide Program Access, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity, Efficiency Customer Service No No Number of Overdue Applications Statewide Program Access, Accuracy & Integrity, Efficiency Customer Service As few untimely as possible Not sure Applications Process Time 0-7 days Statewide Program Access, Accuracy & Integrity, Efficiency Customer Service FNS standards for timeliness Not sure Applications Process Time 8-29 days Statewide Program Access, Accuracy & Integrity, Efficiency Customer Service FNS standards for timeliness Not sure Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency Customer Service No No Percent of Total Recertifications Approved Locally Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Connecticut (continued) A.30 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Not reported No No Percent of Complete Recertifications Denied Locally Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Percent of Unexcused Applications Overdue at End of Month Statewide Not reported No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Connecticut (continued) A.31 Description: General: In Connecticut, SNAP operates through 12 regional offices and 3 partners, with state-level contracts that work primarily on the local level. Their computer system is 37 years old, and staff noted that it has caused problems. One local respondent reported issues and concerns with accurate and timely reports. One main issue is that the system cannot function in real-time. For example, the computer system does not record actions taken the same day, such as a client who applies and is determined eligible on the same day. Such immediate actions are thus not reflected on the monthly reports. Local offices we spoke with look at many application tracking measures that are not calculated at the local level, but rather are provided in state data and reports. Measurement Goals: Connecticut measures performance with a focus on all four FNS goals. Call Center: One local office in Connecticut runs a call center, which does screening and conducts interviews over the phone as well as processing faxes and applications and returning client calls. No data or measures are being tracked for the call center, however, according to the local office that runs it. Online System: Connecticut does not have an online application system. Document Imaging: Connecticut does not have a document imaging initiative in place. Kiosks: Connecticut does not provide kiosks for application access and submission. Waiver of Face-to-Face Interview: Connecticut has a waiver for face-to-face interviews, but the offices we surveyed do not collect measures or track performance. Staff record the interview type in the case notes narrative, but not in a trackable data field. Shortened Interviews: Connecticut does not have a shortened interview initiative. Online Expedited Applications: Connecticut does not have online expedited applications. Application Tracking: Connecticut tracks a number of measures and aggregate data related to applications and recertifications, including the percentage of total applications approved and the average benefit of those who are approved. State staff reported that aggregate application data are tracked, but specific information that would allow the state to break that information down is not tracked. QC reviews are done in accordance with FNS regulations. Connecticut had weekly calls among staff to discuss QC problems. In late 2008, these meetings were discontinued due to a shortage of QC reviewers. They planned to reinstate these calls beginning in December 2010. Changes Over Time: The same state computer system has been used since 1984. Desired or Planned Future Measures: At the time of our study, Connecticut was negotiating with a vendor to purchase an Online Application System, Automated Voice Response Centers, Call Centers, and Document Imaging technology. Partnering: Connecticut has formal arrangements with each of its three community partners. The state does not collect any performance measures for their partners, nor do they require the partners to collect any data. The state respondent thought some partners may collect their own data, used for their own purposes. One local office said that partners are compensated, but the state did not provide further information on compensation. Partners are responsible for SNAP outreach. They accept applications and forward the applications on to the agency. They also do SNAP education and nutrition education. Outreach contractors also answer applicant question. Measures Collected by Partners: We did not contact any of Connecticut's partners as part of this study. A.32 Profile: Delaware State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 1 Initiatives Active in State: Call Center, Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Program Access, Efficiency, Customer Service No If an individual's speed is consistently below peers, they form a performance improvement plan with corrective action steps. Average Hold Time Statewide Program Access, Efficiency, Customer Service It is compared to the unit and worker average. The rate is used in individual performance reviews. Excessive hold time is an indication of staff lack of knowledge or lack of attention to the caller. Percent Calls Abandoned Statewide Efficiency, Customer Service No Not sure Average Call Duration Statewide Efficiency, Customer Service Individual average call duration is compared to the average for staff in the unit. Staff who consistently spend a large amount of time on the majority of their calls may have this addressed in their performance review if improvement s are not made after supervisory intervention. Average Waiting Time (to Speak to Agent) Statewide Program Access, Efficiency, Customer Service No No Delaware (continued) A.33 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Calls Handled Statewide Efficiency No Staff who consistently have low or high averages will have this data discussed in their performance reviews and conferences. Individuals who consistently perform below their unit average will have corrective action measures imposed through a performance improvement plan. Percent of Total Calls Handled Statewide Efficiency No No Percent of Changes Processed Statewide Program Access, Accuracy & Integrity, Customer Service Not sure Not sure Average Staff on Phones Statewide Efficiency No No Average Queue Time Statewide Program Access No No Average After-Call Work Time by Staff Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls (in flow) Statewide Program Access, Efficiency, Customer Service No Not sure Number of Calls Abandoned Statewide Program Access, Efficiency, Customer Service Not sure No Number of Calls Queued Statewide Program Access, Customer Service Not sure No Number of Calls Answered\/Handled Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Agents Assigned to Phones Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure No Number of Calls Received Statewide Program Access, Customer Service No No Number of Changes Completed Statewide Not reported Not reported Not reported Delaware (continued) A.34 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Time to De- Queue Statewide Not reported Not reported Not reported Percent of Queued Calls Handled Statewide Not reported Not reported Not reported Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Not reported Not reported Not reported Percent of Calls Completed in the Computer Phone System Statewide Not reported Not reported Not reported Average Number of Calls per Case Statewide Not reported Not reported Not reported Average Time to Process Change Statewide Not reported Not reported Not reported Number of Clients Accessing Computer Phone System Data Statewide Not reported Not reported Not reported Number of Changes Received Statewide Not reported Not reported Not reported Number of Changes Processed Statewide Not reported Not reported Not reported Number of Calls Not Completed in Computer Phone System Statewide Not reported Not reported Not reported Number of Calls Completed in Computer Phone System Statewide Not reported Not reported Not reported Number of Client Calls Returned Statewide Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Number of Online Screenings Completed: Online Statewide Program Access, Efficiency, Customer Service No No Number of Online Applications Submitted Statewide Not provided No No Number of One- page\/Requests for Assistance Submitted Statewide Program Access, Efficiency, Customer Service No No DOCUMENT IMAGING (Statewide) Number of Documents Tagged to a Case Statewide Not reported No No Number Indexed for a Document Type Statewide Not reported No No Delaware (continued) A.35 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Documents Scanned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Processing Time Locally Not reported No No Time Between Scanning and Tagging Locally Not reported Not reported Not reported Time Between Scanning and Indexing Locally Not reported Not reported Not reported Number of Documents Received Statewide Not reported Not reported Not reported Number of Alerts Processed Statewide Not reported Not reported Not reported Percent of Documents Scanned Statewide Not reported No No Number of Documents Processed Statewide Not reported Not reported Not reported Number of Documents Received: Mail Statewide Not reported Not reported Not reported Number of Documents Received: Fax Statewide Not reported Not reported Not reported Number of Documents Received: Other Electronic Statewide Not reported Not reported Not reported Number of Tasks Completed Statewide Not reported Not reported Not reported PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Not reported Not reported Not reported Average Cost of Partner Arrangement Statewide Not reported Not reported Not reported Number of Partners Statewide Not reported Not reported Not reported Number of Applications Received per Partner Statewide Not reported Not reported Not reported Number Accepting Applications Locally Not reported Not reported Not reported Number Providing Application Assistance Locally Not reported Not reported Not reported Number of Clients Assisted Locally Not reported Not reported Not reported Number of Applications Completed Locally Not reported Not reported Not reported Delaware (continued) A.36 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access, Efficiency, Customer Service No No Percent of Interviews Conducted Face-to-Face Statewide Program Access, Efficiency, Customer Service No No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity, Efficiency, Customer Service No No Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity, Customer Service No No Total Number of Interviews Statewide Program Access, Efficiency, Customer Service Not sure Staff who have a lower than average number of interviews that result in an eligibility determinatio n are counseled and possibly put on an improvement plan. Number of Redetermination Interviews Statewide Program Access, Efficiency, Customer Service Not sure Staff with high performance are recognized at recognition events. Staff with low performance are counseled and may be put on a performance improvement plan. Number of Face-to-Face Interviews Statewide Not reported Not reported Not reported Number of Telephone Interviews Statewide Not reported Not reported Not reported Number of Missed Interviews Statewide Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported Delaware (continued) A.37 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications Approved: Online All Statewide Not reported Not reported Not reported Number of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported Number of Expedited Applications Received Online Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Number of Applications Approved Statewide Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Percent of Community Partner Applications Approved Locally Not reported Not reported Not reported Percent of Community Partner Recertifications Approved Locally Not reported Not reported Not reported Percent of Total Applications Approved Locally Not reported Not reported Not reported Percent of Total Recertifications Approved Locally Not reported Not reported Not reported Average Benefit Amount (for those eligible) Locally Not reported Not reported Not reported Number of Applications Approved: Community Partner Locally Not reported Not reported Not reported Number of Recertifications Approved: Community Partner Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Delaware (continued) A.38 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Total Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Recertifications Started Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Not reported Not reported Not reported Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Number of Applications: Online Statewide Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Number of Applications: Community Partner Locally Not reported Not reported Not reported Number of Recertifications: Community Partner Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Applications Denied Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Locally Not reported Not reported Not reported Percent of Complete Recertifications Denied Locally Not reported Not reported Not reported Percent of Initial Applications Denied Locally Not reported Not reported Not reported Percent of Recertifications Denied Locally Not reported Not reported Not reported Number of Recertifications Denied: Community Partner Locally Not reported Not reported Not reported Delaware (continued) A.39 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Applications Denied: Community Partner Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Number of Cases Withdrawn Statewide Not reported Not reported Not reported Number of Cases Pending Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. General: The Delaware state office collects most of the performance data on its modernization efforts, which are all state-initiated. The state distributes reports to local offices. Local offices we interviewed also collect some measures in-house, particularly for application tracking. Respondents seemed satisfied overall with their data collection and calculation. One local office reported some software and equipment issues, but not all of these impact their performance measurement. Measurement Goals: Delaware's performance measures touch on all four FNS goals. They also use their data to assess worker performance, manage backlog, and for staffing purposes. Call Center: Delaware collects numerous measures and counts of data through their call center phone system. Unless otherwise noted in the table, the measures are calculated automatically by the Delaware (continued) A.40 phone system. There is one call center for the entire state. The data are stored and collected locally. When assessing performance, staff reported Delaware is less concerned with measures and more concerned with data, such as the number of calls and the number of calls abandoned. Delaware's call center handles changes for five different programs including SNAP. They are not able to break out call center data by program. Online System: Delaware has one statewide online application system. The state office records the number of online screenings completed, the number of online applications submitted, and the number of one-page\/requests for assistance submitted. Delaware watches the volume of people using the online system (in terms of the number of applications submitted) in particular, in order to ensure that the system is not backlogged with unprocessed cases. Document Imaging: In Delaware, documents are uploaded into the state run information system. The imaging system calculates the number of scanned documents. Data are entered directly into the system, which can be accessed statewide. Any item scanned is considered a document. Delaware tracks both performance measures and aggregate data, including the percent of documents scanned, number of documents tagged to a case, number indexed for a document type, and number of documents scanned. One local office reported that the computer reporting system associated with the scanner allows them also to track the average processing time, number of documents received, number of documents processed, and number of alerts processed. Kiosks: Delaware has not set up any kiosks. Waiver of Face-to-Face Interview: Delaware tracks measures on percent of interviews conducted by type (telephone versus face-to-face) and error rate by type (telephone versus face-to- face). They also collect aggregate data on the total number of interviews and redetermination interviews. Delaware can pull ad hoc reports on the application decision by type of interview. Currently, they only review that information at the end of the year. For every household, Delaware also captures whether there is an elderly member. Staff reported that theoretically, Delaware could examine case characteristics by interview type. However, the state does not pull these data regularly. Shortened Interviews: Delaware does not have a separate shortened interview. Online Expedited Applications: While the state did not report performance data on online expedited applications, both local offices interviewed reported that some measures and data are available to them, such as: percent of applications approved (online expedited and online all), number of online expedited applications approved, and number of expedited applications received online. Application Tracking: Delaware state and local offices collect a wide range of application tracking information, including data on application accuracy, approvals and denials, application processing and case characteristics, and application receipt. The eligibility system produces automated tallies for all application tracking aggregate data. While the state records the origin of Partnering: Delaware partners with multiple organizations at the state and county levels. The state does not collect any measures or data on their partners. One local office tracks aggregate data, such as the number of partners accepting applications, number of applications received per partner, and number of partners providing applications assistance. Measures Collected by Partners: One partner we interviewed collects aggregate counts of applications approved, applications denied, and applications submitted. Delaware (continued) A.41 applications that were delivered by partner or online, one local office interviewed also differentiates applications that were faxed in or delivered to the office in person. One local office noted issues with the date stamp on the computer system. If a client is already enrolled in one program, and wants to add another program, the system backdates all forms and verifications to the original program. When the local office runs any reports dealing with pending applications, the system will generate the number of days pending from the original application date, not the program add on date. This occurs rarely, and staff is aware of this system glitch. Changes Over Time: Delaware has not made any recent changes to the way they collect or calculate their performance data. One local office recently transitioned to a new process management model of business, wherein staff are divided into teams that handle specific tasks (answer phones, scan, intake, redeterminations, etc.). At the time of the interview, this office was in the process of measuring the efficiencies of the new system and working with other areas to create a standardized reporting system by February or March 2011. This system will include Excel spreadsheets that calculate performance measures for supervisors' use. Another local office discussed a new state initiative to synchronize reporting for all programs administered through the Department of Social Services, with the goal of limiting the need for clients to visit the office in person. Desired or Planned Future Measures: Call center workers handle five different programs including SNAP. Delaware would like to track how many calls relate to each program. When setting up the phone system, Delaware was unable to identify an easy and accurate way to automate this function. The state would also like to track client time in the office prior to the interview and time before benefits were issued. Right now, these can only be tracked manually. Staff interviewed reported that this calculation would allow Delaware to see which offices or staff are most efficient and which need coaching in terms of workload management. One local office expressed an interest reviewing a larger sample of cases for payment accuracy and case error rates. Currently, supervisors review 10 to 30 cases per worker each quarter. In addition, cases are reviewed for all targeted workers (either new workers or workers that have had issues in the past). A.42 Profile: District of Columbia State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 1 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Shortened Interviews, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls (in flow) Statewide Not reported No No Number of Calls Abandoned Statewide Not reported No No Number of Calls Queued Statewide Not reported No No SHORTENED INTERVIEWS (Statewide) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Accuracy & Integrity, Efficiency No No Percent of Applications Not Completed Statewide Accuracy & Integrity No No Percent of Applications: Paper Submission to Local Office Statewide Program Access No No Percent of Recertifications: Paper Submission to Local Office Statewide Program Access No No Total Number of Applications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency No No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency No No District of Columbia (continued) A.43 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency No No Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency No No Number of Applications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity No No Percent of Applications with Incomplete Information Statewide Accuracy & Integrity No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Cases with Complete Verification Submitted Statewide Program Access, Accuracy & Integrity No No Average Timeliness Rate: Approvals Statewide Program Access, Accuracy & Integrity No No Average Timeliness Rate: Recertifications Statewide Program Access, Accuracy & Integrity No No Notes: State collects mandatory accuracy data through QC reviews Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: The District of Columbia has two modernization initiatives and is not actively using performance measures for many purposes other than those required by FNS. The District has received a waiver of the face-to-face interview from FNS but has not yet implemented it. In order to implement the waiver, the District must first expand its call center. They do not yet know which performance measures will be tracked. However, they will track whether the interviewee is an English-language Learner in order to meet local reporting requirements. Measurement Goals: The District's performance measures touch on all four FNS goals. Call Center: The call center is run through the District. There is no performance measurement by the service center currently. When expanded, the call center will operate within the District's Enterprise Call Center. According to staff we interviewed, the District could make improvements in its modernization and performance measurement activities with additional employees. Although they did receive District of Columbia (continued) A.44 emergency funding for administrative purposes, that funding is only for a year. Ramping up the call center will require 6 months, although efficiencies may not be seen for 24 months. Online System: The District has not implemented an online system. Document Imaging: At the time of interview, the District had not yet implemented a document imaging system. Staff reported that the launch was planned for January 2011. Kiosks: The District does not have kiosks. Waiver of Face-to-Face Interview: The District has not yet implemented the waiver of the face-to-face interview. Shortened Interviews: The District reported that they use shortened interviews, but did not provide additional detail on this initiative (beyond noting that there are no measures associated with it). Online Expedited Applications: The District does not have online expedited applications. Application Tracking: The District can track which local office received the application, but not whether the application was received by mail, fax, or in person. Because they have not yet implemented the waiver of the face-to-face interview, nearly all applicants physically bring their applications to a service center. Changes Over Time: The launch of the District's document imaging system was planned for January 2011. They were testing the system's indexing function. They contracted with a vendor to complete the necessary back-scanning of documents. They do not anticipate recording the source of the documentation (mail, fax, etc.); however, they plan to track whether documents are indexed correctly and scanned timely. Indexing will track the document type, such as application, birth certificate, and so on. Document imaging will eventually be integrated with the case management system. Desired or Planned Future Measures: Although the District does not have additional measures in mind, staff reported that they would like to do more with the measures they have. Specifically, staff would like to be able to manipulate current measures more easily by breaking down by service center, worker, supervisor, and do on. The District currently has that data but cannot manipulate them in its current system. According to staff we interviewed, they have seen a significant spike in applications, and the necessary modernization to efficiently handle those caseloads requires significant upfront costs. Partnering: The District of Columbia does not have a formal initiative for partnering. Survey respondents speculated that some informal community partners might provide outreach or application assistance. Measures Collected by Partners: We did not contact any informal partners as part of this study. A.45 Profile: Florida State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 3 Number of Partners Interviewed: 1 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Percent of Agents Assigned to Phones Available to Take Calls Statewide Not reported 77 percent No Number of Calls (in flow) Statewide Program Access No No Number of Calls Abandoned Statewide Program Access No No Number of Calls Answered\/Handled Statewide Customer Service 65 calls per agent per day Meeting standards is part of call agents' performance appraisal Number of Agents Assigned to Phones Statewide Customer Service 276 agents No Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Customer Service 54 busy and incomplete calls No Average Answer Speed Statewide Efficiency, Customer Service 3 minutes No Percent Calls Abandoned Statewide Program Access, Customer Service 12 percent No Average Call Duration Statewide Efficiency 6 minutes 40 seconds No Average Calls Handled Statewide Program Access, Efficiency, Customer Service 60 times average staff on the phones No Percent of Total Calls Handled Statewide Program Access, Efficiency, Customer Service 88 percent No Average Staff on Phones Statewide Program Access, Efficiency, Customer Service 276 No Average Time Prior to Abandonment Statewide Program Access, Efficiency, Customer Service No No Number of Changes Received Statewide None No Not reported Number of Changes Processed Statewide Efficiency 26 changes completed per day per worker Yes, not specified Average Number of Calls per Case Statewide Program Access 1.57 (July 2010) Not reported Florida (continued) A.46 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Changes Processed Statewide None No No Average Time to Process Change Statewide Program Access 10 days No Average Waiting Time (to Speak to Agent) Statewide Not reported No No Number of Clients Accessing Computer Phone System Data Statewide Program Access No No Number of Calls Received Statewide Program Access No No Number of Hang-ups Statewide None No No Number of Changes Processed Statewide Efficiency Not reported Not reported Percent of Calls Requesting Agent Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 66 percent No Number of Calls Completed in Computer Phone System Statewide Accuracy & Integrity No Not reported Number of Calls Transferred to Agent Statewide Accuracy & Integrity Not reported Not reported ONLINE SYSTEM (Statewide) Average Number of Screenings Completed: Online Statewide Program Access No No Number of Online Screenings Completed: Online Statewide Program Access No No Percent of Applicants Who Received Help to Apply Online Statewide Program Access No No Percent Reporting Easy Experience to Complete Application Statewide Program Access, Customer Service No No Percent Who Would Use Again Statewide Program Access, Customer Service No No Percent of Applications Received Statewide Not reported Not reported Not reported Average Number Started per Month Statewide Program Access No No Average Number Submitted per Month Statewide Program Access No No Florida (continued) A.47 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Started Statewide Program Access No No Number of Clients Requesting Help to Apply Online Statewide Program Access, Customer Service No No Number of Applicants who Received Help to Apply Online Statewide Program Access, Customer Service No No Average Number of Log- ins per Month Statewide Program Access, Efficiency No No Average Number of Accounts Created per Month Statewide Program Access, Customer Service Not reported No Average Number of Changes Submitted per Month Statewide Efficiency, Customer Service No No Number of Online Accounts Created Statewide Program Access, Efficiency No No Number of Log-ins Statewide Program Access, Efficiency No No Number of Changes Submitted Statewide Efficiency No No DOCUMENT IMAGING (Statewide) Number of Documents Scanned Statewide None No No KIOSKS (Statewide) None PARTNERING (Statewide) Percent of Partners Providing Access to Terminals\/Kiosks Statewide Not reported All level two and three partners provide assistance No Percent of Partners Providing Application Assistance Statewide Not reported Level two and three partners are expected to meet certain benchmarks Not reported Number of Partners Statewide Program Access, Customer Service Not reported Not reported Number Accepting Applications Statewide Program Access, Customer Service Not reported Not reported Number Providing Application Assistance Statewide Program Access, Customer Service Not reported Not reported Florida (continued) A.48 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number with Terminals\/Kiosks to Submit Application Statewide Program Access, Customer Service Not reported Not reported Number of Applications Received per Partner Statewide Program Access, Customer Service No No Average Cost of Partner Arrangement Statewide Not reported Not reported Not reported Number Clients Assisted per Partner Statewide Program Access, Customer Service Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None SHORTENED INTERVIEWS (Statewide) None ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online All Statewide Efficiency 96 percent No Number of Expedited Applications Received Online Statewide None Not reported Not reported Number of Applications Approved: Online Expedited Statewide Efficiency No No Number of Applications Approved: Online All Statewide Efficiency No No APPLICATION TRACKING (Statewide) Percent of Applications: Online Statewide Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Statewide Program Access No No Average Processing Time of Approvals (Application and recertifications combined) Statewide Efficiency FNS 7- or 30- day standard No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. ARU = Automated Response Unit Florida (continued) A.49 Description: General: Florida was one of the first states to launch many of the initiatives examined here. From 2004 to 2006, they implemented changes through an effort known as Automated Community Connection to Economic Self-Sufficiency or ACCESS Florida. They restructured how applications were processed by having staff specialize in certain tasks, so that many individuals were involved in the processing of a case, and an applicant no longer worked with a single case worker. They screened applicants to identify those at low-risk for errors and conducted shortened interviews with those individuals. They began using online applications, developed internally, and provided kiosks, copiers, and fax machines in the local offices for applicants to access and submit information electronically. They also developed four call centers through which participants could report changes and ask questions about their case\u2014some questions can be answered through the automated response unit; others require transferring to a live agent. They also implemented document imaging and maintain all cases electronically so any worker can access information about any client. Florida continues to upgrade their systems\u2014they are continually moving toward a more automated system of transferring data from the online application to the eligibility system. Through customer surveys of individuals calling the call center, they identify questions that are commonly asked and try to provide better information about that issue to clients. They also identify phone numbers of individuals that commonly call the call center (screening out partners and other agencies that would be likely to have a high call volume) and call the individual to identify the issue that leads them to call often. If possible, they try to find a more automated way to address issues identified by the high-volume callers. Measurement Goals: Having had the initiatives in place for such a long period of time, Florida's measurement focus is on processing applications timely and without errors. They have the ability to track a very large number of measures, but do not regularly track many of them. Call Center: The call center has an automated response unit that answers the phone and can answer many of the callers' questions. If the question is not answered, the caller may choose to speak to an agent, in which case the call is transferred to one of four call centers (one of these call centers, which was opened with funds from the American Recovery and Reinvestment Act, was not intended to be permanent is and closing in 2011). Clients can apply or recertify for SNAP through the call center as well as report changes. Florida has fielded customer satisfaction surveys with callers entering the system. They have a benchmark to answer all calls within three minutes; however; due to high call volume and a focus on providing benefits in a timely manner, they have struggled to meet it. Online System: Applications submitted through the online system are automatically streamed to the access management system for processing by staff members. Once the application has been Partnering: Partnering arrangements are established by region of the state, through the community partner liaison. They are divided into levels based on the types of assistance they provide. Level two and three partners are those that have kiosks on site, self service, and assisted service sites. Some partners are compensated for their work and others are not, depending on the assistance provided and the need in the region. At the time of our interview, 87 partners were compensated, and they tend to be social service agencies, workforce boards, faith- based partners, and community centers. The compensation can be based on the volume of applications, but is not always tied to it. Partners may have formal arrangements with the state even though they are not compensated. Partners have unique addresses for ACCESS (URL codes) that identify the site. They also have their own view for application tracking. If a partner logs into the system without using their unique address, the state does not know that the application came from the partner. Measures Collected by Partners: Partners track the number of applicants who use their services, sometimes through sign-in sheets. Florida (continued) A.50 acknowledged by the staff member and checked for completion, the data are manually passed into the eligibility system. Florida would like to see 70 percent of its customers with ongoing cases using the online system. Document Imaging: The document imaging system started out as a regional initiative, and then became statewide. Faxes are automatically converted into electronic documents. Some scanning is done in a centralized document imaging center; some documents are scanned by staff in local offices. Once scanned, staff categorize the documents into approximately 15 categories, though with subcategories being added, they expect to have about 40 categories. Currently, the documents are attached to the full case, but Florida intends to change this to attach files to individuals (for example, attaching a birth certificate to a person, rather than a household\u2014allowing the birth certificate to be accessed for that individual for other purposes). Once attached to a case, the case worker is notified automatically that a document has been received. Florida stores information about the scanner that imaged the document and whether a document was received by fax or in paper form. Certain documents require access privileges. Kiosks: Kiosks are available in lobbies of local offices and partner agencies. Clients can use the kiosks to apply through ACCESS, check the status of their case, and submit changes. Applicants completing an online application are asked to identify their location when they complete the application, but the information is not required or verified. Waiver of Face-to-Face Interview: Florida stores information about whether the interview is conducted by phone or in person, however, they calculate no measures for this initiative. For the purposes of their waiver, they are required to track error rates for cases with each type of interview. Shortened Interviews: Florida screens applicants to identify those at low risk of having errors. These individuals participate in a shortened interview. Others participate in the full-length interview. Online Expedited Applications: Clients can submit expedited applications through the state's online system, and the state tracks application statistics (volume and approval rate) for these applications. Application Tracking: Florida built a quality management system that allows them to identify cases that should be reviewed for errors. Tracking of applications is largely to redistribute the workload and keep processing applications within the required window. Changes Over Time: Florida now views modernization as the new way of doing business\u2014looking at the combination of initiatives rather than as individual initiatives. Desired or Planned Future Measures: Staff interviewed reported that Florida would like to be better able to track the source of online applications. A.51 Profile: Georgia State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 7 Number of Partners Interviewed: 1 Initiatives Active in State: Call Center, Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average After-Call Work Time by Staff Statewide Not reported Not reported Not reported Number of Calls (in flow) Statewide Customer Service Not reported Not reported Number of Calls Abandoned Statewide Customer Service Not reported Not reported Number of Calls Queued Statewide Customer Service Not reported Not reported Number of Calls Answered\/Handled Statewide Customer Service Not reported Not reported Number of Agents Assigned to Phones Statewide Customer Service Not reported Not reported Percent of Changes Processed Statewide Not reported Not reported Not reported Average Time to Process Change Statewide Not reported Not reported Not reported Number of Changes Received Statewide Customer Service Not reported Not reported Number of Changes Processed Statewide Customer Service Not reported Not reported Average Answer Speed Statewide Customer Service Less than one minute A governor's award that acknowledges good performance. Average Hold Time Statewide Not reported Not Sure Not sure Percent Calls Abandoned Statewide Customer Service Less than 9 percent abandoned rate was the governor's office standard. A governor's award that acknowledges good performance. Average Call Duration Statewide Customer Service 4-6 minutes total time per call A governor's award that acknowledges good performance. Average Waiting Time (to Speak to Agent) Statewide Not reported Not reported Not reported Average Calls Handled Statewide Not reported Not reported Not reported Georgia (continued) A.52 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Total Calls Handled Statewide Not reported Not reported Not reported Average Staff on Phones Statewide Not reported Not reported Not reported Average Queue Time Statewide Not reported Not reported Not reported Number of Calls Received Statewide Customer Service Not reported Not reported ONLINE SYSTEM (Statewide) Average Number of Screenings Started: Online Statewide Not reported Not reported Not reported Average Number of Screenings Completed: Online Statewide Not reported Not reported Not reported Percent of Users Selecting Spanish Language Statewide Not reported Not reported Not reported Percent of Screened Individuals Potentially Eligible: Online Statewide Not reported Not reported Not reported Percent of Screenings Resulting in Application Submission: Online Statewide Not reported Not reported Not reported Number of Online Screenings Started: Online Statewide Not reported Not reported Not reported Number of Online Screenings Completed: Online Statewide Not reported Not reported Not reported Percent Reporting Easy Experience to Complete Application Statewide Not reported Not reported Not reported Percent Who Would Use Again Statewide Not reported Not reported Not reported Percent of Applications Received Statewide Program Access, Customer Service No No Average Number Started per Month Statewide Not reported Not reported Not reported Average Number Submitted per Month Statewide Not reported Not reported Not reported Average Number of Changes Submitted per Month Statewide Program Access, Customer Service No No Number of Changes Submitted Statewide Not reported No No Number of Applications Started Statewide Not reported Not reported Not reported Georgia (continued) A.53 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Received Locally Not reported No No PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Program Access No No Average Cost of Partner Arrangement Statewide Efficiency Not reported Not reported Number of Partners Statewide Not reported Not reported Not reported Number Accepting Applications Statewide Not reported Not reported Not reported Number Providing Application Assistance Statewide Not reported All partners provide assistance Not reported Number with Terminals\/Kiosks to Submit Application Statewide Not reported Not reported Not reported Number Clients Assisted per Partner Statewide Program Access, Customer Service No Number of Applications Received per Partner Statewide Not reported Not reported Not reported Number of Outreach Events Statewide Program Access, Customer Service No Not reported Number of Clients served Statewide Program Access, Customer Service Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Error Rate for Cases with Telephone Interviews Locally Not reported Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Locally Not reported Not reported Not reported Total Number of Interviews Locally Not reported Not reported Not reported Number of Redetermination Interviews Locally Not reported Not reported Not reported Number of Home Visit Interviews Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Face-to-Face Interviews Locally Not reported Not reported Not reported Georgia (continued) A.54 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Telephone Interviews Locally Not reported Not reported Not reported Notice of Missed Interview Mailed Locally Not reported Not reported Not reported SHORTENED INTERVIEWS (Regionally) None ONLINE EXPEDITED APPLICATIONS (Statewide) Number of Expedited Applications Received Online Statewide Not reported Not reported Not reported Number of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported No No Percent of Total Recertifications Approved Statewide Not reported Not reported Not reported Average Benefit Amount (for those eligible) Statewide Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Statewide Not reported Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Not reported No No Percent of Complete Recertifications Denied Statewide Not reported Not reported Not reported Percent of Initial Applications Denied Statewide Not reported Not reported Not reported Percent of Recertifications Denied Statewide Not reported Not reported Not reported Number of Applications that Appear Eligible for Expedited Benefits Statewide Not reported No No Number of Cases with Complete Verification Submitted Statewide Not reported Not reported Not reported Georgia (continued) A.55 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Accuracy & Integrity, Customer Service No No Total Number of Applications Completed Statewide Not reported Not reported Not reported Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Statewide Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Statewide Not reported Not reported Not reported Number of Applications: Online Statewide Not reported Not reported Not reported Number of Recertifications: Online Statewide Not reported Not reported Not reported Pending Applications by Days in Process Statewide Efficiency, Customer Service FNS timeliness standards Not reported Unexpedited Standard of Promptness Rate (County\/Worker Only) Locally Not reported Not reported Not reported Expedited Standard of Promptness Rate (County\/Worker Only) Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Georgia relies on a regional structure for SNAP administration; the state office communicates with the region and the regional offices communicate with the counties. Offices at all levels actively collect performance measures and data on Georgia's initiatives, which are primarily implemented statewide. The state provides monthly reports that contain application tracking measures and data, which are used by offices in conjunction with county data collection. A regional office may monitor accuracy reports and perform second level readings of case accuracy reviews. Although Georgia is generally satisfied with their data collection and reporting, staff interviewed reported issues, such as: keeping track of data, workforce and staffing challenges, some data quality problems (initially the logic for identifying Georgia (continued) A.56 expedited cases was wrong and needed to be fixed), occasional system glitches, and difficulty accessing data that are older than 6 to 8 months. Georgia used ARRA funding to hire temporary workers. Staff were added to the call center to assist with registration. Other workers were located in county offices and assisted with interviewing clients, processing benefits, making and finding case records, and delivering case records to case managers. No data collection or performance measurement was used to evaluate the efficiencies gained by hiring temporary staff or to look at how these workers impacted measures such as application processing time. In addition to modernization, Georgia has implemented a statewide work redistribution plan in fall 2010 to address an increase in caseloads and a decrease in available staff. Online COMPASS applications are typically shifted from high volume, urban areas like Atlanta to other parts of the state to better manage incoming work and to spread it more evenly across the state. While still in the early phases, staff interviewed reported increased efficiencies, more timely case processing, and increased customer service. Georgia does not currently calculate performance measures to compare the efficiencies gained by this project or see how work redistribution affects application time. One regional office also reported a recent change in their business model. The region closed local offices and consolidated staff into area hubs and workers are assigned a specific task within the application process. There are associated benchmarks for each role, and the regional office reviews worker production daily to evaluate whether they are meeting daily quotas. Measurement Goals: Georgia's performance measures touch on all four FNS goals. Georgia also uses measurement to ensure fair workload distribution among workers and for staffing purposes. Call Center: Georgia has a statewide call center operated by state staff. The state reviews the percent of changes processed, percent calls abandoned, and percent of total calls handled. They also collect many averages and counts of aggregate data. Online System: Georgia worked with a contractor to set up a statewide online application system, which has been in place since 2008. Document Imaging: Georgia has not established a document imaging system. Kiosks: Georgia has not set up any kiosks in state or local offices. Waiver of Face-to-Face Interview: One county office calculates the error rate for cases by type of interview (telephone versus face-to-face), total number of interviews, number of redetermination interviews, and number of home visit interviews. Another county office reported collecting the number of interviews by type (telephone versus face-to-face), number of applicants requesting a phone interview, and number of notices of missed interview mailed. Partnering: At the state level, Georgia has established outreach contracts with all partners that are based on application assistance. Partners are reimbursed for half of their outreach costs, so the more outreach that is provided the higher the partner's budget. The state mainly collects aggregate data counts on their partnering arrangements, in addition to the percent of partners providing application assistance and the average cost of partner arrangements. Two county offices also have informal partnerships in place. These partners have computers available for clients to access the online application system and provide staff to help clients navigate the system. These offices look at the number of partners and the number of partners providing application assistance. Measures Collected by Partners: The partner office we spoke with does not collect any performance data. Georgia (continued) A.57 Shortened Interviews: Information not provided. Online Expedited Applications: While the state office does not collect any measures related to online expedited applications, regional and local offices noted two measures that are available to them: number of expedited applications received online and number of expedited applications received online that were approved. Application Tracking: Georgia state and local offices collect a variety of application tracking measures and data, in the areas of application accuracy, approvals and denials, application processing and case characteristics, application receipt, and application processing time. Georgia is able to discern the origin of applications by whether they were filed online versus not online. Changes Over Time: Georgia noted no significant changes over the past year to the way measures are constructed or data are collected. One regional office used to be able to track applications submitted via partner agencies, but they stopped tracking these two years ago. Desired or Planned Future Measures: The Georgia state office is interested in computing the percent of applications received that are approved and examining these rates separately for online and paper submissions. Regional offices would like to track how applications were received (via mail, fax, online, etc.), percentage of people the office is not able to contact to whom they have to mail appointments, and number of interviews by type (phone versus face-to-face). One region wants to see improvements in the technology and computer system, giving them access to both higher quality and more usable data. For example, even though data are recorded on the waiver of the face-to-face interview, reports cannot be run on this initiative. Another office interviewed would like the computer system's monthly reports on the number of applications received by county to separate out the number of COMPASS applications. One local office would like data on the reasons for denials, and another local office would like more frequent reporting on expedite cases, since these applications are time sensitive. Seeing data from other states on the percent of applications by source (online versus paper) would be useful to Georgia. They would also like to see the number of expedited applications filed online and the average SNAP benefit allotment, broken down by case characteristics and demographics. A.58 Profile: Hawaii State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Number of Redetermination Interviews Statewide Program Access, Efficiency, Customer Service No No Total Number of Interviews Statewide Program Access, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Accuracy & Integrity, Customer Service No No Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications: Paper Submission to Local Office Statewide Program Access, Efficiency, Customer Service No No Percent of Recertifications: Paper Submission to Local Office Statewide Program Access, Efficiency, Customer Service No No Total Number of Applications Started Statewide Program Access, Efficiency, Customer Service No No Total Number of Recertifications Started Statewide Program Access, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Efficiency, Customer Service No No Hawaii (continued) A.59 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Paper Submission to Local Office Statewide Program Access, Efficiency, Customer Service No No Number of Recertifications: Paper Submission to Local Office Statewide Efficiency, Customer Service No No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Processing Time of Application Decision Statewide Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews Description: General: Hawaii has a state-administered SNAP program. The state reported that they have two modernization initiatives and rarely use performance measures for purposes other than those required by FNS. Measurement Goals: Hawaii primarily measures performance to ensure accuracy and integrity, efficiency, and customer service. Call Center: Hawaii does not have a call center. Online System: Hawaii does not have an online system. Document Imaging: Hawaii does not have document imaging. Kiosks: Hawaii does not have kiosks. Waiver of Face-to-Face Interview: Hawaii tracks the number of initial eligibility interviews and redetermination interviews under this initiative. Partnering: Hawaii does not have a partnering initiative. Measures Collected by Partners: Not applicable. Hawaii (continued) A.60 Shortened Interviews: Hawaii does not have a shortened interview initiative. Online Expedited Applications: Hawaii does not have online expedited applications. Application Tracking: Hawaii's reported measures for application tracking were designed along with the system in 1988. Hawaii tracks a wide range of measures and aggregate data related to applications and recertifications, including the number and percent of applications and recertifications processed and the average benefit amount. In addition to FNS QC reviews, there is a supervisory review of one case per worker per month (with cases selected at random). Changes Over Time: Hawaii faces corrective action for timeliness problems, and there is a pending lawsuit that may force the state to make changes to the administration of the program. Staff reported that they were not meeting federal timeliness rates at the time of data collection. Desired or Planned Future Measures: State staff reported that Hawaii would like to track phone vs. in-person interviews in the future. A.61 Profile: Idaho State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Document Imaging, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Efficiency, Customer Service Not reported Not reported Average Hold Time Statewide Efficiency, Customer Service Not reported Not reported Percent Calls Abandoned Statewide Efficiency, Customer Service Not reported Not reported Average Call Duration Statewide Efficiency, Customer Service Not reported Not reported Average Waiting Time (to Speak to Agent) Statewide Efficiency, Customer Service Not reported Not reported Average Calls Handled Statewide Efficiency, Customer Service Not reported Not reported Number of Calls (in flow) Statewide Not reported Not reported Not reported Number of Calls Answered\/Handled Statewide Not reported Not reported Not reported Number of Agents Assigned to Phones Statewide Not reported Not reported Not reported Number of Changes Received Statewide Not reported Not reported Not reported Number of Changes Processed Statewide Not reported Not reported Not reported Number of Cases Pending Benefit Decision: Call Center Statewide Not reported Not reported Not reported Number of Applications Processed: Call Center Statewide Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Not reported Not reported Not reported Percent that are Missed and have Notice Mailed Statewide Not reported Not reported Not reported Total Number of Interviews Statewide Not reported Not reported Not reported Number of Redetermination Interviews Statewide Not reported Not reported Not reported Number of Face-to-Face Interviews Statewide Not reported Not reported Not reported Idaho (continued) A.62 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Telephone Interviews Statewide Not reported Not reported Not reported Number of Missed Interviews Statewide Not reported Not reported Not reported Notice of Missed Interview Mailed Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Statewide) Number of Documents Received Statewide Not reported Not reported Not reported Number of Documents Received: Mail Statewide Not reported Not reported Not reported Number of Documents Scanned Statewide Not reported Not reported Not reported Number of Tasks Completed Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported Not reported Not reported Average Processing Time of Application Decision Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Not reported Not reported Not reported Average Processing Time of Recertification Decision Statewide Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Description: General: In 2006, Idaho began a redesign of their eligibility process to address high error rates, timeliness problems, high staff workloads, and low staff morale. They developed a process-driven business design, through which applicants are not required to visit the office and eligibility workers attempt to touch the case just once before making an eligibility decision. Idaho states that the redesign decreased their case processing from 21 days to 1 hour and substantially improved their error rates. Measurement Goals: When designing performance measures, Idaho considers: 1) FNS expectations, 2) customer demand, and 3) operational effectiveness and efficiency. In addition to performance measurements, Idaho has compliance measurements to ensure that the state meets federal requirements. Formerly, Idaho's performance measurements were compliance-based, but did not enable the state to determine whether it was truly effective in terms of its own performance. The drive for new Idaho (continued) A.63 performance measurements originated out of a realization of the shortcomings of the compliance measurements. Call Center: Idaho focuses on performance-based or outcome measures. Although they collect measures such as average call and wait times, they do not use these to make management decisions. Online System: Idaho does not have an online application system. Document Imaging: Idaho has counts of the number of documents being processed, but does not use it as a measure of the initiative. They use it to project data storage requirements. Kiosks: Idaho does not have kiosks for application access and submission. Waiver of Face-to-Face Interview: Idaho tracks the percentage of interviews that are conducted by telephone and the percentage of interviews that are missed and have a notice mailed to them. Shortened Interviews: Idaho does not have a shortened interview initiative. Online Expedited Applications: Idaho does not have an online expedited application. Application Tracking: Idaho tracks the percentage of applications that are approved and denied. They measure accuracy for FNS through the QC system and supervisors also conduct internal reviews. Idaho recently changed their QA process to permit reviewers to correct and coach workers in real-time during the interview process. The state established a benchmark that 70 percent of applications be processed the day of receipt. Changes Over Time: Idaho has changed its measures substantially in order to support its process- driven business redesign. Their measurement focus is now on short-term outcomes for application processing. Desired or Planned Future Measures: Idaho currently calculates if the case was processed in one day based on when an application was created in the system and when it was processed. In addition, they would like to track the time between the interview date and the date an application was processed. Such a measure would enable Idaho to account for those applications where they cannot conduct the interview at the point of creation (for example, for mailed-in applications or for applicants who do not wish to wait for a same-day interview). Idaho also would like to be able to identify, in real-time, the workload across the state in order to distribute the work and improve efficiency. Partnering: Idaho prefers to have state employees conduct all work, including running the call center. However, they recently contracted with a partner to create a state-wide virtual contact center to help them achieve their goal of having a universal workforce. Measures Collected by Partners: We did not interview any partners in Idaho as part of this study. A.64 Profile: Illinois State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 4 Initiatives Active in State: Call Center, Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Customer Service No No Average Hold Time Statewide Customer Service No No Percent Calls Abandoned Statewide Not reported No No Average Call Duration Statewide Program Access, Efficiency No No Average Waiting Time (to Speak to Agent) Statewide Efficiency, Customer Service No No Average Calls Handled Statewide Efficiency, Customer Service No No Percent of Total Calls Handled Statewide Accuracy & Integrity, Efficiency, Customer Service No No Average Queue Time Statewide Not reported No No Average After-Call Work Time by Staff Statewide Accuracy & Integrity, Customer Service No No Percent of Queued Calls Handled Statewide Accuracy & Integrity, Efficiency, Customer Service No No Percent of Calls Completed in the Computer Phone System Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Abandoned Statewide Customer Service No No Number of Calls Received Statewide Program Access, Efficiency, Customer Service No No Number of Calls Queued Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Answered\/Handled Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Agents Assigned to Phones Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Illinois (continued) A.65 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Customer Service No No ONLINE SYSTEM (Statewide) Number of applications submitted Statewide Program Access, Efficiency, Customer Service No No Percent Completed After Hours Statewide Program Access, Customer Service No No Number Providing Application Assistance Regional Program Access No No Number of Applications Received per Partner Regional Program Access No No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity No No Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of interviews that are automated Statewide Customer Service No No APPLICATION TRACKING (Statewide) Number of Applications Approved: Community Partner Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Efficiency, Customer Service No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Applications: Community Partner Statewide Program Access, Efficiency, Customer Service No No Number of Applications Denied: Community Partner Statewide Program Access, Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. PSI = Phone System Interview Description: General: Illinois has a state-wide call center that SNAP applicants and participants can use to get some questions answered and submit limited types of changes\u2014more complicated questions must go Illinois (continued) A.66 through an eligibility worker. At recertification, many individuals are eligible for automated interviews. They work with a variety of partners that are funded through FNS. They participated in a demonstration called Express Stamps that allowed some food banks and their partners to complete shortened applications for their clientele. The demonstration ended in March 2011\u2014it is not being continued because of concerns identified in an evaluation related to accuracy and fraud. They continue to work with a variety of other partners that provide application assistance and outreach. Measurement Goals: They collect a variety of measures related to their call center, and also conduct mandatory reviews of cases with phone interviews to ensure their accuracy. Partners collect a variety of measures that are not required by the state. Call Center: Computer Telephony Assistance System (CTAS) is the software behind the call center and is completely automated. The call center number is centralized and has been in place since the 1980s for the all of the agency's programs including SNAP; TANF; Medicaid; drug, alcohol, and health prevention services; and programs for people with physical or developmental disabilities. CTAS is an automated system that can answer questions about benefit amount and case status. Although it resolves most of the calls that come in, small number of agents (caseworkers) are available to answer calls to field the remaining questions. Call center staff can make simple case changes, such as a change of address, but more complex changes, such as to reported income or household composition that affect the benefit amount, must be reported to the local office. CTAS also conducts Phone System Interviews (PSI) for recertifications only, although the local office determines eligibility. CTAS determines who is eligible for a PSI and sends the person a PIN to gain entry into the system and complete the PSI telephonically. Illinois has made numerous upgrades to the system architecture. The initial transition from the legacy system to CTAS was in November 2001, and the most upgrade was in September 2010. The initial version of CTAS did not allow for tracking call reason codes, but that capability was included in the most recent upgrade. The absence of these reason codes means that analysts have not had the ability to attribute call volume to specific agency programs. However, it is possible to track incoming calls to 1 of 15 toll-free numbers published by program. During these periods of upgrades, the performance measures calculations did not change. Online System: The online system was built by a contractor, and is maintained and modified by the state. Data entered into the online system are reviewed by a caseworker and then automatically transferred to the legacy system. Document Imaging: Illinois does not have document imaging. Kiosks: Illinois has not implemented kiosks. Waiver of Face-to-Face Interview: Illinois has an automated system for conducting the recertification by phone. Elderly and disabled individuals are not eligible for this automated interview, nor are individuals with complicated income calculations. These cases are too complex for the automated system to handle. However, these individuals may request a phone interview with their case worker. Shortened Interviews: Illinois does not have a separate shortened interview. Online Expedited Applications: Illinois does not have online expedited applications. Application Tracking: Statewide software that lets anyone check on the processing work of applications that have been submitted, allowing them to examine on-demand reports to look at trends. Illinois (continued) A.67 Changes Over Time: Illinois staff did not report major changes to measures over time. However, they reported that a recent system system change affects values observed for call center measures. Due to a staff reduction, a business decision was made to decrease the number of calls allowed in the queue by approximately 40 percent. Desired or Planned Future Measures: Illinois recognizes that the measures for the call center do not allow them to gauge how well the call system is meeting the needs of the callers or why callers abandoned calls. According to staff interviewed, they would like to be able to better identify when clients are struggling, such as how long clients spend on a given page of the application so that they could troubleshoot wording or functionality. These kinds of diagnostic tools are hard to add later when attention and resources have shifted elsewhere. They would also like to be able to compare processing time across states\u2014not just an indicator for timeliness or percent timely, but the average number of days to process applications in each state. Partnering: Illinois conducted a demonstration study, which ended in March 2011, called Express Stamps. The state partnered with several agencies, primarily foodbanks, who partnered with local agencies, such as food pantries, to assist individuals with applying for one to two months of benefits. Under the demonstration, applicants do not need to submit as much information, provide documentation, or participate in an interview. Eligibility is determined onsite. Illinois also has formal contracts with several other organizations for outreach and application assistance. Some outreach is targeted to individuals who are found to be participating in other programs, such as parents of students receiving free- and reduced-price school lunches, but not SNAP; other outreach efforts include attendance at fairs, school events, senior centers, et cetera. The partners provide information about SNAP and may also assist the applicants in completing the application process and submit the application for them by fax. The partners are paid for their services. They provide a report to the state discussing their activities. The state is collecting a variety of information for internal use, and would like the ability to determine the outcome of the applications that they have helped to submit. Currently, this is achieved by asking the applicant. Other partners providing SNAP information have informal agreements and are not paid for their services. Measures Collected by Partners: Partners we interviewed in Illinois commonly keep track of application outcomes, measuring either the number of applications approved or their approval rate. Other measures tracked by partners include: average level of benefits, number of applications submitted, number of clients contacted, number of screenings, and application origin (by ZIP code). A.68 Profile: Indiana State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 3 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Average Hold Time Locally Customer Service Not to exceed 3 minutes When metric not achieved for three consecutive months, a full-time employee will be added to this workgroup at full cost to the vendor Percent Calls Abandoned Locally Customer Service Not to exceed 7 percent for hybrid; not to exceed 5 percent for modern When metric not achieved for three consecutive months, a full-time employee will be added to this workgroup at full cost to the vendor Average Call Duration Locally Customer Service No No Average Waiting Time (to Speak to Agent) Locally Program Access, Customer Service 300 seconds (excludes internal call centers) When metric is not achieved for three consecutive months, a full-time employee will be added to this workgroup at full cost to the vendor Number of Calls (in flow) Locally None No No Number of Calls Abandoned Locally Efficiency, Customer Service No No Number of Calls Answered\/Handled Locally Efficiency, Customer Service No No Number of Calls Received Statewide Not reported No No Percent of Voicemail Calls Locally Not reported No No Indiana (continued) A.69 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Regionally) Percent of Applications Received Locally Program Access, Efficiency, Customer Service No No Total Number of Applications Submitted per Month Locally Program Access, Efficiency, Customer Service No No DOCUMENT IMAGING (Statewide) Percent of Documents Received by Mail Statewide Program Access, Efficiency No No Percent of Documents Received by Fax Statewide Program Access, Efficiency No No Average Processing Time Statewide Efficiency 90 percent of documents without a barcode are processed within two business days of receipt. All documents are processed within three business days of receipt. When metric is not achieved for three consecutive months, a full-time employee will be added to this workgroup at full cost to the vendor Number of Documents Received Statewide Program Access, Efficiency No No Number of Documents Received: Mail Statewide Program Access, Efficiency No No Number of Documents Received: Fax Statewide Program Access, Efficiency No No Number of Documents Received: Other Electronic Statewide Program Access, Efficiency No No Number of Documents Processed Statewide Efficiency No No Number of Documents Scanned Statewide Efficiency No No KIOSKS (Regionally) None PARTNERING (Statewide) Number of Partners Statewide Efficiency, Customer Service No No Number Accepting Applications Regional Efficiency, Customer Service No No Indiana (continued) A.70 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number Providing Application Assistance Regional Efficiency, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Regionally) None ONLINE EXPEDITED APPLICATIONS (Regionally) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Efficiency, Customer Service No No Percent of Applications: Online Statewide Program Access No No Percent of Applications: In-Office Statewide Program Access No No Percent of Applications: Mailed Statewide Program Access No No Number of Applications: Online Statewide Program Access No No Number of Applications: Mailed Statewide Program Access No No Notes: State collects mandatory accuracy data through QC reviews. Data are collected for all programs combined and cannot be separated into the separate programs. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Indiana is divided into eight administrative regions and operates with three service delivery models. Characteristics of the three types include: \uf0b7 As-is: Staff process all applications on paper, and each worker has a specific caseload of cases for which she or he is responsible. Clients report changes directly to their caseworker. In January 2011, this model was in place in three of the eight regions, covering 52 percent of the caseload. \uf0b7 Modern: Both document imaging and online applications are in place. All interviews are by phone unless the client requests otherwise, using a two-step process where contractor staff gather data and then caseworkers conduct the interactive and eligibility determination portion of the interview. Indiana (continued) A.71 Contractors manage staff assigned to the phones. Cases are managed at the regional level, so work on a customer's case is not necessarily occurring in their county. In January 2011, this model was in place in two regions. \uf0b7 Hybrid. Both document imaging and online applications are in place, but client interviews occur in-person, using a one-step process with only a state merit employee. The interview takes place at the local county office unless the client requests a phone interview. Cases are pooled, and managers assign tasks to caseworkers as they need to be worked (no worker-specific caseloads are in place). Clients report changes to a regional center, and submit documents to a centralized location for scanning and indexing. State staff manage contractors assigned to answer phones in their local office. Work is managed at the county level, so most casework is done in the county where a customer lives, though it can be shifted as needed to balance the workload. In January 2011, this model was in place in three regions. The state planned to transition the modern regions to the hybrid model in February 2011 and hoped to convert all regions to the hybrid model by the end of 2011. Contractors run the call center, document imaging, outgoing mail, and systems development and maintenance. State merit staff continue to make all SNAP eligibility decisions, but almost everything else, including answering questions not related to eligibility and receiving client documents, has been outsourced. The state's system of service delivery has evolved over time and has shifted hands among contractors. This results in a range of measures and systems, some overlapping, that state staff and contractors use to manage their work. It also means that the history of measure development is somewhat fractured, and that some measures are being collected because former contractors programmed systems to collect them at an earlier time. Indiana has two systems, run by two contractors and used in different parts of the state, that assign tasks to workers based on an algorithm. One has more detail available for tracking status of cases, while the other allows workers to create form letters that are mailed centrally. Measurement Goals: At the time of our visit, Indiana's driving motivation for measurement was timeliness, for several reasons. First, requirements stemming from a lawsuit mandate that the state have a 90 percent timeliness rate by March 2011. Second, in order to get FNS approval for the waiver that would allow them to convert as-is regions to the hybrid model, they need to demonstrate their ability to satisfy timeliness goals. To meet the timeliness goals, they are able to look at several measures in real-time, and reassign staff if any of them are being overloaded or if there is a risk of not meeting timeliness standards. Call Center: The call center is run by a contractor and handles more than one program. It operates only in the modern and hybrid models. Calls are routed to the region and then, if a hybrid area, to the county within the region. Clients can report changes or request information through the call center. If no one answers the call within one minute during business hours, the caller can opt to leave a voicemail. After hours, all calls are routed directly to voicemail. Online System: Online applications are available in the hybrid and modern models. When an application comes in, a worker reviews it to verify it is complete, and then sends the application to the eligibility system to be registered and assigned a case number. Not all information is transferred over Partnering: Indiana has formal arrangements with a variety of contractors, providing application services; software development and support; mail, data entry, and document imaging services; and outbound mail and electronic mail services. Measures Collected by Partners: Because these are formal contracts, Indiana collects, or has the contractor collect, several measures to demonstrate their performance. In addition to the items mentioned in each initiative above, Indiana requires that contractors provide training and maintain the levels of accuracy and timeliness required by FNS. Indiana (continued) A.72 because client-entered information is subject to being both incomplete and incorrect. The system guides caseworkers through interview questions (skipping those that are irrelevant based on prior responses) while they enter additional client information. A contractor built and maintains the system, but state staff oversee the day-to-day operations. Document Imaging: The document imaging center operates out of a county service center and services the entire state. Once imaged, documents can be viewed by workers in any location. Documents may be scanned at local offices as well. The imaging software stores information about the origin of the document. All physical documents are shredded. Kiosks: Kiosks are available in regions operating with the modern model. Individuals can use these kiosks to access the application as they would through any other computer. The state intends to add kiosks to other regions in 2011. Waiver of Face-to-Face Interview: This waiver is used only in the modern model. Supervisors have access to discreetly monitor staff interview calls to monitor performance. Workers are prompted to record the type of interview. Shortened Interviews: Indiana does not have a shortened interview. Online Expedited Applications: In regions that allow online applications, Indiana also accepts expedited applications online. Application Tracking: The state uses the findings from the required Quality Control reviews to identify training opportunities for staff. As the result of a lawsuit, Indiana must process 90 percent of its applications and recertifications timely (higher than its internal goals of 80 percent and 85 percent, respectively). However, the state has a waiver that enables it to extend the processing time to 60 days in cases where the client has not, during the first 30 days, submitted sufficient documentation to make an eligibility decision. While most states would close out the application as ineligible after the first 30 days due to incomplete information, Indiana can keep it open for an additional 30 days to collect the missing information, without requiring the client to resubmit the entire application. A respondent from Indiana noted that the state's timeliness has improved since it increased efforts to track application processing. Changes Over Time: With the transition into the hybrid model across the state, Indiana will likely be relying on a different set of measures than they have been in the past. Desired or Planned Future Measures: None reported. A.73 Profile: Iowa State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Document Imaging, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Efficiency, Customer Service Not sure No Average Hold Time Statewide Efficiency, Customer Service Not sure No Percent Calls Abandoned Statewide Efficiency, Customer Service Not sure No Average Call Duration Statewide Efficiency, Customer Service Not sure No Average Waiting Time (to Speak to Agent) Statewide Efficiency, Customer Service Not sure No Average Calls Handled Statewide Efficiency, Customer Service Not sure No Percent of Total Calls Handled Statewide Efficiency, Customer Service Not sure No Average Staff on Phones Statewide Efficiency, Customer Service Not sure No Average Queue Time Statewide Efficiency, Customer Service Not sure No Average Time Prior to Abandonment Statewide Efficiency, Customer Service Not sure No Average After-Call Work Time by Staff Statewide Efficiency, Customer Service Not sure No Percent of Queued Calls Handled Statewide Efficiency, Customer Service Not sure No Number of Calls (in flow) Statewide Efficiency, Customer Service Not sure No Number of Calls Abandoned Statewide Efficiency, Customer Service Not sure No Number of Calls Queued Statewide Efficiency, Customer Service Not sure No Number of Calls Answered\/Handled Statewide Efficiency Not sure No Number of Agents Assigned to Phones Statewide Customer Service Not sure No Average Time to Process Change Statewide Efficiency, Customer Service Not sure No Number of Changes Received Statewide Efficiency Not sure No Iowa (continued) A.74 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Received Statewide Efficiency, Customer Service Not sure No Number of Changes Processed Statewide Efficiency, Customer Service Not sure No Number of Calls Transferred to Agent Statewide Efficiency, Customer Service No No ONLINE SYSTEM (Statewide) None DOCUMENT IMAGING (Statewide) Number of Documents Received: Other Electronic Statewide Efficiency No No APPLICATION TRACKING (Statewide) Percent of Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure No Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity No No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure No Total Number of Recertifications Approved Statewide Program Access Not sure No Total Number of Applications Approved Statewide Program Access Not sure No Total Number of Applications Statewide Program Access Not sure No Total number of Recertifications Statewide Program Access Not sure No Total Number of Applications Completed Statewide Program Access No No Total Number of Recertifications Completed Statewide Program Access No No Percent of Complete Applications Denied Statewide Program Access No No Percent of Complete Recertifications Denied Statewide Program Access No No Percent of Applications with Incomplete Information Statewide Program Access, Customer Service No No Iowa (continued) A.75 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Application Decision Statewide Program Access, Efficiency, Customer Service Federal regulations\/ state law No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. Description: General: In Iowa, SNAP is state administered. Other than measures linked to the call center and application tracking, performance measurement in Iowa is limited. Measurement Goals: Iowa measures performance with a focus on customer service, accuracy and integrity, and program access. Accuracy measures conform to, but do not exceed, FNS quality control requirements. Call Center: All Iowa call center measures are automatically calculated by their Cisco call center software. The staff we interviewed were not familiar with the process used to design these measures. Online System: Iowa has an online application system maintained by a contractor. At the time of the interview, Iowa did not report any performance measures or aggregate data tied to this initiative. Document Imaging: At the time of the interview, Iowa's policy and documentation for the document imaging initiative was in the early revision stages. They had not yet established any measures (but one measure was planned). Kiosks: Iowa does not have kiosks for application access and submission. Waiver of Face-to-Face Interview: Iowa does not have a waiver of face-to-face interviews in place. Shortened Interviews: Iowa does not have a shortened interview. Expedited Online Applications: Iowa does not have expedited online applications. Application Tracking: Iowa tracks a number of measures for the application process, using data directly extracted from the state data system, CISCO. In addition to the measures noted, the respondent stated that cases are manually tagged with an expedited tag, to note those requiring expedited processing. Changes Over Time: Not reported. Desired or Planned Future Measures: Not reported. Partnering: Iowa does not have a partnering initiative. Measures Collected by Partners: Not applicable. A.76 Profile: Kansas State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) None PARTNERING (Statewide) Number of Partners Statewide Program Access, Efficiency, Customer Service No No Number Accepting Applications Statewide Program Access, Efficiency, Customer Service No No Number Providing Application Assistance Statewide Program Access, Efficiency, Customer Service No No Number Clients Assisted per Partner Statewide Program Access, Efficiency, Customer Service The agencies set goals in their grant application No Number of Applications Received per Partner Statewide Program Access, Efficiency, Customer Service Meet agency goals set in their grant application No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Total Number of Interviews Statewide Not reported Not reported Not reported Number of Redetermination Interviews Statewide Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Average Timeliness Rate: Approvals Statewide Efficiency, Customer Service 95 percent timely No Average Timeliness Rate: Recertifications Statewide Efficiency, Customer Service 95 percent timely No Percent of Applications: Online Locally Program Access Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Program Access Not reported Not reported Kansas (continued) A.77 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications: Paper Submission to Local Office Locally Program Access Not reported Not reported Percent of Applications: Mailed Locally Program Access Not reported Not reported Number of Applications: Mailed Locally Program Access Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Percent of Complete Applications Denied Locally Not reported Not reported Not reported Percent of Complete Recertifications Denied Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Kansas has an online system and works with partners. They do not widely use measures outside of the partnering arrangements and QC reviews. Measurement Goals: Kansas primarily measures performance to ensure accuracy and integrity, efficiency and customer service. Call Center: Kansas does not have a call center. Online System: Data from the online system is not directly transferred into the eligibility system\u2014 staff print the application and enter the information manually. There is no state level performance tracking related to the online system. One region tracks the origin of their applications, including whether they are submitted online, but does so independently of the state. Document Imaging: Kansas has not implemented a document imaging system. Kiosks: Kansas does not have kiosks. Waiver of Face-to-Face Interview: The state did not report the collection of any measures related to the waiver, but one local office reported using state reports of the number of total and redetermination interviews to track its progress on interviews for this initiative. Kansas (continued) A.78 Shortened Interviews: Kansas does not use a shortened interview. Online Expedited Applications: Kansas has online expedited applications, but did not report tracking any performance data. Application Tracking: Kansas has little application tracking aside from required measures that are part of the quality control process. One exception is for timeliness the state tracks the number of days an application has been pending, and when it reaches 20 days, the application goes on a hotlist to alert a worker to take action on the case before it become out of compliance with the FNS 30-day standard. There is no parallel list for expedited applications. Staff in one local office reported that they look at a limited number of performance measures using state level data and reports. One region tracks the time it takes the staff in their seven offices to enter an application into the system once it is received. This is an independent effort by the region and does not occur statewide. Changes Over Time: None. Desired or Planned Future Measures: None. Partnering: Most partnering arrangements are informal and uncompensated in Kansas because of limited staff time. However, the state does track the performance of five formal outreach partners (those on their state SNAP outreach plan). These partners work closely with the state's local offices, but all contracts are maintained and negotiated on the state level. The state distributes applications pre-printed with partner ID numbers to each partner agency to use for tracking purposes. Tracking numbers only track the level of application supplies at each partner, but staff report they could be used for state level tracking in the future. However, because the computer system cannot track the origin of applications, all partner tracking in Kansas is manual. Measures Collected by Partners: We did not contact any of Kansas' partners as part of this study. The state does not require the partner to collect any data. A.79 Profile: Kentucky State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) None PARTNERING (Statewide) None WAIVER OF FACE-TO-FACE INTERVIEW (Regionally) Total Number of Interviews Locally Not reported No No Error Rate for Cases with Telephone Interviews Locally Not reported Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Redetermination Interviews Locally Not reported Not reported Not reported Number of Missed Interviews Locally Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Total Number of Applications Completed Statewide Not reported No No Total Number of Recertifications Completed Statewide Not reported No No Percent of Total Applications Approved Locally Not reported Not reported Not reported Percent of Total Recertifications Approved Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Kentucky (continued) A.80 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Total number of Applications Approved Locally Not reported Not reported Not reported Total number of Recertifications Approved Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported No No Total Number of Recertifications Completed Locally Not reported No No Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Number of Total Applications Denied Locally Not reported Not reported Not reported Number of Total Recertifications Denied Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Percent of Applications Approved Timely Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Kentucky (continued) A.81 Description: General: In Kentucky, SNAP is state-administered. The two county offices interviewed reported that most performance measures are reviewed on a regional level. Measurement Goals: Kentucky did not report any goals for state-level measures. Call Center: Kentucky does not have a call center. Online System: Kentucky does not have an online system for application submission, but the state reported that an application in PDF form is available online and can be downloaded and printed for submission. Another web-based system can be used by clients to track their EBT balance. The state reported no measures for either of these online tools. Document Imaging: Kentucky does not have a document imaging initiative in place. Kiosks: Kentucky does not have kiosks for application access and submission. Waiver of Face-to-Face Interview: Kentucky has a waiver of face-to-face interviews in place. Although the state office did not report collecting any measures for this waiver, local offices reported tracking measures related to the volume of such interviews and the accuracy of cases in which the face-to-face interview had been waived. Shortened Interviews: Kentucky does not have shortened interviews. Online Expedited Applications: Kentucky does not have online expedited applications. Application Tracking: Kentucky tracks measures and aggregate data related to applications and recertifications, including the total number of completed, denials, and processing time. Kentucky previously won a timeliness prize, and they strive for 100 percent timeliness. Changes Over Time: Kentucky staff reported that they had made no changes in the last year to performance measurement, and one respondent noted that the application tracking system has not changed in several years . Desired or Planned Future Measures: At the time of the interview, Kentucky was working towards implementing a document imaging system. Partnering: While the state respondent indicated that there is no state-level initiative, a local respondent indicated two partners. One has a formal contract with the state office to provide SNAP nutrition assistance and outreach. Another works with the county office on an informal agreement, relying on a grant through the National Council on Aging to do Medicare and SNAP outreach. Measures Collected by Partners: We did not interview any Kentucky partners as part of this study. A.82 Profile: Louisiana State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Kiosks, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Not reported Not reported Not reported Average Hold Time Statewide Not reported Not reported Not reported Percent Calls Abandoned Statewide Not reported Not reported Not reported Average Call Duration Statewide Not reported Not reported Not reported Average Calls Handled Statewide Not reported Not reported Not reported Percent of Total Calls Handled Statewide Not reported Not reported Not reported Average Queue Time Statewide Not reported Not reported Not reported Average Time to De- Queue Statewide Not reported Not reported Not reported Average Time Prior to Abandonment Statewide Not reported Not reported Not reported Percent of Queued Calls Handled Statewide Not reported Not reported Not reported Number of Calls (in flow) Statewide Not reported Not reported Not reported Number of Calls Abandoned Statewide Not reported Not reported Not reported Number of Calls Queued Statewide Not reported Not reported Not reported Number of Calls Answered\/Handled Statewide Not reported Not reported Not reported Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Not reported Not reported Not reported Percent of Calls Completed in the Computer Phone System Statewide Not reported Not reported Not reported Number of Clients Accessing Computer Phone System Data Statewide Not reported Not reported Not reported Number of Calls Received Statewide Not reported Not reported Not reported Number of Hang-ups Statewide Not reported Not reported Not reported Louisiana (continued) A.83 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) Average Number of Online Applications Statewide Efficiency No No KIOSKS (Statewide) Number of Users to Access Online Account Locally Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Notice of Missed Interview Statewide Program Access, Efficiency, Customer Service Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Complete Applications Denied Statewide Accuracy & Integrity, Customer Service No No Percent of Complete Recertifications Denied Statewide Accuracy & Integrity, Customer Service No No Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal 30 day processing requirement. Cases meeting expedited criteria must be processed to enable household to access benefits within 4 days of application date. The state may qualify for incentive awards for timeliness of application processing. Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Louisiana (continued) A.84 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Average Benefit Amount (for those eligible) Locally Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Louisiana (continued) A.85 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications: Community Partner Locally Not reported Not reported Not reported Percent of Applications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Mailed Locally Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications: Community Partner Locally Not reported Not reported Not reported Number of Applications: Kiosk Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Percent of Initial Applications Denied Locally Not reported Not reported Not reported Percent of Recertifications Denied Locally Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Percent of Applications with Incomplete Information Locally Not reported Not reported Not reported Louisiana (continued) A.86 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications with Incomplete Information Locally Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: In Louisiana, SNAP is state-administered. The two local offices interviewed reported that most performance measures are reviewed on a regional level. Measurement Goals: Louisiana primarily measures performance to ensure customer service, accuracy and integrity, and efficiency. Call Center: Louisiana has an interactive voice response system that permits clients to access basic information (benefit level, application status, office locations, etc.) A contractor operates the system. Louisiana residents also have access to Disaster SNAP through a call center that transfers callers to live agents when requested. Online System: At the time of the interview, Louisiana was in the first month of the official rollout of their online system. They track the daily number of online applications submitted. A contractor developed the online system with state staff. That contract has expired and the state is trying to acquire a maintenance contract to assist their programmers with system changes. Staff reported that the information uploaded to the online system does not currently transition to the eligibility system; a state worker manually enters all information from the online applications system into the eligibility system. Document Imaging: Louisiana does not have a document imaging initiative in place. Kiosks: Kiosks located in the lobby of SNAP offices provide access to the online application for download and submission. Applications that have already been submitted may not be changed at the kiosk. If a client has not yet submitted an online application, an assigned pin number allows them to make changes to their information for up to 30 days. Waiver of Face-to-Face Interview: The state does not collect measures for their waiver of face-to- face interviews (though they do record when a notice of missed interview has been mailed), but Louisiana Partnering: Louisiana does not have a partnering initiative. Measures Collected by Partners: Not applicable. Louisiana (continued) A.87 can request aggregate data on the number of missed interviews. The state SNAP office does not request or use that data on a regular basis. Shortened Interviews: Louisiana does not have a shortened interview initiative. Online Expedited Applications: Louisiana has an online expedited application initiative, but the state does not collect any measures about this initiative. Application Tracking: Louisiana must report measures for application tracking in accordance with FNS national regulations. According to a Louisiana SNAP staff member, \"I've been involved for 32 years, and we've always had those performance measures. This is nothing new.\" Louisiana has automatic monthly programming that produces reports based on these data. In addition to FNS quality control, Louisiana has a case review system utilized by regional program coordinators (or \"regional specialists\") and first-line supervisors. The case review system is another type of corrective action. Regional specialists will use those case review cases to conduct re-reviews and identify error trends by region, parish, worker, or unit. Louisiana recently began incorporating these error trends into the management evaluation review, another corrective action tool. State staff reported that this case review system uses a more comprehensive sample than FNS quality control, but the sample quality depends upon the quality of first-line supervisors' reviews. Louisiana's case review system does not calculate error rates and does not use or review the information beyond FNS QC guidelines. Changes Over Time: Not reported. Desired or Planned Future Measures: Louisiana is in the process of developing more community partnerships and assigning numbers to each of the community partners and their sites. State staff reported that they plan to track which applications came from which site. Louisiana anticipates having many more modernization initiatives underway in 2011. A.88 Profile: Maine State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System (active January 2011), Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEMa (Statewide) Average Number of Screenings Started: Online Statewide Accuracy & Integrity Not reported Not reported Average Number of Screenings Completed: Online Statewide Accuracy & Integrity Not reported Not reported Percent of Screened Individuals Potentially Eligible: Online Statewide Accuracy & Integrity Not reported Not reported Percent of Applications Received Statewide Accuracy & Integrity Not reported Not reported Average Number Submitted per Month Statewide Accuracy & Integrity Not reported Not reported Average Number Started per Month Statewide Accuracy & Integrity Not reported Not reported Percent of Multiple Applications: Online Statewide Accuracy & Integrity Not reported Not reported Average Time to Complete Online Application Statewide Accuracy & Integrity Not reported Not reported Average Time to Complete Online Screening Statewide Accuracy & Integrity Not reported Not reported PARTNERINGb (Statewide) None WAIVER OF FACE-TO-FACE INTERVIEWb (Statewide) None APPLICATION TRACKING (Statewide) Total Number of Applications Completed Statewide Accuracy & Integrity No No Number of Applications Denied: Total Statewide Accuracy & Integrity No No Number of Applications Approved: Total Statewide Accuracy & Integrity No No Maine (continued) A.89 Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. aThe call center was not in place at the time of our interview and data collection. The measures provided here are the measures the state planned to collect. bThe initiative was under development at the time of our interview and measures were not yet in place. Description: General: Maine has an integrated benefit delivery system, the Automated Client Eligibility System (ACES). It integrates Medicaid, TANF, ASPIRE (Maine's employment and training program), Food Supplement (Maine's SNAP), childcare, and child support. At the time of our interview, Maine was preparing their online system, which was to be launched in January 2011. They system was planned to tie in directly into ACES. They were also working with community partners to plan how partners would be able to access the system to provide application assistance. Conversations were underway with FNS about a waiver for the face-to-face interview. Measurement Goals: Maine plans to track a variety of measures related to their online system. They currently track the counts of applications approved and denied. The goals for tracking these measures are to ensure continued accuracy and integrity of the program. Call Center: Maine does not have a call center. Online System: The online system will have a screening tool and application\u2014unsigned applications can be submitted online. The online system was planned to tie directly into ACES. Document Imaging: Maine has not implemented a document imaging system. Kiosks: Maine does not have kiosks. Waiver of Face-to-Face Interview: The waiver was under discussion at the time of our data collection. Shortened Interviews: Maine does not have a shortened interview process. Online Expedited Applications: Maine does not have online expedited applications. Application Tracking: Maine tracks the counts of applications submitted, approved, and denied. Changes Over Time: None reported. Desired or Planned Future Measures: Maine plans to track a variety of measures related to their online system, and will track the use of the system by partners as well. Partnering: Several community-based organizations have paper copies of the application available. Maine plans to give community partners access to the online system. Measures (to be) Collected by Partners: When partners have access to the online system, Maine anticipates collecting aggregate data with the number of people accessing the screening tool, number of people applying, and number of people granted benefits. The state will also track if an individual applied on their own or received assistance from the community partner. A.90 Profile: Maryland State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 3 Initiatives Active in State: Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) Number of Online Screenings Started: Online Statewide Customer Service No No Number of Online Screenings Completed: Online Statewide Program Access, Customer Service No No Number of Applications Started Statewide Customer Service No No Number of Abandoned Applications Statewide Customer Service No No Number of Applicants who Received Help to Apply Online Statewide Program Access, Customer Service No No Number of Applicants who Did Not Receive Help to Apply Online Statewide Customer Service No No PARTNERING (Statewide) Number of Partners Statewide Program Access, Customer Service No No Number Accepting Applications Statewide Program Access, Customer Service No No Number Providing Application Assistance Statewide Program Access, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Total Number of Interviews Statewide Program Access, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Number of Applications Approved: Phone Interviewed Statewide Efficiency, Customer Service No No Number of Recertifications Approved: Phone Interviewed Statewide Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access No No Maryland (continued) A.91 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Total Number of Recertifications Completed Statewide Program Access No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Recertifications: Online Statewide Program Access, Efficiency, Customer Service No No Percent of Complete Applications Denied Statewide Program Access No No Average Processing Time of Application Decision Statewide Efficiency, Customer Service No No Timeliness Rate Statewide Efficiency, Customer Service 90 percent to avoid corrective compliance with the USDA; 96 percent or better to comply with the Thompson v. Donald court order The local department directors are evaluated on this measure. Notes: State collects mandatory accuracy data through QC reviews. Description: General: Maryland has an online system, supported by a contractor, for application submission and change reporting. Maryland also has numerous community partners providing application assistance\u2014 some formal and some informal. Measurement Goals: Many of Maryland's measurement goals are related to program access and customer service. State staff reported that they would like to be able to track more information about the approvals and denials for their community partners. Call Center: Maryland does not have a call center. Online System: Maryland operates an online system, Service Access and Information Link (SAIL), which they own, but contract with another company to maintain. It can be used for screening, application submission (with electronic signature), and to report changes. When partners log in using their specific login IDs, the system is able to track the applications originating with the partners. Applicants can create an account and return to it at a later time via use of a control number issued when the account is created. These accounts remain active indefinitely. Once an application is filed online, information from the online application (with the exception of a narrative section) transfer to the eligibility system through a subsystem that brings up screens resembling the legacy system. The screens in the legacy system are pre-populated with information from the online application (alongside any pre-existing information about the client from the legacy system). Information from the online application appears in a different color. The worker compares any contradictory information and determines which to keep before submitting the information to the legacy system. The legacy system maintains an indicator noting which applications Maryland (continued) A.92 were filed online. The narrative section of the application may be printed from SAIL; soon, caseworkers will be able to do so from the eligibility system. With regard to measures, Maryland staff noted that the counts of the total number of screenings and total number of applications started include counts from those who may not be serious about applying\u2014 without a way to track why people abandon the screener or the application, they are limited in what they can learn from the measures. Document Imaging: Maryland does not have document imaging. Kiosks: Maryland does not have kiosks. Waiver of Face-to-Face Interview: Maryland tracks whether an interview occurred via telephone, mail-in, or group intake, so with a special query, they can report the percentage of interviews from each source but this is not regularly reported. They could also examine case characteristics by interview type using a special query. They track when an applicant has a language barrier. Shortened Interviews: Maryland does not have a shortened interview initiative. Online Expedited Applications: No information reported. Application Tracking: When examining application accuracy, Maryland tracks error codes in addition to those required by FNS when examining application accuracy. They use the quality control reviews to identify training opportunities. Changes Over Time: None reported. Desired or Planned Future Measures: Maryland would like to systematically track the approvals and denials of applications submitted by partners, which they can currently only do on an ad hoc basis. They also indicate that with online applications, having a national database of participants would assist them in preventing individuals from receiving benefits in multiple states, without waiting for the quarterly review currently conducted. Partnering: Maryland has seven formal outreach partners receiving compensation and several informal partners not receiving compensation. Among formal partners, two provide assistance with paper submission of applications (delivering them to a local office) and five provide assistance with submitting applications through SAIL. They are compensated for their expenditures toward assisting SNAP clients. Informal partners provide assistance with submitting applications through SAIL. They must sign a confidentiality agreement. Partners do not have special access to SAIL, but they do enter identification codes so that the application can be tracked back to their organization. Maryland also partners with a contractor to maintain and support SAIL. Measures Collected by Partners: The contractual arrangements that Maryland makes with partners do not require a specific level of application submissions or approvals. The company maintaining the on- line system must ensure the system is operational 99.3 percent of the time. They report additional system measures, such the system response time. For their own purposes, they collect the measures at a finer level of detail than required by the state. Some of the outreach partners also set their own goals for the number of applications submitted, even though the state does not set a minimum level of assistance. A.93 Profile: Massachusetts State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 5 Number of Partners Interviewed: 3 Initiatives Active in State: Call Center, Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Number of Applications Processed: Call Center Locally None Not reported Not reported ONLINE SYSTEM (Statewide) Average Number of Screenings Completed: Online Statewide Program Access, Efficiency, Customer Service No No Average Number of Screenings Started: Online Statewide Program Access, Customer Service No No Average Number Started per Month Statewide Program Access, Efficiency, Customer Service Yes, not specified No Average Time to Complete Screening Statewide Program Access, Efficiency, Customer Service No Not sure Number of Abandoned Applications Statewide Efficiency, Customer Service No Not sure Number of Applications Started Statewide Program Access, Efficiency, Customer Service Not sure Not sure Percent of First-Time Applications Approved Statewide Program Access, Efficiency, Customer Service Minimum of 50 percent No Percent of First-Time Applications Denied Statewide Program Access, Efficiency, Customer Service 40 percent No Number of Online Accounts Created Statewide Program Access, Efficiency, Customer Service No Not sure Percent of Applications Received Statewide Program Access, Efficiency, Customer Service 40 percent No Percent of Multiple Applications Statewide Efficiency No No Massachusetts (continued) A.94 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Program Access, Efficiency This measure should always be at 100 percent Partners receive set amount per application they submit on behalf of their clients if the application got approved for SNAP benefits Number of Partners Statewide Program Access, Efficiency, Customer Service No No Number Accepting Applications Statewide Program Access, Efficiency, Customer Service Reimburse- ments based solely on number of applications submitted\/ approved Cost reimburseme nt Number Providing Application Assistance Statewide Program Access, Efficiency, Customer Service No Not sure Number Clients Assisted per Partner Statewide Program Access, Efficiency, Customer Service Yes, agencies must submit a certain number of applications per month\/ quarter (varies based on agency size and resources) Yes, reimburseme nt to these agencies based solely on the number of applications they submitted and were approved Number of Applications Received per Partner Statewide Program Access, Efficiency, Customer Service Agencies must submit a certain number of applications per month\/ quarter (varies based on agency size and resources) Financial incentives (not specified) WAIVER OF FACE-TO-FACE INTERVIEWa (Statewide) Percent of Interviews Conducted by Telephone Statewide Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Interviews Conducted Face-to-Face Statewide Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Massachusetts (continued) A.95 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity Yes, Annual performance goals set with USDA Yes, Annual performance goals set with USDA Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity Yes, Annual performance goals set with USDA Yes, Annual performance goals set with USDA Total Number of Interviews Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Accuracy & Integrity, Efficiency, Customer Service State has a waiver for certain elderly\/ disabled cases at recertifica- tion Annual performance goals set with USDA Number of Face-to-Face Interviews Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Telephone Interviews Statewide Accuracy & Integrity, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Number of Applications Approved: Mailed Statewide Accuracy & Integrity, Efficiency, Customer Service Generally expected at 70 percent Not sure Number of Recertifications Approved: Mailed Statewide Accuracy & Integrity, Efficiency, Customer Service No Not sure Number of Applications Approved: Face-to-Face Interviewed Statewide Accuracy & Integrity, Efficiency Not sure Not sure Percent of Community Partner Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Partners are paid for approved applications Partners are paid for approved applications so there is financial incentive to improve this percentage Percent of Applications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Generally expected at 70 percent Not sure Percent of Recertifications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Massachusetts (continued) A.96 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Expected minimum of 50 percent Participating agencies receive financial incentive for submitting approved applications Percent of Mailed Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Generally expected at 70 percent No Percent of Mailed Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 70 percent is generally expected No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, 70 percent is generally expected No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Accuracy & Integrity No No Number of Applications Approved: Paper Submission to Local Office Statewide Accuracy & Integrity, Efficiency, Customer Service No Not sure Number of Recertifications Approved: Paper Submission to Local Office Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online Statewide Accuracy & Integrity, Efficiency, Customer Service 50 percent minimum (for participating agencies) Financial incentives for outreach participating agencies Number of Applications Approved: Community Partner Statewide Accuracy & Integrity, Efficiency 50 percent minimum (for participating agencies) Financial incentive for participating agencies Number of Applications Approved: Faxed Statewide Accuracy & Integrity, Efficiency, Customer Service Not reported Not sure Number of Recertifications Approved: Face-to-Face Interviewed Statewide Accuracy & Integrity, Efficiency No Not sure Number of Applications Approved: Phone Interviewed Statewide Accuracy & Integrity, Efficiency, Customer Service No Not sure Massachusetts (continued) A.97 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Phone Interviewed Statewide Accuracy & Integrity, Efficiency, Customer Service No Not sure Percent of Applications: Online Statewide Program Access, Efficiency, Customer Service Goal set at 40 percent No Percent of Applications: Community Partner Statewide Program Access, Efficiency, Customer Service No Some community partners will be reimbursed for costs associated with application assistance Total Number of Applications Started Statewide Program Access, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service Goal is set for 40 percent (of total applications received) No Number of Applications: Community Partner Statewide Program Access, Efficiency, Customer Service No No Percent of Online Applications Denied for Failure to Submit Documentation Statewide Accuracy & Integrity, Customer Service No No Percent of Online Recertifications Denied for Failure to Submit Documentation Statewide Accuracy & Integrity, Customer Service No No Percent of Online Applications Denied for Failure to Complete Interview Statewide Accuracy & Integrity, Customer Service No No Percent of Initial Applications Denied Statewide Accuracy & Integrity, Customer Service No No Number of Applications Denied: Online Statewide Program Access, Accuracy & Integrity, Customer Service Generally expected to be less than 50 percent No Number of Applications Denied: Community Partner Statewide Program Access, Accuracy & Integrity, Customer Service Generally expected to be less than 50 percent No Massachusetts (continued) A.98 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Application Decision Statewide Efficiency, Customer Service Goal set for 17 days average No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. BEACON is the Massachusetts state eligibility system. aThe Massachusetts waiver of face-to-face interviews cannot have a detrimental effect on timeliness and accuracy. This is reflected in their standards. Description: General: The Massachusetts Department of Transitional Assistance (DTA) reported that they lead all initiatives and performance measurement, so there is much standardization across all offices. Two exceptions are the call center and waiver of face-to-face interviews. The call center has been set up in two local offices only, one of which tracks performance data on it. The waiver of face-to-face interviews has not yet been established in one local office. The state office generates reports and distributes them to the local offices, and offices can also run ad-hoc queries as needed. Staff reported that Massachusetts is generally satisfied with the quality and accuracy of their data. They reported working carefully on their data warehousing system so that most data they need can be meaningfully retrieved or compiled through it. They noted some concerns on the accuracy of the waiver of face-to-face interview measures, due to staff error and the difficulty of finding someone with the business knowledge and technical skills to run the required reports, and timely processing measures, because a case cannot be denied until day 30 even if it is clearly ineligible. It can also be difficult to code the type of application (brand new, recertified, expedited benefits, reinstated), which makes approval rates and recertification measures harder to accurately capture. Measurement Goals: Massachusetts' performance measures touch on all FNS goals for modernization. Their offices also use data for management purposes, staffing and workflow, addressing operational issues, reporting for researchers and legislature, and FNS or Executive Office of Health and Human Services (EOHHS) requirements. Call Center: The state worked with a contractor to establish two local call centers. One office collects the number of applications processed at their call center, but Massachusetts does not track any performance data on call centers beyond this. Because the offices received money to establish the call centers, the state had been requiring a greater level of reporting. They have not used call center data in the past two years. Online System: The online application was designed and built by a contractor to incorporate multiple benefit programs in the state. By default, the system can produce various reports that show the online system measures. The state office collects measures on the percent of applications received, percent of first-time applications approved\/denied, and percent of multiple applications. They also look at averages and counts of aggregate data, such as average number of screenings started\/completed, average time to complete screening, and average number of applications started\/submitted per month. Document Imaging: Massachusetts has not implemented document imaging. Massachusetts (continued) A.99 Kiosks: Neither Massachusetts state nor local offices participating in the study have set up kiosks for application access and submission. Waiver of Face-to-Face Interview: The Massachusetts state office reports the percent of interviews conducted by type (face-to-face and telephone) and the error rate for cases by type (face-to-face and telephone), in addition to collecting some aggregate data. Shortened Interviews: There is no shortened interview initiative in Massachusetts. Online Expedited Applications: Massachusetts reported that expedited applications can be submitted online, but did not provide us with further information. Application Tracking: The Massachusetts state office has many measures and aggregate data on application accuracy, approvals\/denials, application receipt, and processing time. The state records the origin of applications by their source on hard copy applications and within their eligibility system. They break down origin into the following categories: walk-in, online (via partner or consumer), fax, mail or other (such as a home visit). One local office we interviewed tracks applications by origin but they do not have any performance measures or data. Massachusetts staff noted that it is difficult to clearly distinguish new applications from recertifications from the system perspective, and that they are currently working on making this easier. In the past there were three indicators: was the case previously active, is the case currently active, is the application a reinstated case. A combination of these indictors is used to determine if the application is new. These questions are not asked in the application process, so the information must be obtained through the system instead. Changes Over Time: Massachusetts began recording the type and number of interviews provided to applicants about one and a half years ago. Staff reported that no other measures have changed in the past year. Partnering: All partnering arrangements are coordinated out of the state office. Massachusetts staff reported that both formal partnership (that involves federal FFP funding channeled back to partnering agencies) and informal partnership (that does not involve funding) initiatives are in place. Massachusetts tracked the actual expenditure data for eight partnering agencies participating in their outreach initiative during the first quarter of 2010. The state reported that they look at the percent of partners providing applications assistance. They also review the number of partners, number of partners accepting applications, number of partners providing application assistance, number of clients assisted per partner, and number of applications received per partner. Measures Collected by Partners: At the time of the interview, the state office was designing partnering contracts. They planned to track percent of community partner applications approved and set a benchmark of 50 percent approval rate for submissions within the first year. This will be tracked by the state, rather than the partner. Partners will not be required to collect any performance data beyond what can be accessed automatically from the Virtual Gateway. Massachusetts partners reported collecting data on: percent eligible and not eligible for prescreens; percent eligible and not eligible for application assistance; percent of screenings eligible and not eligible; percent of applications approved and denied; percent of applications submitted by origin (online versus paper); number of household approved for SNAP benefits; and number of applications submitted by site. Massachusetts (continued) A.100 Desired or Planned Future Measures: The state is in the process of updating their eligibility system and the data warehouse. This will facilitate presentation of the data and streamline calculations. They are also working on a partnering outreach initiative this year. Under this program they will use federal money to reimburse non-profit organizations for approximately half of their application assistance costs. This program will also set up benchmarks and incentives related to approvals for applications submitted via partners. The state plans to revise their method for tracking application source, in order to better track which agencies are submitting applications. One local office would be interested in seeing performance measures (percentages) and aggregate data (numbers) on the approval rate and reason for incomplete and denied applications, in an effort to decrease their denial rate. Another local office would like to see all states report on the length of time to process applications and the percent of recertifications processed timely, in order to learn more about states' ability to process work. A.101 Profile: Michigan State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 1 Number of Partners Interviewed: 1 Initiatives Active in State: Online System, Kiosks, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) Number Submitted per Day Statewide Program Access, Efficiency, Customer Service No No Average Number of Accounts Created per Month Statewide Efficiency, Customer Service No No Average Number of Changes Submitted per Month Statewide Efficiency, Customer Service No No Percent of Screened Individuals Potentially Eligible: Online Statewide Not reported Not reported Not reported Percent of Screenings Resulting in Application Submission: Online Statewide Not reported Not reported Not reported Percent of Screenings Resulting in Applicant Receiving Benefits: Online Statewide Not reported Not reported Not reported Number of Online Screenings Started: Online Statewide Not reported Not reported Not reported Average Number of Screenings Started: Online Statewide Not reported Not reported Not reported Average Number of Screenings Completed: Online Statewide Not reported Not reported Not reported Percent of Users Selecting Spanish Language Statewide Not reported Not reported Not reported Number of Online Screenings Completed: Online Statewide Not reported Not reported Not reported Number of Applications Downloaded Statewide Not reported Not reported Not reported Number of Applications with Filing Date Only Statewide Not reported Not reported Not reported Number of Applications Submitted With All Application Questions Answered Statewide Not reported Not reported Not reported Michigan (continued) A.102 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications Received Statewide Not reported Not reported Not reported Average Number Started per Month Statewide Not reported Not reported Not reported Average Number Submitted per Month Statewide Not reported Not reported Not reported Percent of Applicants with Hardship Reason for Requesting Phone Interviews Statewide Not reported Not reported Not reported Average Level of Benefits Statewide Not reported Not reported Not reported Average Number of Changes Submitted per Month Statewide Not reported Not reported Not reported Number of Online Accounts Created Statewide Not reported Not reported Not reported Number of Changes Submitted Statewide Not reported Not reported Not reported KIOSKS (Statewide) None PARTNERING (Statewide) Number with Terminals\/Kiosks to Submit Application Statewide Program Access, Efficiency, Customer Service No No Number of Clients Receiving Application Assistance Statewide Program Access, Efficiency, Customer Service No No Number of Partners Statewide Program Access, Efficiency, Customer Service No No Number Accepting Applications Statewide Program Access, Efficiency, Customer Service No No Number Providing Application Assistance Statewide Program Access, Efficiency, Customer Service No No Number of Applications Received per Partner Statewide Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access, Efficiency, Customer Service No No Percent of Interviews Conducted Face-to-Face Statewide Accuracy & Integrity No No Percent of Telephone Interview Requests Honored Statewide None No No Michigan (continued) A.103 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Total Number of Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Home Visit Interviews Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Missed Interviews Statewide Program Access, Accuracy & Integrity, Customer Service No No Notice of Missed Interview Mailed Statewide Program Access, Accuracy & Integrity, Customer Service No Yes Percent that are Missed and have Notice Mailed Locally Not reported Not reported Not reported Error Rate for Cases with Telephone Interviews Locally Not reported Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Locally Not reported Not reported Not reported Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Number of Applicants Requesting an In-Person Interview Locally Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications Approved: Online All Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Expedited Applications Received Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online Expedited Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Michigan (continued) A.104 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Approved: Online All Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure APPLICATION TRACKING (Statewide) Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Accuracy & Integrity Not sure Not sure Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service Not sure Not sure Number of Applications Approved: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Applications Approved After Paper Submission to Local Office Statewide Not reported Not reported Not reported Percent of Recertifications Approved After Paper Submission to Local Office Statewide Not reported Not reported Not reported Percent of Mailed Applications Approved Statewide Not reported Not reported Not reported Percent of Mailed Recertifications Approved Statewide Not reported Not reported Not reported Percent of Total Recertifications Approved Statewide Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Statewide Not reported Not reported Not reported Number of Applications Approved: Mailed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Mailed Statewide Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Michigan (continued) A.105 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications: Community Partner Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications: Kiosk Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applications: Faxed Statewide Not reported Not reported Not reported Percent of Applications: Mailed Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Recertifications: Paper Submission to Local Office Statewide Program Access, Customer Service No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Applications: Community Partner Statewide Efficiency, Customer Service No No Number of Recertifications: Community Partner Statewide Efficiency, Customer Service No No Michigan (continued) A.106 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Kiosk Statewide Efficiency, Customer Service No No Percent of Recertifications: Online Statewide Not reported Not reported Not reported Total Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Recertifications Started Statewide Not reported Not reported Not reported Number of Recertifications: Online Statewide Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Not reported Not reported Not reported Number of Applications Denied: Online Statewide Program Access, Customer Service No No Number of Applications Denied: Community Partner Statewide Program Access, Customer Service No No Percent of Online Applications Denied for Failure to Submit Documentation Statewide Not reported Not reported Not reported Percent of Online Recertifications Denied for Failure to Submit Documentation Statewide Not reported Not reported Not reported Percent of Complete Recertifications Denied Statewide Not reported Not reported Not reported Percent of One- page\/Requests for Assistance Denied Statewide Not reported Not reported Not reported Percent of Initial Applications Denied Statewide Not reported Not reported Not reported Percent of Recertifications Denied Statewide Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Statewide Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Statewide Not reported Not reported Not reported Michigan (continued) A.107 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Denied: Online Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Applications with Incomplete Information Statewide Not reported Not reported Not reported Percent of Recertifications with Incomplete Information Statewide Not reported Not reported Not reported Number of Cases with Complete Verification Submitted Statewide Not reported Not reported Not reported Average Processing Time of Application Decision Statewide Not reported A determination must be made for online applications within the standard of promptness. FNS looks at timeliness for all applications that are processed Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. SOP = Standard of Promptness (all online expedited applications must be processed within six days) The FS-100 report is a Michigan document with data on waivers. It became available annually effective January 2011. Description: General: The Michigan state office directs all modernization efforts and leads performance measurement and reporting. Local offices receive monthly accuracy reports from the state, and they can pull state-compiled reports from the BRIDGES (computerized eligibility) system. Michigan noted that they are working to resolve issues with reporting accuracy, access to the online system, collecting data elements, and worker input errors. Three of Michigan's four contracted partners received ARRA funding. Of those, one partnership was newly created using only ARRA funds. The other two partners used the funds to grow outreach activities, expanding senior center locations and creating a food assistance hotline. Staff interviewed reported that these initiatives would not have been implemented or would have been delayed without ARRA funds. Measurement Goals: Michigan's performance measures touch on all four FNS goals. Michigan emphasized that their initiatives, standards, and incentives are all driven by FNS guidelines and requirements. Call Center: Michigan has not implemented a call center. Michigan (continued) A.108 Online System: Michigan developed a state-wide online application system that was implemented in 2010. They track three counts of aggregate data: number of applications submitted online per day, number of accounts created per month, and number of changes submitted per month. Document Imaging: Michigan does not have a document imaging initiative in place. Kiosks: Michigan has set up kiosks in some local and partner offices for online screening and application, change reporting, and checking and printing benefit summaries. They do not track any data on their kiosks. Waiver of Face-to-Face Interviews: Michigan collects performance measures and data on their waiver, including: percent of interviews by type (telephone versus face-to-face), the percent of telephone interview requests honored, and the percent of interviews that are missed and have a notice mailed. In addition, the state office records certain case characteristics, such as whether a household has an elderly person or English language learner. Shortened Interview: The state office and the local office interviewed do not offer a shortened interview process. Online Expedited Applications: The Michigan state office records the percent of applications approved (all online and expedited online), the number of expedited applications received online, and the number of applications approved (all online and expedited). If needed, the state office could produce a special query reporting case characteristics of expedited and regular applications according to demographics and\/or approval status. Application Tracking: Michigan reports numerous application tracking measures from the state office, especially in the areas of application accuracy, receipt, and approvals. While the state office differentiates applications by source, the local office interviewed does not. Changes Over Time: Michigan recently instated its BRIDGES eligibility system and a second party review system. Desired or Planned Future Measures: One local Michigan office would like to see a faster turn- around time at the local level for error rate reporting. Currently local offices must wait for these data to come from the state, but they would prefer having the capability to pull their own weekly reports. This does not seem feasible to them, as error rates are not reported until the state goes through the QC process. Michigan also reported a desire to track telephone and face-to-face interviews at finer levels of detail. Partnering: Michigan has four formalized, contract-based partnering arrangements and 397 registered community partners (any group that signs up to act as a partner). Many more partners may exist who choose not to register. Michigan monitors the cost of each of their partner contracts. Partners provide application access and assistance. Each of the four, formalized partners has a kiosk. Measures Collected by Partners: Michigan monitors service provision and funding for the four formalized partnerships. One component of this is an activity report provided on a monthly and yearly basis by each partner. Partners must track the number of clients served (via which services) and the number of applications submitted. Depending on the contract, partners may also collect information on the number of applicants deemed eligible, benefit amounts, and case characteristics. One partner interviewed looks at the discrepancies between screening estimates and the actual amount of benefits paid out, as well as differences between their eligibility system and the state's. They report three aggregate counts to the state: screening outcomes, summaries of issues, and the primary sources of referrals to their helpline. A.109 Profile: Minnesota State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 4 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Average Answer Speed Locally Efficiency, Customer Service 5 minutes (or less) No Average Hold Time Locally Efficiency, Customer Service No No Percent Calls Abandoned Locally Efficiency, Customer Service The office established a benchmark input from the workers No Average Call Duration Locally Efficiency, Customer Service No No Average Waiting Time (to Speak to Agent) Locally Efficiency, Customer Service No No Average Calls Handled Locally Efficiency, Customer Service No No Percent of Total Calls Handled Locally Efficiency, Customer Service No No Average Queue Time Locally Efficiency, Customer Service No No Average Time to De- Queue Locally Efficiency, Customer Service No No Average Time Prior to Abandonment Locally Efficiency, Customer Service No No Average After-Call Work Time by Staff Locally Efficiency, Customer Service No No Percent of Queued Calls Handled Locally Efficiency, Customer Service No No Number of Calls (in flow) Locally Efficiency, Customer Service No No Number of Calls Abandoned Locally Efficiency, Customer Service Not reported Not reported Number of Calls Queued Locally Efficiency, Customer Service Not reported Not reported Number of Calls Answered\/Handled Locally Efficiency, Customer Service Not reported Not reported Percent of Calls Completed in the Computer Phone System Locally Efficiency, Customer Service No No Number of Clients Accessing Computer Phone System Data Locally Efficiency, Customer Service Not reported Not reported Number of Calls Received Locally Efficiency, Customer Service Not reported Not reported Minnesota (continued) A.110 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Hang-ups Locally Efficiency, Customer Service Not reported Not reported Number of Calls Not Completed in Computer Phone System Locally Efficiency, Customer Service Not reported Not reported Number of Calls Completed in Computer Phone System Locally Efficiency, Customer Service Not reported Not reported Number of Client Calls Returned Locally Efficiency, Customer Service Not reported Not reported DOCUMENT IMAGING (Regionally) Percent of Documents Scanned Locally Efficiency No No Percent of Documents Received by Mail Locally Efficiency No No Percent of Documents Received by Fax Locally Efficiency No No Average Processing Time Locally Efficiency No No Number of Documents Received Locally Not reported Not reported Not reported Number of Documents Received: Mail Locally Not reported Not reported Not reported Number of Documents Received: Fax Locally Not reported Not reported Not reported Number of Documents Received: Other Electronic Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Number of Documents Scanned Locally Not reported Not reported Not reported Number of Tasks Completed Locally Not reported Not reported Not reported PARTNERING (Regionally) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) Average Benefit Amount (for those eligible) Statewide Program Access, Customer Service No No Minnesota (continued) A.111 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Total Applications Approved Locally Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Recertifications Approved Locally Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Approved Locally Not reported Not reported Not reported Total Number of Recertifications Approved Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applicants that Appear Eligible for Expedited Benefits Locally Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications: Expedited Locally Not reported No No Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Application Processing Time for Approvals for Initial Applications Statewide Efficiency, Customer Service FNS standards FNS incentives Average Processing Time of Application Decision Locally Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. The MAXIS system requires a lag of a few months on some data pulled from it. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: SNAP in Minnesota is state supervised and county administered. The extent of their modernization initiatives and performance measurement varies by county. Of counties we interviewed, only one office has implemented a call center, and it is one of two offices interviewed with a document imaging system. This office collects call center, document imaging measures, and application tracking measures. Minnesota (continued) A.112 Minnesota county offices receive some data through monthly state reports. The reports show the number of applications, the number of expedites, and programs for new application or recertification. Staff in one county office noted that these reports are of limited use. The MAXIS system is 20 years old and presents a barrier to collecting more information. Information is manually entered into the MAXIS system and transferred to a data warehouse. Not all of the information in the MAXIS system can be transferred to the data warehouse because the state does not have the resources to add fields to the data warehouse. The system can produce point-in-time reports of all pending cases by worker and the number of days pending. It cannot distinguish the type of application (new, repeat, or recertification) or the reason for denial, and it cannot differentiate by program (SNAP, Medicaid, etc.) or calculate any performance measures. In Minnesota, application determinations can take longer than 30 days, because workers give applicants more time to supply verification documents. Thus the data used for performance measures are always lagged by at least two months. The state has no official start and stop time when determining processing time. Measurement Goals: Minnesota's performance measures touch on all FNS goals for modernization, with a focus on efficiency and customer service for call center measures. Minnesota offices also track measures for state-conducted management evaluations and to identify potential lags in information availability. Call Center: One county in Minnesota operates a call for all social services programs (not specific to SNAP). They collect numerous performance measures and counts of aggregate data. Online System: Minnesota has no online application system. Document Imaging: Document imaging is handled at the local level in Minnesota, and half of the local offices interviewed reported having document imaging capabilities. One office reported collecting performance measures on percent of documents scanned, percent of documents received by mail and fax, and average processing time, as well as several sets of aggregate data. Kiosks: Minnesota has not implemented kiosks in the state or local offices. Waiver of Face-to-Face Interview: While Minnesota has a waiver of face-to-face interviews in place, the state and local offices do not collect any performance measures on this initiative. Every office records the type of interview (face-to-face versus telephone) in the MAXIS system or case narrative, but there is no corresponding field in their data warehouse system. Therefore, Minnesota cannot calculate any performance measures from this information. According to staff interviewed, creating measures tied to this initiative is not a priority for the state office because data warehouse systems are extremely expensive, they are facing staff layoffs, and FNS did not require any performance measures with the waivers. Partnering: Any Minnesota partnerships would be overseen at the state level because SNAP is county- administered. The state office did not report any partnerships and no local offices reported official partnership arrangements. One office has contracts with food distribution and public application assistance organizations (food shelves, case management groups), but these relationships are not specific to SNAP. Other offices reported informal associations, wherein community agencies provide SNAP information or refer clients to the county office to complete applications. Measures Collected by Partners: Not applicable. Minnesota (continued) A.113 Shortened Interviews: Minnesota does not use shortened interviews. Online Expedited Applications: Minnesota has no online application system. Application Tracking: All Minnesota applications are delivered to county offices. While the state tracks three measures (average benefit amount, percent of complete applications denied, application processing time for approvals for initial applications), the majority of performance measurement for this initiative is done at the local level. Only one local office that we spoke to tracks its applications by origin. This office separates applications received through a partner from all other application sources. Changes Over Time: The Minnesota state office has been calculating application tracking data in the same way for over ten years. Minnesota local offices noted no changes in data collection or reporting in the past year. Desired or Planned Future Measures: Minnesota offices expressed few plans for future expansions in their measurement or reporting. According to staff we interviewed, the data warehouse systems currently in use are expensive and only programmed to calculate certain measures. Due to staff layoffs and budget constraints, additional measures have to be high priority to add fields to the data warehouse system. One local office was interested in knowing the number of face-to-face interviews conducted and plans to perform a quarterly analysis of trends in monthly performance data. Additionally, this office has recently deployed surveys on customer service in an effort to identify areas for improvement. A.114 Profile: Mississippi State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Document Imaging, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives DOCUMENT IMAGING (Statewide) Number of Documents Received Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified The staff Performance Appraisal Rating (PAR) is based on data from the system reviews Number of Documents Scanned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Review of all documents with 100 percent accuracy rate. The staff PAR is based on data from the system reviews. Number of Documents Per Case Statewide Customer Service No No Average Processing Time Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Number of Tasks Completed Locally Not reported Not reported Not reported Percent of Documents Scanned Locally Not reported Not reported Not reported Number of Alerts Processed Locally Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Applications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Mississippi (continued) A.115 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Approved: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications Approved: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Approved: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications Approved: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications Not Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Mississippi (continued) A.116 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Total Number of Applications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Recertifications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications: Faxed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications: Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Requests for Assistance\/One-page Applications Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Mississippi (continued) A.117 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of One- page\/Requests for Assistance Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications with Incomplete Information Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications with Incomplete Information Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Cases with Complete Verification Submitted Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide . If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Mississippi (continued) A.118 Description: General: Mississippi conducts telephone interviews using the hardship waiver. Within the last year, they began using document imaging. Local offices primarily use state data and reports to measure performance. State staff noted that Mississippi has reduced the length of their SNAP application from 24 down to 2 pages, in order to ease the burden on workers with high caseloads. Mississippi reports that they use an expanded definition of the hardship waiver, allowing staff to conduct many interviews via telephone. (The state did not report an official waiver for face-to-face interviews). Local county offices track a wide variety of performance data for interviews conducted face- to-face and over the telephone for both initial applications and redeterminations, including the total number of interviews, percent of interviews by type, number of times unable to schedule an interview with an applicant, error rates for cases with telephone and face-to-face interviews, number of applicants requesting phone interviews, and percent of telephone interview requests honored. These measures are not tied to any modernization initiative, and are therefore not included in the table above. Measurement Goals: Mississippi measures performance to ensure program access, accuracy and integrity, efficiency, and customer service. Call Center: Mississippi does not have a call center initiative. Online System: Mississippi does not have an online system for screening or application. Document Imaging: The document imaging system has been in place since mid-2010. Mississippi records the number of documents received and scanned and the counties they came from, however they do not record the source of documents to be imaged (mail, fax, etc.). Local offices we interviewed reported that they track the number of documents processed, tasks completed, and alerts processed, in addition to average processing time. One local office noted that all quality control for imaging is manual and that there is no automated report to check at this time. Kiosks: Mississippi does not have kiosks for screening and application submission. Waiver of Face-to-Face Interview: Mississippi did not report having a waiver of face-to-face interviews. Shortened Interviews: Mississippi did not report having a shortened interview initiative. Online Expedited Applications: Mississippi does not have online expedited applications. Application Tracking: Mississippi tracks measures related to applications and recertifications, including the percentage received, approved, and denied, and the average benefit of those who are eligible. They also calculate the average processing time and percent of applicants that appear eligible for expedited benefits. Mississippi also calculates accuracy measures based on federal guidelines. Accuracy measures are used for QC review, as well as internally to review cases for training and management purposes. With all application tracking measures, state staff noted their motivation is to ensure accuracy, and that the information from application tracking measures is part of the performance review process for individual staff. However, there are no measure-specific standards or incentives. Staff reported that they measure timeliness in a way that differs from the QC process. Specifically, they said that data from the QC sample is too old for caseworkers to use to track timeliness of their own work. Partnering: Mississippi does not have partnering arrangements. Measures Collected by Partners: Not applicable. Mississippi (continued) A.119 Changes Over Time: Mississippi began imaging documents in mid-2010. The application and interview process overall were both shortened within a year of data collection for this study. In addition, the state added functionality to the eligibility system. Each screen in the eligibility system is now linked to a comment screen, and if a document is scanned, hot key links exist between the eligibility page and the scanned document and they can both be viewed at the same time. Desired or Planned Future Measures: None reported. A.120 Profile: Missouri State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Partnering, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls Received Statewide None No No PARTNERING (Regionally) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity No No Number of Applications Approved Statewide Program Access, Accuracy & Integrity No No Average Benefit Amount (for those eligible) Statewide Program Access No No Number of Applications: Mailed Statewide Program Access; Customer Service No No Number of Recertifications: Mailed Statewide Program Access; Customer Service No No Number of Applications Denied Statewide Program Access, Accuracy & Integrity No No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access No No Average Processing Time of Application Decision Statewide Program Access, Efficiency No No Average Processing Time of Recertification Decision Statewide Program Access, Efficiency No No Application Currency Statewide Program Access, Efficiency Benchmark of 95 percent Corrective action plans are required if application currency falls below 95 percent Expedited Currency Statewide Program Access, Efficiency Benchmark of 95 percent Corrective action plans are required if expedited currency falls below 95 percent Missouri (continued) A.121 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Claims Processing Currency Statewide Program Access, Efficiency Benchmark of 90 percent Corrective action plans are required if claims processing currency falls below 90 percent. Also, FNS could take away state's option\/thres hold if benchmark is not met. Number of Applications: Online Locally Customer Service No No Number of Applications: Faxed Locally Customer Service No No Number of Applications: Mailed Locally Customer Service No No Number of Applications: Paper Submission to Local Office Locally Customer Service No No Percent of Applications: Paper Submission to Local Office Locally Customer Service No No Percent of Applications: Online Locally Customer Service No No Percent of Applications: Faxed Locally Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Missouri has a limited state-run call center. Partnerships are maintained on an informal basis. Applications are available for download on the Department of Children and Family Services (DCFS) website. The site also links to the FNS prescreening tool, but this does not pre-populate the application. Missouri does not have a waiver of the face-to-face interview, though they make use of the hardship waiver to conduct telephone interviews. The type of interview (telephone versus face-to-face) is recorded in each case's narrative section, in addition to the reason for using the waiver. If this information is needed, it must be manually retrieved from each case; there is no easy or quick way to compile statistics on this. Measurement Goals: Missouri tracks error rates with the goal of program access as well as accuracy and integrity. They track the percentage of applications denied and approved for program Missouri (continued) A.122 access and integrity. Timeliness measures (also known as currency measures) relate to efficiency and program access. Overall, program access is an overarching goal for all these measures. At the local level, monthly totals of applications received through all methods are tracked to enhance customer service. Call Center: Missouri has a call center that only consists of an Automated Voice Response System. It operates around the clock, and clients can call to find automated information about: whether their benefits are available and on what date they are available; what the benefit amount is; and what month their certification is set to expire. Prior month's information is also available. The system has 96 phone lines, 12 of which are for SNAP callers (the rest service other DCFS programs). State staff reported that they only track the number of calls received. Reports are produced monthly but no actions are taken based on the reports. Online System: Missouri does not have an online system for screening and application submission for SNAP (but does have a system for the Children's Health Insurance Program and Medicaid). Applications for SNAP are available for download on the DCFS website. The site also links to the FNS prescreening tool, but this does not pre-populate the application. Document Imaging: Missouri does not have document imaging. Kiosks: Missouri does not have kiosks. Waiver of Face-to-Face Interview: Missouri does not have a waiver in place. Shortened Interviews: Missouri does not have a shortened interview initiative. Online Expedited Applications: Missouri does not accept expedited applications online for SNAP. Application Tracking: At the local level, clerical staff manually capture the number of applications received via mail, in-person drop-off, fax, or online. Monthly counts are compiled and tracked. One local office we spoke with also tracks the percentage of applications received via mail, online, paper, and fax. However, the state eligibility system only has two codes for tracking the method of application delivery: mail-in and in-person. As a result, mail-ins, drop-offs, and faxed applications are coded as mail-in in the eligibility system. All applications are screened for expedited service. In addition to the required quality control measures, Missouri has its own case review system that operates at the county level. For the FNS QC process, they read about 120 cases per month, whereas about 9,000 to 10,000 cases are read each month for their internal case review system. Most of these cases are for SNAP (4,000-5,000 cases). The state's QC unit looks at all Case Review System reports, QC reports, and other data. They also work with the counties to identify trends that need to be addressed and develop Corrective Action Plans. The calculation for application timeliness (or currency) differs from the FNS calculation. Missouri focuses on whether eligibility is determined within 30 days, not on whether applicant receives benefits within 30 days. Because of this difference, Missouri does not know their official application timeliness until FNS sends them six-month updates. Changes Over Time: None reported. Partnering: One county has a long-standing relationship with both the two partners. These partners keep paper applications available to improve access to the program. Measures Collected by Partners: We did not interview partners in Missouri for this study. Missouri (continued) A.123 Desired or Planned Future Measures: Missouri staff reported that they would like to have a document imaging system, but they are currently satisfied with the collection of performance measures from their current system. At the local level, offices would like to have data on reasons for denial. The data are currently captured by the system, but reports are not available. Because clerical staff manually record the method by which applications are received, one local office interviewed is currently looking into an electronic means of tracking. A.124 Profile: Montana State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Partnering, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEMa (Statewide) Number of Online Applications Submitted Locally Program Access, Efficiency, Customer Service No No PARTNERING (Statewide) None ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Average Benefit Amount (for those eligible) Statewide No No Applications Not Timely Statewide Efficiency Federal benchmarks are used No Number of Applications: Paper Submission to Local Office Locally Program Access, Customer Service No No Denials for Expedited Applications by Reason Statewide Not reported Not reported Processing Time Report Statewide Federal timeliness standards are used Federal benchmarks are used Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. a Online system was launched in December 2010, after our interview with the state office staff. Description: General: Montana has a new online application system that was launched following our interview with the state agency staff but prior to our interviews with local staff. In general, state and local offices collectively record a limited number of measures, primarily in relation to application tracking. Local offices in Montana do not receive reports from the state, although the state generates a monthly report with county break-downs of application tracking data that is posted on their public website. At the time of the interview, Montana was working toward putting a document imaging initiative in place. Measurement Goals: Montana's measures pursue the FNS goals of program access, efficiency, and customer service. Montana (continued) A.125 Online System: The online application system in Montana is new as of December 2010. One local office reported that they collect the number of online applications submitted. The state may collect additional measures that are not shown here because of the timing of our data collection. Call Center: Montana does not operate a call center. Document Imaging: Montana has not established a document imaging system. Kiosks: Montana has not set up kiosks. Waiver of Face-to-Face Interview: Montana does not have a blanket waiver. They only have a waiver for instances of hardship. Shortened Interviews: Montana did not report having shortened interviews. Online Expedited Applications: The online application system in Montana is new as of December 2010. Montana did not report any measures related to online expedited applications. Application Tracking: State and local offices collect some measures and data on application approvals, receipt, and processing time. At the time of the interview, local offices were recording or planning to record whether applications were delivered online. Changes Over Time: Montana has not changed the way their data are collected or reported recently. At the state's request, one local office did a monthly cross-check of application status to compile a tally of applications approved within the reporting month, but they no longer do this. Another local office tracked applications received through partners, but they discontinued this practice in 2008. Desired or Planned Future Measures: Staff interviewed noted that it would be helpful to have ad hoc reports available without having to request them. One local office is interested in knowing the number of applications received through the online system and plans to ask front desk managers to track these data in their spreadsheets. They are also interested in seeing timeliness data, a breakdown of interviews by type (face-to-face versus telephone), and data on the online system and screening tool usage. At the time of the interview, contractors were working on a new computer application processing system for TANF and SNAP that would provide some of these data as well as more workload management tools. Partnering: Montana has one formal partnership with a food bank. The partner received funds from a participation grant. They do not receive applications. Measures Collected by Partners: We did not interview any of Montana's partners as a part of this study. A.126 Profile: Nebraska State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 4 Number of Partners Interviewed: 6 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionallya) Average Waiting Time (to Speak to Agent) Regional Efficiency, Customer Service No No Average Calls Handled Regional Efficiency, Customer Service Not reported Not reported Percent of Total Calls Handled Regional Efficiency, Customer Service Not reported Not reported Average Staff on Phones Regional Efficiency, Customer Service Not reported Not reported Average Hold Time Regional Efficiency, Customer Service Not reported Not reported Percent Calls Abandoned Regional Efficiency, Customer Service Nine in ten calls are answered Not reported Average Call Duration Regional Efficiency, Customer Service Not reported Not reported Average Queue Time Regional Efficiency, Customer Service Not reported Not reported Average Time Prior to Abandonment Regional Efficiency, Customer Service Not reported Not reported Average After-Call Work Time by Staff Regional Efficiency, Customer Service Not reported Not reported Percent of Queued Calls Handled Regional Efficiency, Customer Service Not reported Not reported Percent of Changes Processed Regional Efficiency, Customer Service Not reported Not reported Percent of Calls Completed in the Computer Phone System Regional Efficiency, Customer Service No No Percentage Answered in Less than Three Minutes Regional Efficiency, Customer Service No No Average Time to Process Change Locally Not reported Not reported Not reported Number of Changes Received Locally Not reported Not reported Not reported Number of Changes Processed Locally Not reported Not reported Not reported Nebraska (continued) A.127 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Time to De- Queue Locally Not reported Not reported Not reported Number of Calls (in flow) Locally Not reported Not reported Not reported Number of Calls Abandoned Locally Not reported Not reported Not reported Number of Calls Queued Locally Not reported Not reported Not reported Number of Calls Answered\/Handled Locally Not reported Not reported Not reported Number of Agents Assigned to Phones Locally Not reported Not reported Not reported Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Locally Not reported Not reported Not reported Average Time to Process Change Locally Not reported Not reported Not reported Number of Clients Accessing Computer Phone System Data Locally Not reported Not reported Not reported Number of Calls Received Locally Not reported Not reported Not reported Number of Hang-ups Locally Not reported Not reported Not reported Number of Changes Received Locally Not reported Not reported Not reported Number of Changes Processed Locally Not reported Not reported Not reported Number of Calls Not Completed in Computer Phone System Locally Not reported Not reported Not reported Number of Calls Completed in Computer Phone System Locally Not reported Not reported Not reported Number of Calls Transferred to Agent Locally Not reported Not reported Not reported Number of Cases Pending Benefit Decision: Call Center Locally Not reported Not reported Not reported Number of Applications Processed: Call Center Locally Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Program Access, Efficiency, Customer Service No No Number of Changes Submitted Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Nebraska (continued) A.128 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives DOCUMENT IMAGING (Regionallya) Percent of Documents Scanned Regional Efficiency Not reported Not reported Percent of Documents Received by Mail Regional Efficiency Not reported Not reported Percent of Documents Received by Fax Regional Efficiency Not reported Not reported Average Processing Time Regional Efficiency Not reported Not reported KIOSKS (Statewide) None PARTNERING (Statewide) Percent of Partners Providing Access to Terminals\/Kiosks Statewide Program Access Not reported Not reported Percent of Partners Providing Application Assistance Statewide Program Access Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access Not reported Not reported Percent of Interviews Conducted Face-to-Face Statewide Program Access Not reported Not reported Error Rate for Cases with Telephone Interviews Statewide Program Access, Accuracy & Integrity Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported Percent of Applications Approved: Online All Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Nebraska (continued) A.129 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Application Decision Statewide Accuracy & Integrity, Efficiency, Customer Service No No Average Processing Time of Recertification Decision Statewide Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. aThe call center and document imaging initiatives are being rolled out across the state in phases. They were not in all areas of the state at the time of our interview. Description: General: Nebraska is divided into five regions. At the time of our interviews, Nebraska was in a state of transition. Across the regions, they were introducing document imaging, a universal caseload system, and call centers. The document imaging and call centers will each cover specific regions of the state, rather than the entire state. Measurement Goals: Nebraska seeks to become a highly modernized state, and thus aspires to compare performance with other highly modernized states. They primarily use performance measurement and reporting to ensure client access and ease of use and reduce the number of times clients need to contact them to receive their benefits. Reports are broken down by service area, supervisor, and staff level. All levels of staff have access to the reports. Call Center: The state is rolling out its call centers, called Customer Service Centers. The first one is located in Lincoln and serves the southeast region of the state. The second one will serve the northern and eastern regions of the state. There will be a total of four. The Customer Service Centers have both automated responses and the ability to transfer calls to agents. They can also be used for accepting and processing applications and recertifications, phone interviews, and reporting changes. To ensure continued access for clients, measures on which they will focus include the call wait time, the number of dropped calls, and how often the system hangs up on callers. They have not yet discussed what standards could be put into place. Nebraska (continued) A.130 Online System: The state accepts applications online. The data do not automatically transfer to the eligibility system, but the system creates a visual link between the fields in the application and the field in the eligibility system using a graphical user interface. The worker can then enter information from the application into the eligibility system. According to staff interviewed, they hope to begin transferring the data automatically, but incomplete data entry by clients makes this difficult. Nebraska tracks whether applications are received online or by other means, and receipt time. Clients also report where they completed the online application, for example, whether they completed it at home, at a friend's house, or at a community partner's office. The computer system sorts the applications by the service area of the client and forwards the application to that work area queue. Document Imaging: Nebraska has two document imaging centers. For several offices, all mail is forwarded directly to the centers\u2014eventually all mail will be sent directly to the imaging centers. Documents are scanned in large batch jobs then transferred to workers for manual indexing and linkage to cases. At this point, the files can be accessed by all staff. They are able to track the number of documents scanned, the worker, and which scanner was used. Kiosks: Kiosks are available inside local offices and at the offices of numerous community-based partners. Primarily, the kiosks are used to access Nebraska's website to apply for benefits. Applicants indicate the place in which they are accessing the system. Waiver of Face-to-Face Interview: Nebraska is working toward having most of its interviews by phone. The eligibility system keeps track of the interview type and the eligibility decision by type. Shortened Interviews: Nebraska did not report having shortened interviews. Online Expedited Applications: Online applications can be processed as expedited cases. Application Tracking: Nebraska tracks applications by whether they were submitted online or through some other means. If online, they also track the location of the applicant when filing (home, friend's house, community partner, et cetera). The local offices receive daily reports of the number of cases that are pending and for how long they have been pending. They can view this data in real time under the universal case management system. Local offices also receive monthly reports describing the office's activities during the month. To maintain a high accuracy rate, Nebraska has a team that reviews processed cases, by worker, to check accuracy. Workers are recognized for correct cases. Changes Over Time: Nebraska's ability to track performance is increasing as they modernize their systems. Partnering: Nebraska has both formal and informal arrangements with community-based organizations. The formal arrangements are for partners that receive funding for the services they provide. The regions and local offices also partner with numerous organizations. The regions have community support specialists to work with the partners and do outreach in the community. The partners generally make kiosks available to their clients to apply online for SNAP and other state benefits. They also provide assistance if needed. Some partners received training from the state about the online system. Measures Collected by Partners: Some partners carefully track the number of individuals they serve, and in some cases the number of staff hours involved in assisting clients. Other partners do not have any performance measures. Nebraska tracks only the number of partners. Nebraska (continued) A.131 Desired or Planned Future Measures: Nebraska has additional reports in the design stage. One local office worker desired a report that indicated the percentage of the eligible population that was being served. A.132 Profile: Nevada State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls (in flow) Statewide Program Access, Customer Service Not reported Not reported Number of Calls Abandoned Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Queued Statewide Program Access, Efficiency, Customer Service Not reported Not reported Average Hold Time Statewide Program Access, Customer Service Goal is an average of 10 minutes. No Average Hold Time Statewide Program Access, Customer Service Not reported Not reported Average Calls Handled Statewide Program Access, Customer Service Not reported Not reported Percent of Total Calls Handled Statewide Program Access, Customer Service Goal of 50 percent of calls that are directed to the call center are processed. Not reported Average Staff on Phones Statewide Program Access, Efficiency, Customer Service Not reported Not reported Percent of Calls Completed in the Computer Phone System Statewide Not reported 95 percent of calls resolved by the Voice Response System. No Average Time Prior to Abandonment Statewide Program Access, Customer Service Not reported Not reported PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Program Access, Customer Service No Continuation of the project Number of Partners Statewide Program Access, Customer Service No No Number Accepting Applications Statewide Program Access, Customer Service No No Number Providing Application Assistance Statewide Program Access, Customer Service No No Number Clients Assisted per Partner Statewide Program Access, Customer Service No No Nevada (continued) A.133 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Received per Partner Statewide Program Access, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) Percent of Applications Approved After Paper Submission to Local Office Statewide Accuracy & Integrity, Efficiency, Customer Service No No Percent of Recertifications Approved After Paper Submission to Local Office Statewide Accuracy & Integrity, Efficiency, Customer Service No No Percent of Community Partner Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Applications Approved Statewide Program Access, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Customer Service No No Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity No No Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Applications Approved: Community Partner Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Recertifications Denied Statewide Accuracy & Integrity, Efficiency No No Percent of Complete Applications Denied Statewide Accuracy & Integrity, Efficiency No No Number of Applications Denied: Paper Submission to Local Office Statewide Accuracy & Integrity, Efficiency No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Accuracy & Integrity, Efficiency No No Nevada (continued) A.134 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Denied: Community Partner Statewide Program Access, Efficiency, Customer Service No No Average Processing Time of Application Decision Statewide Accuracy & Integrity, Efficiency Timeliness based on federal policy No Average Processing Time of Recertification Decision Statewide Accuracy & Integrity, Efficiency Federal guidelines No Notes: State collects mandatory accuracy data through QC reviews. Description: General: Nevada runs a demonstration project with two community partner organizations. (In addition to partnering, Nevada operates a call center and has a waiver of face-to-face interviews. Measurement Goals: Nevada primarily measures performance to ensure efficiency customer service, accuracy and integrity, and program access. Call Center: Nevada operates a call center. Call center staff take client information and answer questions. Performance measures were developed with the goal of monitoring effectiveness per the direction of the Nevada legislature. Online System: Nevada does not have an online system. Document Imaging: Nevada does not have document imaging. Kiosks: Nevada does not have kiosks. Waiver of Face-to-Face Interview: Nevada has a waiver to conduct interviews via telephone; however they do not collect any performance measures or aggregate data for this initiative. State staff reported that they conduct face-to-face interviews unless a client requests otherwise. The waiver was sought to alleviate overload in local offices. Shortened Interviews: Nevada does not have a shortened interview initiative. Online Expedited Applications: Nevada does not accept expedited applications online. Application Tracking: Currently, Nevada only accepts paper applications. Community partners may submit applications, and Nevada tracks approval and denials for these applications separately, from a manual report. Along with the required QC reviews, additional reviews are done for employees. Most employees get five cases reviewed per month. Employees who are new or on probation can have all of Partnering: Nevada partners with five community organizations, two of which are part of an FNS demonstration project. Those partners complete the interview and maintain the records of all interviews and submit the applications directly to the local officers. Other partners assist with applications. The state tracks the number of applications submitted by partners, and can calculate the percentage of these applications that are approved or denied. Nevada partners with community organizations to alleviate high local office caseloads. Measures Collected by Partners: The state requires the partners to collect measures. We did not contact any partners as part of this data collection effort. Nevada (continued) A.135 their caseloads reviewed. Changes Over Time: Not reported. Desired or Planned Future Measures: Nevada is in the process of piloting an online application system (ACCESS Nevada). A.136 Profile: New Hampshire State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) None DOCUMENT IMAGING (Statewide) Percent of Documents Scanned Statewide Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported PARTNERING (Statewide) Number of Partners Statewide Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity Not reported Not reported Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity Not reported Not reported Number of redetermination interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Efficiency, Customer Service Not reported Not reported Percent of Total Recertifications Approved Statewide Program Access, Efficiency, Customer Service Not reported Not reported Average Benefit Amount (for those eligible) Statewide Customer Service Not reported Not reported Percent of Applications Not Completed Statewide Program Access, Accuracy & Integrity, Customer Service Not reported Not reported Total Number of Applications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Recertifications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported New Hampshire (continued) A.137 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Online Recertifications Denied for Failure to Submit Documentation Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Description: General: New Hampshire operates an online system and document imaging system and maintains partnerships with community organizations. The waiver of the face-to-face interview is available at both application and recertification. Measurement Goals: New Hampshire primarily measures performance to ensure customer service, efficiency, accuracy and integrity, and program access. Call Center: New Hampshire does not have a call center. Online System: New Hampshire's Department of Health and Human Services has applications available for download and paper submission and online signed submission. They do not collect any performance data related to the online system. Document Imaging: New Hampshire has document imaging capabilities with electronic case records and remote access to electronic case records. They track the percentage of documents scanned and average processing time. Kiosks: New Hampshire does not have kiosks. New Hampshire (continued) A.138 Waiver of Face-to-Face Interview: New Hampshire tracks the error rate for cases with telephone and face-to-face interviews for the purposes of accuracy and integrity. Shortened Interviews: New Hampshire does not have a shortened interview initiative. Online Expedited Applications: New Hampshire does not accept expedited applications online. Application Tracking: New Hampshire calculates a variety of performance measures and aggregate data related to applications and recertifications, including the percentage not complete, approved, denied, average processing time, and the average benefit of those who are approved. They also track application accuracy measures. Changes Over Time: Not reported. Desired or Planned Future Measures: Not reported. Partnering: New Hampshire maintains partnerships with several community organizations. Partner organizations complete and submit applications. Measures Collected by Partners: New Hampshire does not ask any partners to calculate performance measures. We did not contact partners as part of this study. A.139 Profile: New Jersey State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) Number of Online Screenings Started: Online Statewide Customer Service No No Number of Online Screenings Completed: Online Statewide Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) None Notes: State collects mandatory accuracy data through QC reviews. Description: General: New Jersey has a waiver of the face-to-face interview and an online application system. Measurement Goals: New Jersey measures performance data for customer service purposes. Call Center: New Jersey does not have a call center. Online System: New Jersey operates an online application system and screening tool. The system was first developed by a contractor and is now run by the state. It is possible to pre-populate the online application (OneApp) with this information from the screening tool. Data obtained through the online application is electronically transferred to the eligibility system. New Jersey has the capability to track the number of online screenings started and completed for customer service and outreach purposes. This data is tracked through an automated process and can be monitored down to the county level. Document Imaging: New Jersey does not have document imaging. Kiosks: New Jersey does not have Kiosks. Waiver of Face-to-Face Interview: New Jersey has a waiver of the face-to-face interview. They record the type of interview (telephone, face-to-face, or home visit) in the eligibility system, however, they do not track any performance data for this initiative. Shortened Interviews: New Jersey does not have a shortened interview initiative. New Jersey (continued) A.140 Online Expedited Applications: New Jersey did not report an online expedited application initiative. Application Tracking: New Jersey does not track any performance data related to application tracking. According to the state respondent, some counties may have developed their own systems to track applications. No local county offices were interviewed as a part of this study. Changes Over Time: New Jersey has been using the same application tracking system since the early 1980s. During this fiscal year, New Jersey plans to begin working with community partners. Desired or Planned Future Measures: New Jersey reported that they plan to implement a new eligibility system in Fall 2012. The system will give the state more capabilities than they have with the current system and will be standardized across counties in the state. The state also expressed interest in tracking the number of times a client visits an office prior to receiving benefits. Partnering: New Jersey did not report partnering arrangements. Measures Collected by Partners: Not applicable. A.141 Profile: New Mexico State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Due to the rural nature and mixed populations, a standard benchmark has not yet been determined. No Percent of Interviews Conducted Face-to-Face Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applicants Requesting a Phone Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Percent of Applications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified No Percent of Recertifications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified New Mexico (continued) A.142 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Face-to-Face Interviewed Statewide Program Access, Accuracy & Integrity, Efficiency Not reported Not reported Percent of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Complete Applications Denied Statewide Accuracy & Integrity Not sure Not sure Percent of Complete Recertifications Denied Statewide Accuracy & Integrity Not sure Not sure Percent of Initial Applications Denied Statewide Accuracy & Integrity Not sure Not sure Average Processing Time of Application Decision Statewide Accuracy & Integrity, Efficiency, Customer Service No No Average Processing Time of Recertification Decision Statewide Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Notes: State collects mandatory accuracy data through QC reviews. Description: General: New Mexico's SNAP program is administered by the state. New Mexico would like a system where overnight batching and ad hoc reports can function faster. Most state staff do not have access to their own database table for the purposes of running any in house queries. Measurement Goals: New Mexico primarily measures performance to ensure customer service, accuracy and integrity, and efficiency. Call Center: New Mexico does not have a call center. New Mexico (continued) A.143 Online System: New Mexico does not have an online system. Document Imaging: New Mexico does not have document imaging. Kiosks: New Mexico does not have kiosks. Waiver of Face-to-Face Interview: In New Mexico, the waiver is for recertification interviews only. All offices are encouraged by the state to use telephone interviews, unless the client requests an in office interview, to increase access and participation. The state believes the waiver helps minimize barriers to participation and to decrease the workload for eligibility workers. The current eligibility system was revised to account for the waiver so that the eligibility system could run reports based on interview type. Case data are manually entered by SNAP case workers. Automated reports are available for the initiative. Shortened Interviews: New Mexico does not have a shortened interview initiative. Online Expedited Applications: New Mexico does not accept expedited applications online. Application Tracking: New Mexico's application tracking process tracks a number of measures. State staff reported that legislators and stakeholders use the average benefit amount data, which are broken down by household characteristics to make sure certain populations are not being underserved. In New Mexico, staff told us, the state eligibility system is constantly changing. Data for the application process are all manually entered by SNAP workers. Standard monthly reports are automated and ad-hoc reports can be request as needed. State staff reported that they would like some further control over access to ad-hoc reports. Changes Over Time: In New Mexico, caseworker reviews and trainings have been cut because of funding and budget cuts. A 1988 legal settlement resulted in more stringent quality controls than are required by FNS. The data collection system changed to meet the settlement and the changes have to be approved not only by New Mexico SNAP staff, but also by the attorneys in the settlement case. Desired or Planned Future Measures: New Mexico's plans for a document imagining process were in the early stages of implementation and planning at the time of our study. Partnering: New Mexico does not have an initiative for partnering. Measures Collected by Partners: Not applicable. A.144 Profile: New York State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 5 Number of Partners Interviewed: 1 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Average Time to Process Change Locally Not reported Not reported Not reported Average Queue Time Locally Not reported Not reported Not reported Average Time Prior to Abandonment Locally Not reported Not reported Not reported Number of Calls Abandoned Locally Not reported No No Number of Calls Queued Locally Not reported Not reported Not reported Number of Calls Answered\/Handled Locally Not reported Not reported Not reported Number of Agents Assigned to Phones Locally Not reported Not reported Not reported Average Answer Speed Locally Not reported No No Average Hold Time Locally Not reported Not reported Not reported Percent Calls Abandoned Locally Not reported Not reported Not reported Average Call Duration Locally Not reported Not reported Not reported Average Waiting Time (to Speak to Agent) Locally Not reported Not reported Not reported Average Calls Handled Locally Not reported No No Percent of Total Calls Handled Locally Not reported Not reported Not reported Percent of Changes Processed Locally Not reported No No Number of Changes Received Locally Not reported Not reported Not reported Number of Changes Processed Locally Not reported Not reported Not reported Number of Calls Offered Locally Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Users Selecting Spanish Language Statewide Program Access, Customer Service No No New York (continued) A.145 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Screened Individuals Potentially Eligible: Online Statewide Program Access, Customer Service No No Percent of Applicants Who Received Help to Apply Online Statewide Program Access, Customer Service No No Percent of Applications Received Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Goal of 20 percent of applications coming in online No Percent of Applicants with Hardship Reason for Requesting Phone Interviews Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Applications Received Outside Business Hours Statewide Program Access, Customer Service Not reported Not reported Number of Online Screenings Started: Online Statewide Program Access, Customer Service No No Number of Online Screenings Completed: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Started Statewide Program Access, Customer Service No No Number of Abandoned Applications Statewide Accuracy & Integrity, Efficiency No No Number of Applications in Progress Locally Accuracy & Integrity No No Number of Applications Submitted and Transferred Locally Accuracy & Integrity No No Number of Users Accessing a Specific Page Locally Efficiency, Customer Service No No How Long Users Spent on Each Page of the Online Application Locally Customer Service No No Number of Accounts Created Locally Not reported Not reported Not reported Number of Referrals from 311 Online Locally Not reported Not reported Not reported Average Number Submitted per Month Statewide Efficiency Not reported Not reported Average Level of Benefits Statewide Efficiency Not reported Not reported New York (continued) A.146 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applicants who Received Help to Apply Online Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Registered Applications Statewide Not reported Not reported Not reported Number of Applications Withdrawn by Applicant Statewide Not reported Not reported Not reported Number of Applications Withdrawn by System Statewide Not reported Not reported Not reported Number of Applications Submitted Outside Business Hours Statewide Not reported Not reported Not reported Number of Applications Abandoned Statewide Not reported Not reported Not reported Number of Applications Not Submitted Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Regionally) Number of Documents Processed Statewide Efficiency Not reported Not reported Number of Documents Scanned Statewide Efficiency Not reported Not reported Percent of Documents Scanned Statewide Efficiency Not reported Not reported Number of Documents Received: Mail Statewide Not reported Not reported Not reported Average Processing Time Locally Not reported No No Number of Tasks Completed Locally Not reported Not reported Not reported KIOSKS (Regionally) Percent of Screenings Resulting in Application Submission: Kiosk Statewide Program Access Not reported Not reported PARTNERING (Statewide) Number Accepting Applications Statewide Not reported Not reported Not reported Number with Terminals\/Kiosks to Submit Application Statewide Not reported Not reported Not reported Number of Partners Statewide Program Access, Efficiency, Customer Service No No Number Providing Application Assistance Statewide Program Access, Efficiency, Customer Service No No New York (continued) A.147 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Received per Partner Statewide Efficiency No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Error Rate for Cases with Face-to-Face Interviews Statewide Not reported Not reported Not reported Error Rate for Cases with Telephone Interviews Statewide Not reported Not reported Not reported Number of Applicants Requesting an In-Person Interview Statewide Not reported Not reported Not reported Number of Face-to-Face Interviews Statewide Not reported Not reported Not reported Number of Telephone Interviews Statewide Not reported Not reported Not reported Notice of Missed Interview Mailed Statewide Efficiency Not reported Not reported Number of Applicants Requesting a Phone Interview Statewide Not reported Not reported Not reported Number of Missed Interviews Statewide Efficiency Not reported Not reported Number of Redetermination Interviews Statewide Efficiency Not reported Not reported Number of Times Unable to Schedule Interview with Applicant Statewide Efficiency Not reported Not reported Percent of Interviews Conducted by Telephone Statewide Efficiency Not reported Not reported Percent of Interviews Conducted Face-to-Face Statewide Efficiency Not reported Not reported Percent of Telephone Interview Requests Honored Statewide Efficiency Not reported Not reported Percent that are Missed and have Notice Mailed Statewide Efficiency Not reported Not reported Total Number of Interviews Statewide Efficiency Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online All Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No New York (continued) A.148 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Expedited Applications Received Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online All Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online Expedited Statewide Efficiency Not reported Not reported Percent of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Timeliness Rate Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Recertifications Approved After Paper Submission to Local Office Statewide Efficiency Not reported Not reported Percent of Mailed Recertifications Approved Statewide Efficiency Not reported Not reported Percent of Applications Approved After Paper Submission to Local Office Statewide Efficiency Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Number of Recertifications Approved: Mailed Statewide Efficiency Not reported Not reported New York (continued) A.149 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Approved: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Number of Applications Approved: Mailed Statewide Efficiency Not reported Not reported Percent of Kiosk Applications Approved Statewide Efficiency Not reported Not reported Percent of Mailed Applications Approved Statewide Efficiency Not reported Not reported Percent of Community Partner Applications Approved Statewide Not reported Not reported Not reported Percent of Community Partner Recertifications Approved Statewide Not reported Not reported Not reported Percent of Call Center Applications Approved Statewide Not reported Not reported Not reported Percent of Call Center Recertifications Approved Statewide Not reported Not reported Not reported Average Benefit Amount (for those eligible) Statewide Efficiency Not reported Not reported Number of Applications Approved: Kiosk Statewide Efficiency Not reported Not reported Number of Applications Approved: Community Partner Statewide Not reported Not reported Not reported Number of Recertifications Approved: Community Partner Statewide Not reported Not reported Not reported Number of Applications Approved: Call Center Statewide Not reported Not reported Not reported Number of Recertifications Approved: Call Center Statewide Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Statewide Not reported Not reported Not reported New York (continued) A.150 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Statewide Efficiency Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Statewide Efficiency Not reported Not reported Number of Applications Denied: Online Statewide Efficiency Not reported Not reported Number of Recertifications Denied: Online Statewide Efficiency Not reported Not reported Percent of Complete Applications Denied Statewide Accuracy & Integrity, Efficiency Not reported Not reported Percent of Complete Recertifications Denied Statewide Accuracy & Integrity, Efficiency Not reported Not reported Percent of Initial Applications Denied Statewide Accuracy & Integrity, Efficiency Not reported Not reported Percent of Recertifications Denied Statewide Accuracy & Integrity, Efficiency Not reported Not reported Number of Recertifications Denied: Mailed Statewide Efficiency Not reported Not reported Number of Applications Denied: Mailed Statewide Efficiency Not reported Not reported Percent of Online Applications Denied for Failure to Submit Documentation Statewide Efficiency Not reported Not reported Percent of Online Applications Denied for Failure to Complete Interview Statewide Not reported Not reported Not reported Number of Applications Denied: Kiosk Statewide Efficiency Not reported Not reported Number of Applications Denied: Community Partner Statewide Not reported Not reported Not reported Number of Recertifications Denied: Community Partner Not reported Not reported Not reported Number of Applications Denied: Call Center Statewide Not reported Not reported Not reported New York (continued) A.151 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Denied: Call Center Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Applications with Incomplete Information Statewide Efficiency Not reported Not reported Number of Cases with Complete Verification Submitted Statewide Efficiency Not reported Not reported Percent of Recertifications with Incomplete Information Statewide Efficiency Not reported Not reported Number of Recertifications: Community Partner Statewide Not reported Not reported Not reported Number of Applications: Call Center Statewide Not reported Not reported Not reported Number of Recertifications: Call Center Statewide Not reported Not reported Not reported Number of Applications: Faxed Statewide Not reported Not reported Not reported Number of Recertifications: Faxed Statewide Not reported Not reported Not reported Percent of Applications: Faxed Statewide Not reported Not reported Not reported Percent of Recertifications: Faxed Statewide Not reported Not reported Not reported Percent of Applications: Call Center Statewide Not reported Not reported Not reported Number of Applications: Kiosk Statewide Efficiency Not reported Not reported Number of Applications: Mailed Statewide Efficiency Not reported Not reported Percent of Applications: Kiosk Statewide Efficiency Not reported Not reported Percent of Applications: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Percent of Applications: Online Statewide Efficiency Not reported Not reported Percent of Applications: Community Partner Statewide Efficiency Not reported Not reported New York (continued) A.152 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Number of Applications: Online Statewide Efficiency Not reported Not reported Total Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Efficiency Not reported Not reported Number of Applications: Community Partner Statewide Efficiency Not reported Not reported Percent of Applications: Mailed Statewide Efficiency Not reported Not reported Number of Recertifications: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Number of Recertifications: Mailed Statewide Efficiency Not reported Not reported Number of Requests for Assistance\/One-page Applications Statewide Not reported Not reported Not reported Percent of Applications Not Completed Statewide Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Statewide Efficiency Not reported Not reported Percent of Recertifications: Mailed Statewide Efficiency Not reported Not reported Percent of Recertifications: Community Partner Statewide Not reported Not reported Not reported Percent of Recertifications: Call Center Statewide Not reported Not reported Not reported Total Number of Recertifications Started Statewide Not reported Not reported Not reported Total Number of Recertifications Completed Statewide Efficiency Not reported Not reported Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported New York (continued) A.153 Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: New York is state supervised and county administered. The state use two different eligibility systems; one is in use in one region (New York City) and the other in the rest of the state. The online system was fairly new at the time of our data collection, so most applications were still coming in on paper. One region runs a change center that only handles outgoing calls for interviews. Another county runs a call center. Numerous measures are available statewide through the Commissioner's Dashboard and myWorkspace. Measurement Goals: The local agencies participating in the study primarily use measurement for staffing purposes and to ensure they are processing applications according to state standards. Call Center: The regional call center in New York City is a change center only. It handles outgoing interview calls, and therefore does not track or need any measures of incoming call volume or wait time. Another county has its own call center, serving only its county, which is a sophisticated voicemail system that routes calls as necessary. If more than 16 calls are in progress, new callers will receive a busy signal. The phones flash at worker desks when the call volume gets high (more than five calls in the queue) so that others will pick up phone calls and keep the number in the queue lower. The system can produce a few limited reports, but the data cannot be easily transferred into spreadsheets for further processing. The county is upgrading its system. Online System: The online system, provided by a contractor, allows individuals to submit signed applications and changes, and to check their account balance. The information automatically transfers to the eligibility system. New York City has its own, separate online application portal and they collect their own measures\/data independently of the state. Document Imaging: New York has document imaging in place. Some counties package their documents and send to an offsite state location for imaging, and some counties (including New York City) have their own document imaging capability. In New York City, where SNAP offices have established a paperless office system, staff expressed a wish for clients to be able to scan their own documents and attach the images to their account. Kiosks: Kiosks are relatively new, with only a few counties providing them for applicants. Most kiosks are in the lobby of the local agencies, and they must be located somewhere that there are staff available. Waiver of Face-to-Face Interview: The state is not reporting any information about the waiver, though they do have a place to record when the interview was conducted by phone, face-to-face, or in the home. Shortened Interviews: One local office in New York reported that they have a shortened interview process, but did not provide us with further information. New York (continued) A.154 Online Expedited Applications: The state is incorporating expedited screening questions into the online application. Application Tracking: The state and local agencies are tracking a variety of measures related to applications received, approved, and denied; the help received; and possible difficulties with the application. One local office was sued by an advocacy group for not processing applications in a timely way. Since then that agency has focused on the number of applications, whether the applications are submitted online or on paper, and timeliness of processing. Changes Over Time: At the time of the survey the state was transitioning to a new online application system and new interface for worker processing of applications. One local office we spoke to was working on improvements to the call center and phone system that would enhance their internal tracking capabilities. Desired or Planned Future Measures: The state plans to track applications submitted online versus by other means in 2011. One region would also like to track more related to the telephone interviews, such as the timeliness of the calls and the number of calls required to reach the applicant; they are seeking funding to put this in place. Partnering: Most partnering in the state is related to application assistance. One county we interviewed requires that the partner provide a shortcut to the application on their computers. Counties make arrangements with individual partners, documenting confidentiality and application procedures. Once the partner has a login ID for the system, the partner can see limited information, such as whether an application was approved or denied and reports of the number of applications submitted, pending, approved, and denied, and the denial reasons. Partners do not have access to the eligibility system, and are not paid for application assistance services. The state and counties do not generally require the partners to track anything, though they do track the number of applications coming from partners. Other, informal partners provide assistance now that the state has an online application. Measures Collected by Partners: Partners may collect their own counts of the number of clients served, and have the ability to look at which applications were approved and denied. However, the state and local agencies we spoke to do not require them to collect specific measures. A.155 Profile: North Carolina State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 3 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Shortened Interviews, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls (in flow) Statewide Not reported Not reported Not reported Number of Calls Answered \/Handled Statewide Not reported 11,150 Not reported Number of Calls Abandoned Statewide Not reported Not reported Not reported Total Calls Busy Statewide Not reported Not reported Not reported Percent of Total Calls Handled Statewide Not reported Not reported Not reported Percent Calls Abandoned Statewide Not reported No No Percent of Calls Busy Statewide Not reported Not reported Not reported Average Call Duration Statewide Not reported No No Average Answer Speed Statewide Not reported Not reported Not reported Average Time Prior to Abandonment Statewide Not reported Not reported Not reported Percent of Calls Completed in the Computer Phone System Statewide Not reported No No Number of Transactions Locally None No No Number of LEP (language) Calls Locally None No No Percent of Needs Met through Service Referral or Actions Taken Locally None 84 percent No Average Customer Satisfaction Rating Locally Customer Service 84 percent No Number of Referrals Made Locally None 1,529 Not reported Number of Trips Scheduled Locally None 5,885 Not reported Call Response Locally Efficiency 71 percent No Percent of Changes Processed Locally Not reported Not reported Not reported Number of Changes Processed Locally Not reported Not reported Not reported North Carolina (continued) A.156 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Waiting Time (to Speak to Agent) Locally Customer service No No Average Calls Handled Locally Not reported Not reported Not reported Average Staff on Phones Locally Not reported Not reported Not reported Average Queue Time Locally Customer service No No Average Time to De- Queue Locally Not reported Not reported Not reported Average After-Call Work Time by Staff Locally Not reported Not reported Not reported Percent of Queued Calls Handled Locally Not reported Not reported Not reported Number of Calls Queued Locally Not reported Not reported Not reported Number of Agents Assigned to Phones Locally Not reported Not reported Not reported Number of Changes Received Locally Not reported Not reported Not reported Number of Calls Received Locally Not reported Not reported Not reported Number of Hang-ups Locally Not reported Not reported Not reported Number of Calls Not Completed in Computer Phone System Locally Not reported Not reported Not reported Number of Calls Completed in Computer Phone System Locally Not reported Not reported Not reported Number of Calls Transferred to Agent Locally Not reported Not reported Not reported Average Hold Time Locally Not reported Not reported Not reported Average Time to Process Change Locally Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Number of Online Screenings Completed: Online Statewide Program Access Not reported Not reported Number of Applicants Screened as Potentially Eligible Statewide Program Access Not reported Not reported Total number of Website Hits per Month Statewide Not reported Not reported Not reported Number of One-Page Requests for Assistance Submitted Locally Not reported Not reported Not reported North Carolina (continued) A.157 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives DOCUMENT IMAGING (Regionally) Number of Documents Received Locally Not reported Not reported Not reported Number of Documents Received: Mail Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Number of Documents Scanned Locally Not reported Not reported Not reported Number of Tasks Completed Locally Not reported Not reported Not reported Number of Alerts Processed Locally Not reported Not reported Not reported KIOSKS (Statewide) None PARTNERING (Regionally) Number of Applications Received per Partner Locally Not reported Not reported Not reported Number of Partners Locally Not reported Not reported Not reported Number Accepting Applications Locally Not reported Not reported Not reported Number Providing Application Assistance Locally Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Total Number of Interviews Locally Not reported Not reported Not reported Notice of Missed Interview Mailed Locally Not reported Not reported Not reported SHORTENED INTERVIEWS (Regionally) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported No No Percent of Total Recertifications Approved Statewide Not reported Not reported Not reported North Carolina (continued) A.158 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Benefit Amount (for those eligible) Statewide Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Statewide Not reported Not reported Not reported Percent of Applications Approved After Paper Submission to Local Office Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Program Access, Customer Service No No Number of Applications Denied: Paper Submissions to Local Office Statewide Not reported No No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Not reported No No Average Processing Time of Recertification Decision Statewide Efficiency, Customer Service FNS timeliness standards NC has received FNS timeliness awards Average Processing Time of Application Decision Statewide Efficiency, Customer Service One local office asks employees to have approvals processed no later than the 25th day. Another local office reported that 98 percent will be processed within 9 days (regular applications) and 99 percent will be processed within 2 work days (emergency applications). Bonus money from FNS. One local office: director challenged department to process applications more quickly Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported North Carolina (continued) A.159 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Percent of Cases Reviewed that are Accurate Locally Not reported Food assistance staff will maintain an accuracy rate of 98 percent No Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications: Faxed Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported North Carolina (continued) A.160 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Initial Applications Denied Locally Not reported No No Percent of Recertifications Denied Locally Not reported No No Percent of Complete Applications Denied Locally Not reported Not reported Not reported Percent of Complete Recertifications Denied Locally Not reported Not reported Not reported Percent of One- Page\/Requests for Assistance Denied Locally Not reported Not reported Not reported Percent of Applications with Incomplete Information Locally Not reported Not reported Not reported Percent of Recertifications with Incomplete Information Locally Not reported Not reported Not reported Number of applications pending decision Locally Not reported Not reported Not reported Number of initial applications approved over 30 days Locally Not reported Not reported Not reported Number of recertifications approved over 30 days Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. ePASS = Electronic Pre-Assessment Screening Service Description: General: North Carolina has an online system with electronic screening assessment and paper application available for download. They also operate a state call center solely for providing information about benefits. Late in 2010, the state obtained the waiver of the face-to-face interview. Local offices mange their own document imaging, call centers, and partnerships with community organizations; implementation varies by county. Measurement Goals: North Carolina typically did not describe measurement goals for their initiatives, but customer service, program access, and accuracy were goals for some measures. North Carolina (continued) A.161 Call Center: North Carolina operates a statewide call center for inquiries on electronic benefits only. They track several performance measures, including percentage of calls handled, abandoned, calls busy, average answer speed, average call duration, and average time prior to abandonment. Local counties operate separate call centers for case management, and implementation varies by locality. Two local county offices interviewed operated call centers. In one county, the call center operations are divided into two sections, consisting of technical workers who answer questions related to SNAP and call center workers who route calls to the correct location. This call center is fairly new and began operating in September 2010. Another county office interviewed for this study operates a call center for all Department of Social Services programs. The call center, as well as the measures and benchmarks were designed by consultants and based on industry standards. Supervisors monitor performance data in real time for staffing purposes and to ensure operations are running smoothly. Real time data are available for the number of callers waiting in each queue, wait time, abandonment, and status of individual workers. Monthly call center reports track measures and whether the office meets the associated benchmark, including call response efficiency, percentage of needs met through referral or action, and percentage customer satisfaction rating. The office reported they are unable to measure incoming call volume due to an issue with both the software and phone server capabilities. Online System: North Carolina has an online system with electronic screening assessment (ePASS) and paper application available for download. At this time, North Carolina does not have electronic application submission. All online applications must be printed and sent to an office via mail, fax, or drop-off. According to the state, information entered in the ePASS screening pre-populates the application. At the state level, North Carolina tracks the number of ePASS screenings completed, number of potentially eligible applications from ePASS screenings, and number of website hits. At the local level, at least one county tracks the number of one-page requests for assistance submitted and the number of applications downloaded. Document Imaging: Document imaging operations in North Carolina are local office specific and implementation varies from county to county. As a result, scanned documents are stored in county- specific systems and there is no cross county access at this time. At least one county tracks performance data, including the number of documents received, and processed. Workers manually track performance data using a spreadsheet. Documents are also coded by the date and as part of an application, recertification, or other. Kiosks: According to the state, some Department of Social Services county offices have computers for completing, scanning, and printing applications. Any performance data tracking would be at the county level. None of the county offices interviewed as a part of this study reported having kiosks. Waiver of Face-to-Face Interview: North Carolina obtained the waiver of the face-to-face interview in late 2010. The type of interview (telephone versus face-to-face) is recorded for the purposes of scheduling and the narrative section of each case. If this information is needed, it must be manually retrieved from each case; there is no easy or quick way to compile statistics. Performance data is tracked at the local level and no data on the waiver is sent to the state. One local office interviewed tracked the Partnering: Some local offices partner with community organizations. No data are sent to the state for monitoring. One county office interviewed tracks the number of partners, number of partners accepting applications, and the number of partners providing application assistance. For partners that accept applications, the local office tracks the number of applications received per partner. Performance data are tracked manually and staff log all applications collected off-site on a spreadsheet. Measures Collected by Partners: We did not contact any of North Carolina's partners as part of this study. North Carolina (continued) A.162 phone interview requests for scheduling purposes. Another county office tracked the total number of interviews, but is unable to distinguish between those conducted over the phone and those conducted face-to-face. Shortened Interviews: North Carolina does not collect any performance data for the shortened interview process. According to one local office, abbreviated interviews are conducted with applicants that applied through The Benefit Bank of North Carolina (a screening tool offered by trained counselors at a range of community partner organizations). These applications are tracked on a log for the purposes of assigning the case to a worker. Online Expedited Applications: North Carolina does not accept expedited applications online. Application Tracking: North Carolina calculates a wide variety of application tracking measures related to applications and recertifications, including approvals, denials, average processing time, and average benefit amount for those eligible. Staff manually enter data into the eligibility system as they process applications. The eligibility system populates the North Carolina data warehouse monthly, but data and reports can be accessed as necessary. In general, county offices use state data to track performance, but may set their own internal benchmarks for performance (for example, two local offices had two different standards for processing time). North Carolina also tracks accuracy measures for the FNS QC process. This data is used to assess agency wide performance goals and to evaluate worker performance. Local county level program integrity teams track accuracy rates separately from the state. The state does not track applications by the method of submission. However, local offices report that they track application submission by drop-off, partner organization (for counties with partners), mail, and fax. Two local offices interviewed report they use a county-specific internal computer system to record whether applications were received in-person, fax, or mail. According to one county office interviewed, the state data system is cumbersome to work with and it is difficult to download data into a more usable format. Recently, this office started using an internally written program to assist them with downloading the data. Changes Over Time: The state office is currently implementing North Carolina Families Accessing Services Through Technology (NC Fast), which is a statewide case management and eligibility system. NC FAST Program consists of three main projects: online verification, service delivery interface, and case management. Four counties have been selected for the pilot program and total state wide rollout is planned for 2013. Document imaging is a new initiative in North Carolina. While functionality varies from county to county, localities are in general still in the early stages of implementation. Likewise, call centers were implemented at varying times throughout North Carolina. One county office interviewed recently established its call center in September 2010. The state runs the eligibility system, FSIS (Food Stamp Information System), but case management systems are run at the county level. Two local offices interviewed used internal case management systems, consisting of in-house computer systems developed by county IT departments, in addition to FSIS. The offices reported using the internal systems since February 2009 and early 2010, respectively. Internal system capabilities vary county to county, but in general the internal computer system stores narratives about the client, as well as household information. Staff log client visits, applications, and client interviews in the system. Scanned documents can also be uploaded and attached to client records. Counties can use the in-house system to produce reports on the number of application taken, number of applications received per day, method by which application was received (mail, fax, in person), and arrival time for in-person applicants. Local county offices report that they must perform some double data entry (into the internal case management system and the state eligibility system). North Carolina (continued) A.163 Desired or Planned Future Measures: North Carolina is interested in developing more measures about how online applications are disposed, especially as functionality increases with the use of NC FAST. Locally, counties reported a desire for additional performance measures. One local office would like to know the number of callers that try to reach the call center. This is currently not tracked due to a lack of call center software capabilities. They are also interested in monitoring the processing time for recertifications. Counties are still in the early phases of developing document imaging and electronic case files. Another county office interviewed indicated that while there are no specific performance measures planned currently, but this may change once the office uses these systems more. An additional respondent expressed interest in tracking agency error by the type of error. A.164 Profile: Ohio State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 10 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Wavier of Face\u2010to\u2010 Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Average After-Call Work Time by Staff Locally Not reported Not reported Not reported Percent of Queued Calls Handled Locally Not reported Not reported Not reported Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Locally Not reported Not reported Not reported Average Time to Process Change Locally Not reported Not reported Not reported Number of Hang-ups Locally Not reported Not reported Not reported Number of Changes Processed Locally Not reported Not reported Not reported Percent of Calls Requesting Agent Locally Not reported Not reported Not reported Number of Calls Received Locally Not reported Not reported Not reported Average Answer Speed Locally Not reported No No Average Hold Time Locally Not reported No No Percent Calls Abandoned Locally Not reported No No Average Waiting Time (to Speak to Agent) Locally Not reported No No Average Queue Time Locally Not reported No No Average Time to De- Queue Locally Not reported No No Average Time Prior to Abandonment Locally Not reported No No Number of Calls Abandoned Locally Not reported No No Number of Calls Queued Locally Not reported No No Number of Calls Transferred to Agent Locally Not reported No No Average Call Duration Locally Not reported No No Percent of Calls Completed in the Computer Phone System Locally Not reported No No Ohio (continued) A.165 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Completed in Computer Phone System Locally Not reported Not reported Not reported Percent of Total Calls Handled Locally Efficiency, Customer Service No No Percent of Changes Processed Locally Efficiency, Customer Service No No Number of Applications Processed: Call Center Locally Not reported Not reported Not reported Number of Changes Received Locally Not reported Not reported Not reported Total Number of Calls Handled Locally Not reported No No Number of Clients Requesting Case Status Locally Not reported Not reported Not reported Number of Clients Reporting Case Change Locally Not reported Not reported Not reported Number of Clients Reporting Verifications Turned In Locally Not reported Not reported Not reported Average Calls by Reason for the Call Locally Not reported Not reported Not reported Average Staff on Phones Locally Not reported No No Number of Agents Assigned to Phones Locally Accuracy & Integrity, Customer Service No No Number of Calls Answered\/Handled Locally Accuracy & Integrity, Customer Service No No Number of Calls (in flow) Locally Program Access, Efficiency, Customer Service Not reported Not reported Average Calls Handled Locally Program Access, Efficiency, Customer Service No No Number of Cases Pending Benefit Decision: Call Center Locally Not reported Not reported Not reported Number of Client Calls Returned Locally Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Not reported Not reported Not reported Average Number of Screenings Completed: Online Statewide Not reported Not reported Not reported Ohio (continued) A.166 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Online Screenings Completed: Online Statewide Not reported Not reported Not reported Number of First-Time Applications Approved Statewide Not reported Not reported Not reported Number of First-Time Applications Denied Statewide Not reported Not reported Not reported Average Number of Screenings Started: Online Statewide Not reported Not reported Not reported Average Number Started per Month Statewide Not reported Not reported Not reported Average Number Submitted per Month Statewide Not reported Not reported Not reported Number of Changes Started Statewide Not reported Not reported Not reported Average Number of Accounts Created per Month Statewide Not reported Not reported Not reported Number of Applications Started Statewide Not reported Not reported Not reported Number of Changes Submitted Statewide Not reported Not reported Not reported Number of Applications Downloaded Statewide Not reported Not reported Not reported Average Number of Changes Submitted per Month Statewide Not reported Not reported Not reported Average Level of Benefits Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Regionally) Average Processing Time Locally Not reported Not reported Not reported Number of Documents Processed Locally Not reported Not reported Not reported Percent of Documents Scanned Locally Not reported 100 percent of documents need to be scanned. No Percent of Documents Received by Mail Locally Not reported No No Percent of Documents Received by Fax Locally Not reported No No Number of Documents Received Locally Not reported Not reported Not reported Ohio (continued) A.167 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Documents Received: Mail Locally Not reported Not reported Not reported Number of Documents Received: Fax Locally Not reported Not reported Not reported Number of Documents Received: Other Electronic Locally Not reported Not reported Not reported Number of Tasks Completed Locally Not reported Not reported Not reported Number of Alerts Processed Locally Not reported Not reported Not reported Number of Documents Scanned Locally Not reported One local office expects documents to be labeled and scanned within 24 hours of receipt. No KIOSKS (Regionally) Number of Uses to Submit Changes Locally Not reported Not reported Not reported PARTNERING (Statewide) Number of Partners Locally Not reported Not reported Not reported Number Accepting Applications Locally Not reported Not reported Not reported Number Providing Application Assistance Locally Not reported Not reported Not reported Percent of Partners Providing Application Assistance Locally Not reported Not reported Not reported Average Cost of Partner Arrangement Locally Not reported Not reported Not reported Number Clients Assisted per Partner Locally Not reported Not reported Not reported Number of Applications Received per Partner Locally Not reported Not reported Not reported Number with Terminals\/Kiosks to Submit Application Locally Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Ohio (continued) A.168 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Interviews Conducted Face-to-Face Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity, Efficiency No State: No One local office: Informal achievement award certificates and stickers. Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity, Efficiency No State: No One local office: Informal achievement award certificates and stickers. Total Number of Interviews Statewide Program Access, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applicants Requesting an In-Person Interview Locally Not reported Not reported Not reported Number of Home Visit Interviews Locally Not reported Not reported Not reported Number of Times Unable to Schedule Interview with Applicant Locally Not reported Not reported Not reported Number of Applicants who Did Not Answer to Type of Interview Requested Locally Not reported Not reported Not reported Percent of Telephone Interview Requests Honored Locally Not reported No No Number of Applicants Requesting a Phone Interview Locally Not reported Not reported Not reported Percent that are Missed and have Notice Mailed Locally Not reported No No Ohio (continued) A.169 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Notice of Missed Interview Mailed Locally Program Access, Efficiency, Customer Service Not reported Not reported Number of Missed Interviews Locally Program Access, Efficiency, Customer Service Not reported Not reported Average Length of Interview Locally Not reported No No SHORTENED INTERVIEWS (Regionally) Number of Shortened Interviews Locally Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported Percent of Applications Approved: Online All Statewide Not reported Not reported Not reported Number of Expedited Applications Received Online Statewide Not reported Not reported Not reported Number of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Program Access No No Number of Recertifications Approved: Faxed Locally Not reported Not reported Not reported Number of Applications Approved: Mailed Locally Not reported Not reported Not reported Number of Recertifications Approved: Mailed Locally Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Locally Not reported Not reported Not reported Ohio (continued) A.170 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Online Recertifications Approved Locally Not reported Not reported Not reported Percent of Community Partner Recertifications Approved Locally Not reported Not reported Not reported Percent of Mailed Applications Approved Locally Not reported Not reported Not reported Percent of Total Recertifications Approved Locally Not reported Not reported Not reported Number of Applications Approved: Online Locally Not reported Not reported Not reported Number of Recertifications Approved: Online Locally Not reported Not reported Not reported Number of Recertifications Approved: Community Partner Locally Not reported Not reported Not reported Number of Applications Approved: Faxed Locally Not reported Not reported Not reported Percent of Online Applications Approved Locally Not reported Not reported Not reported Percent of Applications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications Approved After Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Community Partner Applications Approved Locally Not reported Not reported Not reported Percent of Call Center Applications Approved Locally Not reported Not reported Not reported Percent of Call Center Recertifications Approved Locally Not reported Not reported Not reported Percent of Mailed Recertifications Approved Locally Not reported Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Community Partner Locally Not reported Not reported Not reported Ohio (continued) A.171 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Recertifications Approved: Call Center Locally Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Call Center Locally Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Locally Not reported Not reported Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Percent of Recertifications: Online Locally Not reported Not reported Not reported Percent of Recertifications: Community Partner Locally Not reported Not reported Not reported Percent of Applications: Mailed Locally Not reported Not reported Not reported Percent of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Applications: Online Locally Not reported Not reported Not reported Number of Recertifications: Online Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Community Partner Locally Not reported Not reported Not reported Ohio (continued) A.172 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Faxed Locally Not reported Not reported Not reported Percent of Applications Not Completed Locally Not reported Not reported Not reported Total Number of Applications Started Locally Not reported Not reported Not reported Total Number of Recertifications Started Locally Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Total Number of Applications Completed Locally Not reported Not reported Not reported Total Number of Recertifications Completed Locally Not reported Not reported Not reported Percent of Applications: Faxed Locally Not reported No No Percent of Recertifications: Faxed Locally Not reported Not reported Not reported Number of Applications: Community Partner Locally Not reported Not reported Not reported Percent of Applications: Paper Submission to Local Office Locally Not reported No No Percent of Applications: Online Locally Not reported No No Percent of Applications: Community Partner Locally Not reported No No Percent of Applications: Call Center Locally Not reported No No Percent of Recertifications: Call Center Locally Not reported Not reported Not reported Number of Applications: Call Center Locally Not reported Not reported Not reported Number of Recertifications: Call Center Locally Not reported Not reported Not reported Number of Recertifications: Faxed Locally Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Ohio (continued) A.173 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Initial Applications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Recertifications Denied Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Online Applications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported Percent of Online Recertifications Denied for Failure to Submit Documentation Locally Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Online Locally Not reported Not reported Not reported Number of Recertifications Denied: Community Partner Locally Not reported Not reported Not reported Number of Applications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Faxed Locally Not reported Not reported Not reported Number of Recertifications Denied: Mailed Locally Not reported Not reported Not reported Number of Applications Denied: Online Locally Not reported Not reported Not reported Number of Applications Denied: Community Partner Locally Not reported Not reported Not reported Number of Applications Denied: Call Center Locally Not reported Not reported Not reported Number of Applications Denied: Mailed Locally Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Ohio (continued) A.174 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Cases with Complete Verification Submitted Locally Not reported Not reported Not reported Average Processing Time of Application Decision Locally Not reported No No Average Processing Time of Recertification Decision Locally Not reported Not reported Not reported Number of Days Application Pending Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Ohio has implemented numerous modernization initiatives, primarily at the county level. Performance measurement differs among regions, with each county independently determining the information they will track. Counties have access to Ohio's online reporting tool, the Business Intelligence Channel (BIC) that collects performance data from the state's computerized systems (e-Gateway and central registry information system [CRIS-E]). Offices can use this statewide system to pull information regarding applications or see statewide or countywide data. Collabor8 is an inter-county collaborative among eight Ohio counties. The state requested an FNS waiver so that these counties could function as one project area. Participating counties will establish a memorandum of understanding among themselves and with the state. The memorandum will likely incorporate performance standards, including timeliness standards. Clients will be able to move among counties without having to reapply for SNAP benefits. The Collabor8 project is working towards one multi- county call center with a toll free number and there have been discussion of opening up a document imaging system across counties. Counties involved in the project are starting to see data and measures from the other counties within the collaborative. One local office began a performance measurement initiative to help mainly with their error rate. They have a QA unit, but as workers have left they have not been replaced. The QA workers used to review cases prior to authorization, and do a random pull of cases authorized the month before. Now they review intake cases prior to authorization, and do a random pull of cases prior to the month of recertification. While most offices interviewed were satisfied with their collection and use of performance measures and data, a few offices noted challenges. These challenges include: financial difficulties, system failures or glitches, and human error. One office commented that they may have chosen to pull too much information when designing their systems and reports. Measurement Goals: Ohio's performance measures touch on all four FNS goals. They also track performance data in order to monitor staffing, distribute work fairly and evenly, to discern whether clients are using certain initiatives and why, to identify when more training is needed, and for performance reviews. Ohio (continued) A.175 Call Center: Ohio has no statewide call center; each county has the capability to operate its own call center. Eight of the 10 county offices interviewed were developing or had already developed a call center. The characteristics and functionality of the call centers vary by county office. All local offices with call centers collect numerous performance measures and data. Online System: Ohio developed a statewide online application system for implementation in October 2010. Information on this initiative is gathered at the state level primarily, although some local offices track measures or counts of aggregate data. These include: number of applications downloaded, number of applications started, and number of changes submitted. Document Imaging: There is no statewide document imaging system, but approximately half of the counties interviewed have implemented a system. The type of system and its capabilities may differ among county offices. Multiple local offices collect information on their document imaging systems, with the majority focused on aggregate data rather than performance measures. Kiosks: Two of the 10 local offices interviewed in Ohio track kiosk measures. They look at the number of uses to submit changes and lobby wait time. The measure on lobby wait time is not included in the table above because that kiosk's primary function is managing client appointments, not application submission. At the time of the interview, the state had received ARRA funds to buy computer kiosks for each county office, and a few local offices interviewed had already set them up. The state was working to implement kiosks statewide. There are no plans to track applications submitted from these kiosks, but theoretically it is possible via the new online system initiative. Waiver of Face-to-Face Interview: Ohio has a statewide waiver in place, and both state and local offices collect a variety of aggregate data and performance measures on this initiative. Shortened Interviews: In some counties, applicants may receive a fast-track application. Online Expedited Applications: Three local offices from which we collected data record data on online expedited applications, including: percent of applications approved (all online and expedited online), number of expedited applications received online, and number of expedited online applications approved. Application Tracking: Ohio state and local offices collect a number of application tracking measures and data, including information on application accuracy, approvals and denials, application processing and case characteristics, application receipt, and application processing time. Whether the application source is recorded varies by office, with some offices not tracking this and others keeping detailed records. Partnering: Ohio has widespread formal and informal partnering arrangements. One of the state's most active partnerships operates on an annual grant agreement. Though established at the state level, this partner has volunteers that work in some Ohio counties. The partner provides community outreach, information distribution and application assistance using online application software they developed. The state and local offices maintain other partnerships that provide application assistance, station caseworkers at hospitals or community offices, set up outreach initiatives, or have modernized public relations through social networking. Measures Collected by Partners: The grant recipient has extensive capability to track performance but state staff did not know the specifics about its measurement capacity. One partnership provides their local office with the number of applications per month and the type of benefits received. Ohio (continued) A.176 Changes Over Time: Ohio has not changed its data collection or reporting in the past 12 months, beyond developing new measures along with new initiatives. One office has adjusted the phone system numerous times since they began measurement and has been changing the description of the outcome. Desired or Planned Future Measures: State and local officials noted many desired future measures and data, and some offices were in the process of designing and changing measures. The state would like to develop performance measures for the online system, but has not yet (at the time of the interview) nominated specific measures. One local office recommended measures specifically on the effectiveness of the online system. Another local office wants to track measures on the average lengths of case processing, data entry in the CRIS-E system, and mailings. As telephone interviews and initial applications via telephone become more established, one office would like to look at corresponding measures, especially on timeliness. Another is interested in having data on why clients request telephone interviews and client reactions to face-to-face versus telephone interviews. Measures on the number of times per worker that QC errors are found would be helpful to one local office. Two local offices currently include calls to voicemail in their calculation of average calls handled. One local office is concerned that this inclusion is inflating the numbers, and they would like to exclude these types of calls in the future. Finally, one local office would like performance data on the amount of money and time it takes to process a SNAP case. Some local offices had a desire to see reports from other states or other counties, such as: information on benefits, error rate performance measures, information tied to federal standards for timeliness and accuracy, and reasons why other Ohio counties are struggling with timeliness (including information on caseload sizes, worker to case ratio, and length of time to process a case). A.177 Profile: Oregon State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Regionally) None PARTNERING (Regionally) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent that are Missed and have Notice Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity Not reported No Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity Not reported No Total Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Interviews Conducted by Telephone Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Interviews Conducted Face-to-Face Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) None Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: In Oregon, SNAP is state-administered, divided into a number of districts and regions across the state. Each district develops a process to collect performance data, which the state can then access. Districts do not track information at the applicant level, but that information is collected in the Oregon (continued) A.178 case worker's narration. The district office-level is the greatest level of detail Oregon uses to assess program performance. The state noted that their technological capability is very limited. Measurement Goals: Oregon primarily measures performance to ensure customer service, accuracy and integrity, and program access. Call Center: Oregon does not have a call center. Online System: At the time of our data collection, Oregon did not have a statewide online system. One local office we interviewed reported that an online system was being tested in part of the state, with help from a partner agency, and that full rollout of the online system to the rest of the state was planned for spring 2011. Document Imaging: Oregon does not have document imaging. Kiosks: Oregon does not have kiosks. Waiver of Face-to-Face Interview: Oregon modeled its waiver after other states and followed guidance from the Western Region office. The state tracks the error rate for cases with telephone interviews, and if telephone interviews experience higher error rates, the state may conduct targeted training in problem sites or across the board if the problem were statewide. They may also issue statewide transmittals or reminders Shortened Interviews: Oregon does not have a shortened interview initiative. Online Expedited Applications: Oregon did not have the ability to accept expedited applications online at the time of our data collection. Application Tracking: The Oregon SNAP conducts targeted case reviews that are not required by or reported to FNS. Specifically, 16 field reviewers review their own random sample of cases from the field branches. This sample is not associated with the FNS QC sample. In this process, the state sanctions branch offices that are worse than the state average. Sanctions include corrective actions, such as additional training or reviews, to ensure that accuracy improves. Oregon has established this sanction as part of its corrective action plan to avoid sanctions from FNS, and the reviews are intended for internal use as a coaching tool to identify consistent problem trends at the field offices. For FNS QC, Oregon only collects information for the QC sample. This process covers some different performance measures than the quality control process, as well as some overlapping performance measures that they report they approach differently. Each month, quality control and quality assurance staff use several processes to examine all performance measures associated with their sample. One such process is a monthly video-conference, the Quality Assurance Panel Discussion, in which field offices are invited to participate. Policy and training representatives are also present. The discussion focuses on any problems identified in the current month of the sample, as well as how to prevent errors. The quality assurance process collects some of its performance measures for its sample with identifiers that allow them to separate applications by type. Specifically, quality assurance is able to tell which type of application was used (for example, an application for the Self Sufficiency office or an application for day care). Changes Over Time: The state established sanctions for the waiver initiative that has evolved over time. According to the state respondent, the state sanction has been very effective. Oregon now has its Partnering: Oregon does not have an initiative for partnering. However, one local office reported that partner agencies were assisting the state with piloting an online application tool. Measures Collected by Partners: No partner measures were reported. Oregon (continued) A.179 lowest error rate in over 10 years and has maintained an error rate below the national average for the past three to four years. Oregon had not previously ranked below the national average. Desired or Planned Future Measures: At the time of data collection, Oregon was piloting an online system. For 2011, they planned to track whether an application was filed online, but only for the quality control sample. Oregon staff reported that they would like to be able to track which applications were completed using the web-based application for the purpose of comparing accuracy across application type. Such an automated process would require resources beyond Oregon's current capacity. A.180 Profile: Pennsylvania State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 5 Number of Partners Interviewed: 7 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives CALL CENTER (Statewide) Percent of Queued Calls Handled Statewide Efficiency, Customer Service 80 percent is the goal No Number of Calls (in flow) Statewide Efficiency, Customer Service No No Number of Calls Abandoned Statewide Efficiency, Customer Service No No Number of Calls Queued Statewide Efficiency, Customer Service No No Number of Calls Answered\/Handled Statewide Efficiency, Customer Service No No Number of Agents Assigned to Phones Statewide Efficiency, Customer Service No No Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Efficiency, Customer Service No No Average Queue Time Statewide Efficiency, Customer Service No No Average Time Prior to Abandonment Statewide Efficiency, Customer Service Not reported Not reported Average After-Call Work Time by Staff Statewide Efficiency, Customer Service 60 seconds is the goal. Some calls are more complex, but this should balance out. No Percent of Calls Requesting Agent Statewide Efficiency, Customer Service No No Number of Calls Transferred to Agent Statewide Efficiency, Customer Service No No Maximum Time to Answer Statewide Not reported Not reported Not reported Maximum Time to Abandon Statewide Not reported Not reported Not reported Total Number of Calls Unanswered Statewide Not reported Not reported Not reported Total Calls Receiving a Queue Full Message Statewide Not reported Not reported Not reported Number of Calls Answered in English (total) Statewide Not reported Not reported Not reported Pennsylvania (continued) A.181 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Calls Answered in English (in service area) Statewide Not reported Not reported Not reported Number of Calls Answered in English (outside service area) Statewide Not reported Not reported Not reported Average Answer Speed Statewide Efficiency, Customer Service No No Average Hold Time Statewide Efficiency, Customer Service No No Percent Calls Abandoned Statewide Efficiency, Customer Service The goal is 20 percent or less. No Average Call Duration Statewide Efficiency, Customer Service The goal is to keep calls around the 5 minute range No Average Calls Handled Statewide Efficiency, Customer Service The goal is 8 calls per hour (used to be 7, and this was achieved so it was increased). No Percent of Total Calls Handled Statewide Efficiency, Customer Service The goal is 80 percent No Average Staff on Phones Statewide Efficiency, Customer Service The goal is no more that 25 percent of staff off the phones at one time No Number of Calls Received Locally Not reported No No ONLINE SYSTEM (Statewide) Average Number of Screenings Started: Online Statewide Program Access Not sure Not sure Average Number of Screenings Completed: Online Statewide Program Access Not sure Not sure Percent of Users Selecting Spanish Language Statewide Program Access Not sure Not sure Percent of Screened Individuals Potentially Eligible: Online Statewide Program Access Not sure Not sure Percent of Screenings Resulting in Application Submission: Online Statewide Program Access No Not sure Number of Online Screenings Started: Online Statewide Program Access Not sure Not sure Pennsylvania (continued) A.182 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Online Screenings Completed: Online Statewide Program Access Not sure Not sure Number of Applications Submitted per Month Statewide Program Access No Not sure Number of Applications Started Statewide Program Access Not sure Not sure Number of Applications Submitted With All Application Questions Answered Statewide Program Access Not sure Not sure Number of Online Accounts Created Statewide Program Access Not sure Not sure Number of Log-ins Statewide Program Access Not sure Not sure DOCUMENT IMAGING (Statewide) Ratio of Staff to Documents Scanned Statewide Not reported Not reported Not reported Number of Documents Attached Statewide Not reported Not reported Not reported Percent of Documents Attached in a Timely Manner Statewide Not reported Not reported Not reported Number of Documents Scanned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Documents Scanned But Not Attached Locally Efficiency No No PARTNERING (Statewide) Number of Screenings per Partner Statewide Program Access, Customer Service Grant payments to partners are based on meeting certain application goals. The goal is specific to the individual partner's contract. The incentive and sanction are tied to grant payments Pennsylvania (continued) A.183 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Applications Received per Partner Statewide Program Access, Customer Service Grant payments to partners are based on meeting certain application goals. The goal is specific to the individual partner's contract. The incentive and sanction are tied to grant payments KIOSKS (Statewide) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Error Rate for Cases with Telephone Interviews Statewide Program Access, Accuracy & Integrity No No Total Number of Interviews Statewide Not reported Not reported Not reported Number of Face-to-Face Interviews Statewide Not reported Not reported Not reported Number of Telephone Interviews Statewide Not reported Not reported Not reported Number of Interview Walk-Ins, New Applications Statewide Not reported Not reported Not reported Number of Interview Walk-Ins, Pending Applications Statewide Not reported Not reported Not reported Average Total Interviews Per Worker Statewide Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Number of Applications Approved: Community Partner Statewide Program Access Not sure Not sure Percent of Total Applications Approved Statewide Program Access Not sure Not sure Percent of Community Partner Applications Approved Statewide Program Access No No Pennsylvania (continued) A.184 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Expedited Applications Approved Statewide Not reported Not reported Not reported Percent of Applications: Online Statewide Program Access, Efficiency, Customer Service Not reported Counties are ranked according to the percentage of applications they receive online. Internal competition could be motivational among counties. Percent of Applications: Community Partner Statewide Program Access 30 percent target for percent of applications received through COMPASS Not sure Percent Change in Applications Received by County Statewide Program Access Not reported Not reported Number of Expedited Applications Pending Statewide Not reported Not reported Not reported Percent of Applications Not Completed Statewide Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Statewide Not reported Not reported Not reported Number of Applications: Mailed Statewide Not reported Not reported Not reported Number of Pending Applications Statewide Not reported Not reported Not reported Number of Resurrected Applications Statewide Not reported Not reported Not reported Number of Applications Received Statewide Not reported Not reported Not reported Number of Expedited Applications Denied Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Program Access Not sure Not sure Number of Applications Denied: Community Partner Statewide Program Access No Not sure Pennsylvania (continued) A.185 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Applications Denied by Denial Reason Statewide Not reported Not reported Not reported Number of SNAP Cases Closed by Closure Reason Statewide Not reported Not reported Not reported Percent of Initial Applications Denied Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Expedited Applications Approved in 5 Days or Less Statewide Not reported Not reported Not reported Number of Expedited Applications Approved or Rejected in More Than 5 Days Statewide Not reported Not reported Not reported Average Processing Time of Application Decision Statewide Program Access, Efficiency, Customer Service State: Not sure One local office tracks the number of pending cases more than 30 days old by worker on a weekly basis. Not sure Percent of Approved Applications Processed Within 7, 15, 30, and 45 Days Statewide Efficiency Not reported Not reported Average Days to Process Approved Applications Statewide Efficiency Not reported Not reported Number of Expedited Applications Pended in 5 Days or More Statewide Not reported Not reported Not reported Number of Days Applications are Pending Statewide Not reported FNS sets a 30 day maximum Not reported Total Number of Pending Cases, by worker Statewide Not reported Not reported Not reported Pending Cases >30 Days, by Worker Statewide Not reported National standard of 30 day timeliness Not reported Number of Applicants Pre-Screened, by Worker Statewide Not reported Not reported Not reported Number of Cases Ready To Go, by Worker Statewide Not reported Not reported Not reported Number of Cases Ready To Go in <25 days, by Worker Statewide Not reported Not reported Not reported Pennsylvania (continued) A.186 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarksa Performance Incentives Number of Cases Ready To Go in >24 Days\/Resurrected, by Worker Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Customer Service Not sure Not sure Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data is listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported statewide. Measure descriptions are unavailable for the online application system, because these calculations are done by a contractor. Pennsylvania staff receive the measures, but do not know how they are determined. Pennsylvania has implemented a statewide call center. An additional call center that serves one specific region in Pennsylvania. aThis column indicates a performance goal. Pennsylvania does not have any official standards or benchmarks because of how collective bargaining agreements are structured. Description: General: The Pennsylvania state office leads all modernization efforts and performance measurement and its related data. Monthly performance reports are sent to the local offices, and further reports are available on Dashboard, an electronic task tracking system available to state staff, but some staff reported these can be cumbersome to use. One office cited the timeliness and error reports as the most valuable. One office noted that technological innovations and access to more data have placed an increased burden on staff, who are presumed to have regularly checked and used this information. Staff reported that even though there may be potentially useful performance measures available in state reports, local office staff must devote their full resources to keeping up with the caseload. Multiple local offices have divided the workload by task, wherein certain staff are responsible for a particular piece of the application processing, rather than being responsible for a specific set of cases. Partnering: Pennsylvania’s partnering arrangements are managed by the state office. Partners provide application assistance and work under a grant agreement that requires them to submit a certain number (which varies by partner) of applications per year. The Pennsylvania state office tracks two aggregate data items on their partnerships: number of screenings completed per partners and number of applications received per partner. Measures Collected by Partners: Pennsylvania partners collect several measures, including information on approvals and denials, screening and application volume, benefit types and amounts, conversion rate, processing time, error rates, and demographic or case characteristics. Pennsylvania (continued) A.187 Measurement Goals: Pennsylvania’s performance measures touch on all four FNS goals. They have also used certain measures for staff training and to test the effectiveness of initiatives, such as the online screening tool. Call Center: The Pennsylvania state office operates a call center, which is staffed by state staff and used in all but one county interviewed. The state tracks a wide variety of data, though they are more concerned with aggregate counts than measures. Local offices receive reports from the state documenting the number of calls from their county processed by the Change Center. These reports are available as needed, but not distributed regularly. In October 2010, one district worked with a vendor to establish a regional (district-wide) call center. Call center staff and the call center computer phone system compile lists of: number of calls (in flow), number of calls abandoned, number of calls queued, and number of calls received. Online System: The online system is called COMPASS. The state office receives performance reports on the online application system from their contractor. They review the percent of users selecting Spanish language, percent of screened individuals potentially eligible, percent of screenings resulting in application submission, the average number of screenings started and completed, and some sets of aggregate data. Document Imaging: Pennsylvania calculates the percent of documents attached in a timely manner and the ratio of staff to documents scanned. They also collect the number of documents attached and the number of documents scanned. One local office records the number of documents scanned but not attached. Kiosks: Pennsylvania does not collect any performance data on their kiosks. Kiosks have been set up in local offices for online application submission, viewing benefit amount, change reporting, or checking application status. Waiver of Face-to-Face Interview: The state office looks at the error rate for cases with telephone interviews. One local office reported that the state makes a few counts of aggregate data available to them. Shortened Interviews: Pennsylvania does not offer a shortened interview. Online Expedited Applications: Clients can submit expedited applications through the state’s online system, but Pennsylvania does not collect any performance data on their online expedited applications. Application Tracking: Pennsylvania reports numerous application tracking measures from the state office, in the areas of application accuracy, receipt, approvals\/denials, and timely processing. Changes Over Time: The contractor operating the computer phone system for the call center changed in 2010. Over the past year, the state has instituted a new requirement that partners use COMPASS. Before, COMPASS was optional and partners could also use paper applications. State staff reported the partnership initiative is easier for the state to manage when partners submit online application. Desired or Planned Future Measures: One local office we interviewed expressed an interest in seeing reports by county for all counties in Pennsylvania, especially QC reports, for comparison purposes. Pennsylvania county offices are evaluated in terms of effective management measures, such as application timeliness, QC errors, and valid client complaint frequency. One county office that participated in the study would like to calculate these measures internally and with greater regularity in order to Pennsylvania (continued) A.188 identify problems preemptively. This effort is limited by staffing constraints, particularly in light of recent staff turnover. They would also like to see reports showing the number of applications that are opened but not completed and are later resubmitted. These applications cause inefficient repetition of initial tasks for clients and staff. Having measures on this might lead to changes in the nature of the annual review or other approaches to caseload renewals. A.189 Profile: Rhode Island State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives ONLINE SYSTEM (Statewide) Percent of Applications Started Online that Were submitted Statewide Program Access, Customer Service No No Number of Applications Submitted Statewide Program Access, Customer Service No No Number of Applications Started Statewide Program Access, Customer Service No No Number of Abandoned Applications Statewide Program Access, Customer Service No No Number of First-Time Applications Approved Statewide Program Access, Accuracy & Integrity, Customer Service No No DOCUMENT IMAGING (Statewide) Number of Documents Processed Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Documents Scanned Statewide Accuracy & Integrity, Efficiency, Customer Service No No Number of Tasks Completed Statewide Not reported Not reported Not reported PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent that are Missed and have Notice Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Applicants Requesting a Phone Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Notice of Missed Interview Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Rhode Island (continued) A.190 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applicants Requesting a Phone Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applicants Requesting an In-Person Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No APPLICATION TRACKING (Statewide) Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Processed: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 100 percent of the potentially eligible population- for both paper and electronic applications must be processed No Number of Recertifications Processed: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applications Approved: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Applications: Community Partner Statewide Efficiency Not sure Not sure Number of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Rhode Island (continued) A.191 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service FNS standard: Within 7 days for cases screened as expedited and within 30 days for non- expedited cases. FNS awards bonuses based on timeliness. Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service FNS standard: Within 7 days for cases screened as expedited and within 30 days for non- expedited cases. FNS awards bonuses based on timeliness. Notes: State collects mandatory accuracy data through QC reviews. Description: General: Rhode Island has a state-administered SNAP program. The state used ARRA funds to support some of its modernization initiatives. Staff reported that a new data warehouse has recently streamlined the state’s reporting abilities. Measurement Goals: Rhode Island primarily measures performance to ensure customer service, accuracy and integrity, and program access and efficiency. Call Center: Rhode Island does not have a call center. Online System: ARRA funds supported some systems development for online applications. Previously, workers had to execute multiple steps to convert information from the contractor-operated online application to the eligibility system. The systems changes have automated some steps in this process. Document Imaging: ARRA funds completely covered the purchase of new fax\/copier\/scanners for each of the offices, and the state reports the initiative would not have been implemented without the funds. Rhode Island indexes all of its scanned files directly into its processing system a procedure they report is both time consuming and necessary. The state is re-evaluating the best way to execute document imaging. Typically, workers use desktop scanners to scan a file and index it to a particular client, recording the document type in the system. Scanned documents are stored in a data warehouse and accessed through a drop down box in the eligibility system. This information is integrated with the electronic case management system. Kiosks: Rhode Island does not have kiosks for application access and submission. Rhode Island (continued) A.192 Waiver of Face-to-Face Interview: ARRA funds supported an upgrade to a digital telephone system, which the state reports would not have been implemented without the use of stimulus funds. On an ad-hoc basis, Rhode Island could request a breakdown of phone versus face-to-face interviews. However, the agency has not done so due to the prohibitive associated costs. Eventually, they hope the new data warehouse will enable internal staff to generate ad-hoc reports at little to no additional cost. No automatically generated report shows whether interviews were missed by type of interview (telephone versus face-to-face), but those data elements are in the system and could be extracted through an ad-hoc report. Shortened Interviews: Rhode Island does not have a shortened interview process. Expedited Online Applications: Rhode Island does not have an expedited online application initiative. Application Tracking: Rhode Island does not have an internal standard for timeliness, but aims to outperform the FNS standard to avoid another court case. The state regularly tracks only the percentage of interviews that are missed and have a notice mailed. A recent federal lawsuit addressed application timeliness in Rhode Island. Rhode Island’s eligibility system includes three different sections: 1) application panels (screening information); 2) statistic panels (interview information); and 3) eligibility panels (benefit calculation). Rhode Island’s old process took the information from the statistic panels, which use interview information, to track timeliness of expedited cases. As a result of the lawsuit, the state changed its focus to the application panels, which use screening information to note whether a case is expedited. The changed system now calculates expedited processing time by starting the processing time clock when a case is determined expedited (which may be when the client is interviewed for a case that did not screen in as expedited). This resolved the issue of some expedited cases appearing untimely when in fact they had been determined expedited after the initial seven-day window had elapsed. Changes Over Time: Rhode Island’s eligibility system uses 30-year-old technology, but most data are now transferred from that eligibility system into the new data warehouse, making ad-hoc reports more accessible. The respondent hopes that a range of employees will be trained to generate ad hoc reports, not just the technology staff who currently handle this. Desired or Planned Future Measures: The state would like to reward offices and individuals for outstanding accuracy but does not have the funding to do so. Individuals without errors in the quality control sample receive a certificate of appreciation. To improve efficiency, Rhode Island would standardize the process of entering applications into the eligibility system. Partnering: Rhode Island has one formal, contractual partner that conducts SNAP outreach on behalf of the state: the University of Rhode Island. The University has annual goals delineated in the contract, and the respondent believes compensation was not dependent on the achievement of those goals or of a certain output. The respondent was unable to provide any further specific details about performance measurement for the University. Rhode Island also has informal partnerships with Community Action Programs via an electronic bridge that transfers data elements from the community action program agencies’ systems into the SNAP online application. That information is reviewed by SNAP staff before being transferred to the SNAP eligibility system. Measures Collected by Partners: We did not contact Rhode Island’s partners as part of this study. A.193 Profile: South Carolina State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Document Imaging, Partnering, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Program Access, Efficiency, Customer Service 5 minutes. Selected because it is the industry standard No Percent Calls Abandoned Statewide Program Access, Efficiency, Customer Service No No Average Call Duration Statewide Customer Service No No Average Waiting Time (to Speak to Agent) Statewide Program Access, Efficiency, Customer Service 5 minutes. Selected because it is the industry standard No Average Calls Handled Statewide None Not sure Not sure Average Time Prior to Abandonment Statewide None Not sure Not sure Average After-Call Work Time by Staff Statewide Program Access Not sure Not sure Number of Calls (in flow) Statewide Program Access, Efficiency, Customer Service Not sure Not sure Number of Calls Abandoned Statewide Customer Service Not sure Not sure ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Program Access, Customer Service Not sure Not sure Average Number Submitted per Month Statewide Program Access, Customer Service Not sure Not sure DOCUMENT IMAGING (Statewide) Number of Documents Scanned Statewide Customer Service No No PARTNERING (Statewide) Number of Partners Statewide Program Access, Efficiency, Customer Service No Not sure Number Accepting Applications Statewide Program Access, Efficiency, Customer Service No Not sure Number Providing Application Assistance Statewide Program Access, Efficiency, Customer Service No Not sure South Carolina (continued) A.194 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives APPLICATION TRACKING (Statewide) Number of Applications: Online Statewide Program Access, Customer Service No Not sure Number of Recertifications: Mailed Statewide Efficiency, Customer Service Not sure Not sure Notes: State collects mandatory accuracy data through QC reviews. Description: General: In South Carolina, SNAP is state-administered. They have a call center, online system, conduct document imaging, and work with community partners. Measurement Goals: South Carolina primarily measures performance to ensure customer service and program access. Staff reported concern about implementing incentives associated with performance measures. For example, an incentive related to minimizing call duration may have unintended consequences, such as decreased quality of customer service. Call Center: The call center is operated in house and uses the Avaya tracking system. The Avaya call center system is not interfaced with the eligibility system. Call center measures have been in place for two years, and the reports used by the state came packaged with the call center software. One limitation of the current system is that call center agents can sometimes be logged in and ready to receive calls, but the call center software does not recognize that they are logged in. Furthermore, the call center system places restrictions on queued calls. The queue capacity is 120, and the system cuts off additional calls from entering the queue at this point. The system also prevents calls from entering the queue after 4:15 p.m., in order to allow staff to answer all calls remaining in the queue before their workday ends. ARRA funding was used to put extra call center agents on the phones. According to staff interviewed, the demand for increased call center capacity demonstrates a need to maintain a larger phone center staff, even when the funds are exhausted. Online System: The online application system is one year old. The online system is not currently advertised to potential applicants. Staff reported they are surprised by the volume of website hits. Applicants are required to provide (at a minimum) name, address and signature when applying online. Document Imaging: Staff reported that large county offices sometimes struggle with the document imaging process and find it to be a burden. The system counts and tracks the number of documents imaged. Transfer of data on an application first goes to an image, but then the image’s data must be manually entered. Scanned images and cases share numbers, but there is no electronic link between them in the system. Local databases have labels and are assigned case numbers, but they are not linked Partnering: Partnering for application submission is pending because of a grant, but that application access is not yet implemented. South Carolina has two formal contracts. One of the partners is reimbursed quarterly based on the number of the applications they submit. Measures Collected by Partners: We did not contact either partner as part of this study. South Carolina (continued) A.195 to the eligibility system in any way. The documents in the system are available to all the workers, except for folders deemed confidential. Kiosks: South Carolina does not have kiosks. Waiver of Face-to-Face Interview: South Carolina reported that they do not have a waiver of the face-to-face interview. Shortened Interviews: South Carolina reported that they do not have a shortened interview process. Online Expedited Applications: South Carolina does not have online expedited applications. Application Tracking: South Carolina can track the source of applications, but does not run reports or otherwise use the data. The state tracks the quality control measures that are required by FNS. Only the quality control sample is used to look at accuracy measures, not all applications. Changes Over Time: The eligibility system was designed many years ago, but many tracking codes have been added within the last year. Desired or Planned Future Measures: South Carolina would like to institute a process to track the rate at which partners sign up more applicants. South Carolina eventually would like to have all their applications come in online, but staff said the immediate goal is to have as many as possible done this way. A.196 Profile: South Dakota State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Document Imaging, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives DOCUMENT IMAGING (Statewide) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) None Notes: South Dakota did not complete the survey. We were able to interview them to obtain the information described below. Description: General: South Dakota has a document imaging system and a waiver of the face-to-face interview for recertifications. Measurement Goals: South Dakota has very few measures beyond those required by FNS. Call Center: South Dakota does not have a call center. Online System: South Dakota has not implemented an online system. Document Imaging: South Dakota manages the document imaging system in-house. Workers can access the scanned documents from their desktops if they have permission to view that case number. South Dakota does not formally track any performance measures, but some aspects of the document imaging system may be reviewed at times. Kiosks: South Dakota does not have kiosks. Waiver of Face-to-Face Interview: South Dakota conducts all application interviews in person and recertification interviews via phone. The type and number of interviews are captured in the narrative of the case record but are not entered into an automated system for tracking. Shortened Interviews: South Dakota does not use a shortened interview process. Online Expedited Applications: South Dakota does not have online expedited applications. Partnering: South Dakota did not indicate that they partnered with any organizations. Measures Collected by Partners: Not applicable. South Dakota(continued) A.197 Application Tracking: South Dakota tracks the number of pending and approved applications and approval and denial rates for applicants. They also track the number of applications that include elderly or disabled individuals or children. Local offices review cases with errors to identify trends. Changes Over Time: They have not changed state performance measures in at least 20 years. Desired or Planned Future Measures: None reported. A.198 Profile: Texas State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 2 Initiatives Active in State: Call Center, Online System, Document Imaging, Partnering, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Percent of Calls Completed in the Computer Phone System Statewide Efficiency, Customer Service Yes, not specified Not reported Average Answer Speed Statewide Program Access, Customer Service 180 seconds. Not reported Average Hold Time Statewide Program Access, Customer Service Yes, not specified Not reported Percent Calls Abandoned Statewide Program Access, Customer Service No more than 10 percent abandoned in a month (there is also a weekly measure). For every percentage point below the standard, there is a $500 to $1,000 penalty to the contractor. Average Call Duration Statewide Efficiency, Customer Service Yes, not specified Not reported Average Calls Handled Statewide Program Access, Efficiency, Customer Service Yes, not specified Not reported Average Staff on Phones Statewide Program Access, Efficiency, Customer Service Yes, not specified Not reported Number of Hang-ups Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Changes Received Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Not Completed in Computer Phone System Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Abandoned Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Queued Statewide Program Access, Efficiency, Customer Service Not reported Not reported Texas (continued) A.199 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Answered\/Handled Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Clients Accessing Computer Phone System Data Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Calls Received Statewide Program Access, Efficiency, Customer Service Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Program Access, Efficiency, Customer Service No No Average Number Submitted per Month Statewide Program Access, Efficiency, Customer Service No No Number of Applications Submitted for Each Type of Program Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Statewide) Percent of Documents Imaged Same-Day Statewide Efficiency 98 percent of documents must be imaged same- day Not reported Percent of Documents Imaged by Next Business Day Statewide Efficiency 100 percent of documents must be imaged by the next business day. Not reported Number of Documents Received Statewide Efficiency Not reported Not reported Number of Documents Scanned Statewide Efficiency Not reported Not reported Number of Staff Assigned to Scanning Statewide Efficiency Not reported Not reported PARTNERING (Statewide) Number Clients Assisted per Partner Statewide Program Access, Efficiency, Customer Service No No Texas (continued) A.200 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Applications Received per Partner Statewide Program Access, Efficiency, Customer Service No No Number of Clients Educated Statewide Program Access No No Number of Clients Assisted Statewide Program Access No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent that are Missed and Have Notice Mailed Statewide Efficiency No No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity No No Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity No No ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Percent of Community Partner Applications Approved Statewide Program Access, Efficiency, Customer Service No No Percent of Community Partner Recertifications Approved Statewide Program Access, Efficiency, Customer Service No No Percent of Total Applications Approved Statewide Program Access, Efficiency, Customer Service No No Percent of Total Recertifications Approved Statewide Program Access, Efficiency, Customer Service No No Percent of Applications Not Completed Statewide Program Access, Efficiency, Customer Service No No Percent of Applications: Online Statewide Program Access, Efficiency, Customer Service Not reported No Percent of Recertifications: Online Statewide Program Access, Efficiency, Customer Service Not reported Not reported Texas (continued) A.201 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Online Recertifications Denied for Failure to Submit Documentation Statewide Not reported No No Percent of Initial Applications Denied Statewide Program Access, Customer Service No Percent of Recertifications Denied Statewide Program Access, Customer Service No No Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Benefit Amount (for those eligible) Statewide Program Access, Accuracy & Integrity, Customer Service No No Percent of Applications Processed Timely Locally Efficiency, Customer Service No No Number of Applications Approved: Community Partner Statewide Program Access, Efficiency, Customer Service No No Number of Recertifications Approved: Community Partner Statewide Program Access, Efficiency, Customer Service No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Recertifications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Applications: Community Partner Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Recertifications: Community Partner Statewide Program Access, Efficiency, Customer Service Not reported Not reported Number of Cases with Complete Verification Submitted Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No, but in the process of establishing some No, but in the process of establishing some incentives Number of Applications that are Not Processed Timely Locally Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. Texas (continued) A.202 Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Texas has the Texas Integrated Eligibility Redesign System (TIERS), a new eligibility determination system that is being rolled out across the state as an upgrade from the state’s legacy system. The state call center and document imaging center are run by contractor staff. Texas also has a new online application system, built by a contractor, and a variety of other partnering efforts. Measurement Goals: Texas closely monitors a variety of measures from the partners with whom they have formal arrangements. They also review cases beyond those required for QC reviews to identify training opportunities. Call Center: Texas has two call centers, but they do not track data by location\u2014the call centers share the pool of calls. Tied to the call centers is a work management system that operates real-time. If the system fails, it can be difficult for staff to manage the call volume; staff reported that this happens only intermittently, and has not been a problem recently. The call center can receive applications, recertifications, and changes and can be used to schedule interviews and return client phone calls. Clients can sign applications telephonically as well. Call center staff have access to imaged documents to answer client questions about what documents the state has received. Information coming into the call center does not automatically transfer data into TIERS, but creates a digital image from which the eligibility worker can enter the data into TIERS. At the time of our interview, Texas was planning to launch a system to automatically move the data into TIERS. Some information, such as expenses and income, will continue to be entered manually to ensure that the workers review the information carefully. A contractor runs the call center and is required by Texas to report the measures listed in the table. They also conduct monthly reviews of the calls to ensure that the information provided to the callers is accurate. Partnering: Texas has formal agreements with the contractors for the call center, online system, and document imaging. Both formal and informal arrangements govern relationships with community- based organizations that provide application assistance and outreach. One group of partners is focused on the Children’s Health Insurance Program, but they help with SNAP as needed. Another partner assists clients through their own call center, filling out applications for clients, then sending to the client for their signature. The state reimburses partners for the labor, materials, and travel for educating and assisting clients. Texas funds two outreach coordinator positions for one of the partners that is working with other community-based organizations in many counties\u2014this organization is required to serve all of these counties throughout the year. The partners providing application assistance do not have special access to the online system. Texas also has a waiver that allows non-merit employees to conduct the SNAP interview, although state employees continue to determine the benefit. Texas is working with a designated group of community-based organizations to conduct these interviews. Measures Collected by Partners: Texas requires reports from the formal outreach partners about the number of clients assisted and educated, the number of applications distributed, and (for one partner) the counties served in the month. Texas is also working toward tracking which applications come from which partners to identify potential areas for outreach and training. For their own purposes, one of the partners intends to start collecting demographic information\u2014age, number of people in the household, and level of education. Texas (continued) A.203 Online System: Contractors also developed the online system for Texas. Clients can apply online, signing the application electronically if they choose. Reporting for the online system was new at the time of this study, so details about the calculations were not yet available. Texas is also exploring standards for the online system, and staff reported that they plan to attempt to maximize the percentage of online applications. Staff said they are interested in ensuring that the measures can be calculated real-time so supervisors can be responsive to current activity levels. Document Imaging: Everything imaged at the document processing center comes to that center by mail. Texas does not track whether the documents were originally provided by mail or fax or dropped off at the office. Once imaged, the documents are classified as applications or supporting documents. Contractor staff register applications, schedule appointments, and route the documents for state staff to take action. Documents are stored in a repository for the state, allowing workers to search for documents related to a client. The Texas staff meet with the contractor every other week to review the reports and discuss imaging issues and trends. Contractor staff also sample and review the imaged documents for quality control purposes. Kiosks: Texas does not have kiosks. Waiver of Face-to-Face Interview: Telephone interviews as part of the face-to-face waiver are conducted by merit staff, outside the call center. They track whether interviews were conducted in person, through a home visit, or by phone. Shortened Interviews: Texas does not have a shortened interview initiative Online Expedited Applications: Texas accepts expedited applications online, but the state does not collect any data or measures about this initiative. Application Tracking: Texas can track whether applications are received online, by paper, or from a partner, but they do not do so regularly. However, they are not able to track other aspects of processing, such as timeliness, by the source of the application. Local offices in Texas pull cases, in addition to those needed for QC review, for internal quality assurance. They use these for training, accountability, and performance evaluation purposes. State reports track the number of cases handled by each worker Changes Over Time: Texas rolled out a new eligibility determination system, Texas Integrated Eligibility Redesign System (TIERS), beginning in 2009. Texas also reported a new document imaging vendor as of January 2010 and a new online application system built by a contractor. At the time of the interview, state staff described plans to transition partners from hand-delivering or faxing applications to assisting clients with the online application. This would enable the state to automatically track the number of online applications coming in from each partner. Additionally, the layout and production of application tracking reports changed in December 2010, although the calculation of the measures did not change. In the last quarter of 2010, the reports became available on a daily rather than monthly basis. Desired or Planned Future Measures: Texas staff reported that they are interested in tracking why clients come into the office (for example, for an EBT card, to submit an application, and so on). Currently, they only manually track some of the information. Having a report could help with customer flow and improve their services. Staff would like to be able to compare the approval rates of their partners with those of other states to see if they need to improve the services partners provide, and to seek advice from states that have high partner approval rates. A.204 Profile: Utah State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 5 Number of Partners Interviewed: 4 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Answer Speed Statewide Program Access, Efficiency, Customer Service State: No One local office: Less than 30 minutes. No Percent Calls Abandoned Statewide Program Access, Customer Service No No Average Call Duration Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Waiting Time (to Speak to Agent) Statewide Program Access, Efficiency, Customer Service State: No One local office: Reported that the standard is 30 minutes, or 8 calls waiting, at which time more help should be requested. No Average Calls Handled Statewide State: None Local: Program Access, Efficiency, Customer Service State: Within 5 percent of the team average for number of calls No Average Queue Time Statewide Program Access, Efficiency, Customer Service No No Average Time Prior to Abandonment Statewide Program Access, Efficiency, Customer Service No No Average After-Call Work Time by Staff Statewide Accuracy & Integrity, Efficiency, Customer Service State: No One local office: 20 minutes No Number of Calls (in flow) Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Abandoned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Utah (continued) A.205 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Queued Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Answered\/Handled Statewide Program Access, Efficiency, Customer Service No No Number of Agents Assigned to Phones Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service State: No One local office: each team should staff the queue with at least 5 members. No Number of Calls Received Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Calls Transferred to Agent Statewide None No No Average Hold Time Statewide Program Access, Efficiency, Customer Service One local office: less than 20 minutes No Average Staff on Phones Statewide Local: Program Access, Accuracy & Integrity, Efficiency, Customer Service One local office: phones are staffed with at least 5 people, but expect half of the team which is generally 7 No Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Program Access, Customer Service Not sure Not sure Number of Clients Accessing Computer Phone System Data Statewide Program Access, Accuracy & Integrity Not sure Not sure Percent of Calls Completed in the Computer Phone System Statewide None Not reported Not reported Percent of Queued Calls Handled Statewide None Not reported No Percent of Total Calls Handled Statewide None Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Program Access, Customer Service No No Average Number Submitted per Month Statewide Program Access, Efficiency, Customer Service No No Utah (continued) A.206 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Number of Changes Submitted per Month Statewide No No Average Level of Benefits Statewide None No No Average Number of Accounts Created per Month Statewide Program Access, Efficiency, Customer Service No No Number of Online Accounts Created Statewide Program Access, Efficiency, Customer Service No No Number of Online Instant Messaging\/Chats Statewide Program Access, Efficiency, Customer Service No No Average Number of Log- ins per Month Statewide Program Access, Efficiency, Customer Service Not sure Not sure DOCUMENT IMAGING (Statewide) Number of Documents Received Statewide None Individual worker performance expectation is based upon a fluctuating workload average. No Number of Documents Received: Fax Statewide None Not reported No Number of Documents Received: Other Electronic Statewide None Individual performance workload measurement. No Number of Documents Scanned Statewide None Individual performance workload measurement. No Percent of Documents Received by Fax Statewide Program Access, Customer Service Workload measurement expectations are found in individual performance plans for those who primarily image documents. No KIOSKS (Statewide) None PARTNERING (Statewide) Number of Partners Statewide Program Access, Efficiency, Customer Service No No Utah (continued) A.207 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Error Rate for Cases with Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Meet or exceed the federal QC accuracy rates set for all cases No Error Rate for Cases with Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Meet or exceed federal QC accuracy rates set for all cases No SHORTENED INTERVIEWS (Statewide) Percent of Total Interviews that Are Shortened Statewide Not reported Not reported Not reported Percent of Clients Electing Shortened Interview Statewide Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Expedited timeframe of 7 days Yes, not specified Percent of Applications Approved: Online All Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide None No No Percent of Online Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Benefit Amount (for those eligible) Statewide None No No Percent of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Percent of Recertifications: Mailed Statewide None No No Total Number of Applications Completed Statewide Program Access No No Number of Applications: Online Statewide Program Access, Efficiency, Customer Service No No Number of Recertifications: Mailed Statewide None No No Utah (continued) A.208 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Processing Time of Application Decision Statewide Program Access, Efficiency, Customer Service 30 days, but prefer to process applications more quickly. No Percent of Complete Applications Denied Statewide Program Access, Customer Service No No Percent of Applications Approved After Paper Submission to Local Office Statewide Not reported Not sure Not sure Percent of Call Center Applications Approved Statewide Not reported Not sure Not sure Percent of Call Center Recertifications Approved Statewide Not reported Not sure Not sure Percent of Mailed Recertifications Approved Statewide Not reported Not sure Not sure Percent of Total Recertifications Approved Statewide Not reported Not sure Not sure Percent of Applications: Call Center Statewide Not reported Not sure Not sure Percent of Online Applications Denied for Failure to Complete Interview Statewide Not reported Not sure Not sure Percent of Recertifications Denied Statewide Not reported Not sure Not sure Average Processing Time of Recertification Decision Statewide Not reported Not sure Not sure Percent of Applications that Appear Eligible for Expedited Benefits Locally Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Utah (continued) A.209 Description: General: Utah has been modernizing SNAP and other programs for over a decade. Until June, 2009, the offices around the state had different policies and different ways for determining eligibility. In 2009 they consolidated all eligibility services (including SNAP, child care, and financial assistance) under one division. They now have a standardized document imaging center and one phone number for a virtual call center environment. All of Utah’s modernization efforts are initiated and standardized by the state. State staff reported that they are working to improve upon the many existing initiatives, including the online application and their document imaging system. Utah has faced few challenges with their data collection and reporting since they standardized and streamlined their procedures within the last year. While the state noted that they would like reporting to be more automated for certain initiatives, they are fairly satisfied with their current capabilities. Utah is pursuing expanded performance measurement with some of their new initiatives, such as e- notifications and the live-chat feature. Any new measures will be collected in addition to the large number of measures they already track. The state pays to be part of a Call Center Network Group (CCNG), so that they can learn about best practices and recommendations for standards. Measurement Goals: Utah’s performance measures touch on all FNS goals. They also use their performance data for staff development, workload management, responses to requests (from community advocates, legislative workers, or in-house staff), and for monitoring the frequency of use for the online application. Call Center: The call center has one toll-free number, which is the main method of contact for customers to access the program. This includes applications, inquiries, change reporting, and recertification. When a customer calls in, they reach an interactive response system that pulls up their case based on information they enter and routes them to the correct team of agents (the system does not have the functionality to receive information without agent intervention). While all measures are standardized across the state, some local offices interviewed reported additional modernization goals, reporting period, or management targets than the state. Utah sets some of their standards or benchmarks using the team concept, which means setting standards for each worker within a certain range (for example, 5 percent) of the team average. They track wait-time in real time to identify when more staff needed to answer the phones. Online System: Utah has two online systems: one for eligibility workers to interface with cases and to control workflow (E-REP\u2014released in mid-2011) and one for customers to access their account (MyCase\u2014released November 2011). MyCase features include allowing customers to see when tasks will be complete, if documents have been received, and their benefit amount. More features are under development. Utah also offers customers an online chat feature: through the website, they can interact with staff on demand. Utah reports this is more efficient than phone calls because one eligibility worker can handle two to four chats simultaneously. Within the next two years, Utah plans to redesign their online application. They reported plans to expand it to include change reporting, recertifications, instant messaging interviews, and an improved pre-screening tool. Document Imaging: Utah’s document imaging center handles 60 to 75 percent of the statewide documents, and images are stored on a statewide file server. A few locations have the ability to scan Partnering: Utah has a count of the number of partners with whom they have a relationship (usually, this is a written MOU). Partners assist clients and provide computer access, but do not make eligibility determinations. Partners do not provide Utah offices with performance data, though they may gather their own performance data. Measures Collected by Partners: Utah partners did not report any performance measurement. Utah (continued) A.210 and image their own documents if necessary, when mailing will take too long. All paper applications received (whether via fax, scan, email, or state mail) are sent to the centralized Image Operation Center. Utah uses barcoding to help attach correspondence originating with the state back to the case. Kiosks: Utah has more than thirty computer stations throughout the state, termed Job Connection Areas. Clients have the capability to use the kiosks to connect to the Internet for the online application or to download a paper application. Utah does not track any measures for this initiative. Waiver of Face-to-Face Interview: Utah collects the error rate for cases by the type of interview (telephone or face-to face), but these measures are not used unless requested by FNS. Although they do not currently collect it, they would be able to record the type and number of interviews conducted with SNAP applicants. Shortened Interviews: Utah reported that they have a shortened interview initiative, but did not provide us with additional details. Online Expedited Applications: Utah records whether an application is expedited or not, but they do not have any other measures for online expedited applications Application Tracking: Utah tracks a number of application tracking measures, including those required for FNS QC. Utah is aware of the origin of all paper applications while they are processed at the centralized imaging unit, but they do not have a system field to record and save this type of information. Changes Over Time: In the past year there have been no significant changes to the way Utah calculates measures or collects data. They have recently standardized old systems or switched to new systems, but the basic methodology has not changed. Due to one change, Utah does not have as much detail on denial reason, but they are adding back in some of that information. Desired or Planned Future Measures: At the time of the interview, Utah had created MyCase and was trying to encourage more customers to use it to access their information. They have begun to look at numbers based on the homepage but have not put standards in place yet. Additionally, they would like to establish an email notification system for any correspondence sent through the customer homepage (the customer would receive an email when they have a message waiting) and would track data related to this system. Utah would also like to track more information on the live-chat feature. Utah state staff would like to have information on performance measures used by other states, particularly those related to call centers and costs. Due to a lack of standardization, they noted difficulty comparing measures among call centers in other states. Staff in all local offices interviewed were satisfied with the data and reports they received from the state office; they did not name any performance measures that they would like to calculate outside of those they can already access. A.211 Profile: Virginia State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 3 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Waiver of Face\u2010to\u2010Face Interview, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Regionally) Average Queue Time Regional Efficiency Not reported Not reported Average Time Prior to Abandonment Regional Efficiency Not reported Not reported Number of Calls Answered\/Handled Regional Efficiency Not reported Not reported Number of Agents Assigned to Phones Regional Efficiency Not reported Not reported Average Hold Time Regional Efficiency Not reported Not reported Percent Calls Abandoned Regional Efficiency Not reported Not reported Average Calls Handled Regional Efficiency Not reported Not reported Average Staff on Phones Regional Efficiency Not reported Not reported Number of Calls Abandoned Regional Efficiency Not reported Not reported Number of Calls Queued Regional Efficiency Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applicants Who Received Help to Apply Online Statewide Program Access, Customer Service No No Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Applications Submitted per Month Statewide Not reported No No Number of Abandoned Applications Statewide Not reported No No Number of Applicants who Received Help to Apply Online Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Regionally) None KIOSKS (Regionally) None Virginia (continued) A.212 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives PARTNERING (Statewide) Number of Partners Statewide Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted Face-to-Face Statewide Program Access, Customer Service No No Number of Denials Due to Missed Interview Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Redetermination Interviews Statewide Efficiency Not reported Not reported Number of Missed Interviews Statewide Efficiency Not reported Not reported Notice of Missed Interview Mailed Statewide Efficiency Not reported Not reported Total Number of Interviews Statewide Efficiency Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) None APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported No No Percent of Total Recertifications Completed Statewide Not reported No No Number of Applications Online Locally None Not reported Not reported Average Benefit Amount (for those eligible) Statewide Not reported No No Number of Applications Approved: Online Statewide Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Percent of Applications Not Completed Statewide Not reported Not reported Not reported Virginia (continued) A.213 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Total Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Recertifications Started Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Not reported Not reported Not reported Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Program Access No No Timeliness Rate Statewide Customer Service No Because of a court order, if the agency is below 97percent for regular processing time of applications, the local agency is required to submit a corrective action plan for each case that was out of compliance. Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Virginia’s SNAP is state supervised and locally administered. They have a 60-day application process rather than a 30-day process. The online system is available statewide, and the call center is available in some counties. Some counties are also beginning to incorporate document imaging and kiosks. Measurement Goals: Virginia’s primary goal for the measures related to efficiency. Call Center: The call center operates in one county, and they consider it to be a pilot. The call center handles change reporting, transfers callers to agent, and makes outgoing calls. The county’s primary measures for tracking are the total number of calls, number of abandoned calls, and the average queue time. They use the measures primarily to distribute work and modify office procedures for handling calls. Virginia (continued) A.214 Online System: The online system provides a screening tool and allows applicants to submit signed application. At the time of this data collection, the state had a manual process for entering the online information into the eligibility system. The state sends the electronic version of the application to the appropriate local agency; the local agency has to retrieve and download the application and upload it into the eligibility system. In November 2010, the system will become automated and information will go directly into the eligibility system. Virginia developed a variety of reports to measure the system’s performance, but they are not used due to questions about the accuracy of the data. The reports primarily measured program access and efficiency. Document Imaging: At the time of our data collection, one county was imaging documents and another county was preparing to image documents. The county did not report any measures related to document imaging. Kiosks: At the time of the interview, one county had just recently put a few computers in their lobby for applicants. Waiver of Face-to-Face Interview: Virginia has a waiver of the face-to-face interview at both application and recertification. Their system records whether the interview is conducted by phone or face- to-face. Shortened Interviews: Virginia does not have a shortened interview process. Online Expedited Applications: The eligibility system automatically determines if an application should be expedited. The state believes they could provide measures on approval status, possibly by some demographic characteristics, but it’s not regularly done now. Application Tracking: Virginia believes they could be doing more measuring, such as differentiating between applications and recertifications, but it would require a shift in priorities. They also have an internal database for tracking applications that works in tandem with an appointment scheduler. This information is currently used to make staffing decisions across offices. Changes Over Time: None reported. Desired or Planned Future Measures: Virginia would like to see more readily available data on accuracy rates for states, particularly high performing ones. A local agency is interested in tracking what percentage of applicants are repeat applicants versus first-time applicants. Partnering: Virginia is in the process of developing outreach plans with several community-based organizations. No partnerships completed for SNAP outreach but the state reported performance measures will likely include expenditures, number of screenings completed, number of applications, and final disposition of applications Measures Collected by Partners: Not applicable. A.215 Profile: Washington State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 7 Number of Partners Interviewed: 4 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering Arrangements, Waiver of Face\u2010to\u2010Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls (in flow) Statewide Program Access, Efficiency, Customer Service No No Number of Calls Abandoned Statewide Program Access, Efficiency, Customer Service No No Number of Calls Answered\/Handled Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Agents Assigned to Phones Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Average Answer Speed Statewide Program Access, Efficiency, Customer Service 5 minutes No Average Hold Time Statewide Program Access, Efficiency, Customer Service 8 minutes No Percent Calls Abandoned Statewide Program Access, Efficiency, Customer Service No No Average Call Duration Statewide Program Access, Efficiency, Customer Service No No Average After-Call Work Time by Staff Statewide Program Access, Efficiency, Customer Service No No Number of Changes Received Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Changes Processed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Calls Received Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Cases Pending Benefit Decision: Call Center Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applications Processed: Call Center Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Washington (continued) A.216 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Client Calls Returned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of documents processed within 30 days Statewide Program Access, Accuracy & Integrity, Customer Service 90% of documents processed within 30 days No Standard of Promptness for Applications and Recertifications Statewide Program Access, Accuracy & Integrity, Customer Service 95% of applications processed within standard of promptness No Percent of Total Calls Handled Locally Program Access, Customer Service Not reported Not reported Average Staff on Phones Locally Program Access, Customer Service Not reported Not reported Average Time Prior to Abandonment Locally Program Access, Customer Service Not reported Not reported Percent of Queued Calls Handled Locally Program Access, Customer Service Not reported Not reported Number of Calls Queued Locally None Not reported Not reported ONLINE SYSTEM (Statewide) Percent of Applications Received Statewide Program Access, Efficiency, Customer Service No No Number of Changes Submitted Statewide Program Access, Accuracy & Integrity, Customer Service No No Number of Online Applications Submitted Locally Program Access, Customer Service No No DOCUMENT IMAGING (Statewide) Percent of Documents Scanned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 100% of customer documents scanned. Mandated by Governor due to lawsuit. No Washington (continued) A.217 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Documents Scanned within Standard of Promptness Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 100% of non- completed documents scanned within 1 business day. 100% of completed documents scanned within 3 business days, mandated by governor. No Number of Documents Received Statewide Efficiency No No Number of Documents Processed Statewide Efficiency No No Number of Documents Scanned Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Tasks Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No KIOSKS (Statewide) Number of Uses to Submit Changes Statewide Program Access, Customer Service No No PARTNERING (Statewide) Number of Partners Statewide Program Access, Customer Service No No Number Accepting Applications Statewide Program Access, Customer Service No No Number Providing Application Assistance Statewide Program Access, Customer Service No No Number with Terminals\/Kiosks to Submit Application Statewide Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Number of Face-to-Face Interviews Locally Customer Service Not reported Not reported SHORTENED INTERVIEWS (Statewide) None ONLINE EXPEDITED APPLICATIONS (Statewide) None Washington (continued) A.218 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported Not reported Not reported Percent of Total Recertifications Approved Statewide Not reported Not reported Not reported Percent of Applications: Online Statewide Program Access, Customer Service No No Percent of Recertifications: Online Statewide Program Access, Customer Service No No Number of Applications: Online Statewide Program Access, Customer Service No No Number of Recertifications: Online Statewide Program Access, Customer Service No No Average Processing Time of Application Decision Statewide Efficiency, Customer Service No No Average Processing Time of Recertification Decision Statewide Efficiency, Customer Service Yes, not specified. Yes, not specified. Average Benefit Amount (for those eligible) Locally Not reported No No Percent Errors where Information was Incorrect Locally None Not reported Not reported Total Number of Applications Completed Locally None Not reported Not reported Total Number of Recertifications Completed Locally None Not reported Not reported Percent of Complete Applications Denied Locally Program Access, Customer Service No No Percent of Initial Applications Denied Locally Program Access, Customer Service No No Percent of Applicants that Appear Eligible for Expedited Benefits Locally None Not reported Not reported Number of Cases with Complete Verification Submitted Locally None Not reported Not reported Percent of Applications Pending Locally Program Access No No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. Washington (continued) A.219 If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. ACD = Automatic Call Distribution: also known as call center software, which sorts callers into queues by the reason for their call. VDN = Vector Directory Number: phone numbers of agents who are connected to different parts (vectors) of the call center queue. CSO = Community Service Office: Washington’s name for local SNAP offices. Description: General: Washington has each modernization initiative that we have reviewed for the study. They launched their online system in the early 2000s. They recently redesigned their service delivery, and one outcome was an alignment of the use of technology across the state. The call centers now use the Avaya system to track the same data across states. Documents are scanned at four indexing sites in the state. Washington partners with community organizations and has kiosks available for client use at both local offices and community partners. The state has both a waiver of the face- to-face interview and a shortened interview process. Measurement Goals: Washington measures performance with the goal of improving program access, efficiency, customer service, and accuracy and integrity. Call Center: The state has a series of regional call centers. The state uses the Avaya Call Management System. The system automatically tracks a wide variety of data for calls received, handled, and abandoned, as well as performance data to monitor staff, such as number of agents assigned to phones and after call work time by staff. Hold time and answer speed are also tracked and have associated performance standards. Washington developed performance data by visiting existing call centers in both private industry and other government agencies. Call center supervisors also requested performance measures they thought would be most useful for management purposes. Online System: Washington operates the online system and tracks the percent of applications received, number submitted, and number of changes submitted. Local offices can query reports as needed. Staff manually enter information obtained through the online application system into the eligibility system. At the time of data collection, Washington was in the process of upgrading their online system. Also, at the time of interview, it was not possible to use the screening tool to pre-populate the application; however, two local offices are testing this functionality as part of a pilot program. Document Imaging: Washington tracks the number of documents received, processed, and scanned; the state also tracks the percentage of documents scanned overall (for which they set a standard of 100 percent), and within standard of promptness. Non-completed documents must be scanned within one business day, while completed documents must be scanned within three business days. The state maintains these benchmarks to comply with standards mandated by the governor. When offices receive a document, it is sent via US mail to one of four indexing sites in the state to be sorted, Partnering: Washington tracks the total number of partners, as well as the number accepting applications, providing application assistance, and hosting kiosks to submit applications. Washington partners with approximately 500 community- based organizations (as direct contractors or as subcontractors). Partnerships at the state level are governed by memoranda of understanding. Local offices also partner, and this contact is monitored and reported to the state. There are four levels of partnership, depending on the equipment and services, ranging from a computer with self-service access to online applications and providing equipment and staff resources for a variety of assistance and advice. Measures Collected by Partners: Partners in Washington collect performance data, including the number of applications and application approval rate. Washington (continued) A.220 scanned, and indexed. The indexing process both identifies the origin of the document and the type of document. Once indexed, the document is automatically loaded into the barcode document imaging system, where it is linked to the case of the client who submitted it. This process takes a maximum of 2.5 days. Scanned documents are stored on mega-servers with multiple backups. Case managers and workers assigned to the case have access to the documents. Kiosks: Washington has kiosks available at the local Community Service Offices (CSOs) for all clients. Clients can use the kiosks to complete a screening for benefit eligibility, submit a change of circumstance, or complete and submit an application or recertification. Staff are on hand at the CSO as a resource to answer questions and walk clients through the application process, resulting in a higher level of customer service. Washington is currently unable to track if an application originated at a kiosk, but the functionality has been requested by at least one local office. The online application contains an optional question allowing clients to enter who helped them complete the application; however, Washington does not use this information for any purpose. Waiver of Face-to-Face Interview: Washington has a waiver to conduct interviews via telephone. Locally, Washington tracks the number of face-to-face interviews, but at the state level the type of interview is not tracked. Missed interviews or other problems completing the interview are recorded in the case narrative, but are not tracked. Shortened Interviews: Washington assigns cases to an interview type based on how error prone the household is expected to be. Simple cases that get the shortened interview are often single-person or small households or Medicaid applicants. More difficult cases, such as those with more people, self- employment income, or an accompanying TANF application are sent through the longer interview process. Washington did not report collecting any measures related to the shortened interview. Online Expedited Applications: Expedited applications can be submitted through the online system. At the state level, demographic information or approval status for expedited cases is available on an ad-hoc basis. Application Tracking: Washington tracks the percentage of applications approved, percentage submitted online, and the average processing time. They also track accuracy measures required by FNS. Washington developed application tracking performance data many years ago. Some measures are based on federal requirements, while others were developed by quality assurance or policy and operations staff in the state office. Data are collected at the state level, and the reports are then shared with local offices. Changes Over Time: Washington delivered approximately 17 kiosks to outreach partners with funding from an FNS grant to improve SNAP access among the working poor population. Washington installed the online application system in 2000. Since then, they have tracked the percentage of application received online to monitor program access. At the time of data collection, they were working with private industry and customer focus groups to develop a new online application. Desired or Planned Future Measures: Washington is unable to track the type of interview, but staff reported that they would like to have that capability. For online application, they are interested in tracking the number of applications by source, including from community partners, home computers, and from the office lobby. This capability would assist outreach efforts and help to identify the most active partners. To increase customer service, Washington is interested in monitoring client outcomes. This capability should be available next year using quality monitoring software. Washington also plans to upgrade the call center with virtual hold software, allowing customers can hang up if there is a wait to speak with an agent. The system will call them back when the next agent is available. In addition, respondents in Washington stated a desire for additional performance data to monitor staff. Additional performance data would allow supervisors to identify training needs and oversee staff work. To capture this type of information, Washington plans on integrating the current call management system with Workforce Management Software to develop staffing models. A.221 Profile: West Virginia State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 0 Number of Partners Interviewed: 0 Initiatives Active in State: Call Center, Online System, Wavier of the Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Number of Calls Answered\/Handled Statewide Program Access, Efficiency, Customer Service At least 40 calls per day, per worker. No Number of Agents Assigned to Phones Statewide Efficiency, Customer Service 40 contacts per day, per agent. All agents are automatically on the phones during high volumes. No Percent of Changes Processed Statewide Program Access, Efficiency, Customer Service Goal is 100 percent. No Average Hold Time Statewide Program Access, Efficiency, Customer Service Not sure No Percent Calls Abandoned Statewide Program Access, Efficiency, Customer Service Less than 20 percent dropped calls No Average Call Duration Statewide Accuracy & Integrity, Efficiency, Customer Service No No Average Waiting Time (to Speak to Agent) Statewide Program Access, Efficiency, Customer Service Less than 5 to 7 minutes. Yes, not specified Average Calls Handled Statewide Accuracy & Integrity, Efficiency, Customer Service Minimum of 40 calls per day, per worker. No Percent of Total Calls Handled Statewide Accuracy & Integrity, Efficiency, Customer Service 80 percent of clients. Goal to drop no more than 30 percent. They plan to reduce this number to 20 percent. No Average Queue Time Statewide Program Access, Efficiency, Customer Service No No Number of Calls (in flow) Statewide Program Access, Customer Service No No Number of Calls Abandoned Statewide Program Access, Customer Service Not reported No West Virginia (continued) A.222 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Queued Statewide Program Access, Customer Service If more than eight calls in queue or if wait time is greater than eight minutes, all workers are instructed to log onto the phones. No Number of Calls Received Statewide Program Access, Customer Service Not reported No Number of Hang-ups Statewide Program Access, Efficiency, Customer Service Not sure No Number of Changes Received Statewide Accuracy & Integrity, Customer Service 40 contacts per day, per agent. No Number of Changes Processed Statewide Accuracy & Integrity, Customer Service 40 contacts per day, per agent. No Number of Calls Transferred to Agent Statewide Program Access, Efficiency, Customer Service No No ONLINE SYSTEM (Statewide) Number of Online Accounts Created Statewide Program Access, Customer Service No No Number of Log-ins Statewide Program Access, Customer Service No No WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Interviews Conducted by Telephone Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Percent of Interviews Conducted Face-to-Face Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No West Virginia (continued) A.223 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Interviews Conducted by Telephone for Redeterminations Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percent of Closures Related to Telephone Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported APPLICATION TRACKING (Statewide) Number of Applications Approved: Face-to-Face Interviewed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Recertifications Approved: Face-to-Face Interviewed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Started Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Recertifications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Notes: State collects mandatory accuracy data through QC reviews. West Virginia has two call centers, Northern and Southern. Description: General: West Virginia has an online system, call center, and waiver of the face-to-face interview. Enhanced call center functionality is planned. Measurement Goals: West Virginia primarily measures performance to ensure customer service, accuracy and integrity, efficiency, and program access. Call Center: West Virginia has two call centers: Northern and Southern. State staff reported that the Southern call center is advanced and has automated functionality. It became operational in May 2010. The Northern call center is in the process of converting to the same operations as the Southern call center; funds for this conversion have been allocated (but not awarded). Data for the measures is calculated by the systems and provided in reports. Thus, many details of the calculations were not available. Online System: West Virginia tracks the number of online applications and the number of log-ins. Some demographic information is transferred from the online system to the mainframe eligibility system. A contractor developed the system that the state now maintains. Some reports are available to system staff while others are available by caseload to supervisors. West Virginia (continued) A.224 Document Imaging: West Virginia does not have document imaging. Kiosks: West Virginia does not have kiosks. Waiver of Face-to-Face Interview: West Virginia received guidance from FNS and looked at other state operations for procedural advice for the waiver of the face-to- face interview, with the goal of maintaining a high level of customer service. West Virginia tracks the number of applications and recertifications that are completed by a phone interview or a face-to-face interview. They also track the percent of case closures related to telephone interviews, which was monitored regularly until it was determined that the error rate was not increasing. This information is now reported on demand. Data collection for this measure is automatic, but report production is not. The office aims for the failure rate for telephone interview to be less than that for face-to-face; however, there is no specific target. All initial applications are face-to-face interviews, except for hardship interviews. Redetermination application interviews that only apply to SNAP benefits are completed on the telephone. The percent of interviews conducted by telephone for redetermination was monitored regularly until they determined that the error rate was not increasing. This information is now reported on demand. Shortened Interviews: West Virginia does not have a shortened interview initiative. Online Expedited Applications: West Virginia did not report that they have developed the initiative for online expedited applications. Application Tracking: West Virginia tracks the number of approvals for face-to-face interviews, in comparison to telephone interviews. The number of applications, type of application, and number of applications by county are tracked on a worker manual contact sheet. These are transferred to a common report by region submitted to the state monthly. West Virginia also collects data for the FNS QC process. Changes Over Time: West Virginia implemented a call center in May 2010. Desired or Planned Future Measures: State staff reported that, by 2014, the eligibility system in West Virginia will be completely web-based, which they expect will increase efficiency. They are also creating an automated supervisory review process. This process will gather data and measure performance on a much larger sample than quality control, based on worker or supervisor review. Partnering: West Virginia does not have partnering arrangements. Measures Collected by Partners: Not applicable. A.225 Profile: Wisconsin State Administered or County Administered: County Number of Local\/County Agencies Interviewed: 9 Number of Partners Interviewed: 6 Initiatives Active in State: Call Center, Online System, Document Imaging, Kiosks, Partnering, Waiver of Face\u2010to\u2010 Face Interview, Shortened Interviews, Online Expedited Applications, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives CALL CENTER (Statewide) Average Hold Time Statewide Customer Service No No Average Waiting Time (to Speak to Agent) Statewide Not reported One local office: Under 10 minutes (and no more than 10 people in the queue) One local office: No official standard but would like to see this time to be under 1 minute (currently ranges from 30 seconds to 2 minutes). No Average Time Prior to Abandonment Statewide Not reported Not reported Not reported Average Calls Handled Statewide Not reported No No Percent of Total Calls Handled Statewide Not reported State: No One local office: 80 percent of calls answered. State: No One local office: Posted in the call center as a worker incentive Number of Calls (in flow) Statewide Not reported Not reported Not reported Number of Calls Abandoned Statewide Not reported Not reported Not reported Number of Calls Queued Statewide Not reported Not reported Not reported Number of Calls Answered\/Handled Statewide Not reported One local office: 45 calls answered a day per worker (during a full work day) One local office: Posted in the call center as a worker incentive Number of Agents Assigned to Phones Statewide Not reported Not reported Not reported Wisconsin (continued) A.226 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Changes Processed Statewide Not reported Not reported Not reported Average Time to Process Change Statewide Not reported One local office: Informal goal of average time between 5 and 7 minutes to process changes. Another local office: No No Number of Changes Received Statewide Not reported Not reported Not reported Number of Changes Processed Statewide Not reported Not reported Not reported Number of Cases Pending Benefit Decision: Call Center Statewide Not reported Not reported Not reported Number of Applications Processed: Call Center Statewide Not reported Not reported Not reported Average Answer Speed Statewide Customer Service No One local office: Goal is to answer 95 percent of calls within 30 seconds. No Percent Calls Abandoned Statewide Not reported Not reported Not reported Average Call Duration Statewide Not reported No No Average Time to Process Changes and Documents Locally Not reported One local office: Informal goal to stay within 10 days, ideally 2-3 days. No Percent of Calls Completed in the Computer Phone System Locally Not reported Not reported Not reported Percentage of Calls Within Their Categories of Time Intervals Locally Not reported One local office: 95 percent of calls within 30 seconds No Average After-Call Work Time by Staff Statewide Not reported No No Wisconsin (continued) A.227 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System Locally Not reported Not reported Not reported Average Time to De- Queue Locally Not reported Not reported Not reported Number of Calls Received Locally Not reported Not reported Not reported Number of Calls Completed in Computer Phone System Locally Not reported Not reported Not reported Average Completion Length Locally Not reported No No Percent of Screened Individuals Potentially Eligible: Call Center Locally Not reported Not reported Not reported Percent of Screenings Resulting in Applicant Receiving Benefits: Call Center Locally Not reported Not reported Not reported Percent of Screenings Resulting in Application Submission: Call Center Locally Not reported Not reported Not reported Average Staff on Phones Locally Not reported Not reported Not reported Average Queue Time Locally Not reported Not reported Not reported Percent of Queued Calls Handled Locally Not reported Not reported Not reported Number of Hang-ups Locally Not reported Not reported Not reported Percent of Calls Requesting Agent Locally Not reported Not reported Not reported Number of Calls Transferred to Agent Locally Not reported Not reported Not reported ONLINE SYSTEM (Statewide) Average Number of Screenings Started: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Average Number of Screenings Completed: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Percent of Users Selecting Spanish Language Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Percent of Screened Individuals Potentially Eligible: Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Wisconsin (continued) A.228 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Online Screenings Started: Online Statewide Not reported Not reported Not reported Number of Online Screenings Completed: Online Statewide Not reported Not reported Not reported Percent of Applicants Who Received Help to Apply Online Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Not sure Percent of Applications Received Statewide Program Access, Accuracy & Integrity, Efficiency No Not sure Average Number Started per Month Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Average Number Submitted per Month Statewide Program Access, Accuracy & Integrity, Efficiency No Not sure Percent of Multiple Applications Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Applicants with Hardship Reason for Requesting Phone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Average Level of Benefits Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of One- page\/Requests for Assistance Submitted Statewide Not reported Not reported Not reported Number of Applications Started Statewide Not reported Not reported Not reported Number of Abandoned Applications Statewide Not reported Not reported Not reported Number of Clients Requesting Help to Apply Online Statewide Not reported Not reported Not reported Number of Applicants who Received Help to Apply Online Statewide Not reported Not reported Not reported Number of Applicants who did not Receive Help to Apply Online Statewide Not reported Not reported Not reported Average Number of Log- ins per Month Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Average Number of Accounts Created per Month Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Wisconsin (continued) A.229 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Average Number of Changes Submitted per Month Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No Not sure Number of Online Accounts Created Statewide Not reported Not reported Not reported Number of Changes Started Statewide Not reported Not reported Not reported Number of Changes Submitted Statewide Not reported Not reported Not reported DOCUMENT IMAGING (Statewide) Number of Documents Scanned Statewide Accuracy & Integrity, Efficiency No No Number of Documents Received Statewide Not reported Not reported Not reported Number of Documents Processed Statewide Not reported Not reported Not reported Number of Tasks Completed Statewide Not reported Not reported Not reported Number of Alerts Processed Statewide Not reported Not reported Not reported Percent of Documents Scanned Locally Not reported One local office: 100 percent of documents are required to be scanned. No Average Processing Time Locally Not reported No No KIOSKS (Statewide) Number of Screenings Completed: Kiosk Statewide Not reported Not reported Not reported Number of Uses to Access Online Account Statewide Not reported Not reported Not reported Number of Uses to Submit Changes Statewide Not reported Not reported Not reported PARTNERING (Statewide) Percent of Partners Providing Application Assistance Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Average Cost of Partner Arrangement Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Wisconsin (continued) A.230 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Partners Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number Accepting Applications Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number Providing Application Assistance Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number Clients Assisted per Partner Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number of Applications Received per Partner Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number with Terminals\/Kiosks to Submit Application Statewide Not reported Not reported Not reported WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) Percent of Telephone Interview Requests Honored Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service 50 percent No Error Rate for Cases with Telephone Interviews Statewide Accuracy & Integrity, Efficiency 50 percent Yes, not specified Error Rate for Cases with Face-to-Face Interviews Statewide Accuracy & Integrity, Efficiency 50 percent Yes, not specified Total Number of Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Number of Applicants Requesting a Phone Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Redetermination Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Percent of Interviews Conducted by Telephone Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service State: Not sure One local office: No more than 50 percent of the caseload One local office: No State: Yes, not specified Two local offices: No Wisconsin (continued) A.231 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Interviews Conducted Face-to-Face Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service State: At least 50 percent face-to-face One local office: No State: Not sure One local office: No Percent that are Missed and have Notice Mailed Statewide Program Access, Accuracy & Integrity, Customer Service No State: Yes, not specified One local office: No Number of Face-to-Face Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Telephone Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, 50 percent Yes, not specified Number of Home Visit Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not sure Not sure Number of Missed Interviews Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Notice of Missed Interview Mailed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Yes, not specified Yes, not specified Number of Applicants Requesting an In-Person Interview Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Number of Applicants who Did Not Answer to Type of Interview Requested Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Not reported Not reported Percentage of Interviews Conducted by Phone Without Documented Hardship Reason Statewide Not reported State; According to the conditions of the waiver, the waiver of the requirement to document hardship status was limited to 50 percent of the caseload. No Number of Times Unable to Schedule Interview with Applicant Locally Not reported Not reported Not reported Wisconsin (continued) A.232 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives SHORTENED INTERVIEWS (Regionally) Percent of Total Interviews that Are Shortened Locally Not reported Not reported Not reported Percent of Clients Electing Shortened Interview Locally Not reported Not reported Not reported Number of Shortened Interviews Locally Not reported Not reported Not reported Number of Clients with Shortened Interviews Locally Not reported Not reported Not reported ONLINE EXPEDITED APPLICATIONS (Statewide) Percent of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported Percent of Applications Approved: Online All Statewide Not reported Not reported Not reported Number of Expedited Applications Received Online Statewide Not reported Not reported Not reported Number of Applications Approved: Online Expedited Statewide Not reported Not reported Not reported APPLICATION TRACKING (Statewide) Percent of Total Applications Approved Statewide Not reported Not reported Not reported Percent of Total Recertifications Approved Statewide Not reported Not reported Not reported Average Benefit Amount (for those eligible) Statewide Not reported Not reported Not reported Number of Applications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Face-to-Face Interviewed Statewide Not reported Not reported Not reported Number of Applications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Number of Recertifications Approved: Phone Interviewed Statewide Not reported Not reported Not reported Wisconsin (continued) A.233 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Number of Total Applications and Recertifications Approved Statewide Not reported Not reported Not reported Number of Second Party Reviews Locally Not reported One local office: A minimum of 34 per month Not reported Number of Applications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications Approved: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications Approved: Call Center Locally Not reported Not reported Not reported Number of Recertifications Approved: Call Center Locally Not reported Not reported Not reported Total Number of Applications Started Statewide Not reported Not reported Not reported Total Number of Recertifications Started Statewide Not reported Not reported Not reported Total Number of Applications Completed Statewide Not reported Not reported Not reported Total Number of Recertifications Completed Statewide Not reported Not reported Not reported Percent of Applications Not Completed Statewide Not reported Not reported Not reported Percent of Applications Received Online Statewide Not reported Not reported Not reported Number of Applications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Recertifications: Paper Submission to Local Office Locally Not reported Not reported Not reported Number of Applications: Mailed Locally Not reported Not reported Not reported Number of Recertifications: Mailed Locally Not reported Not reported Not reported Number of Requests for Assistance\/One-page Applications Locally Not reported Not reported Not reported Wisconsin (continued) A.234 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications: Call Center Locally Not reported Not reported Not reported Percent of Recertifications: Call Center Locally Not reported Not reported Not reported Number of Applications: Call Center Locally Not reported Not reported Not reported Number of Recertifications: Call Center Locally Not reported Not reported Not reported Percent of Online Applications Denied for Failure to Complete Interview Statewide Not reported Not reported Not reported Percent of Online Recertifications Denied for Failure to Complete Interview Statewide Not reported Not reported Not reported Percent of Complete Applications Denied Statewide Not reported Not reported Not reported Percent of Complete Recertifications Denied Statewide Not reported Not reported Not reported Percent of One- page\/Requests for Assistance Denied Statewide Not reported Not reported Not reported Percent of Initial Applications Denied Statewide Not reported Not reported Not reported Percent of Recertifications Denied Statewide Not reported Not reported Not reported Number of Applications Denied Statewide Not reported Not reported Not reported Number of Recertifications Denied Statewide Not reported Not reported Not reported Number of Applications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Recertifications Denied: Paper Submissions to Local Office Locally Not reported Not reported Not reported Number of Applications Denied: Call Center Locally Not reported Not reported Not reported Number of Recertifications Denied: Call Center Locally Not reported Not reported Not reported Wisconsin (continued) A.235 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Applications with Incomplete Information Statewide Not reported Not reported Not reported Percent of Recertifications with Incomplete Information Statewide Not reported Not reported Not reported Percent of Applicants that Appear Eligible for Expedited Benefits Statewide Not reported One local office: No One local office: No Number of Cases with Complete Verification Submitted Statewide Not reported Not reported Not reported Number of Applicants that Appear Eligible for Expedited Benefits Locally Not reported Not reported Not reported Number of Applications with Incomplete Information Locally Not reported No No Average Processing Time of Application Decision Statewide Not reported One local office: From January 1 Oct 30 2010, county was required to meet 70 percent timeliness. This benchmark increased to 90 percent for subsequent months. No Average Processing Time of Recertification Decision Statewide Not reported One local office: From January 1 Oct 30 2010, county was required to meet 70 percent timeliness. This benchmark increased to 90 percent for subsequent months. Not reported Percent of documents processed within 30 days Locally Not reported Not reported Not reported Applications in Intake Mode over 30 days Locally Not reported Not reported Not reported Notes: State collects mandatory accuracy data through QC reviews. Wisconsin (continued) A.236 Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. All measures reported by Milwaukee County have been marked as Statewide because the state has responsibility. However, not all localities within Wisconsin may be required to collect these measures. Description: General: Wisconsin modernized SNAP, which it calls FoodShare, by establishing many initiatives, primarily at the county level. The state and counties actively collect performance measures and data. Milwaukee County and a centralized Enrollment Services Center have been fully administered by the state since January 2010 in response to a lawsuit. Wisconsin staff said they are generally satisfied with the accuracy of their data. County offices described difficulties using call center software for reporting. One county stressed that it took time to get the system operational to the point where they could pull data elements and generate reports. Another office has had difficulty accessing historical data. On the whole, county offices expressed a desire to receive more reports from the state and to have greater system functionality in order to break down data, automatically calculate measures, or retrieve needed reports. Some Wisconsin counties used ARRA funding to support their programs and modernization initiatives. One local office used funds to expand their county call center to take on regional work. They also used ARRA funding to pay for kiosk phone lines, which are linked to the change center. After receiving ARRA funds, another county implemented a call center, kiosks, and expedited online applications. Additionally, funds were used to support the state takeover of FoodShare in one county and fund eligibility workers at the local level. Though no performance measures were created specifically based on ARRA funding, one respondent said that reporting increased as a result of the state takeover of FoodShare. One county has set up a new workflow. Under this arrangement, three workers are dedicated to specific tasks (answering the phone, processing changes, answering general questions) and do not manage caseloads. This allows other caseworkers more time to process cases and handle detailed client phone calls. Six months of data will be evaluated this winter to determine the success of the workflow plan. The office plans to set benchmarks based on these data once they know their averages for certain measures (such as average processing time for scanning and average time to process changes). Measurement Goals: Wisconsin’s performance measures touch on all four FNS goals. They also track performance data in order to track licensing and partnership costs, monitor workers, see the impact of an initiative, and for staffing purposes. All training staff and managers at the Milwaukee call center are state employees, while the eligibility workers are still county employees. Call Center: Wisconsin has established locally run call centers in each county office. The state and county offices collect numerous measures and sets of aggregate data on their call centers. Partnering: Wisconsin offices work with several partners at the state and county levels. Wisconsin primarily collects aggregate data on their partnering arrangements. The terms of the state takeover in Milwaukee established a partnering contract that designated one partner as a community access point . Measures Collected by Partners: Wisconsin partners collect many aggregate data items, including information on application assistance, volume of screenings and applications, outreach, hold times, and use of scanning capabilities for verification through ACCESS. Wisconsin (continued) A.237 Online System: Wisconsin has a statewide online application system, ACCESS, which was developed with a contractor. The state office tracks percent of users selecting Spanish language, percent of screened individuals potentially eligible, percent of applicants who received help to apply online, percent of applications received, percent of multiple applications, and percent of applicants with hardship reason for requesting phone interviews. Staff noted that some outreach projects may offer informal incentives for use of the online application, but those incentives are unknown to SNAP staff. Document Imaging: All Wisconsin counties have document imaging capabilities, which fall under three categories: scan first, process first, or hybrid. Scanned documents are stored in the statewide electronic case file system. While only the number of documents scanned is tracked at the state level, multiple county offices track information beyond this. They collect average processing time, numbers of alerts and documents processed, number of documents received, number of documents scanned, number of tasks complete, and percent of documents scanned. Local offices track the date that documents were received, in order to manage workload. In these offices, documents are scanned as they come in and processing time is determined by looking at the date noted on the documents. One office reported a state-mandated 10-day processing time frame and another reported a 30-day scanning timeframe for process first documents. Kiosks: Wisconsin county offices participating in the study, with one exception, have established kiosks for application access and submission. Some kiosks also provide telephones and\/or application assistance at the kiosks. Some local offices we surveyed collect aggregate data, including: number of screenings completed at a kiosk, number of uses to access online account, and number of uses to submit changes. Waiver of Face-to-Face Interview: All Wisconsin counties are included under the waiver. Both the state and local offices collect aggregate data and performance measures on this initiative. Shortened Interviews: Some local offices have a shortened interview available. One office reviews the percent of total interviews that are shortened, percent of clients electing shortened interviews, and number of clients with shortened interviews. Online Expedited Applications: Some counties we interviewed track information about online expedited applications, such as: percent of applications approved (online expedited and online all), number of online expedited applications approved, and number of online expedited applications received. Application Tracking: Wisconsin local offices we interviewed collect information on application accuracy, approvals and denials, application processing and case characteristics, application receipt, and application processing time. Whether the application source is recorded varies by office; the state has detailed records of application origin, while some counties keep limited or no record of this. Changes Over Time: Some local offices participating in the study have adopted new call center systems and have begun collecting new data as part of the software they are using. In one office, the wait time was previously reviewed weekly. This stopped when the division manager position became vacant. Since the office has hired a new manager, they are anticipating they will monitor this monthly. For nine months in 2009, staff at one local call center would fill out reports on the types of calls they received (people calling with questions or with changes), how long the calls took, and how problems were resolved. Tracking this information became difficult for staff and the call center supervisor was not receiving accurate information. The office abandoned this completely and now uses reports pulled from the call center software. Desired or Planned Future Measures: Wisconsin state staff reported they are interested in seeing how QC data affects reporting. Local offices would like to see: customer satisfaction measures; data on a regional change center, broken down by county; records of documents by origin; measures on Wisconsin (continued) A.238 abandonment rate; current reports on application processing time; and measures on accuracy rates for the waiver of face-to-face interview. Various offices mentioned specific measures, such as: dropped call rate, the point (number of minutes) at which calls are dropped, number of Spanish-language calls, percent of applications approved and denied, number of applications received per month, number of changes per case, and average call duration. Multiple offices noted that developing some of these measures could be possible with more staff time or a greater number of staff. Wisconsin would like to see all states report on participation rate by federal poverty level. Some offices mentioned that any measures would be useful to help streamline reporting, gain efficiencies, and help state to state communication. One office thinks it would be useful to have the ability to cross-match information with other states. This will help them address instances where client does not provide the correct state of residence or work. A.239 Profile: Wyoming State Administered or County Administered: State Number of Local\/County Agencies Interviewed: 2 Number of Partners Interviewed: 0 Initiatives Active in State: Partnering, Waiver of Face\u2010to\u2010Face Interview, Application Tracking Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives PARTNERING (Other) None WAIVER OF FACE-TO-FACE INTERVIEW (Statewide) None APPLICATION TRACKING (Statewide) Percent of Applications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow the federal standard. If it drops below the federal standard then we explore and monitor further and implement corrective action if needed. No Percent of Recertifications Approved After Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal guidelines No Percent of Total Applications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal guidelines No Percent of Total Recertifications Approved Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow the federal benchmark No Number of Applications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow the federal benchmark No Number of Recertifications Approved: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow the federal benchmark No Percent of Applications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Wyoming (continued) A.240 Measure or Aggregate Data Collected Measure Implemented Statewide or Locally Modernization Goal(s) Performance Standards and Benchmarks Performance Incentives Percent of Recertifications: Paper Submission to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service No No Total Number of Applications Completed Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow the federal benchmark No Percent of Complete Applications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal standards for timeliness No Percent of Complete Recertifications Denied Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal standards for timeliness No Number of Applications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal standards for timeliness No Number of Recertifications Denied: Paper Submissions to Local Office Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal standards for timeliness No Average Processing Time of Application Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Follow federal regulations around timeliness No Average Processing Time of Recertification Decision Statewide Program Access, Accuracy & Integrity, Efficiency, Customer Service Federal standards for timeliness No Notes: State collects mandatory accuracy data through QC reviews. Table includes all measures indicated as calculated by state and local offices. If the local office indicated the same measure as a state, the local response was deleted and performance data are listed as Statewide. If a local office reported that they use a measure they receive from a statewide system, the measure is reported as statewide. Description: General: Wyoming has a waiver of the face-to-face interview. Applications are available for download on the state website. Local offices may partner informally with community based organizations. Measurement Goals: Wyoming tracks applications ensure program access, accuracy & integrity, efficiency, and customer service. Call Center: Wyoming does not have a call center. Online System: Wyoming does not have an online system. Document Imaging: Wyoming does not have document imaging. Kiosks: Wyoming does not have kiosks. Wyoming (continued) A.241 Waiver of Face-to-Face Interview: Wyoming does not track any performance data related to the waiver of the face-to-face interview. Recently, the computer system has been modified to record an indicator for the type of interview. Shortened Interviews: The state respondent indicated they do not have a shortened interview process. Online Expedited Applications: Wyoming does not accept expedited applications online. Application Tracking: Wyoming tracks a range of measures and aggregate data related to applications and recertifications, including the percentage submitted, completed, approved, and denied, and the average processing time. Application tracking has been a part of the eligibility system since its inception in 1983. Wyoming also tracks the accuracy measures required by FNS. When a client misses an interview, the office sends a \”notice of missed interview\” letter, advising the client to reschedule. Any time a notice is generated the notice history keeps a record of what notice is sent and the date. Some notices are generated automatically by data entered elsewhere into the system; most are generated by the caseworker. Changes Over Time: Wyoming has been collecting the application measures since 1983. The eligibility system is old and it difficult to make changes or find knowledgeable programming staff. Desired or Planned Future Measures: Recently, the computer system has been modified to record include an indicator for the type of interview. Data by interview type has not yet been reported, but may be in the future. Wyoming is planning new caseload reporting. The report will include timeliness information, such as the date an application has been started or processed. Partnering: At least one local office partners informally with community organizations. This office presents information on their programs to leadership groups, advocacy organizations, and senior centers. Partners refer clients to the local office for services. At the state level, Wyoming partners with JP Morgan to maintain EBT cards. Measures Collected by Partners: We did not contact Wyoming’s partners as part of this study. Page 2 performance standards for 39, and of those, few States assigned benchmarks to gauge and incentives to encourage their success. The performance measures used by the States were also categorized according to FNS’ four modernization goals of Program Access, Accuracy and Integrity, Efficiency, and Customer Service. In general: \uf0b7 For Program Access, States seek to monitor overall access (rather than just for the initiative) and improve program access through efficiencies and correct use of procedures. \uf0b7 For Accuracy and Integrity, States determine staff training needs and ensure that staff uses correct procedures, in addition to tracking overall accuracy. \uf0b7 For Efficiency, States track the initiative usage, seek to improve the customer experience, determine staffing needs and ensure that staff follows procedures. \uf0b7 For Customer Service, States track initiative-specific efficiency and customer experiences, determine staffing needs and ensure that staff follows procedures. This research suggests that performance measurement is a useful and important tool to integrate into new State modernization initiatives, and specifically that: \uf0b7 Performance measurement is most effective when built into the initiative during the design phase. \uf0b7 Establishment of an expected level of performance (standard) for each measure is important to gauge success. \uf0b7 Strong performance measures and standards align with goals for improving overall program outcomes. Summary States and local SNAP offices are collecting a large number of measures. Standards for these measures are less common, and benchmarks and incentives are almost nonexistent. Most measures are used for technology-related initiatives. Measurement in the early stages of implementation can indicate whether an initiative is performing its function as designed. As initiatives mature, measures can be used to study trends and identify potential problems through periodic reviews of reports. For More Information U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report, by Laura Castner, Amy Wodarek O’Reilly, Kevin Conway, Maura Bardos, Emily Sama-Miller, Mathematica Policy Research, Inc. FNS Project Officer: Rosemarie Downer, Alexandria, VA: 2012 (available online at www.fns.usda.gov\/ora). U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings, by Kathleen Keefe, Emily Sama- Miller, Laura Castner, Maura Bardos, Elizabeth Clary, Sarah Wissel, and Larry Vittoriano, Mathematica Policy Research, Inc. FNS Project Officer: Rosemarie Downer, Alexandria, VA: 2012 (available online at www.fns.usda.gov\/ora). The U.S. Department of Agriculture (USDA) prohibits discrimination in all of its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, political beliefs, genetic information, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write: USDA, Director, Office of Adjudication, 1400 Independence Avenue, SW, Washington, DC 20250-9410; or call (866) 632-9992 (Toll-free Customer Service), (800) 877- 8339 (Local or Federal relay), or (866) 377-8642 (Relay voice users) or (800) 845-6136 (Spanish Federal- relay). USDA is an equal opportunity provider and employer. Nutrition Assistance Program Report Series Office of Research and Analysis Family Nutrition Programs Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report Final Report United States Food and Department of Nutrition Agriculture Service December 2012 Non-Discrimination Policy The U.S. Department of Agriculture (USDA) prohibits discrimination in all of its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, political beliefs, genetic information, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write: USDA, Director, Office of Adjudication, 1400 Independence Ave., SW, Washington, DC 20250-9410 or call (866) 632-9992 (Toll-free Customer Service), (800) 877-8339 (Local or Federal relay), (866) 377-8642 (Relay voice users). USDA is an equal opportunity provider and employer. Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report Final Report Authors: Laura Castner Amy Wodarek O’Reilly Kevin Conway Maura Bardos Emily Sama-Miller Submitted by: Submitted to: Mathematica Policy Research Office of Research and Analysis 1100 1st Street, NE, 12th Floor Food and Nutrition Service Washington, DC 20002-4221 3101 Park Center Drive Telephone: (202) 484-9220 Alexandria, VA 22302-1500 Facsimile: (202) 863-1763 Project Director: Project Officer: Laura Castner Rosemarie Downer This study was conducted under Contract number AG-3198-D-08-0105 with the Food and Nutrition Service. This report is available on the Food and Nutrition Service website: http:\/\/www.fns.usda.gov Suggested Citation: U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report, by Laura Castner, Amy Wodarek O’Reilly, Kevin Conway, Maura Bardos and Emily Sama-Miller, Project Officer: Rosemarie Downer, Alexandria, VA: 2012. United States Food and Department of Nutrition Agriculture Service Family Programs Report December 2012 iii ACKNOWLEDGMENT This report was prepared by Laura Castner, Amy Wodarek O’Reilly, Kevin Conway, Maura Bardos, and Emily Sama-Miller of Mathematica Policy Research. Several additional staff members contributed substantially to the report as interviewers: Lauren Akers, Elizabeth Clary, Kathleen Keefe, Elizabeth Laird, Alexander Millar, Antoniya Owens, Sarah Wissel, and Larry Vittoriano. The manuscript was prepared by Jackie McGee. The authors would like to thank Rosemarie Downer, Anita Singh, John Knaus, and regional staff from the U.S. Department of Agriculture’s Food and Nutrition Service (FNS). We also greatly appreciate the invaluable efforts of the state and local SNAP staff and partnering agencies in responding to our survey and participating in telephone and in-person interviews. v CONTENTS EXECUTIVE SUMMARY …………………………………………………………………………………… xiii I INTRODUCTION ………………………………………………………………………………… 1 A. What Is Modernization?…………………………………………………………………. 3 B. Why Modernize? ………………………………………………………………………….. 3 C. What Modernization Initiatives Have States Put in Place? …………………….. 4 D. Why Is Measurement Important? …………………………………………………….. 5 E. How Are Measures Currently Used for Federal Oversight? …………………… 5 F. How Have States Used Performance Measures? …………………………………. 6 1. Early Stages of Implementation ………………………………………………… 7 2. Maintenance Stage of Implementation ……………………………………….. 7 3. Real Time \/ Daily Measures ……………………………………………………… 8 4. Focus on Quality and Timeliness …………………………………………….. 10 G. How Are Measures Assessed? ………………………………………………………. 11 H. Study Objectives and Research Questions ………………………………………. 12 II METHODS ………………………………………………………………………………………. 15 A. Phase 1: Preliminary Assessment and Instrument Development …………. 15 1. Introduction ………………………………………………………………………… 15 2. Who We Interviewed ……………………………………………………………… 15 3. What We Learned ………………………………………………………………….. 16 4. A Limited Set of Initiatives to Examine ……………………………………… 17 5. Data Collection Instruments …………………………………………………… 18 B. Phase 2: Respondent Selection and Data Collection …………………………. 19 1. Selecting Respondents ………………………………………………………….. 19 2. Responses Received ……………………………………………………………… 21 3. Level of Response ………………………………………………………………… 21 III SUMMARY OF PERFORMANCE MEASURES ACROSS INITIATIVES …………………. 23 A. Purpose of Measures by Modernization Goal …………………………………… 23 Contents Mathematica Policy Research vi III (continued) B. Key Performance Measures and Gaps, by Initiative …………………………… 25 1. Call Center ………………………………………………………………………….. 25 2. Online System ……………………………………………………………………… 27 3. Document Imaging ……………………………………………………………….. 28 4. Kiosks ………………………………………………………………………………… 29 5. Partnering (for Application Assistance) …………………………………….. 29 6. Waiver of Face-to-Face Interview ……………………………………………… 30 7. Shortened Interviews …………………………………………………………….. 30 8. Expedited Applications\u2014Submitted Online ……………………………….. 31 C. General Gaps in Performance Measurement ……………………………………. 31 D. Use of Standards, Benchmarks, and Incentives ………………………………… 34 E. Relationship of Measures to SNAP Lifecycle ……………………………………. 36 IV LIMITATIONS TO USE OF MEASURES AND STANDARDS FOR CROSS- STATE COMPARISONS ………………………………………………………………………. 39 A. Contextual Limitations ……………………………………………………………….. 39 1. Initiative Scope and Features ………………………………………………….. 39 2. System Limitations ……………………………………………………………….. 40 3. Terminology Differences ……………………………………………………….. 41 4. Varying Measurement Motivations …………………………………………… 41 B. Data Limitations ………………………………………………………………………… 41 1. Accuracy …………………………………………………………………………….. 42 2. Validity ……………………………………………………………………………….. 42 3. Reliability ……………………………………………………………………………. 42 V OPPORTUNITIES AND CHALLENGES FOR UNIFORMLY MEASURING INITIATIVES …………………………………………………………………………………….. 43 A. Criteria for Inclusion in the Proposed Set of Measures ……………………… 45 1. Addressing Goals for Modernization ………………………………………… 45 2. Feasibility as a Reporting Requirement …………………………………….. 46 B. Proposed Set of Measures ……………………………………………………………. 46 1. Application Tracking …………………………………………………………….. 46 2. Call Centers ………………………………………………………………………… 47 3. Online Systems ……………………………………………………………………. 49 4. Document Imaging ……………………………………………………………….. 50 5. Partnering (Application Assistance) …………………………………………. 52 6. Waiver of Face-to-Face Interview ……………………………………………… 53 Contents Mathematica Policy Research vii VI CONCLUSION ………………………………………………………………………………….. 55 A. Summary of Study Findings …………………………………………………………. 55 B. Setting Measurement Requirements: Recommendations and Limitations ……………………………………………………………………………….. 56 C. Next Steps ………………………………………………………………………………… 56 REFERENCES ………………………………………………………………………………………………… 57 GLOSSARY …………………………………………………………………………………………………… 59 APPENDIX A: PERFORMANCE MEASURES AND AGGREGATE DATA ix TABLES II.1 Modes of Data Collection for Each Respondent Type ……………………………… 20 III.1 Types of Measures States Are Collecting to Assess Progress Toward Modernization Goals ………………………………………………………………………… 24 III.2 Number of Measures States Are Collecting to Assess Progress Toward Modernization Goals …………………………………………………………….. 26 III.3 Top Performance Measures: Call Center ………………………………………………. 27 III.4 Top Performance Measures: Online System ………………………………………….. 28 III.5 Top Performance Measures: Document Imaging ……………………………………. 29 III.6 Top Performance Measures: Kiosks …………………………………………………….. 29 III.7 Top Performance Measures: Partnering ……………………………………………….. 30 III.8 Top Performance Measures: Waiver of Face-to-Face Interview ………………….. 30 III.9 Top Performance Measures: Shortened Interviews …………………………………. 31 III.10 Top Performance Measures: Expedited Applications\u2014Submitted Online …………………………………………………………………………………………… 31 III.11 Number of States Able to Track Application Status, by Application Source …………………………………………………………………………………………… 34 III.12 Use of Standards, Benchmarks, and Incentives ……………………………………… 35 III.13 Measures and Reported Purpose by Stages of the Lifecycle …………………….. 37 V.1 Recommended Application Tracking Measures …………………………………….. 47 V.2 Recommended Call Center Measures ………………………………………………….. 48 V.3 Recommended Online System Measures ……………………………………………… 50 V.4 Recommended Document Imaging Measures ……………………………………….. 51 V.5 Recommended Partnering Measures …………………………………………………… 52 V.6 Recommended Measures for Waiver of the Face-to-Face Interview ……………. 53 Tables Mathematica Policy Research x A.1 Measures and Aggregate Data for Call Centers …………………………………….A.3 A.2 Measures and Aggregate Data for Online Systems ………………………………..A.5 A.3 Measures and Aggregate Data for Document Imaging ……………………………A.7 A.4 Measures and Aggregate Data for Kiosks …………………………………………….A.8 A.5 Measures and Aggregate Data for Partnering ……………………………………….A.9 A.6 Measures and Aggregate Data for Waiver of Face-to-Face Interview ………..A.10 A.7 Measures and Aggregate Data for Shortened Interview ………………………..A.11 A.8 Measures and Aggregate Data for Complete Expedited Interviews Online …………………………………………………………………………………………A.12 A.9 Measures and Aggregate Data for Application Tracking ……………………….A.13 xi FIGURES I.1 Number of Real-Time and Daily Call Center Measures Calculated by States ……………………………………………………………………………………………… 9 I.2 Number of Real-Time and Daily Application Tracking Measures Calculated by States ………………………………………………………………………… 10 II.1 Number and Combination of Respondents, by State ………………………………. 21 xiii EXECUTIVE SUMMARY Over the last decade, several factors have come together and substantially affected the administration of the Supplemental Nutrition Assistance Program (SNAP). For example, the number of participants rose from 17 million people in fiscal year 2000 to 40 million in fiscal year 2010. At the same time, state budget crises led to staff cuts and federal agencies have emphasized increasing access to SNAP and participation among eligible individuals, while also increasing accuracy, and have provided incentives for states who achieve this. The U.S. Department of Agriculture Food and Nutrition Service (FNS), with responsibility for overall administration of SNAP, has supported the states in these efforts by providing them with several policy options to better tailor the program to the states’ specific needs. At the same time, substantial growth has occurred in the acceptance and use of technology for accessing a wide range of services. States have responded to these factors by seeking out ways to improve the efficiency of their service delivery with fewer staff and without affecting accuracy\u2014collectively referred to as modernization. Modernization initiatives can include the following types of activities: policy simplification, restructuring organizational and administrative functions, partnering with other organizations, and the use of technology. Major changes to any program do not always go smoothly, however. Without methodical introduction of the changes and careful monitoring of how well the initiatives are working to achieve the states’ goals, service delivery can be affected negatively. This report is an exploratory study intended to add to the growing body of knowledge about how states are modernizing their programs by focusing specifically on how they monitor and measure the success of discrete aspects of their initiatives. For example, when SNAP offices institute call centers to handle inquiries from participants, eliminating the need for participants to talk to a specific person who may not be available when they call, how does the state know if participants’ calls are getting through to the call center? Does the state know how many participants hang up because they were on hold for too long? Does it know if a participant has to call back repeatedly because the person who answered the phone could not answer a question? In this report, we present our findings on how states are measuring the performance of a specific set of modernization initiatives, which we selected in consultation with FNS. We discuss the range of measures, identify those most commonly used across sites, compare and contrast how the measures are defined across sites, and discuss standards and incentives associated with the measures. We also suggest a standard set of measures for each initiative that FNS and states could consider using to systematically track the performance of each initiative. Methods To conduct the study, we used a two-phase approach. In the first phase, we interviewed a broad group of stakeholders (including SNAP staff at the national, regional, and state levels, and advocates) to obtain their perspectives on state performance measurement activities, identified the key modernization initiatives to include in the study, and developed the data collection instruments. During the second phase, we collected data from 44 states and the District of Columbia, more than 100 local agencies within those states, and more than 50 community and business partners who work with the states and local agencies. Data collection with the state and local agencies included an Executive Summary Mathematica Policy Research xiv electronic survey through which we gathered information about their modernization initiatives and requested the names and definitions of each performance measure they collect for each initiative. We followed up on the information they provided through in-depth telephone interviews. We also conducted telephone interviews with staff from the community and business partners about the performance measures states ask them to collect and those they collect for their own purposes. Background The primary reason states have given for choosing to modernize the delivery of SNAP was increased staff caseloads (Rowe et al. 2010). A survey, conducted in 2008, also identified the economic downturn, state legislation, and staff turnover at the local level as influencing their modernization decisions. Modernizing because of increased caseloads can be categorized as striving to achieve efficiency\u2014one of four goals FNS typically uses to categorize modernization efforts. The others are program access, accuracy and integrity, and customer service, all of which are described here: Efficiency. Efficiency relates to delivering the program at the lowest cost possible without sacrificing the other goals. Program Access. The goal is to ensure that benefits can be accessed by individuals eligible to receive them and that equal program access is available for protected classes of clients. It is affected by the location and operating hours of local SNAP offices, the modes through which applications can be submitted, the level of effort needed to complete the application process, and other factors. Accuracy and Integrity. Maintaining the integrity of SNAP requires that staff accurately determine both eligibility and the benefit amount for households as well as minimize fraud. Ensuring accuracy can include policies about reporting and verifying information. Any change to the responsibilities of and expectations for program staff could inadvertently lead to changes in program integrity. Customer Service. Improving customer service involves ensuring the quality of staff interactions, minimizing the length of time needed to complete the application process, and improving the ease and clarity of that process. However, steps taken to ensure payment accuracy and efficiency can reduce customer satisfaction. New technologies and other major changes to the traditional client services approach also can affect customer satisfaction. Many types of modernization activities fit with these goals. In this study, however, we focus on eight key initiatives: call centers, online systems, document imaging, kiosks, partnering, waiver of face-to-face interviews, shortened interviews, and online expedited applications. We also discuss measurement associated with tracking application submissions, approvals\/denials, and accuracy. Key Study Findings Across the initiatives, we identified the measures the states have in place; examined how they align with FNS’s goals for modernization; and verified the states’ purposes for collecting the measures, how commonly they were used across states, and how often they set an expected level of performance. The key findings are as follows: Executive Summary Mathematica Policy Research xv States and local offices are collecting a large number of measures. Across the eight modernization initiatives we examined, states and local offices reported using 89 different performance measures to assess their activities. We asked the SNAP offices to identify the modernization goals that the measures address. We then categorized the measures within each goal according to their use. For example, among measures that states and local offices identified as assessing progress toward program access, we found that they fit into several categories based on their use: monitoring SNAP as a whole; monitoring the initiative; improving access to SNAP by maximizing staff time and program costs or by having effective procedures; ensuring correct use of procedures; and ensuring that customers are able to make effective use of the initiative. In Table 1, we show the number of different measures associated with each goal, further categorized by each measure’s use (note that some measures may be included under more than one goal). The number of measures for each theme yields insights into which areas state and local offices focus their measurement activities: For Program Access, states seek to monitor overall access (rather than just at the initiative level) and improve program access through efficiencies and correct use of procedures. With Accuracy and Integrity as a goal, states determine staff training needs and ensure that staff use correct procedures, in addition to tracking overall accuracy. For Efficiency, states track the initiative usage, seek to improve the customer experience, reduce staff time, and ensure that staff are following correct procedures. For Customer Service, states track initiative-specific efficiency and customer experiences, determine staffing needs, and ensure that staff are following correct procedures. Standards are less common and benchmarks and incentives are rare. Performance measurement typically includes the use of standards, benchmarks, and incentives to assess performance of the selected measures. Standards and benchmarks establish the criteria against which performance is measured. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes\u2014while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. An incentive is a motivator for performance and either can be rewards and public recognition for the highest performers and\/or some combination of sanctions and technical assistance for the lowest performers. If no standards exist, there is no way of knowing if an activity is meeting its goals. Executive Summary Mathematica Policy Research xvi Table 1. Types of Measures States Are Collecting to Assess Progress Toward Modernization Goals FNS’s Modernization Goal Purpose of Measure Number of Measuresa Number of States Collecting Measures Program Access Monitor combined result of initiatives to increase program access 43 27 Improve program access through maximizing staff time and agency cost efficiencies 37 20 Ensure correct procedures are being used by staff 34 17 Monitor use of initiative 30 12 Improve program access through establishing effective procedures 21 14 Determine if customers are able to use the initiative 5 3 Accuracy and Integrity Track accuracy related to the program as a whole as opposed to a specific initiative 84 32 Assess general accuracy used in eligibility determinations as part of FNS quality reviews 24 20 Determine staff training needs and ensure correct procedures are used by staff 17 16 Reduce overall errors or improve overall accuracy 12 10 Identify overall error rate or trends, not related to a specific initiative 9 11 Identify error rate or trends for a specific initiative 5 8 Reduce errors or improve accuracy for a specific initiative 3 2 Efficiency Track usage or system load 73 26 Reduce staff time and agency costs 47 21 Improve customer experience 46 20 Determine staffing needs and ensure that correct procedures are used by staff 30 19 Assess initiative-specific accuracy used in eligibility determinations as part of FNS quality reviews 20 12 Customer Service Assess general customer service 61 26 Increase efficiency\/improve customer experience for a specific initiative 52 24 Identify barriers to program access for specific initiative 40 12 Determine staffing needs and ensure that correct procedures are used by staff 32 17 Assess general accuracy used in eligibility determinations as part of FNS quality reviews 27 13 Eliminate or reduce barriers to program access for customers 8 6 Note: Totals are based on responses from the 45 states that participated in the study. Each respondent indicated its own purpose for collecting the measure, and those can differ across the state and local offices within a state. The measures in this table include those reported by both offices, so a measure may be captured more than once. a Numbers in this column include performance measures reported for each initiative and application tracking. Executive Summary Mathematica Policy Research xvii Of the 89 measures being collected, states reported developing performance standards for 39 measures and, of those, a few are assigned benchmarks and incentives to gauge their success. In Table 2, we present, by initiative, the number of measures with standards or benchmarks and summarize how states use them. Table 2. Use of Standards, Benchmarks, and Incentives Initiative (Number of Measures Using Standards or Benchmarks) Use of Standards, Benchmarks, and Incentives Call Center (20) Standards: Evaluate performance of individual call center agent or a group of agents Incoming Calls Benchmarks: Assess volume of calls through specifying waiting and call duration times Incentives: Determine high or low staff performance review; penalize vendor poor performance (when contracting with a vendor) Standards: Track incoming call handling Phone System Benchmarks: Resolve maximum number of calls within phone system or via agent Incentives: Not reporteda Standards: Track processing of all changes and their processing time Change Reporting Benchmarks: Not provided Incentive: Determine high staff performance review rating Online System (3) Standards: Track portion of applications received online Online Application Benchmarks: Increase usage of application option Incentives: Not used Not used Online Screening and Online Account Access Document Imaging (6) Standards: Assess quantity of documents scanned, by document type, within specified timeframe Benchmarks: Scan all documents within a certain timeframe Incentives: Satisfaction of achieving mandate; penalize vendor poor performance (when contracting with a vendor) Kiosks (0) Not used Partnering\u2014Application Assistance (2) Standards: Monitor partners providing application assistance Benchmarks: Ensure that all partners provide assistance Incentives: Pay partners for approved applications for which they provided assistance Waiver of Face-to-Face Interviews (6) Standards: Monitor the proportion of interviews conducted face-to-face and telephonically to track utilization Benchmarks: Ensure that the percentage of telephone interviews does not exceed waiver requirement Incentives: Not reporteda Shortened Interviews (0) Not used Expedited Applications (2) Standards: Process expedited applications Benchmarks: Process expedited applications within 7-day timeframe required by FNS Incentives: Not reporteda Note: Totals are based on responses from the 45 states that participated in the study. a Not reported indicates that the respondent identified the use of an incentive but did not describe the specific incentive utilized. Executive Summary Mathematica Policy Research xviii Measures most commonly are used for technology-related initiatives. The most common measures are those for call centers and online systems (see Table 3). The technology built into these systems makes it easier to collect and report performance measures. Thus, states with more technology-driven initiatives have many more performance measures than states without those initiatives. Table 3. Number and Use of Measures States Are Collecting, by Initiative Initiative Number of States with Initiative Number of Different Measures for Initiative Use of Measure Call Center 28 34 Identify staffing needs Identify need to train staff Assess efficiencies and inefficiencies of operations Assess customer service Online System 33 27 Demonstrate program access and increased participation Track utilization of online application feature, including making comparisons with paper applications Document Imaging 24 8 Track system operations Manage staff workload Kiosks 14 1 None reported Partnering 34 3 Track approvals Track partners providing assistance Track partner assistance provided\u2014from monitoring to evaluating effectiveness and reimbursing them for assistance provided Enhance program access Waiver of Face-to- Face Interview 40 12 Show effectiveness of interview option Determine accuracy, including making comparison with face-to-face interviews Comply with federal waiver requirement for performance measure calculations Shortened Interviews 12 2 None reported Online Expedited Applications 20 2 Increase program access Track approvals Note: Totals are based on responses from the 45 states that participated in the study. In most states, staff are driven by federal accuracy and timeliness requirements. Staff at all levels of SNAP agencies indicated that states are not meeting their mission if they do not provide benefits to those eligible, get the beneficiaries the right benefit amount, or achieve these goals in a timely fashion. At times, states may sacrifice the result for certain operational measures of individual initiatives so they can ensure that other, more critical goals, such as FNS timeliness standards, are achieved. If FNS were to require additional measures, states likely would divert resources to meet those requirements. When incentives are available, such as for high accuracy and timeliness rates, states are motivated to outperform other states so as to receive the incentive. Executive Summary Mathematica Policy Research xix Use of measures changes over time: first to assess whether the initiative is working as designed; then to monitor trends; and finally, to allocate resources in real time. In the early stages of implementation, reports can indicate that each piece of the initiative is performing its particular function as planned. The measures provide proof of success to stakeholders and can help secure funding for continued operations. As initiatives mature, performance measurement allows for monitoring. Once staff are confident that the initiative is working as designed, they can analyze trends and identify potential problems through periodic reviews of reports. However, too much monitoring can create unnecessary work for staff if they need to perform additional tasks purely for tracking purposes. As measurement matures, real-time and daily reports help to allocate limited staff resources. Frequent and timely measurement of operations allows managers to assign more workers to the area most in need at a particular moment, such as assigning more agents to answer phones during periods of high call volume, or assigning more eligibility workers to process applications if too many are in danger of failing to meet the timeliness standard. Limitations While many states are collecting performance measures, several factors related to modernization and performance measures affect cross-state comparisons. Two particular aspects are contextual limitations (related to the context and environment in which the initiatives operate and their functions) and data limitations (related to the ability to calculate accurate, valid, and reliable measures). Contextual Limitations. State and local offices operate and implement modernization initiatives in different contexts, which influence their choice of performance measures and standards and their observable outcomes. Common contextual limitations include the following: Initiative Scope and Features. The size and breadth of an initiative, especially whether it serves the entire state or just a region, and what services are provided through that initiative. System Limitations. The inability of eligibility and reporting systems to capture and report measures of interest to each state. Terminology Differences. The variations in how measures are worded and defined across states show that states are measuring different performance aspects. Varying Measurement Motivations. Motivations for using measures and standards vary across states, with some choosing measures to manage staff workloads and others setting standards to comply with legislative or other mandates. Data Limitations. While contextual limitations impact cross-state analysis of measures, the data used to calculate the measures also set limits to performance evaluations and can jeopardize interpretations of individual measures. Performance measures are subject to three main types of data limitations: accuracy, validity, and reliability. Accuracy. When data are used to calculate performance measures, how they are entered impacts the quality of the measure. Data entered automatically are likely subject to fewer errors and less subjectivity. In many cases, however, staff must manually track data for measures, such as the time spent on a call or the number of documents scanned in a day. Manual entries and calculations are more subject to error. Executive Summary Mathematica Policy Research xx Validity. This refers to whether or not states actually are measuring what they intend to measure, or if their measure includes data they do not intend to capture. Respondents sometimes indicated validity concerns regarding the measures they reported, but did not elaborate. Reliability. Data reliability addresses the consistency of how measures are calculated over time and across localities or states. To be reliable, a measure must not have changed recently\u2014either in how it is defined or calculated. In addition, the definition must reflect the same concept regardless of where it is being collected. For example, hold time in one call center must reflect the same period of time in another, which we did not always find to be the case. Setting Measurement Requirements: Recommendations and Limitations Measurement improves the chances that an initiative will succeed, both at implementation and during ongoing operations. It also improves the chances even more when measures are built into initiatives during the design stage. Developing measures helps states clearly articulate the purpose of the initiative and set a preliminary expected level of performance. Developing measures and stating goals also can help ensure that the initiative is helping them achieve their mission of providing accurate benefits in a timely fashion. With many states developing and launching broadly similar initiatives, sharing lessons learned and discussing expectations for performance can help later-adopting states avoid the pitfalls faced by the early-adopting states. However, each state operates SNAP within its own set of circumstances. States differ in the computer capabilities supporting their eligibility systems, assistance programs included in those systems, combinations of modernization initiatives, functionalities for the modernization initiatives, and abilities to calculate measures. Given the unique environment in which each state operates, FNS and state staff must be cautious in setting expectations for a modernization initiative based on the performance achieved by other states. Based on our research, we make the following recommendations for FNS and states when launching new initiatives: 1. Performance of initiatives should be measured\u2014states acknowledge that where measurement occurs, performance improves. 2. Performance measurement should be built into the initiative during the design stage. 3. States should have an expected level of performance (standard) for each measure. 4. The performance measures and standards should be tied to improving overall program outcomes. However, because of the limitations noted above, and because of the exploratory nature of this study, we did not develop a detailed understanding of every measure in every state; therefore, we do not recommend a set of performance measures for each initiative for use across all states in all situations. Instead, we present (see Table 4) a limited set of measures that appears to be useful within a broad range of state operational contexts. States implementing new initiatives could review this list for suggested measures. Although we hope that most will be appropriate for the states, some measures may not fit within a particular state’s context, while others may be a close fit, but need slight modification to be appropriate. States will need to make these decisions based on their specific goals for implementation, the functionality of their initiative, the other initiatives they have in place, Executive Summary Mathematica Policy Research xxi the unique features the initiative may entail, and the integration of SNAP with other assistance programs. Table 4. Recommended Measures Measure Name Definition Rationale Comments Application Tracking Percent of Applications Submitted by Source Number of applications submitted through each mode (mail\/fax, in- person, online\/kiosk, call center, through a partner), divided by total number of applications. (Maximum of five measures, depending on activities in a state.) Helps the state to track the means by which applicants are applying. Even states that can track whether an application was submitted online often cannot track when it was delivered by mail separately from those dropped off at the office. These two may need to be combined. Percent of Applications from Each Source that Are Approved Number of applications submitted through each mode and subsequently approved, divided by number of applications submitted by mode. (Maximum of five measures, depending on activities in a state.) Helps the state to understand whether one mode of application tends to be used by more people who are not eligible or do not complete the process. Excludes from both the numerator and denominator the number of applications in process during the period data are collected. Call Center Calls Received per Active Case Number of calls, divided by number of active cases. Demonstrates volume of calls in relation to caseload size, making the measure more comparable across states and regions. Include in the numerator and denominator only the cases in the area covered by the call center. States with online account access may have much lower call volume; states with more functionality may have higher call volume. High numbers of calls from nonparticipants would not be reflected in the denominator. Average Number of Calls Handled per Agent Number of calls handled by agents, divided by number of agents. Demonstrates load on individual agent Need to set standards based on functionality of systems\u2014 those with automated systems likely will see lengthier calls and thus have a lower expectation for number of calls possible per agent. Percent of Calls Abandoned Number of calls abandoned before reaching automated system or agent. Potentially demonstrates dissatisfaction of callers with amount of time required to wait for service. If recorded information is played during hold time, it may answer the caller’s question and not truly be an abandoned call, even though it would be recorded as such. Average Time to Answer by Automated Total time callers wait to access automated system, divided by total number Potentially demonstrates dissatisfaction of callers with amount of time Will not apply to call centers with no automated response unit. Executive Summary Mathematica Policy Research Table 4 (continued) xxii Measure Name Definition Rationale Comments Response Unit of calls into system. required to wait for service. Average Waiting Time to Speak to Agent Total time callers wait before talking to an agent, divided by total number of calls into system. Potentially demonstrates dissatisfaction of callers with amount of time required to wait for service. Should not include time spent being directed by automated unit; clock should not stop if an agent answers only to place caller on hold. Online System Percent of Applications Received Online Number of applications submitted online, divided by the total number of applications received. Demonstrates use of online system in relation to other modes of application. States may differ in how they count unsigned applications that must be printed and sent to the applicant for approval because an unsigned application does not constitute a completed application. Percent of SNAP Caseload with an Online Account Number of active SNAP accounts, divided by size of SNAP caseload. Demonstrates use of system by entire caseload. Defining active as accounts associated with ongoing cases. Average Number of Logins per Account Number of logins, divided by number of active accounts. Demonstrates use of system by those who have accounts. Defining active as accounts associated with ongoing cases. Average Number of Changes Submitted per Account Number of changes submitted, divided by number of active accounts. Potentially demonstrates that system is difficult to use or not meeting clients’ needs. Defining active as accounts associated with ongoing cases. Document Imaging Percent of Documents Scanned within 24 Hours Number of documents successfully scanned within 24 hours of receipt, divided by total number of documents to be scanned received in the same 24-hour period. Demonstrates ability of system to process documents efficiently. All documents should be included\u2014even those that are damaged\u2014to track percent requiring manual scanning. Some states are not attempting to achieve scanning within 24 hours, so a longer timeframe may be preferable for them. Percent of Documents Attached to Case within One Business Day of Being Scanned Number of documents attached to case record by close of business on the business day following imaging of the document, divided by number of documents imaged the previous day. Documents need to be accessible to case workers quickly for the system to work well. They are not accessible until they are attached to the file. Not all documents may have enough information in them to attach to a case immediately. Low attachment rate could reflect errors by the person submitting the document, as well as lack of ability of staff to attach documents to cases. Does not reflect how many documents never get attached to a case. Percent of Orphaned Documents Number of documents scanned exactly four weeks prior but that are still not attached to a case, divided by daily average of scanned documents. Tracks extent to which scanned documents could not be tied to a specific case and thus are unusable for purposes of eligibility determination and\/or recertification. Difficult to set the time period over which to measure\u2014a worker may be able to attach the document days or weeks later if the sender provides information that can assist the worker in identifying the case. Executive Summary Mathematica Policy Research Table 4 (continued) xxiii Measure Name Definition Rationale Comments Partnering Number of Partners Providing Application Assistance Number of partners who have formally declared they are working with the state, even though there may be no formal agreement on how they conduct this activity or how many people they are trying to serve. Helps the state to track the organizations, eases communication of changes in procedures. Definitions of application assistance may differ across states, making this more of a gauge for internal purposes than for comparison across states. Number of Clients Assisted by Partners Report from partners of number of clients they assisted with the application. Helps the state understand the use of the partners by their residents and how much need there is for providing continued training to partner staff. Not all those receiving assistance ultimately will submit their applications. Waiver of Face-to-Face Interview Percent of Application Interviews Conducted by Telephone Number of application interviews conducted by telephone, divided by number of application interviews. Demonstrates the use of the waiver at application. Percent of Recertification Interviews Conducted by Telephone Number of recertification interviews conducted by telephone, divided by number of recertification interviews. Demonstrates the use of the waiver at recertification. Error Rate for Cases with Telephone Interviews Number of cases in error that included a telephone interview, divided by number of cases in error. Demonstrates the ability of the eligibility worker and applicant to communicate all necessary information over the phone rather than through an in-person meeting. Error rates generally are calculated through formal quality control reviews, and some states can separate the error rate based on the interview type. For this measure to be accurate and unbiased, it likely would require a change in the QC review process\u2014the sampling would need to account for both types of interviews. 1 I. INTRODUCTION Over the last decade, states have initiated a wide range of enhancements to their administration and operation of the Supplemental Nutrition Assistance Program (SNAP). These enhancements, generally captured through the term modernization, can include increasing the use of technology and the Internet, specializing staff roles, expanding office hours, aligning eligibility policies across multiple assistance programs, partnering with community-based organizations, and other initiatives. Recently, modernization activities have received substantial attention from stakeholders: state legislators and administrators are interested in ways to reduce costs, advocacy agencies watch for potential negative impacts on service delivery, community partners seek to link clients with all services for which they are eligible, and the federal government must ensure the accuracy and timeliness of benefit delivery. The underlying question for the stakeholders, then, is How well are the initiatives working? In this report, we examine how states are determining the performance of their initiatives. We identify the measures states have in place for each initiative and how these measures compare across states. However, it is helpful to first review certain factors that have led to and influenced modernization initiatives in the states, which include the following: Number of SNAP participants rose sharply. The number of participants in SNAP more than doubled over the last 10 years. In fiscal year 2000, more than 17 million people participated in an average month; in fiscal year 2010, more than 40 million did. State budget crises led to staff cuts and smaller operating budgets. Almost all states have experienced budget shortfalls, and because states generally cannot run a budget deficit, they must find ways to balance their budgets. At least 44 states and the District of Columbia have achieved this in part by making cuts in their workforce\u2014 eliminating or not filling jobs, imposing furloughs, or through other means (Johnson et al. 2011). In addition, states pay approximately 50 percent of the costs to administer SNAP, so they look beyond staff cuts to find ways to reduce the SNAP operating budget. States are attempting to integrate multiple assistance programs. States can find additional cost savings in integrating programs such as Temporary Assistance to Needy Families (TANF), Supplemental Security Income (SSI), and Medicaid. This sort of integration may allow them to use one computer system to determine eligibility for all programs rather than maintaining different systems for each program. Similarly, providing one phone number through which clients can access all programs and having a computer direct the calls to the right department can reduce the number of state staff needed to answer phones. Federal performance efforts led to national SNAP participation goals. In July 2002, the Office of Management and Budget required the U.S. Department of Agriculture (USDA) and other federal agencies to complete the Performance Assessment Rating Tool (PART). Using the PART, agencies had to establish specific goals and show progress over time in meeting them. One of the goals of the Food and Nutrition Service (FNS), the USDA agency responsible for SNAP, is to improve program participation rates. Introduction Mathematica Policy Research 2 FNS increased pressure on states to raise their participation rates without decreasing accuracy. Because they administer their own programs, FNS relies on states to increase their participation. In 2003, FNS established monetary rewards to encourage states to increase participation. In 2009, it split $12 million dollars among the eight states with the most improved and highest rates of participation. However, FNS also must ensure that states are not providing benefits to people who are not eligible, so it also established both sanctions for those with high rates of error and rewards for those with low rates of error, with the highs and lows being determined in relation to other states. FNS provided several policy options for states to tailor programs to their particular needs. FNS has had a long-standing policy allowing states to apply for waivers regarding certain policies. In addition, in the early 2000s, FNS began to give states increased flexibility in setting policies. For example, states may align their asset rules with other assistance programs to make applying for multiple programs easier for residents, simplify the conditions under which SNAP participants report changes in their income, and provide support for those leaving cash assistance by allowing their SNAP benefits to remain constant for a period of time. Technology is more widespread and its improvements have increased its use. The past decade has seen remarkable growth in the use of the Internet, both in the amount of general information available and the ability of individuals to access or submit information unique to them, such as through online banking or online benefit account access. States increasingly accept electronic or telephonic signatures. Several states now allow electronic or telephonic signatures when residents submit required information by phone or Internet. Increased need among residents, decreased availability of staff, smaller state budgets, and monetary incentives related to quality have led states to find ways to improve the efficiency of their service delivery without affecting accuracy. Monetary incentives to increase participation have led them to improve their customer service and access. Flexibility in setting policy, paired with technological improvements, has given states many options for exactly how they achieve the improvements. Major changes to programs do not always happen smoothly, however. Without a methodical introduction of the changes and careful monitoring of how well they are achieving the states’ goals, service delivery can be severely and negatively affected. This report is an exploratory study intended to add to the growing body of knowledge on how states are modernizing their programs by focusing specifically on how they are monitoring and measuring the success of discrete aspects of their efforts. For example, when SNAP offices initiate call centers to handle inquiries from participants, eliminating the need for callers to talk to a specific person who may not be available when they call, how does the state know if the people were able to get through to the call center? Does the state know how many participants hang up because they were on hold for too long? Does it have information on whether a participant has to call back repeatedly because the person who answered the phone was not able to answer a question? We present our findings on how states are measuring performance of a specific set of modernization initiatives, which we selected in consultation with FNS. The findings are based on data obtained through surveys, telephone interviews, and in-person interviews with state and local Introduction Mathematica Policy Research 3 SNAP administrators and organizations that work for or partner with SNAP agencies. We discuss the range of measures, identify those most commonly used across states, compare and contrast how the measures are defined across states, and discuss standards and incentives associated with the measures. We also suggest a standard set of measures for each initiative that FNS and states could consider using to systematically track the performance of each. In the remainder of this chapter, we first review how we define modernization for the purpose of this report and why states develop modernization initiatives. We then discuss how both the federal government and states use performance measurement of initiatives. Finally, we review how we will assess measures and discuss the objectives and research questions for the study. In Chapter II, we discuss the methods and sources of data. We provide a summary of the measures in Chapter III\u2014tying them to FNS’s goals for modernization and the states’ purposes for measurement, and discuss limitations in cross-state comparison in Chapter IV. In Chapter V, we present a set of measures for each initiative for FNS and the states for consideration when implementing the initiatives. Finally, in Chapter VI, we summarize our findings and the use of performance measurement in the states. Additionally, we provide a glossary of terms used throughout the study\u2014including descriptions of modernization initiatives and their functionalities. In Appendix A, we provide a list of all of the measures states are collecting, by initiative (using the word measure in its broadest sense\u2014a wide range of data collected to assess performance). A. What Is Modernization? The term modernization refers to more than just using technology to accept SNAP applications or convey information to applicants and participants. Rather, modernization refers to a broad set of changes that can be adopted to improve efficiency and access to the program and\/or enhance customer service. In some states, modernization refers to a sweeping set of changes\u2014 essentially a reconfiguration of the business model for administering SNAP. In other states, it refers to a handful of changes but not a fundamental shift in the state’s business model. Modernization changes are not always adopted statewide. Some states pilot test modernization changes in parts of a state. Additionally, in about one-fifth of the states, SNAP is administered by counties. In those states, some counties have instituted their own modernization initiatives. B. Why Modernize? The primary reason states have given as to why they chose to modernize the delivery of SNAP was increased caseloads for their staff (Rowe et al. 2010). The survey conducted by Rowe et al. in 2008, also identified that the economic downturn, state legislation, and staff turnover at the local level influenced their modernization decisions. Introduction Mathematica Policy Research 4 Modernizing SNAP because of increased caseloads can be viewed as an effort to achieve efficiency\u2014one of four primary FNS goals. For example, Florida completely redesigned its business model in 2004 to improve efficiency in response to a need to cut costs drastically in a very short period of time. The other goals are to improve program access, increase accuracy and integrity, and improve customer service. Utah, for example, rolled out an integrated software management system in 2003 that improved access to several assistance programs, including SNAP, by automatically assessing a person’s eligibility for all related programs at one time. C. What Modernization Initiatives Have States Put in Place? Along with classifying the goals for modernization into four categories, we also can classify the components of modernization into four categories: Policy Simplification. Policy simplification can improve operational efficiency by reducing the time needed for staff to collect and process information. It also can increase program access and customer service by reducing the burden of applying and participating. Examples include combining applications across programs, reducing the need for documentation to verify information, increasing the use of telephone and\/or shortened interviews at application and recertification, and simplifying income reporting policies. Restructuring of Organizational and Administrative Functions. Streamlining organizational and administrative functions can improve operational efficiency. Examples include specializing staff roles and eliminating the caseworker model, centralizing functions, closing local offices, and expanding or reducing office hours. Partnering with Other Organizations. States can reduce administrative costs and increase program access by partnering with commercial businesses and nonprofit community-based partners. Business partners often take over specific support activities, such as sorting and mailing or developing computer systems, saving the agency from having to employ staff with these specialized roles. Community-based partners typically provide access to computers and\/or application assistance. They often have a strong presence within a certain geographic area or with a specific demographic. FNS Categorization of Goals for Modernization Program Access. The goal is to ensure that benefits can be accessed by individuals who are eligible to receive them. It is affected by the location and operating hours of local SNAP offices, the modes through which applications can be submitted, the level of effort needed to complete the application process, and other factors. Accuracy and Integrity. Continued support for SNAP requires that staff accurately determine both eligibility and the benefit amount for households. Ensuring accuracy can include policies about reporting and verifying information; ensuring integrity may include minimizing fraud and providing equal program access for protected classes of clients. Any change to the responsibilities of and expectations for program staff could inadvertently lead to changes in program integrity. Efficiency. Efficiency relates to delivering the program at the lowest cost possible without sacrificing the other goals. Customer Service. Improving customer service involves ensuring the quality of staff interactions, minimizing the length of time needed to complete the application process, and improving the ease and clarity of that process. Steps taken to ensure payment accuracy and efficiency can reduce customer satisfaction. New technologies and other major changes to the traditional client services approach also can affect customer satisfaction. Introduction Mathematica Policy Research 5 Technology. Many states are including technology as part of their modernization efforts. States can use technology to improve operating efficiency, increase program access, and increase customer service for clients who prefer to use the technology. Examples include online systems, automated eligibility systems, automated response units (phone systems), telephone call centers and change centers, electronic signatures, data matching, document imaging, and electronic learning. From their 2008 survey, Rowe et al. (2010) found that almost every state either had implemented or piloted some type of initiative related to improving customer access, implemented a technological change, or initiated an information-sharing process. They found that half of the states had initiated organizational changes, online applications, electronic record-keeping, and call centers. D. Why Is Performance Measurement Important? Major changes to systems and policies, especially when they are implemented quickly due to an immediate need or affect a large group of people, often are accompanied by unexpected challenges that can lead to problems or delays in service delivery. If the problems are not caught early, states may face a number of consequences: problems causing high error rates have led to sanctions by FNS, and issues with timeliness have led to lawsuits and increased oversight and scrutiny by state legislators. Partly in reaction to the issues some states have faced in modernizing the administration of SNAP, the 2008 Farm Bill requires that the USDA identify standards for major changes in operations and collect data that can be used to identify and correct problems relating to integrity and access, particularly by certain vulnerable households. In its proposed rule to meet this requirement, FNS has identified several measures that could be collected if a state were to implement a major change. For example, for states implementing online applications, FNS’ reporting requirements may include the number of applications submitted, approved, and denied online; the processing time for approved applications; and demographic information on the households using online applications. For states requiring reporting through change centers, requirements may include the number of changes received; the average time to process changes; and\/or the number of changes processed (Federal Register, 2011). Measuring individual aspects of modernization efforts may not ensure that every state initiative will work exactly as planned as soon as it is implemented, but building in automated checks on the system will help state officials to identify issues sooner and may prevent any issues that arise from having substantial negative consequences for the already at-risk population. E. How Are Measures Currently Used for Federal Oversight? For decades, FNS has required states to collect several performance measures. States are expected to process applications within 30 days of receipt of a signed application, and applications identified for expedited processing must be completed within 7 days. The states with the best timeliness rates receive financial rewards. FNS measures the accuracy of benefit issuance and eligibility determination through the SNAP Quality Control data and provides financial rewards to states with the best or most improved accuracy rates. States with accuracy rates that consistently perform worse than other states may be subject to sanctions. FNS also measures program participation among the low-income population through the Program Access Index and financially rewards states with the highest and most improved indices. Introduction Mathematica Policy Research 6 Arizona staff reported that after their implementation of document imaging, they needed to prove they were saving staff time. To do so, they developed a staffing efficiency model to measure the work times on document imaging tasks (as well as those they replaced, such as filing). The state then provided the governor’s office with quarterly reports documenting that the imaging system not only worked effectively but also showed clear cost savings resulting from the staff time savings. FNS has contracted with Mathematica to look at outcome measures in several states. In 2006 2007, we studied Florida’s Automated Community Connection to Economic Self-Sufficiency (ACCESS Florida) and examined how caseload size, administrative costs, client access to benefits, and program accuracy changed with its introduction (Cody et al. 2008). We currently are conducting a study to look at similar measures in Florida and four additional states: Georgia, Massachusetts, Utah, and Washington. However, FNS generally has not required that states meet specific performance standards on individual initiatives, instead leaving it to the states. States conduct measurements at the initiative level to determine if each specific activity is working in the way intended. Once they are satisfied the initiative is performing at an acceptable level, they often stop measuring and focus only on the broader outcome measures. In requiring states to achieve a certain level of performance on the broader outcome measures, FNS has been acting as a monitor\u2014that is, consistently reviewing the measures to be sure states are meeting a certain level and implementing consequences when they do not meet these levels. In conducting an exploratory study such as this one and providing a wealth of information about the range of measures, FNS is acting in a facilitating role. It is providing information to the states with the goal of helping them plan better systems and avoid some of the pitfalls other states have experienced. If FNS chooses to put a set of standards in place for individual initiatives, it will be moving to the monitoring role at the individual initiative level as well. F. How Have States Used Performance Measures? States use performance measurement differently at different stages of implementation. In the early stages, states measure an initiative to determine whether it is working as designed and meeting initial expectations. Later, states review reports to monitor the performance and ensure that acceptable levels of operations are sustained over time. The intensity of the monitoring will vary over time, however. When states are confident that the initiative is working as desired, they generally shift their attention and resources to other issues. If, while monitoring the reports, they identify issues that need to be addressed, their attention will return to the initiative and they generally will review the measures more frequently until these issues are resolved. On the other hand, when individual initiatives need less monitoring, managers\u2014particularly local managers\u2014tend to want more immediate access to results of measures. They become less interested in reports about what has happened in the past and instead want to have reports that tell them the state of activities at that exact moment: instead of wanting to know, for example, the average wait time for callers over the past week or month, they want more real-time data from these measures. For example, they may want data on how many people are waiting on hold at the present moment and how long they have been waiting. If the numbers are too high, the managers can reassign staff. Once the measures return to more desirable levels, those staff can return to their previous activities. Introduction Mathematica Policy Research 7 1. Early Stages of Implementation Emerging from discussions with states, particularly during our site visits, is the fact that early on in the life of an initiative, SNAP state and local managers face pressure to justify the changes being made\u2014whether they be policy changes, such as a waiver of face-to-face interviews; technology changes, such as online applications, a call center, or document imaging; or partnerships with community organizations or businesses. Given that significant resources are needed to implement these changes and that numerous internal and external stakeholders have an interest in the outcome of the initiatives, the pressure to demonstrate success is often quite strong. Much of the pressure derives from the fact that states need to show they actually have achieved their key objective\u2014for example, reducing overall costs, reducing staff workloads, improving service delivery to clients, or some combination of these. Measurement, then, often is the tool by which states can establish proof of concept. In other words, measurement helps answer the question of whether an initiative is doing what it is intended to do. For example, states that have implemented a document imaging system want proof that the scanners can effectively image a document that is readable, that the imaged document can be indexed or coded properly, and that it will be attached to the correct case file. It is also important for the state to show that the centralization of document imaging services actually achieved cost savings by requiring fewer workers to handle the same or increasing levels of imaging. In addition to proving the concept of the initiative, measurement during this early stage of implementation helps states to demonstrate its success, making it easier for funders to continue its funding. It also may make it easier for them to introduce other initiatives in the future. Equally important is that measurement helps states ensure that they are not creating unintended consequences for clients or other processes. 2. Maintenance Stage of Implementation Once proof of concept is confirmed, the focus of states and managers shifts to monitoring the modernization initiatives. During this maintenance stage, managers routinely review static reports\u2014 weekly, monthly, or quarterly\u2014to track performance during that period, as well as compare results over time. The purpose of these reviews is to assess how well the initiative is working and ensure that the results the state has achieved initially can be maintained. Analysis of static reports also can help states establish standards for the future. In this respect, states will review past reports and ask: How did we do last month? Last quarter? Or last year? Then they will ask if they can do better. These standards, however, are usually informal and not rigorously defined or tracked; they act mainly as guides by which managers judge progress. However, managers and staff eventually face time or resource constraints, forcing them to make choices about how frequently and intensely they will continue to monitor the static reports. When most initiatives tend to operate at a satisfactory level, the act of reviewing reports becomes less revealing\u2014and compelling\u2014over time. So, while managers continue to produce the reports, their focus tends to shift to reviewing them only to identify red flags that would cause them concern about the initiative’s operations. Furthermore, the red flags that seem to concern the managers most involved with the initiatives are those that could directly affect quality; for example, the ability to We benchmark against ourselves in terms of what’s possible, where we can push the envelope. \u2014State SNAP Director Introduction Mathematica Policy Research 8 correctly determine eligibility or deliver the right benefit amount, or timeliness, such as the ability to meet the 30-day deadline for eligibility determination. 3. Real Time \/ Daily Measures As static reports become less revealing, the trend is for states to want real-time data. The desire for more frequent data may seem at odds with many states’ views that they do not have the time or resources to review static reports. However, daily and real-time measures provide state staff, particularly local office managers, with information that they can act on immediately. Having information on a daily or real-time basis allows managers to focus on the now, which enables them to track staff workloads most effectively, identify obstacles to effective flow as they occur, and quickly identify potential problems with cases that are most time-sensitive or those considered as highest risk. Most important, having access to this frequency of data enables managers and staff to take immediate action in response to conditions as they currently exist and not how things were last week, last month, or last quarter. In this study, we find that 30 states have at least one performance measure or aggregate data calculated on a real-time or daily basis. Overall, the 30 states average 13 performance measures and aggregate data calculated based on these immediate timeframes. The initiatives that have the greatest number of real-time and daily measures are focused primarily in two areas\u2014of the 381 (non-unique) performance measures and aggregate data calculated at this frequency, 173 are related to the call center (Figure I.1) and another 113 are related to application tracking (Figure I.2). Introduction Mathematica Policy Research 9 Figure I.1. Number of Real-Time and Daily Call Center Measures Calculated by States Note: Of the 45 responding states, 28 had call centers, 19 (shown in blue and green) calculate real- time or daily measures and 9 do not (shown in yellow, along with those who do not have call centers). Of the 9 states, 4 calculate longer-term measures, another 3 states calculate measures but did not report the period of time, and 2 states did not report calculating any measures. Counts are based on reported frequencies. Most states had one or more measures for which they did not report a frequency. Introduction Mathematica Policy Research 10 Figure I.2. Number of Real-Time and Daily Application Tracking Measures Calculated by States Note: Of the 45 responding states, 20 (shown in blue and green) identified application tracking measures that they calculated real-time or daily. Of those 20, 15 states identified 1 to 5 measures, 4 states identified 6 to 10 measures, and 1 state identified more than 16 measures. Counts are based on reported frequencies. Most states had one or more measures for which they did not report a frequency. 4. Focus on Quality and Timeliness States also made clear that their primary concern is to ensure quality and timeliness. Staff at all levels of SNAP agencies indicated that states are not meeting their mission if they do not provide benefits to those who are eligible, get the beneficiaries the right benefit amount, or achieve these goals in a timely fashion. At times, then, states may allow performance to drop for certain operational measures so they can ensure that other, more critical goals are achieved. For example, one state noted that it made the strategic decision not to shift resources to call centers when it noticed that the average answer speed was declining. Instead, the state kept its resources in areas that best ensured benefits were being provided to eligible clients in a timely manner. Introduction Mathematica Policy Research 11 G. How Are Measures Assessed? Until now, we have used the word measure in its broadest sense; that is, as the wide range of data that can be collected to assess an initiative’s or program’s performance. In fact, in performance measurement terminology, there are three key types of measures used to assess performance: data elements, aggregate data, and performance measures. A data element is the lowest level of measure and refers to a field that can track a specific instance of an activity. For instance, if the state tracks whether an application comes to it through an online system or through traditional means (fax, mail), the field in which it would store the information is the data element. The next level is aggregate data, or counts of data elements. Using the same example, the total number of applications that come through the online system and the total that come through traditional means are both aggregate data. Finally, performance measures are calculations using related data elements, such as the percentage of all applications that come to the state through its online system and the percentage that come through traditional means. A performance measure, used in this very strict sense, is normalized in such a way to make it comparable with other measures. For example, the normalization makes it comparable with other measures of the initiative in the same state or with the same measure in another state. Not all measures are equally appropriate for assessing performance. The measures themselves need to be assessed, which we have done according to the following six dimensions: 1. Validity: Does the measure accurately reflect performance toward a given goal? The connection between the measure and the goal needs to be clear. 2. Level of Detail: What are the measure’s unit of analysis and frequency? How often it needs to be measured will depend on its use\u2014measures that help allocate staff need to be available at high levels of frequency. Measures for trend analysis may be reported less often. 3. Reliability and Comparability: Are the data elements accurate, as well as the aggregate data used to construct the measure? A measure may appear to reflect the desired information, but if the means by which the data are captured is subject to error, it may not be a valid measure. The data also need to be collected similarly across states for comparisons to be valid. 4. Efficiency: How much time, effort, and money are needed to construct the measure? A measure that requires manual reporting or substantial post-processing of data elements is not likely to be sustainable. 5. Performance Standards: Is it reasonable to set an expectation for performance? Some measures may be used simply to track trends, but measures used to assess performance typically are paired with an expected result. Performance Measurement Terminology 1. Data Element is a field in a database that stores an instance of an activity or characteristic and is the basis of aggregate data and performance measure calculations. 2. Aggregate Data are counts of data elements, such as the number of observations. 3. Performance Measures are calculations using related pieces of aggregate data to assess an activity and typically are displayed as percentages and averages. 4. Performance Standard includes a standard and a benchmark. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes, while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. Introduction Mathematica Policy Research 12 6. Performance Initiatives: Is it reasonable to attach incentives or disincentives to the measure? Will staff performance reviews be tied to their ability to meet the standards? Will offices be rewarded if they meet the standard for a given period of time or penalized if they fail to meet it? Answers to these questions may differ across states, even for measures that appear to be the same. A complete understanding of measures, and the ability to compare across states, requires an assessment at this level. H. Study Objectives and Research Questions In this report, we seek to discuss the range of performance measures states have in place for specific initiatives\u2014assessing them according to the dimensions described above and comparing and contrasting their definitions and the level of performance that states meet. We also propose a small set of measures for each initiative that (1) aims not to be overly burdensome for the states to collect, (2) consists of reliable and valid measures, and (3) assists FNS and the states in assessing the likely success of the initiative. We also identify the gaps in this set of measures. In a separate report prepared as part of this study (Keefe et al. 2012), we provide a profile of initiatives and measures by state. Specifically, we address the following objectives and questions: a. Describe Each State’s SNAP Performance Measures and Standards in Detail: Which SNAP modernization performance measures do states have in place? What gaps exist in the performance measures currently used? Which standards are in place to gauge performance? What gaps exist in state performance standards? What is the rationale for the performance standards states use, and has the rationale changed over time? How were the performance measures developed? Have performance measures changed over time? What similarities and differences in performance measures and performance standards exist across states? What alternatives are there for states in measuring performance? b. Provide a Detailed Description of How Performance Measures Are Implemented, What Results Are Observed, and How the Results Are Used in Each State Are states using performance measures that are reliable and valid? How are performance measures operationalized across states? To what extent are different performance measures used? Using these performance measures, what results are observed? Introduction Mathematica Policy Research 13 Does performance vary? If so, on what basis? Are performance data used to gauge performance and make decisions? If so, how? What opinions do stakeholders offer about measures in place and potential additions? What similarities and differences occur across states? c. Assess the Pros and Cons of Applying Alternative Performance Measures and Standards Across States Which criteria should be considered in choosing to implement individual performance measures and standards? How well do the alternative measures and standards meet these criteria? Which measures appear to be more burdensome or require sophisticated technology to collect? Is there a best set of performance measures for program access, payment accuracy, efficiency, and customer service? Do these measures provide added value to the existing SNAP measures? Is there a set of measures and standards that are generally applicable? Under what circumstances? 15 II. METHODS To answer the research questions, we used a two-phased approach. During Phase 1, we interviewed a broad group of stakeholders to obtain their perspective on state performance measurement activities, identified the key modernization initiatives to include in the study, and developed the data collection instruments. During Phase 2, we developed a process to select the respondents and conducted data collection from state and local SNAP offices and organizations partnering with them. In this chapter, we describe the activities that occurred in these two phases. A. Phase 1: Preliminary Assessment and Instrument Development 1. Introduction Because of the exploratory nature of the study, Phase 1 involved developing insights on the performance measures and standards states use to assess their modernization initiatives. Based on our interviews with a broad group of SNAP stakeholders, we worked with FNS to refine the data collection objectives, identified the key modernization initiatives to include in the study, and developed a framework for assessing modernization initiatives for use in developing the data collection instruments. This section describes our approach to these activities. 2. Who We Interviewed We interviewed stakeholders with a wide perspective on state modernization and measurement activities, as well as those with insight on a specific aspect. They fell into four main groups: FNS, national human services organizations, state SNAP agencies, and community-based organizations and business partners. Questions for these stakeholder groups targeted their particular experience and perspective in the following areas: National and Regional FNS Office Staff. We interviewed staff members in the national office and all seven regional offices. We obtained an understanding of FNS’s goals for the project and learned more about state modernization initiatives and efforts to measure them. National Human Service Organizations. We solicited input from organizations researching and\/or working with states as they modernize. We identified their concerns about state modernization initiatives and what they would like to see from the study. They also discussed their insights on state and partner measurement activities. State SNAP Offices. We had in-depth discussions with state agencies that focused on the scope, functionalities, and measurement activities (including standards and benchmarks) of their modernization initiatives. Community-Based Organizations and Business Partners. We discussed these organizations’ concerns and knowledge of state-based measurement activities, state measurement of partnering activities, and their internal measurement capabilities. In addition to interviewing these groups, we reviewed related documents to supplement the feedback we received. These documents included call center statistics, online application utilization rates, applicant surveys, and SNAP reports, which we obtained from stakeholders and state websites. Methods Mathematica Policy Research 16 They provided an account of modernization initiatives and descriptions of specific performance measurement activities, including calculation methodologies and performance standards and incentives for selected measures. Also, we reviewed preliminary data collected for the study Enhancing Supplemental Nutrition Assistance Program (SNAP) Certification: SNAP Modernization Efforts (Rowe et al. 2010) to extract information that states reported on these activities. 3. What We Learned Using the findings from the interviews and document analysis, we drafted a preliminary inventory of state performance measurement activities. This inventory helped us assess the extent of measurement activities for specific modernization initiatives. Four themes emerged about how states were developing their approach to measuring performance: Official SNAP measures motivate existing performance measurement activities. States emphasize measurement of four SNAP measures: the payment error rate (the percentage of approved households with benefits calculated incorrectly), the negative error rate (the percentage of applying households incorrectly denied benefits), timeliness (the percentage of applications processed within 30 days), and the program access index (the percentage of the low-income population receiving benefits). FNS reporting requirements and performance bonuses motivate states to pay close attention to their performance in these areas. Some states developed corollary performance measures to identify the sources of errors or delays to improve their performance. States collect performance measures and data but may not use the information to their full advantage. Although computer systems retain a large volume of information, not all states are using the data to assess the initiatives’ overall impact on SNAP administration. State financial and technical resource and time constraints hinder the development of measures to assess progress in meeting program goals. Even in states with performance measures, we uncovered few performance standards against which they are benchmarking their efforts. Technology-related modernization initiatives facilitate current and future performance measurement. Building performance measures and tracking results is easier for technology-related modernization initiatives, as compared to others. We saw more performance measures with technology-related initiatives because systems are designed to track key indicators to ensure their functioning. Some states used this to their advantage to develop program performance measures. Other states simply may need to determine how to extract the data according to concrete measure specifications and leverage them for their performance needs. States make limited use of performance measures to assess modernization initiatives’ impacts on program access. For some stakeholders, it is vital to track where applicants are falling out of the system and their characteristics. (For example, do elderly individuals abandon online applications more often or at earlier stages than applicants of other ages?) States appear to be doing this only on a very limited basis. States have been tracking application and recertification approvals and denials and identifying errors, but preliminary research did not find that they tracked individuals’ characteristics, such as age, along with the approval, denial, and error rates. Methods Mathematica Policy Research 17 4. A Limited Set of Initiatives to Examine The objective of the study is to build a comprehensive inventory of the performance measurement activities used by states and local offices to monitor the performance of SNAP modernization initiatives. The comprehensive inventory includes specific measures and associated performance standards to enhance FNS’ understanding of how agencies collect, analyze, and use performance data to monitor their modernization activities. While our preliminary inventory included all initiatives FNS includes in its definition of modernization, we identified a subset of eight initiatives, in consultation with FNS, based on their wide use across states and their importance to FNS. To request states to submit detailed accounts of performance measures used for all initiatives would have been too difficult and time-consuming for agencies with limited staff resources, especially those already overwhelmed with growing caseloads. Limiting the number of initiatives was important to balance the time required and give staff the opportunity to provide well thought-out and thorough answers to questions. Below we list the eight selected initiatives, which fall into three categories\u2014technology, partnering with other organizations, and policy simplification: Technology – Call centers, including computer phone system, change center, interviews, and application processing – Online systems, including the online screening tool, online application, and online account – Document imaging – Kiosks used for application access and submission Partnering with other organizations for application assistance Policy simplification – The waiver of face-to-face interviews – A shortened interview process – The capacity for clients to complete expedited applications online The 12 initiatives included in the preliminary but not the comprehensive assessment includes the following: 1. Automatic case management 2. Data matching 3. Telecommuting 4. Staff e-training 5. Allowing clients 60 instead of 30 days to complete applications 6. Improving computer system characteristics using upgrades and modifications 7. Expanding use of electronic benefit transfer Methods Mathematica Policy Research 18 8. Outreach activities 9. Office changes 10. Organizational changes: transferring and sharing functions 11. Organizational changes: staff functions 12. Training Also, due to the emphasis that states place on existing FNS measures and the centrality of application processing to SNAP operations, we developed a performance measures module focused on the receipt and processing of applications and recertifications. This module, referred to as application tracking, expanded on the FNS-required performance measures regarding application approvals and denials by including performance measures related to the source of the application or recertification. 5. Data Collection Instruments The data collection plan involved a combined methods approach, using surveys, phone interviews, and in-person interviews and observations to collect detailed information for the inventory and provide states with an interactive response approach to describe and demonstrate their use of performance measures. We designed an electronic survey for state and local SNAP agencies that provided us with information about the presence and functionality of initiatives in the state and basic information about the performance measures the state collects. We then followed up with phone interviews to clarify survey responses and obtain more details about their select performance measures. For partner organizations, we developed an interview protocol focusing on their partnering activities with the state or local SNAP agencies as well as their performance measurement activities. After completing surveys and interviews in the state, we visited 10 states to conduct in-person interviews and observe their use of the performance measures. Below, we describe the content of the survey, interview, and site visit data collection instruments. Electronic Survey. We designed an electronic survey to collect details on the performance measures used for the modernization initiatives. For each of the eight initiatives, we provided states and local agencies with a list of known performance measures, aggregate data, and data elements collected during Phase 1. Respondents identified which of the eight modernization initiatives they had in place and their characteristics. Then, based on their responses, the survey revealed only the portion of the performance measures list relevant to their initiative. To augment this list and allow us to identify other areas of measurement, we gave states the opportunity to include additional performance measures. This option allowed us to build a more comprehensive inventory. For each performance measure and aggregate data, respondents answered questions on (1) how (and how frequently) they calculate the measure or element, (2) their purpose for collecting it and how it relates to FNS’s SNAP program goals, (3) their assessment of the accuracy and uses of the measure or element, and (4) the performance incentives or standards the respondent’s organization uses with respect to the measure. The survey also included a section for all respondents about application tracking, separated into six key steps in the applications process: (1) receipt, (2) processing and case characteristics, (3) approvals, (4) denials, (5) accuracy, and (6) processing time. Methods Mathematica Policy Research 19 Respondents also had the opportunity to add additional application tracking measures not on the preliminary list. Interview with State and Local SNAP Agencies. The interview protocol includes a series of questions to better understand the characteristics of the modernization initiative and to follow-up on the survey responses to obtain further detail about the performance measure calculations for a subset of the performance measures being calculated. These questions assess the six areas of the measure framework we developed: (1) validity, (2) level of detail, (3) reliability and comparability, (4) efficiency, (5) performance standards, and (6) performance incentives. Interview with Partner Organizations. The partner-only interview protocol focused on both the measures partners report to the state or local office and internal measures they use to assess their own performance. The interview questions on the measures assessed the same six qualities as those in the SNAP agency interview. Site Visits with Select States. The site visits to states included interviews with staff and tours of the state SNAP office, a local SNAP office, and a partner office to better understand the usage of performance measures for daily SNAP operations. We developed a semi-structured protocol for the interviews, which was tailored to each state after reviewing findings from the surveys and interviews. We also requested that the states send us 12 months’ worth of actual performance data for the performance measures they reported tracking, if possible. B. Phase 2: Respondent Selection and Data Collection With the data collection instruments developed, we identified and selected respondents and conducted the data collection. In this section, we describe the process, the modes of data collection by respondent type, the response rate, and our approach to following through with respondents. 1. Selecting Respondents Collecting information from every state and the District of Columbia provides FNS with the broadest view of the use of SNAP performance measures and standards across the country. All state SNAP agencies received an invitation to participate in the study and, in most states, a subset of their county and local SNAP offices and partner organizations also received one. Responses collected from the sample of county and local SNAP offices supplemented the state-level picture by determining the extent to which local-level offices are conducting additional performance measurement activity, as well as giving a front-line perspective on performance data generation and usage. All state, county, and local SNAP office respondents also received a request to submit 12 months’ worth of performance data for each measure their office calculates. The process we used to identify individuals to contact varied by the respondent type. State SNAP Offices Selection. All states SNAP offices and the District of Columbia received a survey, request for interview, and request for performance data. Local Office Selection. Initially, we planned to survey, interview, and request performance data from 150 local offices from the 19 states identified as having a relatively high number of the key initiatives and that together covered the range of Methods Mathematica Policy Research 20 initiative functionalities and regions of the country. We also factored in the performance on the outcome measures for which FNS provides financial incentives (timeliness, accuracy, and participation levels). In county-administered\/state-supervised states, we requested from the state contact information for 13 local offices and in state- administered states we requested it for 7. (When necessary, we randomly sampled from among the county and local offices.) During data collection, we often found little variation within state-administered states regarding their measurement of modernization initiatives because they primarily followed direction from the state. As a result, to enhance the data collection effort, we modified our approach and requested contact information for local offices in all states as opposed to only the subset of states. The target numbers changed to five for county-administered states and two for state-administered states. When contacting the states to obtain the local office contact information, we suggested offices based on a random selection (to simplify the process for states), but states also had the opportunity to identify specific local offices they wanted as part of this study. Switching the approach to local office selection allowed us to obtain wider understanding of the modernization initiatives and their measurement activities within more states. It also increased the opportunity for the discussions of modernization initiatives not utilized at the state-level. Partner Organization Selection. We targeted three types of partner organizations\u2014 national businesses, local businesses, and community-based organizations. During the interview with the office, we obtained further details on these partnering activities and requested the contact information. In selecting the partners for the interviews, we focused on those that were doing a wide variety of measurement activities or had unique partnering arrangements. Site Visit State Selection. We selected states for site visits in two stages. Before beginning data collection, seven states stood out in terms of their implementation of modernization initiatives and likelihood of having developed a wide range of performance measures. During data collection, after conducting numerous interviews and becoming more informed about the types and prevalence of performance measures across states, we identified three additional states. Deferring the decision for the remaining states allowed us to identify modernization activities that states had undertaken but were not known by the regions or well publicized. It also allowed us to uncover innovative approaches to performance measurement and particularly interesting lessons learned by states. Table II.1 lists the three respondent types and the modes through which each responded to the study. Table II.1. Modes of Data Collection for Each Respondent Type Respondent Type Electronic Survey Telephone Interview Performance Data Site Visit State SNAP Offices X X X X County\/Local SNAP Offices X X X X Partner Organizations X X X Methods Mathematica Policy Research 21 2. Responses Received During the nine-month data collection period from August 2010 to April 2011, we received feedback from 217 respondents representing 44 of the states and the District of Columbia. Figure II.1 depicts the states that contributed to the study and the total number of respondents within each. There were 15 states where respondents included the state and local SNAP offices and partner organizations. Of these 15, 10 also participated in the site visits. There were 19 states where both the state and local offices responded, and 11 where the state was the only respondent. Figure II.1. Number and Combination of Respondents, by State 3. Level of Response The number of solicited respondents differed from our planned approach. We sought participation from all 50 states and the District of Columbia as originally planned. However, 6 did not have time available to contribute, resulting in a total of 45 states participating in the study. We accommodated the schedules of respondents to make the request as minimally burdensome as possible, which included both allowing states to complete an interview only and extending the data collection period. Despite our best attempts, some state and local office respondents still were unable to participate due to their administrative responsibilities. When we changed our approach to selecting local office respondents during data collection, most state offices we interviewed provided the contact information upon request. We did not request this information from the six state offices that chose not to respond to the initial survey. We Methods Mathematica Policy Research 22 completed a survey, telephone interview, or both a survey and interview with 117 offices, out of 137 originally contacted. Although we collected contact information for numerous partner organizations, it would not have been fruitful to interview all of them. Many partner activities involved conducting SNAP outreach and providing application assistance. After conducting a substantial number of interviews with these types of partners and identifying the typical measurement activities, we chose to continue interviewing organizations with activities beyond outreach and application assistance. We sent participation requests to 71 and interviewed 55. 23 III. SUMMARY OF PERFORMANCE MEASURES ACROSS INITIATIVES Across the eight modernization initiatives included in our comprehensive inventory, states reported using 89 different performance measures to assess their activities. Of these 89 measures, states reported developing performance standards for 39 and, of those, assigning benchmarks and incentives to gauge the success of the standard to only a few. A wide variety of factors influence states as they develop performance measures for their modernization initiatives, including FNS’s goals for modernization and operational considerations, such as staffing and understanding utilization of the initiative. Barriers to additional measure development include insufficient resources (financial and time) and the technical incapacity of some legacy eligibility systems to track and store data related to modernization initiatives. In this chapter, we describe the purpose of measures according to FNS’s modernization goals; key state performance measures for each initiative; general gaps in performance measurement; states’ use of standards, benchmarks, and incentives; and how the measures relate to the SNAP lifecycle of application processing. Appendix A lists all measures and aggregate data that were identified by the states for each of the initiatives. A. Purpose of Measures by Modernization Goal Using FNS’s four goals for modernization\u2014program access, accuracy and integrity, efficiency, and customer service\u2014we asked states and local offices to identify the modernization goal that a measure addressed. We then categorized the measures within each goal according to the measure’s use. For example, among measures that states and local offices identified as assessing progress toward program access, we found that they fit into several categories based on their use: monitoring SNAP as a whole, monitoring the initiative, improving access to SNAP by maximizing staff time and program costs or having effective procedures, ensuring correct use of procedures, and ensuring that customers can make effective use of the initiative. In Table III.1, we show the number of different measures associated with each goal, further categorized by the measure’s use (note that some measures may be included under more than one goal). The number of measures for each of these themes yields insight into the focus areas state and local offices choose for their measurement activities. The list below highlights the themes for each goal: Program Access. Monitoring overall program access (rather than just at the initiative level) and improving it through efficiencies and correct use of procedures, have a large number of measures, but customer use of the initiative has fewer. Accuracy and Integrity. Aside from tracking overall accuracy, determining staff training needs and ensuring that staff use the correct procedures are the primary areas in which state and local offices focus their measurement activities. Efficiency. Tracking initiative usage, improving customer experience, reducing staff time, and following correct procedures are the areas in which the most measurement occurs. Performance Measures Summary Mathematica Policy Research 24 Table III.1. Types of Measures States Are Collecting to Assess Progress Toward Modernization Goals FNS’s Modernization Goal Purpose of Measure Number of Measuresa Number of States Collecting Measures Program Access Monitor combined result of initiatives to increase program access 43 27 Improve program access through maximizing staff time and agency cost efficiencies 37 20 Ensure correct procedures are being used by staff 34 17 Monitor use of initiative 30 12 Improve program access through establishing effective procedures 21 14 Determine if customers are able to use the initiative 5 3 Accuracy and Integrity Track accuracy related to the program as a whole as opposed to a specific initiative 84 32 Assess general accuracy used in eligibility determinations as part of FNS quality reviews 24 20 Determine staff training needs and ensure correct procedures are used by staff 17 16 Reduce overall errors or improve overall accuracy 12 10 Identify overall error rate or trends, not related to a specific initiative 9 11 Identify error rate or trends for a specific initiative 5 8 Reduce errors or improve accuracy for a specific initiative 3 2 Efficiency Track usage or system load 73 26 Reduce staff time and agency costs 47 21 Improve customer experience 46 20 Determine staffing needs and ensure that correct procedures are used by staff 30 19 Assess initiative-specific accuracy used in eligibility determinations as part of FNS quality reviews 20 12 Customer Service Assess general customer service 61 26 Increase efficiency\/improve customer experience for a specific initiative 52 24 Identify barriers to program access for specific initiative 40 12 Determine staffing needs and ensure that correct procedures are used by staff 32 17 Assess general accuracy used in eligibility determinations as part of FNS quality reviews 27 13 Eliminate or reduce barriers to program access for customers 8 6 Note: Totals are based on responses from the 45 states that participated in the study. Each respondent indicated its own purpose for collecting the measure, and those can differ across the state and local offices within a state. The measures in this table include those reported by both offices, so a measure may be captured more than once. a Numbers in this column include performance measures reported for each initiative and application tracking. Performance Measures Summary Mathematica Policy Research 25 Customer Service. Tracking initiative-specific efficiency and customer experience, as well as determining staffing needs and following correct procedures, are the areas in which states concentrate their measurement activities. In Table III.2, we present similar information about the use and purpose of the measure, but focusing on each initiative. In the 28 states with a call center, for example, we find 34 different measures that states and local offices are using to identify training needs, assess operations efficiency, and assess customer service. Within the online systems, they are tracking how much a system is being used and making comparisons of its use with other ways of submitting applications. In Table III.2, we also show how states and local offices viewed these measures in relation to FNS’s modernization goals. In most cases, respondents matched a measure with more than one goal. They selected the goal of Accuracy and Integrity least often but identified the remaining three goals about equally. The respondents cited goals for all of the measures used for these initiatives: online account access, waiver of face-to-face interviews, and expedited online applications. For call centers, they cited all goals equally except for Accuracy and Integrity, which they cited least frequently. The state with the single kiosk measure used it for program access B. Key Performance Measures and Gaps, by Initiative State and local offices are using a large number of measures to oversee their modernization initiatives. Many of these measures exist within most states implementing an initiative. Some state and local offices supplement the common measures with others less common to enhance the set of measures used. States also described gaps in their measurement activities and their desire to calculate additional performance measures and aggregate data. Using measures is practical for states\u2014they need the information the measures provide to make operational decisions. For example, they may ask these questions: How many staff do they need for a given shift? Are potential applicants using the available options to learn about and apply to the program? They also may ask the following questions but not necessarily be in a position to use the measures to address them: How is this initiative impacting the broader picture of program access? How does the work under one initiative impact the operations of another for improving application processing? In this section, we describe the types and numbers of measures that states use for each initiative, their purposes in using them, and gaps in measurement activities. 1. Call Center The call center is a point of access whereby individuals call to obtain information or some other service by listening to a recording, talking to a person, and\/or interacting with a computer. There are three functionalities that states might choose to implement: call center, computer phone system, or change reporting. The general call center has agents available to answer caller questions. 26 Table III.2. Number of Measures States Are Collecting to Assess Progress Toward Modernization Goals Initiative Number of States with Initiative Number of Different Measures of Initiative Reported Use of Measure Number of Measures Collected for Each Goal Program Access Accuracy and Integrity Efficiency Customer Service Call Center 28 34 Identify staffing needs Identify need to train staff Assess efficiencies and inefficiencies of operations Assess customer service 19 12 18 20 Online System 33 27 Demonstrate program access and increased participation Track utilization of online application feature, including making comparisons with paper applications 20 17 16 19 Document Imaging 24 8 Track system operations Manage staff workload 5 3 7 4 Kiosks 14 1 None reported 1 0 0 0 Partnering 35 3 Track approvals Track partners providing assistance Track partner assistance provided\u2014from monitoring to evaluating effectiveness and reimbursing them for assistance provided Enhance program access 3 2 2 3 Waiver of Face-to-Face Interview 40 12 Show effectiveness of interview option Determine accuracy, including making comparison with face-to-face interviews Comply with federal waiver requirement for performance measure calculations 8 8 8 9 Shortened Interviews 12 2 None reported 0 0 0 0 Expedited Applications 20 2 Increase program access Track approvals 2 2 2 2 Note: Totals are based on responses from the 45 states that participated in the study. Performance Measures Summary Mathematica Policy Research 27 Throughout this report, we describe the performance measures associated with the overall call center as applying to incoming calls. The computer phone system facilitates clients interacting with a computer through an integrated voice recognition system or similar technology to get answers to questions, access account information, or report account changes. It also may route callers to a call center agent. States can choose to implement a computer phone system with the abilities to complete all transactions electronically (and not transfer the caller to an agent), transfer the caller to an agent, and\/or accept change reporting, allowing the caller to report changes to his\/her case. Last, the call center might have the ability to accept change reporting from the SNAP client. In Table III.3, we list the most frequently calculated performance measures for the call center initiative. States report that they use these measures to identify staffing and training needs and assess the efficiency of operations. For example, call center supervisors rely on the information these measures provide to identify when they need to add staff to answer calls due to high call volume. If high call volume is not an issue, supervisors might want to assess whether their call center agents have adequate skills to handle the calls and provide training where appropriate. Because states tend to emphasize their immediate staffing needs at daily and hourly frequencies, they did not report looking at the measures over the longer term. Also, the results of these measures fluctuate at peak times in the week and month, so averaging them across longer time periods hides the fluctuation. Table III.3. Top Performance Measures: Call Center Number of States Implementing Initiative Top Measures Number of States with Measure 28 Percent Calls Abandoned Average Calls Handled Average Hold Time Average Call Duration Percent of Total Calls Handled Average Waiting (to Speak to Agent) Average Answer Speed Average Queue Time Average Staff on Phones Average Time Prior to Abandonment 22 22 21 21 18 17 17 16 15 15 Note: Some states reported collecting multiple related measures that they defined in the same way (such as Average Hold Time, Average Queue Time, and Average Answer Speed). Using their definitions and details about the functionality of the call center, we retained only one measure out of those defined the same way, choosing the measure name most consistent with the way we and other states were defining it. Counts are based on responses from the 45 states that participated in the study. 2. Online System An online system is a website an individual may use to submit information. Like the call center, the online system has three basic functionalities from which states can choose to implement. These are the screening tool, the online application, and online accounts. The state either creates the screening tool (internally or under contract) or provides a link through which a client can enter household information and assess eligibility for SNAP benefits. Through the online application functionality, the client can access, complete, and submit the application online, either with or without an electronic signature, depending on the state-selected method. Finally, online accounts Performance Measures Summary Mathematica Policy Research 28 provide individuals with the option to check account history or benefit status or submit change reporting. In Table III.4, we show the most frequently calculated performance measures for the online system initiative. Table III.4. Top Performance Measures: Online System Number of States Implementing Initiative Top Measures Number of States with Measure 33 Percentage of Applications Received Average Number Submitted per Month Average Number of Screenings Completed: Online Average Number of Screenings Started: Online Average Number Started per Month 15 12 9 8 8 Note: Counts are based on responses from the 45 states that participated in the study. State and local offices report using these measures to monitor system utilization. Also, these measures allow them to determine whether individuals are electing to use the online venue to access the program, with an increase in this number demonstrating the online system’s usefulness for increasing program access. However, the measures focus on general utilization; most states do not have additional measures to identify the characteristics of individuals electing to use the system features. For example, the measures do not track the use of individuals over 65 in comparison to those under 65 and cannot demonstrate whether the initiative is increasing program access for a particular demographic. State and local offices also reported a gap in their measurement activities related to tracking the proportion of applications received online versus in paper format. Some states would like to compare the percentage of applications submitted online and on paper, including approval and denial rates, but the previously mentioned system limitations do not make this possible for many of them. 3. Document Imaging A state implementing document imaging is operating a system or a process in which it receives documents in either paper or electronic form, scans the paper documents, and stores all documents electronically for future access. State might store these images in an independent directory not linked to another system or as part of an electronic case record. In Table III.5, we list the most frequently calculated performance measures and aggregate data for the document imaging initiative. The most frequently calculated performance measures are the percentage of documents scanned and the average processing time. Nine states collect these measures, which indicates that only a third of states with this initiative have performance measures (as opposed to aggregate data). As a result, we also chose to include in the table the aggregate data calculated for this initiative. States reported that they track the numbers of documents scanned, received, and processed, and the completion of tasks associated with processing the document. Even though some states track these activities, they do not have a performance measure to assess how using the information stored in the document imaging system affects the accuracy of the application decision or processing time. Performance Measures Summary Mathematica Policy Research 29 Table III.5. Top Performance Measures: Document Imaging Number of States Implementing Initiative Top Measures Number of States with Measure 24 Performance Measures Percentage of Documents Scanned Average Processing Time Aggregate Data Number of Documents Scanned Number of Documents Received Number of Documents Processed Number of Tasks Complete 9 9 18 12 11 11 Note: Counts are based on responses from the 45 states that participated in the study. 4. Kiosks Kiosks are computer terminals in a community location or SNAP office at which an individual may access a SNAP application or change reporting function. Kiosks are public or semi-public terminals, so clients’ personal computers are not included in this definition. We list in Table III.6 the most frequently calculated kiosk performance measures. About a quarter of states are implementing this initiative, and one state calculates the applications submitted after the applicant completes a screening. A few states are tracking the measures listed in this table for changes, account access, and screenings completed. Table III.6. Top Performance Measures: Kiosks Number of States Implementing Initiative Top Measures Number of States with Measure 14 Performance Measure Percentage of Screenings Resulting in Application Submission: Kiosk Aggregate Data Number of Uses to Submit Changes Number of Uses to Access Online Account Number of Screenings Completed: Kiosk 1 3 2 1 Note: Counts are based on responses from the 45 states that participated in the study. 5. Partnering (for Application Assistance) Partnering for application assistance occurs when organizations or agencies other than the SNAP office provide access or services to SNAP clients under a formal or informal agreement with that office. The agreement may be in the form of a contract, memorandum of understanding, or another type of request. In Table III.7, we list the most frequently calculated performance measures and aggregate data for the partnering initiative. States did not report tracking performance measures for their partnering activities other than the percentage of partners providing application assistance. They use this measure to assess their outreach activities with target populations. The aggregate data that states most often track include their number of partners, the number providing application assistance, the number accepting applications, and the number of applications received per partner. They generally use this Performance Measures Summary Mathematica Policy Research 30 information to reimburse partners as a part of their statewide outreach plan. In some states, the application approval status also affects the amount of payments to the partner. Because so few states closely monitor partner activities, they cannot use measures to demonstrate broader impact on program access. States also do not use the aggregate data and application determinations to track program access for underserved or specific populations. Table III.7. Top Performance Measures: Partnering Number of States Implementing Initiative Top Measures Number of States with Measure 35 Performance Measure Percentage of Partners Providing Application Aggregate Data Number of Partners Number Providing Application Assistance Number Accepting Applications Number of Applications Received per Partner 10 20 18 17 15 Note: Counts are based on responses from the 45 states that participated in the study. 6. Waiver of Face-to-Face Interview The waiver of the face-to-face interview is a formal approval received from the FNS national office to perform interviews by telephone. We list the most frequently calculated performance measures and aggregate data for the waiver of this interview in Table III.8. Those state and local offices reporting that they calculate this set of measures said they do so to assess the accuracy of the eligibility determination as part of FNS’s quality control process. Calculating the error rate of the face-to-face interview often is challenging for them. The information for the interview type (either telephone or face-to-face) typically is stored in the case file notes and so does not lend itself to creating automated reports for calculating these measures efficiently. Table III.8. Top Performance Measures: Waiver of Face-to-Face Interview Number of States Implementing Initiative Top Measures Number of States with Measure 40 Performance Measures Error Rate for Cases with Telephone Interviews Error Rate for Cases with Face to Face Interviews Percentage of Interviews Conducted by Telephone Percentage of Interviews Conducted Face-to-Face Aggregate Data Total Number of Interviews Number of Redetermination Interviews 16 14 13 13 20 19 Note: Counts are based on responses from the 45 states that participated in the study. 7. Shortened Interviews Some clients are eligible to participate in SNAP eligibility interviews, consisting of a shorter list of questions than the regular interview. In Table III.9, we list the most frequently calculated Performance Measures Summary Mathematica Policy Research 31 Table III.9. Top Performance Measures: Shortened Interviews Number of States Implementing Initiative Top Measures Number of States with Measure 12 Performance Measures Percentage of Clients Electing Shortened Interview Percentage of Total Interviews that Are Shortened Aggregate Data Number of Shortened Interviews Number of Clients with Shortened Interviews 2 2 3 1 Note: Counts are based on responses from the 45 states that participated in the study. performance measures for the shortened interviews. The measures for this initiative are not used broadly across states. 8. Expedited Applications\u2014Submitted Online Some states provide the capacity for clients to complete expedited applications online. In Table III.10, we list the most frequently calculated performance measures for this initiative. Table III.10. Top Performance Measures: Expedited Applications\u2014Submitted Online Number of States Implementing Initiative Top Measures Number of States with Measure 20 Performance Measures Percentage of Applications Approved: Online All Percentage of Applications Approved: Online Expedited Aggregate Data Number of Expedited Applications Received Online Number of Applications Approved: Online Expedited Number of Applications Approved: Online All 10 9 9 9 5 Note: Counts are based on responses from the 45 states that participated in the study. C. General Gaps in Performance Measurement Within each initiative above, we address very specific gaps in performance measurement\u2014areas in which states do not use specific measures broadly or lack measures for specific activities occurring in an initiative. In addition, some gaps we have identified are not as tied to individual initiatives. Some states expressed a desire for more aggregate data. Also, states provided feedback on the utility and feasibility of additional national-level performance measures for reporting on SNAP activities. Apart from desiring additional performance data, states reported that they would like to enhance their ability to analyze the data within their state systems and the time, financial, and technological barriers to developing additional performance measures. Aggregate Data Gaps. Some state and local offices expressed a desire for more aggregate data so they can learn more about client experience with SNAP and better understand the client decision making process around completing the application and recertification processes. For example, some states and partners expressed the desire to better understand SNAP churning (when households exit Performance Measures Summary Mathematica Policy Research 32 SNAP for a short time, such as one to four months, and then reapply for benefits). Identifying patterns in disenrollment and re-enrollment would facilitate program efforts to reduce the occurrence of churning; some aggregate data the states identified for this purpose include information on the source of the application (mail, fax, online, partner), interview completion mode (phone or face-to-face), reasons for failing to complete the interview, and benefit denial reasons. Respondents also discussed tracking such data as the number of telephone interview attempts, customer experience with interviews, and the time lapse between interview completion and the date the application was processed. Partner Organizations Desire Application Determination Information. Partner organizations would like to have information on the application determination for individuals they assist with applying. To assist them in targeting their outreach efforts, partners would like to know the amount and approval date for approved applications and the denial reason and denial date for denied applications. Some states are unable to provide partners with this information, while those that are able to do so vary in the information they provide. Some SNAP offices do not track partner-assisted applications. This means that to determine the impact of outreach efforts on increasing SNAP enrollment, partners must call applicants to ask if they received approval notification and their monthly benefit amount. This process is time consuming, and it is challenging to reach all of those they assisted. When an applicant grants the partner written permission to discuss his or her case with the SNAP office, partners can call the office to obtain this information. Some SNAP offices have been able to develop a formal process through which they track all partner-assisted applications. This process most frequently occurs when the partner receives reimbursement from the state for each application with which the partner provides assistance. In this process, the SNAP office provides the determination information to the partner at a specified interval so that the latter can assess its outreach efforts. However, SNAP offices vary in the specific information they provide. Some states only indicate the final determination of either approval or denial. Others provide the amount of benefits approved; few states provide details on the reason for denial. National-Level Performance Measures. Some states would like to have additional national- level performance measures to gauge their activities against other states (as opposed to establishing new national standards for these activities), while others feel the current national-level measures are sufficient and that they do not have the resources to generate additional reports. Those states that would like to gauge their activities against others expressed a desire to see the proportion of applications processed online and on paper as well as the average number of days to process applications (rather than the percentage processed within 30 days, as required by FNS). Initiative-specific national measures they requested also include the percentage of applications received online versus in paper to assess utilization patterns. For the call center, respondents were most interested in two measures: average wait time and average call duration. Seeing these results nationally would allow states to look at their operations compared to the states they identify as their peers\u2014taking into consideration the characteristics of the state\u2014to assess their own performance and the reasonableness of their results. Those states that did not see the need for additional nationally reported performance measures said that the current FNS national measures are sufficient. Also, the current reporting effort consists of many measures, and increasing the number would overwhelm them with reporting activities. Performance Measures Summary Mathematica Policy Research 33 Moreover, states reported that it would be challenging to use additional measures to make comparisons across states because of variations in initiative scope, capacity, operations, and the nature of state demographics. Analytical Capabilities Desired. Apart from more performance measures and aggregate data, state and local offices reported a desire for increased analytical capabilities for the measures they already are calculating. Some aggregate reports are available only at the state level, so staff do not have the ability to drill down to the local or individual levels. Increasing such analytical capabilities would help with training and monitoring staff. For example, with such data, a supervisor could try to identify performance challenges according to application disposition and processing timeframe; alternatively, a program manager could view the state’s overall application processing time to ascertain how this number varies by county and local office to identify variations in processing time, which in turn could help identify outliers. Also, program managers could look at application denials according to the applicants’ demographics to assess in more detail subpopulations’ access to the program. To a lesser extent, some state and local officials said that reports, once produced, often are not available or distributed in a timely way across the state. For existing performance measures, states would like their analytical abilities enhanced in two primary areas. The first includes automating manual reports. Some measures require time-consuming manual calculations at the local office; such data are more susceptible to error than automated data because of this manual process. Also, the reporting burden resulting from aggregating and submitting these data to the state or other reporting entity increases because the paper documents must be totaled manually. Barriers to Measure Development. Despite the desire to have more measures, track more aggregate data, and increase the number of measures reported nationally, states encounter barriers\u2014 time, financial, and technological constraints\u2014to identifying, specifying, and developing new measures from data they currently collect. Respondents reported that it is challenging to devote time to assessing critically their performance measurement gaps so as to identify how calculating an additional measure could help them operate their modernization initiatives. Respondents also reported that technical challenges pose a barrier to increasing their measure development, specifically when tracking applications received and disposition by application source. In Table III.11, we describe the current state capabilities. More states have the capacity to track applications that were submitted either online or directly to the SNAP office (mailed, faxed, or hand-delivered) than applications submitted through a kiosk, call center, or community partner. However, the ability to track approval and denial determinations is more limited than the ability to track the application source. More states are able to track the source because mode- or initiative-specific tracking efforts exist for this information. However, source information is less often stored in the eligibility system, where it could be used to assess the mode in relationship to the final determination. A local office director reported an interest in seeing improvements in the technology and computer system that they currently have to generate better data and better use the data that is already captured in the system. For example, for the waiver of the face to face interview, this is only recorded in documentation. Reports cannot be run on this initiative, even though the data is recorded. Performance Measures Summary Mathematica Policy Research 34 Table III.11. Number of States Able to Track Application Status, by Application Source Submitted Application Complete Application Approved Denied All Applicants 34 34 33 Source of Application Delivered to office (mail, fax, in person) 26 20 17 Submitted through kiosk 3 1 1 Submitted online 25 14 10 Submitted to call center 4 4 3 Submitted by community partner 11 11 9 Note: This table includes both state-reported performance measures and aggregate data to generate the total numbers in these categories. Counts are based on responses from the 45 states that participated in the study. Each respondent indicated its own purpose for collecting the measure, and those can differ across the state and local offices within a state. The measures in this table include those reported by both offices, so a measure may be captured more than once. Specifically, respondents said that their eligibility systems do not store this information in a discrete field(s). Although it is possible to access individual records within the eligibility system to see the final disposition, without storing the application source these calculations cannot be made in the same system. For example, many states reported that their online systems operate separately from their eligibility systems, and these cannot be linked easily or at all for reporting purposes. Even though one system records the online applications received, it does not store the application disposition data as well. Each system retains a portion of the information to perform this calculation, but these are not connected for reporting purposes. Likewise, for partner-submitted applications, few states have created a new eligibility system field or other discrete method to identify them. Some states with document imaging systems reported that it is possible to look at the scanned image of an online application or partner-assisted application to determine from which of these sources the application was processed. D. Use of Standards, Benchmarks, and Incentives Performance measurement typically includes the use of standards, benchmarks, and incentives for the selected measures. Standards and benchmarks establish the criteria against which performance is measured. A standard is the desired outcome of an activity\u2014for example, answering a call within three minutes\u2014while a benchmark is the desired rate of success\u2014for example, answering at least 80 percent of calls within three minutes. An incentive is a motivator for performance and can encompass rewards and public recognition of the highest performers and\/or some combination of sanctions and technical assistance to the lowest performers. If no standards exist, there is no way of knowing if an activity is meeting its goals. States’ use of standards, benchmarks, and incentives varies across their modernization initiatives, measurement purposes, and initiative operations. We found five initiatives with standards, benchmarks, and incentives; one initiative with standards and benchmarks, but no incentives; and two initiatives without any of these. Call centers and online systems each have three functionalities; states vary in their application of standards, benchmarks, and incentives to these initiatives. In Performance Measures Summary Mathematica Policy Research 35 Table III.12, we present the number of measures with standards or benchmarks, by initiative, and summarize how states use them. Table III.12. Use of Standards, Benchmarks, and Incentives Initiative (Number of Measures Using Standards or Benchmarks) Use of Standards, Benchmarks, and Incentives Call Center (20) Standards: Evaluate performance of individual call center agent or a group of agents Incoming Calls Benchmarks: Assess volume of calls through specifying waiting and call duration times Incentives: Determine high or low staff performance review; penalize vendor poor performance (when contracting with a vendor) Standards: Track incoming call handling Phone System Benchmarks: Resolve maximum number of calls within phone system or via agent Incentives: Not reporteda Standards: Track processing of all changes and their processing time Change Reporting Benchmarks: Not provided Incentive: Determine high staff performance review rating Online System (3) Standards: Track portion of applications received online Online Application Benchmarks: Increase usage of application option Incentives: Not used Not used Online Screening and Online Account Access Document Imaging (6) Standards: Assess quantity of documents scanned, by document type, within specified timeframe Benchmarks: Scan all documents within a certain timeframe Incentives: Satisfaction of achieving mandate; penalize vendor poor performance (when contracting with a vendor) Kiosks (0) Not used Partnering\u2014Application Assistance (2) Standards: Monitor partners providing application assistance Benchmarks: Ensure that all partners provide assistance Incentives: Pay partners for approved applications for which they provided assistance Waiver of Face-to-Face Interviews (6) Standards: Monitor the proportion of interviews conducted face-to- face and telephonically to track utilization Benchmarks: Ensure that the percentage of telephone interviews does not exceed waiver requirement Incentives: Not reporteda Shortened Interviews (0) Not used Expedited Applications (2) Standards: Process expedited applications Benchmarks: Process expedited applications within 7-day timeframe required by FNS Incentives: Not reporteda a Not reported indicates that the respondent identified the use of an incentive but did not describe the specific incentive utilized. Performance Measures Summary Mathematica Policy Research 36 Use of Standards. States vary in their use of performance standards. We found more performance standards for many of the unique performance measures associated with the call center, document imaging, waiver of the face-to-face interview, expedited applications, and partnering initiatives. States do not use standards for the performance measures associated with certain online system functionalities (online screening and account access), kiosks, and shortened interviews. Use of Benchmarks and Incentives. States use benchmarks to monitor SNAP office operations, such as supervising staff activities and initiative operations and tracking partner activities, including vendors contracted to operate an initiative and community-based organizations providing application assistance. For the online application, some states reported wanting to increase the use of this application mode and identify the proportion of the total applications received by each mode. Call center supervisors evaluate agent activities and track incoming call handling and processing changes, as well as the computer phone system’s handling of calls. For the waiver of face-to-face interviews, staff monitor the proportion of interviews they conduct on the phone to limit them to the 50 percent balance required for the FNS waiver of face-to-face interviews. As to online expedited applications, standards focus on state staff approving applications within the seven-day timeframe mandated by FNS. States use both positive and negative incentives. For the call center functionality incoming calls and document imaging, vendors contracted to operate the call center on the state’s behalf are held accountable to benchmarks established in the contracts and penalized for poor performance, which is a negative incentive. Similarly, call center agents working for a state-operated initiative have benchmarks to ensure that the calls they handle meet the intended goal. This incentive is both positive and negative because the achievement of or failure to meet the benchmark affects their performance review rating. For some state staff working in document imaging centers, the incentive may not be quantified in a performance review but rather by the general satisfaction of achieving the state mandate. Partner organizations receive positive incentives for achieving their benchmarks in the form of payment for the assistance they provide. E. Relationship of Measures to SNAP Lifecycle In attempting to meet FNS’s standards or additional state requirements, such as lowering the budget, states may pursue one or more changes to their program’s administration. Generally speaking, these initiatives are tied to one or more steps in the application, maintenance, and recertification process\u2014that is, the SNAP lifecycle. This lifecycle has seven general stages: (1) learn about SNAP, (2) acquire application, (3) application, (4) interview, (5) eligibility determination, (6) case maintenance, and (7) recertification. We mapped the modernization initiative and application tracking measures provided on the survey onto one or two of the stages. We then analyzed how respondents reported their measurement activity and purpose for measurement in each stage. We list the number of measures collected for each stage of the lifecycle in Table III.13. Within each stage, we categorize the purpose that states cited for collecting these measures and present the number of different measures calculated for the particular stage and purpose, the number of states with the measures, and the number of measures with a standard. States calculate most of the measures in each stage of the lifecycle, with most measures found in the application stage. They also calculate many measures within the eligibility determination, case Performance Measures Summary Mathematica Policy Research 37 Table III.13. Measures and Reported Purpose by Stages of the Lifecycle Stage in Lifecycle Purpose of Measurea Number of Respondents Stating a Purpose for Collection Number of Different Measures Calculated Number of States with Measures Number Having Standards Learn about SNAP 6 4 6 0 Monitor use 4 3 4 0 Monitor customer service 1 3 1 0 Maximize program access 4 2 4 0 Determine applicant interest 1 1 1 0 Acquire Application 0 0 0 0 Application 61 52 32 26 Monitor system use 34 44 24 14 Minimize client time required 26 37 22 12 Maximize program access 21 32 18 10 Distribute staff load 29 24 19 9 Monitor accuracy and integrity 11 13 9 4 Monitor partners 13 6 8 2 Interview 38 8 22 5 Increase efficiency 5 3 5 0 Monitor accuracy and integrity 24 6 17 4 Maximize program access 22 8 11 2 Monitor system use 6 6 6 0 Decrease staff workload 4 5 4 0 Monitor customer service 5 2 5 0 Eligibility Determination 66 24 40 18 Monitor accuracy and integrity 48 21 37 17 Monitor system use 42 21 28 13 Maximize program access 14 18 13 12 Monitor customer service 16 17 15 15 Monitor staff load and training 17 14 15 8 Monitor partners 6 2 6 1 Case Maintenance 56 22 33 15 Monitor program management 24 21 18 15 Minimize client time required and create efficient process 18 18 16 10 Monitor accuracy and integrity 35 15 30 3 Monitor staff load and training 24 14 15 7 Recertification 33 18 27 8 Maximize program access 12 12 12 6 Monitor accuracy and integrity 13 12 13 5 Monitor system load 9 10 9 1 Minimize client time required and create efficient process 13 8 13 5 Monitor program management 16 7 14 5 Monitor staff load and training 12 7 9 3 Note: Each respondent indicated its own purpose for collecting the measure, and these can differ across the state and local offices within a state. For example, of the 94 measures collected on the survey (excluding measures respondents wrote-in), we identified 56 (not shown) as being associated with the application stage (individual measures were categorized into up to two stages). For those 56 measures, 61 respondents provided a purpose for collecting at least one of the measures. After placing the various purposes reported into the categories listed, we found that, for 34 of the measures, one or more respondents collected the measure to monitor the use of the application system; for 26, one or more respondents collected the measure to help work toward minimizing client time required to apply. Totals are based on responses from the 45 states that participated in the study. Performance Measures Summary Mathematica Policy Research 38 maintenance, and recertification stages. The high concentration of measures in these four stages demonstrates that states focus their measurement on program administration as opposed to how individuals learn about SNAP or acquire the application; no state currently tracks the latter. Although states calculate many measures within the lifecycle stages, a smaller percentage of measures for application and recertification have associated standards than for some of the other measures (excluding the acquire application stage, for which no state calculates a measure). Across the lifecycle stages, states focus most frequently on system use and staff load. They also calculate many measures in these stages to maximize program access and monitor accuracy and integrity. In the application and eligibility determination stages, states calculate measures related to monitoring partners the least frequently; this is important to note, because FNS does not calculate national measures or require the reporting of information related to these partnering activities. However, FNS does work with states on an individual basis to monitor some partner reimbursement for application assistance activities. 39 IV. LIMITATIONS TO USE OF MEASURES AND STANDARDS FOR CROSS-STATE COMPARISONS While many states are collecting performance measures for initiatives that have the same name, these measures cannot be compared across states. Several factors related to modernization and performance measures affect cross-state comparisons. In this chapter, we focus on two aspects: contextual limitations (related to the context and environment in which the initiatives operate and the functions of the initiatives) and data limitations (related to the ability to calculate accurate, valid, and reliable measures). Because this is an exploratory study, we face limitations in assessing how well the particular performance measures identified by the states can be compared. We asked states for basic information about all performance measures they collect related to their initiatives, but to avoid placing an excessive burden on them, we limited the number of measures for which we requested clarifying information and further details. This means that we often received incomplete information about performance measures. Also, six states did not have time available to participate, so this study does not include an analysis of their performance measurement activities. A. Contextual Limitations State and local offices operate and implement modernization initiatives in different contexts, which influence their choice of performance measures and standards and the observable outcomes, as well as complicating cross-state comparisons. Common contextual limitations include: Initiative Scope and Features. Initiatives differ in their size and breadth, especially whether they serve the entire state or just a region, and what services are provided through them. System Limitations. Eligibility and reporting systems are limited in their ability to capture and report measures of interest to each state. Terminology Differences. Variations in measure wording and definitions across states mean that states are measuring different performance aspects. Varying Measurement Motivations. Motivations for using measures and standards also vary across states, with some choosing measures to manage staff workloads and others setting standards to comply with legislative or other mandates. 1. Initiative Scope and Features An initiative’s scope and its features or functionalities all play a role in determining performance measures and their associated outcomes, and likewise affect the performance standards guiding an initiative. Factors that can influence the measures, and examples of them, include the following: Geographic Reach. It may be misleading to compare two states’ initiatives if one serves an entire state and the other serves only a local area. For instance, states that run statewide call centers may set different standards for average number of calls handled than those running local centers. Limitations to Use of Measures and Standards Mathematica Policy Research 40 Complexity of Initiative Design. Some call centers share a phone line that rings at multiple desks, while others use software to queue and assign calls to agents. These features impact how many people can be served, regardless of the number of staff available. Outcomes for measures such as average answer speed also can differ. Complexity of Technology Supporting Initiative. For document imaging, some states put barcodes on the documents they provide to households so that when the documents are returned, they can be scanned and linked automatically to a case file. Documents clearly will be processed more quickly in these states than in those in which staff manually attach documents to cases. Also, both types of states will achieve much faster imaging speeds than those in which workers send the documents through scanners manually. Presence of Complementary Initiatives. Whether a state or locality has a waiver of face-to-face interviews and a call center to handle those interviews impacts data that feed into call center performance measures. The average wait time, answer speed, and call duration measures may achieve different levels in states that conduct phone interviews than in areas with a more limited number of services available by phone. Functions of the Initiative. States with online screening tools may have fewer applications submitted per month online if, before submitting their applications, people realize they are not eligible or would receive only a small benefit amount. Similarly, the ability to submit applications online and to print applications and mail them in could affect average number of applications submitted through the mail and online, or could increase the average number of duplicate applications if people choose to apply via both modes. Community Characteristics. States with a waiver of the face-to-face interview may encourage telephone interviews for all applicants, but individuals for whom transportation to the SNAP office is difficult may take advantage of this option more often than those with easy access. States with few urban centers may have higher take-up rates. 2. System Limitations The efficacy of comparing performance measures across states also is affected by the eligibility and reporting systems the states use. Respondents reported three main limitations to these systems: reporting capacity, system reliability, and system capability. Each affects states differently and may present more problems for some states than others. Some states’ systems do not have the capacity to report aggregate data or generate reports that can be manipulated by users. They often combine measures across programs, such as Medicaid, SNAP, and cash welfare. Alternatively, data may be aggregated to the state level and not be available by county or local office. Other measures may be available at a point in time but not be aggregated systematically to show trends or longer-term performance; for example, hourly or real-time reports captured throughout the day may need to be aggregated manually to days and then weeks or months. Reports also may capture only one piece of a broader measure. For instance, in some cases, a state can track only clients approved for SNAP benefits through their food bank partners, not those that applied and were rejected. Limitations to Use of Measures and Standards Mathematica Policy Research 41 State systems may be unreliable or face periodic outages. States reported times when they have had to enter data manually that should have been entered automatically, introducing the possibility of errors in the data. The systems also may be limited in what they can collect or measure. Some states rely on systems that have been in place for 30 years and are limited as to the amount of data they can record or process; these may not be updated easily. Other states with newer systems might find that their use of multiple assistance programs makes it more complicated to make system modifications. Some call centers have queues with limited capacity, which may have been set at what seemed an appropriate level when the initiative was launched but may no longer be adequate, given record- breaking participation levels. Callers trying to access such a system while the queue is full will not be counted in measures monitoring call center usage. 3. Terminology Differences A lack of standardized terminology limits cross-state performance comparisons across all initiatives. For example, many states measure call duration as the total number of minutes a worker spends on the phone with the caller, but another state includes the time a worker spends working on the case after the caller hangs up. Another state, which has multiple call centers working independently, calculates the measure of average calls handled differently across call centers. In yet another variation, one state excludes hang-ups and wrong numbers from its calculation altogether, while other states count them as handled calls. 4. Varying Measurement Motivations Although some states may calculate the same performance measures and standards, their motivations for doing so may vary. A performance measure designed to meet a legislative mandate in one state could be calculated differently from one used primarily for staffing purposes, and any performance standards associated with those measures likely will differ as well. For example, a state interested in ensuring that all calls are being answered may calculate the percentage of total calls handled by counting all calls that come into the call center, while a state interested in monitoring individual staff performance may include only calls that are not abandoned. This is not problematic in and of itself but can complicate comparisons of multiple states because motivations can affect how a state office prioritizes and uses its measures. B. Data Limitations While contextual limitations impact cross-state analysis of measures, the data used to calculate the measures also pose limits to performance evaluations and can jeopardize interpretations of individual measures. Performance measures are subject to three main types of data limitations: (1) accuracy, meaning whether data are entered and measures are calculated correctly; (2) validity, or whether states actually measure what they intend to measure; and (3) reliability, defined as the consistency in the calculation of performance measures over time and across sites. Limitations to the accuracy, validity, or reliability of measures hinder cross-state comparability and performance analyses. Limitations to Use of Measures and Standards Mathematica Policy Research 42 1. Accuracy When states use data to calculate performance measures, how they enter the data impacts the quality of the measure. Procedures to ensure that data are entered correctly also influence the measures’ dependability. Data entered automatically likely have fewer errors and less subjectivity (assuming the systems automatically generating those data were programmed correctly). Overall, state and local offices often reported using automatic data entry performance measures, leading to a higher degree of accuracy. However, this more often tends to be true at the state than the local level, where staff typically have less control over generating reports. 2. Validity Validity refers to whether or not states actually are measuring what they intend to measure, or if their measure includes data they do not intend to capture. Numerous respondents indicated in the survey that they had validity concerns about their measures, although few specified the reason for their concern, and it would have been too burdensome to request this information from each respondent. 3. Reliability Data reliability addresses the consistency of how measures are calculated over time and across localities or states. To be reliable, a measure must not have changed recently\u2014either in how it is defined or calculated. Such changes are not inherently bad but may indicate that a measure was not calculated optimally prior to the change, which thus impairs comparability over time. Changes to software or computer systems or purchases of new systems can bring about new calculations. Other changes occur because of alterations in business practices\u2014for example, staff reductions have led to some states reducing their call center queue capacity. In addition, a measure’s definition must reflect the same concept, regardless of where it is being collected. For example, a call center in one state or locality might assume that people hanging up within 15 seconds have dialed the wrong number and so not count them as having abandoned the call. Another center in a different state using a different definition would not count a call unless it stays in the system for at least 60 seconds. For this reason, the measure must allow for a concise definition and calculation that can be compared across sites. 43 V. OPPORTUNITIES AND CHALLENGES FOR UNIFORMLY MEASURING INITIATIVES FNS currently focuses its assessment of states’ SNAP activities through measures of timeliness, accuracy, and participation. It requires states to meet a set percentage of applications processed within a 30-day period and maintain high levels of accuracy in eligibility and benefit determination in relation to other states. It also measures the percentage of low-income individuals participating in SNAP in each state. In 2003, FNS began to provide financial incentives to states that achieved high performance in these areas relative to other states. For those not achieving such high performance, FNS has imposed penalties and\/or facilitated communication across the states so that those performing at a high level can share best practices and lessons learned with those performing at a lower level. The timeliness, accuracy, and participation measures assess total program outcomes\u2014they do not focus directly on how well individual initiatives are working in aid of or against the outcomes. The mix of initiatives, as well as how a particular state uses that mix, allows for different levels of performance on individual initiatives and similar results on overall program outcomes. For example, a state could achieve high levels of accuracy and also process nearly all its applications within 30 days, yet not image documents until a week after receipt or keep clients on hold for 30 minutes or more. In this situation, individual initiatives are working at subpar levels, but the efficiencies and services offered through other initiatives and processes compensate. Poor performance in some initiatives may not show up in the overarching measures unless the performance becomes so deficient that other activities no longer are able to offset them. On the other hand, a state’s modernization initiatives all could be working at a desirable level of performance yet not result in desirable program outcome measures. In other words, a state could have online applications that could be seamlessly entered into the eligibility system, all client documents imaged and attached to the case within a day, and all calls to the call center answered within a few minutes, yet not meet the 30-day timeliness requirement. In this chapter, we explore defining a compact set of measures for each initiative that states or FNS could use to assess their initiatives individually. Such a set of measures could be useful under a variety of circumstances: States not meeting timeliness, accuracy, and participation measures. If states are having difficulty in meeting the overarching outcome measures, they or FNS may want to assess their performance at the initiative level. States implementing a major change to their SNAP administration. When states first launch one or more initiatives, having a set of measures with which to assess the performance could help them identify and resolve problems quickly. In fact, FNS recently proposed a rule related to major changes in SNAP procedures that requires states to provide descriptive information regarding the major change together with an analysis of its projected impacts on program operations (Federal Register, v76, no 85, Tuesday, May 3, 2011, p. 24823). As part of the rule change, FNS may require the states to measure and report on specific aspects of a change. Once an initiative’s success is demonstrated, measurement could cease. Uniformly Measuring Initiatives Mathematica Policy Research 44 General requirements. FNS could require that all states implementing an initiative meet a basic set of standards, so that performance across states could be compared more easily. However, imposing a set of standards for each initiative has both limitations and dangers. If FNS were to set requirements for specific initiatives, states would do their best to comply so as not to face penalties. If financial incentives were included for high performance, states would work hard to receive the incentive. Also, they might improve performance on the individual initiatives in general, yet not improve access, accuracy, efficiency, or customer service. Examples of limitations and dangers inherent in setting standards for each initiative include the following: State administrative procedures are very different, resulting in substantially diverse performance expectations for individual initiatives across states. For example, the functionality of some initiatives varies across states: call centers simply may direct a person to the appropriate agent or may be able to immediately address a variety of customer questions. Even though a set of measures could be applied differently based on functionality, a state able to address a wide range of questions through automated responses will achieve a different level of performance on measures such as the average call duration or average waiting time to speak to an agent than an automated response unit providing limited information, such as office hours or assistance in locating the nearest office. States have different combinations of initiatives, which can affect performance on individual initiatives. A state that has both a call center and an online system to handle account inquiries, for example, will have different call center and online account usage than a state that has only one of these. This can affect wait time for the call center and lower the likelihood of abandoned calls or callers receiving a busy signal. States have limited additional resources for modernization. If states are required to build measures into their systems retroactively, they may need to expend resources to improve existing procedures or develop new initiatives. Building measurement into a new initiative could be expensive enough to prevent a state from implementing it. For example, some states conduct much of their document imaging manually and across numerous offices. For these states, tracking the number of documents scanned and the timeframe in which they were imaged could require a process that takes more time than the imaging itself. Requiring a certain level of performance could reduce creative approaches and access. In partnering with community-based organizations, for example, requiring a certain level of performance from partners could be counterproductive. If partners must meet a certain quota for application submissions, they may submit applications for individuals they really do not expect to be eligible. This would help them to reach their quota but create unnecessary work for the state’s eligibility workers. If partners must maintain a certain approval percentage for their submitted applications, they may limit the applications they submit only to those individuals of whose eligibility they are confident, denying assistance to those on the border of eligibility. Similarly, a state may try to increase the percentage of calls handled by the automated response unit and reduce the percentage needing to be transferred to agents. Navigating through the menus needed to achieve these results could become so difficult that calls stop coming into the system. Uniformly Measuring Initiatives Mathematica Policy Research 45 Several initiatives are not limited to SNAP. Call centers and online systems, for example, usually are set up for all programs administered by an agency; these generally include both medical assistance and cash welfare, but vary by state. The use of call centers and online systems, expected duration of calls, and number of available staff all will vary for these different programs. Based on our discussions with FNS and state, local, and community partner staff, we make the following recommendations for FNS and states when launching new initiatives: Performance of initiatives should be measured\u2014states acknowledge that where measurement occurs, performance improves. Performance measurement should be built into the initiative during the design stage. States should have an expected level of performance (standard) for each measure. The performance measures and standards should be tied to improving overall program outcomes. However, because of the limitations described above and in Chapter IV, and because the exploratory nature of this study did not allow us to develop a detailed understanding of every measure in every state, we are not recommending a set of performance measures for each initiative for use across all states in all situations. Instead, we present below a selected set of measures that appears useful within a broad range of state operational contexts. States implementing new initiatives could review this list for suggested measures. Although we hope most of these measures will be appropriate for the states, some may not fit within the context of a state, while others may be a close fit, but need slight modification. States will need to make these decisions based on their specific goals for implementation, the functionality of their initiative, other initiatives already in place, the unique features the initiative may entail, and the integration of SNAP with other assistance programs. Before presenting the measures for each initiative, we describe the criteria we used in their selection. After discussing the measures, we discuss several advantages and limitations. A. Criteria for Inclusion in the Proposed Set of Measures We considered a variety of criteria in selecting measures. We sought measures that are both in line with FNS’ four goals for modernization and can be measured reliably and without placing excessive burdens on states. In general, we preferred to choose measures that at least some states, and ideally many, already have in place. In some cases, however, we suggest measures that states are not collecting but appear feasible based on what we know about their existing measures. 1. Addressing Goals for Modernization As discussed in Chapter I, FNS has delineated four goals for modernization: accuracy and integrity, efficiency, customer service, and program access. Many modernization initiatives achieve several of the goals. All measures in our set, either by themselves or in combination with others, also address at least one of these goals. Uniformly Measuring Initiatives Mathematica Policy Research 46 Ideally, the set of measures for each initiative will fully address the goals achieved by the modernization initiative. In other words, if an initiative relates to three of FNS’s goals, then the full set of measures calculated also should cover each of these three goals. 2. Feasibility as a Reporting Requirement The measures must be applicable across a range of functionalities and not impose an unnecessary burden on states. To ensure this, we assessed each measure based on the following dimensions: Validity and Reliability: Is a measure an accurate reflection of performance toward a goal? Are the required data available? Can it be measured similarly across states? Can it be measured consistently over time? Efficiency: Is it reasonable to ask the state to collect the information? How much effort will it take? Is it an automated process or something the state would track manually? To identify our suggested set of measures, for each initiative we reviewed the full set of measures the states used, their frequency, the purposes states had for collecting them, states’ sense of their accuracy, and the ability of all states to collect them. B. Proposed Set of Measures For each initiative, we provide the name of the measure, along with a very specific definition, a rationale, and its limitations. At times, we suggest measures not currently collected by states, although these usually are minor modifications to measures they already do collect. For this reason, where possible, we indicate the number of states currently collecting the measure. The definition we provide for the measure may not match exactly what some states are reporting\u2014because of slight differences in how states define measures, we chose the measure we thought most appropriate for a broad range of states. 1. Application Tracking In Chapter III, we talked about measures in relation to the SNAP life cycle. One key aspect is the application process. Without making it through the process, applicants will not become participants. It thus is important to have some sense of the stage at which applicants may fall out of the process. Because this process crosses many of the initiatives, we look separately at broad measures for tracking applications. For application tracking, we sought measures to address the following questions: By what mode do applicants submit applications (mail, in-person, online, through a partner)? Do approval and denial rates vary by the application mode? How do the application modes and approval and denial rates vary by characteristics of the applicants? In Table V.1, we present our suggested measures for application tracking. States that collect these measures often do so on a monthly basis. Uniformly Measuring Initiatives Mathematica Policy Research 47 The set of ten measures simply addresses the first two questions above\u2014helping states understand the usage of the various application portals and identify any consistent differences in approval and denial rates. We recognize that the third question, related to understanding whether certain individuals have a more difficult time with the process than others, is vital to improving the application process. However, even some of the states with the most advanced computer systems and reporting ability cannot track applications at this level of detail. At this time, to suggest that states collect such measures would impose a substantial burden on them. Table V.1. Recommended Application Tracking Measures Measure Name Definition Rationale Comments Number of States Collecting Measurea Percent of Applications Submitted by Source Number of applications submitted through each mode (mail\/fax, in-person, online\/kiosk, call center, through a partner), divided by total number of applications. (Maximum of five measures, depending on activities in a state.) Helps the state to track the means by which applicants are applying. Even states that can track whether an application was submitted online often cannot track when it was delivered by mail separately from those dropped off at the office. These two may need to be combined. Mail: 10 Fax: 7 Paper: 14 Online: 13 Kiosk: 2 Call center: 4 Community Partner: 8 Percent of Applications from Each Source that Are Approved Number of applications submitted through each mode and subsequently approved, divided by number of applications submitted by mode. (Maximum of five measures, depending on activities in a state.) Helps the state to understand whether one mode of application tends to be used by more people who are not eligible or do not complete the process. Excludes from both the numerator and denominator the number of applications in process during the period data are collected. Mail: 9 Fax: 0 Paper: 14 Online: 8 Kiosk: 1 Call Center: 3 Community Partner: 10 a Counts are based on responses from the 45 states that participated in the study. 2. Call Centers Because the functionality of the 28 states’ call centers in the 45 responding states varies substantially, the data available and the appropriateness of each measure also vary. Some call centers are as basic as a shared phone line that rings at multiple desks. Other initiatives use software that queues calls and assigns them to agents not currently on a call. Some are solely voice response systems, while others pair automated voice responses with a function that routes harder questions to available agents. The technology supporting the phone system, purpose of the call center, and division of functions between call agents and an automated system all influence decisions about what to measure and, when measures are the same, what outcomes the state can strive to achieve. For the proposed set of measures, we sought to answer the following three questions: How busy is the call center? Is the call center able to handle the volume? How long do clients wait for service? Uniformly Measuring Initiatives Mathematica Policy Research 48 Table V.2 provides our suggested set of measures. States may prefer to collect these at least on a daily basis. Table V.2. Recommended Call Center Measures Measure Name Definition Rationale Comments Number of States Collecting Measurea Calls Received per Active Case Number of calls, divided by number of active cases. Demonstrates volume of calls in relation to caseload size, making the measure more comparable across states and regions. Include in the numerator and denominator only the cases in the area covered by the call center. States with online account access may have much lower call volume; states with more functionality may have higher call volume. High numbers of calls from nonparticipants would not be reflected in the denominator. Average Number of Calls per Case: 2 Number of calls received: 19 Average Number of Calls Handled per Agent Number of calls handled by agents, divided by number of agents. Demonstrates load on individual agent Need to set standards based on functionality of systems\u2014those with automated systems likely will see lengthier calls and thus have a lower expectation for number of calls possible per agent. Number of Calls Answered\/ Handled: 21 Percent of Calls Abandoned Number of calls abandoned before reaching automated system or agent. Potentially demonstrates dissatisfaction of callers with amount of time required to wait for service. If recorded information is played during hold time, it may answer the caller’s question and not truly be an abandoned call, even though it would be recorded as such. 22 Average Time to Answer by Automated Response Unit Total time callers wait to access automated system, divided by total number of calls into system. Potentially demonstrates dissatisfaction of callers with amount of time required to wait for service. Will not apply to call centers with no automated response unit. Average Answer Speed (not restricted to calls being answered by automated unit): 17 Average Waiting Time to Speak to Agent Total time callers wait before talking to an agent, divided by total number of calls into system. Potentially demonstrates dissatisfaction of callers with amount of time required to wait for service. Should not include time spent being directed by automated unit; clock should not stop if an agent answers only to place caller on hold. 17 a Counts are based on responses from the 45 states that participated in the study. Uniformly Measuring Initiatives Mathematica Policy Research 49 Most states with call centers collect either these measures or some closely resembling them. For example, many states collect information about the number of calls they receive. By dividing the number of calls received by the size of the caseload covered by the call center, states will have a sense of whether the call volume is larger than expected based on its functionality. A call center that routes calls to agents would not expect to see more calls per case than caseworkers expected to receive for their cases before the call center was implemented. A higher average load could indicate that inefficiencies in the design of the call center exist. States also often collect the number of calls queued. By relating this figure to the number of agents taking calls, the state can learn whether the number of calls queued is too high and possibly make more staff available to take calls. Most states with call centers also collect the remaining three measures defined here. These provide an indirect measure of client satisfaction\u2014whether clients hang up often and whether client wait times are seen as appropriate for the types of calls the call center generally handles. Wait times are especially important to callers using cell phones, who must pay for each minute they remain on the phone even if they are receiving no services. Not all states’ call centers should be subject to these measures. For example, a call center used solely to make outgoing calls for interviews would not experience callers abandoning their calls or waiting in queues. Also, these measures do not address the accuracy of the data provided by the call center, nor do they directly address customer satisfaction. The automated responses may provide wrong or outdated information (related to office hours or office closings, for example). Agents may act rudely or not answer the callers’ questions properly. Measuring this level of customer service generally requires developing a survey for callers, which can be cost prohibitive for the states. In effect, the states would have to develop a new initiative to measure the success of the call center. 3. Online Systems Online systems are common among states, with 33 of the 45 responding states providing the opportunity for applicants at least to fill out an application online, and some allowing them to submit the application over the Internet. Additional capabilities include online accounts that individuals can use to check the status of their application or access benefit information and systems that can accept changes to the income, expenses, or household composition reported by participants. For the proposed set of measures, we sought to answer the following questions: How often is the online system used for submitting applications? For accessing account information? For submitting changes? Are online application submissions of comparable quality to paper submissions? Are customers using the online system satisfied with access and ease of use? Table V.3 provides our suggested set of measures. It may be sufficient to calculate these measures on a monthly basis, but some may prefer a shorter time period. About half of the states with online applications track the percentage of all applications submitted online. Few states track measures associated with their online accounts. For online Uniformly Measuring Initiatives Mathematica Policy Research 50 Table V.3. Recommended Online System Measures Measure Name Definition Rationale Comments Number of States Collecting Measurea Percent of Applications Received Online Number of applications submitted online, divided by the total number of applications received. Demonstrates use of online system in relation to other modes of application. States may differ in how they count unsigned applications that must be printed and sent to the applicant for approval because an unsigned application does not constitute a completed application. 15 Percent of SNAP Caseload with an Online Account Number of active SNAP accounts, divided by size of SNAP caseload. Demonstrates use of system by entire caseload. Defining active as accounts associated with ongoing cases. 0 Average Number of Logins per Account Number of logins, divided by number of active accounts. Demonstrates use of system by those who have accounts. Defining active as accounts associated with ongoing cases. Number of log-ins: 4 Average Number of Changes Submitted per Account Number of changes submitted, divided by number of active accounts. Potentially demonstrates that system is difficult to use or not meeting clients’ needs. Defining active as accounts associated with ongoing cases. Number of changes submitted: 8 a Counts are based on responses from the 45 states that participated in the study. accounts, we suggest tracking the usage by looking at the percentage of participating households that have online accounts and the average number of logins the account holders make each month. We also suggest tracking the use of change reporting when that is available through the online system. If only a small percentage of its caseload is establishing accounts, a state may want to review the procedures for creating accounts. If usage remains low once accounts are established, it may be that the system is too difficult to use or does not have capabilities important to the users. As with the call center measures, the suggested measures for online systems do not address accuracy or customer service. Online applications may be more prone to error simply because the ease of submission may allow people to work faster and forget to report some income or expenses. Online systems also may process changes incorrectly or users may be more prone to enter information incorrectly if they do not understand how the system works. Customer service can be tracked through these measures only indirectly. Given the wide general use of online technologies, lack of client use likely indicates dissatisfaction with the system for one or more reasons. Identifying those reasons could require the development of a survey. 4. Document Imaging Document imaging currently is in place in about half of the states (24 of the 45 we interviewed). Nineteen of them did at least some measurement of their system. Several states have large document imaging centers, to which all hard copy documents are sent. Workers load stacks of these papers through large scanners that can scan thousands of documents within seconds. Clerical staff then process the scanned images by identifying the type of document and attaching it to the electronic Uniformly Measuring Initiatives Mathematica Policy Research 51 case file. In other states, clerical staff or case workers scan those documents related to their cases. Some states are moving in the direction of allowing clients to scan their own documents and attach them to their case record. Other systems can automatically process faxes of documents that include a barcode to identify the case to which the document belongs. For the proposed set of measures, we sought to answer the following questions: How quickly are documents imaged? How accurate is the imaging and association with a case file? In Table V.4, we present the proposed set of measures. These measures likely will be useful only for states with document imaging systems or dedicated staff, not for states whose workers image only the documents for their own cases. States with less automated systems would need to track this data manually\u2014a time-consuming effort. Table V.4. Recommended Document Imaging Measures Measure Name Definition Rationale Comments Number of States Collecting Measurea Percent of Documents Scanned within 24 Hours Number of documents successfully scanned within 24 hours of receipt, divided by total number of documents to be scanned received in the same 24-hour period. Demonstrates ability of system to process documents efficiently. All documents should be included\u2014even those that are damaged\u2014to track percent requiring manual scanning. Some states are not attempting to achieve scanning within 24 hours, so a longer timeframe may be preferable for them. 9 Percent of Documents Attached to Case within One Business Day of Being Scanned Number of documents attached to case record by close of business on the business day following imaging of the document, divided by number of documents imaged the previous day. Documents need to be accessible to case workers quickly for the system to work well. They are not accessible until they are attached to the file. Not all documents may have enough information in them to attach to a case immediately. Low attachment rate could reflect errors by the person submitting the document, as well as lack of ability of staff to attach documents to cases. Does not reflect how many documents never get attached to a case. 0 Percent of Orphaned Documents Number of documents scanned exactly four weeks prior but that are still not attached to a case, divided by daily average of scanned documents. Tracks extent to which scanned documents could not be tied to a specific case and thus are unusable for purposes of eligibility determination and\/or recertification. Difficult to set the time period over which to measure\u2014a worker may be able to attach the document days or weeks later if the sender provides information that can assist the worker in identifying the case. 0 a Counts are based on responses from the 45 states that participated in the study. Uniformly Measuring Initiatives Mathematica Policy Research 52 5. Partnering (Application Assistance) Partnering is a very common initiative. States make both formal and informal arrangements with partners and rely on them to conduct a variety of activities, including developing software systems, running call centers, and providing application assistance. In this section, we consider only partners providing application assistance, because the other types of partnerships are usually formal, entailing exhaustive sets of measures, and may be covered by the measures discussed previously for online systems and call centers. Of the 45 responding states, 34 have partners conducting application assistance. In some states, partners are reimbursed for their expenditures or paid by the number of applications submitted, the number of approved applications submitted, or a flat fee. In Table V.5, we present our suggested measures for states partnering with organizations without paid arrangements, under the assumption that those states with paid arrangements already are tracking a sufficient amount of information. For those partners not being paid, we suggest just two measures: the number of partners providing application assistance and the number of applications submitted through the partner. The two are, in fact, examples of aggregate data that can be used to gauge and track partnering activities, rather than performance measures that imply the existence of a desired level of performance. Some states track the number of submissions of online applications that originate at a partner site. This measure is limited because organizations can assist an applicant without using the agency’s dedicated online account number. Table V.5. Recommended Partnering Measures Measure Name Definition Rationale Comments Number of States Collecting Measurea Number of Partners Providing Application Assistance Number of partners who have formally declared they are working with the state, even though there may be no formal agreement on how they conduct this activity or how many people they are trying to serve. Helps the state to track the organizations, eases communication of changes in procedures. Definitions of application assistance may differ across states, making this more of a gauge for internal purposes than for comparison across states. 18 Number of Clients Assisted by Partners Report from partners of number of clients they assisted with the application. Helps the state understand the use of the partners by their residents and how much need there is for providing continued training to partner staff. Not all those receiving assistance ultimately will submit their applications. 9 Note: The two items listed here are both examples of aggregate data, rather than true performance measures. We continue to use the term measure in reference to them for consistency with other initiatives. a Counts are based on responses from the 45 states that participated in the study. Uniformly Measuring Initiatives Mathematica Policy Research 53 6. Waiver of Face-to-Face Interview Almost all states (40 of the 45 we interviewed) provided for a waiver of face-to-face interviews or conducted many interviews over the phone because of hardships faced by the client. Almost two- thirds of them were tracking some information about the waiver’s success, often related to accuracy as stipulated by a given waiver. For the proposed set of measures, we sought to answer the following questions: How prevalent is the use of telephone interviews? At application? At recertification? How accurate is the application or recertification when the interview is conducted by phone, compared to a face-to-face interview? We present our suggested measures in Table V.6, anticipating that most states would collect them monthly. Many states may find it difficult to calculate these measures. Although all case workers indicate whether the interview was conducted by phone or in person in the narrative associated with the case or in a field in an online system, the information is not always retained in the eligibility systems in an easily reportable way. Thus, at present, tracking the percentage of applications and recertifications for which interviews are conducted by phone could require changes to computer systems. Some states began tracking error rates based on the interview type but quickly became satisfied with the accuracy of the phone interview and stopped reviewing the data. Table V.6. Recommended Measures for Waiver of the Face-to-Face Interview Measure Name Definition Rationale Comments Number of States Collecting Measurea Percent of Application Interviews Conducted by Telephone Number of application interviews conducted by telephone, divided by number of application interviews. Demonstrates the use of the waiver at application. Percent of (all) Interviews Conducted by Phone:b 13 Percent of Recertification Interviews Conducted by Telephone Number of recertification interviews conducted by telephone, divided by number of recertification interviews. Demonstrates the use of the waiver at recertification. Percent of (all) Interviews Conducted by Phone:b 13 Error Rate for Cases with Telephone Interviews Number of cases in error that included a telephone interview, divided by number of cases in error. Demonstrates the ability of the eligibility worker and applicant to communicate all necessary information over the phone rather than through an in-person meeting. Error rates generally are calculated through formal quality control reviews, and some states can separate the error rate based on the interview type. For this measure to be accurate and unbiased, it likely would require a change in the QC review process\u2014the sampling would need to account for both types of interviews. 16 a Counts are based on responses from the 45 states that participated in the study. b Measure combines both application and recertification interviews. 55 VI. CONCLUSION A. Summary of Study Findings The primary goal of this study was to identify and describe the range of measures states and local offices are using to measure the performance of their SNAP modernization initiatives. We gathered information from 44 states and the District of Columbia, more than 100 local offices, and more than 50 community and business partners. Because it was the first study of its kind, we aimed to collect basic information about all measures the respondents were collecting and detailed information about select measures. The key findings are as follows: States and local offices are collecting a large number of measures. Across the eight modernization initiatives we examined, states and local offices reported using 89 different performance measures to assess their activities. Standards are less common and benchmarks and incentives are rare. Of these 89 measures, states reported developing performance standards for 39 measures; of those, only a few standards are assigned benchmarks and incentives to gauge their success. So states are setting a desired level of staff achievement for about half of their measures. In a few cases, they also identify a rate or percentage of time within which they can reasonably hope to reach that level; in a few cases, they provide some type of reward if the benchmark is met or a penalty if it is not. Measures are most commonly used for technology-related initiatives. The most common measures are those for call centers and online systems. The technology built into the systems make it easier to collect and report performance measures. Thus, states with more technology-driven initiatives have many more performance measures than states without such initiatives. In most states, staff are driven by federal accuracy and timeliness requirements. States are very focused on meeting FNS requirements for accuracy and timeliness. When necessary, they will allow performance on individual initiatives to fall below ideal levels (such as call center wait time) to focus staff resources on meeting these federal benchmarks. If FNS requires a measure, states will most likely comply. States will divert resources to meet federal requirements. When incentives are available, such as for high accuracy and timeliness rates, they are motivated to outperform other states to receive the incentive. When an initiative is launched, performance measurement can assess whether it is working as designed. In the early stages of implementation, reports can indicate that each piece of the initiative is performing its particular function as planned. Along with providing proof of success to stakeholders, this can help secure funding for continued operations. As initiatives mature, performance measurement allows for monitoring. Once staff are confident that the initiative is working as designed, they can analyze trends and identify potential problems through periodic reviews of reports. However, excessive monitoring can create unnecessary work for staff if they need to perform additional tasks purely for tracking purposes. Conclusion Mathematica Policy Research 56 As a measurement matures, real-time and daily reports help allocate limited staff resources. When initiatives are operating as planned, managers desire improvements in measures that allow them to track operations daily or in real time. Measures calculated at such short intervals can help managers assign staff to the highest priority tasks at each point in time. B. Setting Measurement Requirements: Recommendations and Limitations Measuring the performance of initiatives plays a key role in ensuring their success. When launching an initiative, states already should have considered and built in measures to assess its performance. They should have set some level of expected performance, which should be tied to meeting the overarching goals of providing accurate benefits in a timely fashion. With many states developing and launching broadly similar initiatives, sharing their lessons learned and discussing expectations for performance can help later-adopting states avoid the pitfalls faced by the early adopters. However, each state must operate SNAP within its own unique environment. They differ in the computer capabilities supporting their eligibility systems, assistance programs included in those systems, combinations of modernization initiatives, functionalities of their modernization initiatives, and abilities to calculate measures. Given each state’s unique operational environment, FNS and state staff must be cautious in setting expectations for a modernization initiative based on the performance achieved by other states. In this report, we provide a set of measures that each state could consider in light of their goals, technology, and circumstances for assessing a new initiative’s performance. This set of measures is intended to provide a comprehensive view of the initiative’s performance without being overly burdensome to collect. C. Next Steps In collecting the data for this study, we sought to identify the broad range of measures that states are using in implementing a fairly large set of initiatives. We then sought detailed information on a limited set of measures within each state and local agency. Collecting this level of detail for each measure would have placed an extraordinary burden on most of these organizations. In identifying the measures on which to follow up for additional details, we focused on those measures that states indicated were most important to them. Thus, the measures for which we sought more detail varied accordingly across states and local agencies. Although multiple states and local agencies may have collected a measure with the same name, we do not have the same level of detail on the measures from each of the states collecting it. This approach makes it difficult to identify the precise differences in the definitions and accurately compare results for the measures across states. Differences in results, even in states with the same set of initiatives and functionalities, may be due to the difference in the definition, rather than their performance. Given this basic understanding of the measures that states are collecting for each initiative, follow-up studies could focus on a key set of measures for each. The details could be gathered from each state collecting the measure to identify the differences more precisely and allow for better cross-state comparison (although it still will be limited by the variation in functionalities and accompanying initiatives). 57 REFERENCES Associated Press. U.S. reps to Vilsack: Review Indiana food stamp OK, http:\/\/www.wthr.com\/story\/10972768\/us-reps-to-vilsack-review-indiana-food-stamp- ok?redirected=true (downloaded September 21, 2011). Cody, Scott D., Ren\u00e9e Nogales, and Emily Sama Martin. Modernization of the Food Stamp Program in Florida. Washington, DC: Mathematica Policy Research, February 2008. Johnson, Nicholas, Phil Oliff, and Erica Williams. An Update on State Budget Cuts: At Least 46 States Have Imposed Cuts That Hurt Vulnerable Residents and the Economy. Center on Budget and Policy Priorities, http:\/\/www.cbpp.org\/files\/3-13-08sfp.pdf (downloaded on 5\/13\/11). Keefe, Kathleen, Emily Sama-Miller, Maura Bardos, Laura Castner, Elizabeth Clary, Sarah Wissel, and Larry Vittoriano. Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Individual State Findings. Washington, DC: Mathematica Policy Research, July 2012. Rowe, Gretchen, Sam Hall, Carolyn O’Brien, Nancy Pindus, Robin Koralek. Enhancing Supplemental Nutrition Assistance Program (SNAP) Certification: SNAP Modernization Efforts Interim Report Volume 1. The Urban Institute: Washington, DC, April 2010. 59 GLOSSARY Modernization Initiatives Call Centers: A point of access whereby individuals dial a telephone number to obtain information or some other service, by listening to a recording, talking to a person, and\/or interacting with a computer. Within a state, call centers may operate statewide or regionally, and may place calls, receive calls, or both. Each call center may have a different combination of functions, including: answering basic questions about a program or a specific case, change reporting, screening for potential eligibility, and taking applications. Caseworkers at call centers may also process information they receive including faxes or reported changes. Online Systems: An internet site that an individual may access and interact with in order to submit or receive information about their potential eligibility or existing SNAP case (not a website that only provides general information about a program). Online systems may allow users to screen for potential eligibility, submit applications online, or check the status of\/report changes to an existing case. Some online applications integrate directly with state eligibility determination software, while others are separate tools. In some states, partners (see below) have special levels of access to the online system to enable them to serve the applicants they assist. Document Imaging: A system or a process whereby paper documents are scanned and an electronic version is created and stored for future access. Kiosks: A computer terminal located in the community or an office (but not in a home) where an individual may access one or more functions of an online system. Partnering: Formal relationships or services that the SNAP agency solicits from non- governmental groups. The solicitation may be in the form of a contract, memorandum of understanding, or another type of request. Waiver of Face-to-Face Interview: Formal approval received from FNS to perform interviews by telephone rather than in person and application, recertification, or both. Shortened Interview: Use of an abbreviated interview protocol for certain types of households based on their characteristics. Measurement Terminology Data Element: An instance of an activity or characteristic that is the basis of aggregate data and performance measure calculations. Aggregate Data: Counts of data elements, such as the number of observations. Performance Measure: Calculation used to assess an activity and is typically displayed as percentages and averages. Performance Standards: Include both standards and benchmarks. A standard is the desired outcome of an activity\u2014for example answering a call within three minutes, while a benchmark is the desired rate of success\u2014for example answering at least 80 percent of calls within three minutes. APPENDIX A PERFORMANCE MEASURES AND AGGREGATE DATA Performance Measures and Aggregate Data Mathematica Policy Research A.3 Table A.1. Measures and Aggregate Data for Call Centers Number of States with Call Center: 28 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent Calls Abandoned 22 Average Calls Handled 22 Average Hold Time 21 Average Call Duration 21 Percent of Total Calls Handled 18 Average Waiting Time (to Speak to Agent) 17 Average Answer Speed 17 Average Queue Time 16 Average Staff on Phones 15 Average Time Prior to Abandonment 15 Average After-Call Work Time by Staff 13 Percent of Queued Calls Handled 13 Percent of Calls Completed in the Computer Phone System 12 Percent of Changes Processed 10 Average Time to Process Change 10 Average Time to De-Queue 7 Percent of Calls Requesting Agent 4 Average Number of Calls per Case 2 Percent of Screened Individuals Potentially Eligible: Call Center 1 Percent of Screenings Resulting in Applicant Receiving Benefits: Call Center 1 Percent of Screenings Resulting in Application Submission: Call Center 1 Average Calls by Reason for the Call 1 Average Completion Length 1 Average Customer Satisfaction Rating 1 Average Time to Process Changes and Documents 1 Call Response 1 Percent of Agents Assigned to Phones Available to Take Calls 1 Percent of Calls Busy 1 Percent of Documents Processed within 30 Days 1 Percent of Needs Met through Service Referral or Actions Taken 1 Percent of Voicemail Calls 1 Percentage Answered in Less than Three Minutes 1 Percentage of Calls Within Their Categories of Time Intervals 1 Standard of Promptness for Applications and Recertifications 1 Aggregate Data Number of Calls Abandoned 23 Number of Calls Answered\/Handled 21 Number of Calls (In Flow) 20 Number of Calls Queued 20 Number of Calls Received 19 Number of Agents Assigned to Phones 17 Number of Changes Received 14 Number of Changes Processed 13 Performance Measures and Aggregate Data Mathematica Policy Research Table A.1 (continued) A.4 Number of Calls Receiving Busy Signal\/Unable to Connect with Phone System 12 Number of Hang-ups 10 Number of Calls Transferred to Agent 10 Number of Calls Completed in Computer Phone System 9 Number of Clients Accessing Computer Phone System Data 8 Number of Calls Not Completed in Computer Phone System 6 Number of Applications Processed: Call Center 6 Number of Cases Pending Benefit Decision: Call Center 5 Number of Client Calls Returned 4 Maximum Time to Abandon 1 Maximum Time to Answer 1 Number of Calls Answered in English (In Service Area) 1 Number of Calls Answered in English (Outside Service Area) 1 Number of Calls Answered in English (Total) 1 Number of Calls Offered 1 Number of Clients Reporting Case Change 1 Number of Clients Reporting Verifications Turned In 1 Number pf Clients Requesting Case Status 1 Number of LEP (Language) Calls 1 Number of Referrals Made 1 Number of Transactions 1 Number of Trips Scheduled 1 Total Calls Receiving a Queue Full Message 1 Total Number of Calls Unanswered 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.5 Table A.2. Measures and Aggregate Data for Online Systems Number of States with Online System: 33 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Applications Received 15 Average Number Submitted per Month 12 Average Number of Screenings Completed: Online 9 Average Number of Screenings Started: Online 8 Average Number Started per Month 8 Average Number of Changes Submitted per Month 7 Percent of Users Selecting Spanish Language 6 Percent of Screened Individuals Potentially Eligible: Online 6 Average Level of Benefits 6 Average Number of Accounts Created per Month 6 Percent of Applicants Who Received Help to Apply Online 5 Percent of Screenings Resulting in Application Submission: Online 4 Percent of Applicants with Hardship Reason for Requesting Phone Interviews 4 Average Number of Log-ins per Month 3 Percent Reporting Easy Experience to Complete Application 2 Percent Who Would Use Again 2 Percent of Multiple Applications 2 Average Time to Complete Screening 1 Percent of Screenings Resulting in Applicant Receiving Benefits: Online 1 Average Number of Online Applications 1 Average Time to Complete Online Application 1 Average Time to Complete Online Screening 1 Percent of applications received outside business hours 1 Percent of applications started online that were submitted 1 Percent of First-Time Applications Approved 1 Percent of First-Time Applications Denied 1 Percent of Multiple Applications: Online 1 Aggregate Data Number of Online Screenings Completed: Online 13 Number of Applications Started 12 Number of Online Screenings Started: Online 9 Number of Changes Submitted 8 Number of Abandoned Applications 7 Number of Online Accounts Created 7 Number of Applicants who Received Help to Apply Online 6 Number of Log-ins 4 Number of Applications Downloaded 3 Number of One-page\/Requests for Assistance Submitted 3 Number of First-Time Applications Approved 3 Number of Clients Requesting Help to Apply Online 3 Number of Applications Submitted With All Application Questions Answered 3 Performance Measures and Aggregate Data Mathematica Policy Research Table A.2 (continued) A.6 Number of Applicants who did not Receive Help to Apply Online 3 Number of Changes Started 3 Number of Online Applications Submitted 3 Total Number of Applications Submitted per Month 2 Number of First-Time Applications Denied 2 Number of Applications Submitted 2 How Long Users Spent on Each Page of the Online Application 1 Number of Accounts Created 1 Number of Applicants Screened as Potentially Eligible 1 Number of Applications in Progress 1 Number of Applications Received 1 Number of Applications Submitted and Transferred 1 Number of Applications Submitted for Each Type of Program 1 Number of Multiple Applications 1 Number of One-Page Requests for Assistance Submitted 1 Number of Online Applications Submitted per Month 1 Number of Online Instant Messaging\/Chats 1 Number of Referrals From 311 Online 1 Number of Users Accessing a Specific Page 1 Number Submitted per Day 1 Percent Completed After Hours 1 Total Number of Website Hits per Month 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.7 Table A.3. Measures and Aggregate Data for Document Imaging Number of States with Document Imaging: 24 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Documents Scanned 9 Average Processing Time 9 Percent of Documents Received by Fax 5 Percent of Documents Received by Mail 4 Percent of Documents Imaged by Next Business Day 1 Percent of Documents Imaged Same-Day 1 Percent of Documents Scanned within Standard of Promptness 1 Ratio of Staff to Documents Scanned 1 Aggregate Data Number of Documents Scanned 18 Number of Documents Received 12 Number of Documents Processed 11 Number of Tasks Completed 11 Number of Documents Received: Mail 7 Number of Documents Received: Other Electronic 6 Number of Alerts Processed 6 Number of Documents Received: Fax 5 Amount of days in queue to be indexed 1 Number Indexed for a Document Type 1 number of barcode errors 1 Number of documents attached 1 Number of documents in Error Queue 1 Number of documents pending indexing 1 Number of Documents Per Case 1 Number of documents scanned but not attached 1 Number of Documents Tagged to a Case 1 Number of Queues with Over 1,000 Documents 1 Number of staff assigned to scanning 1 Percent of documents attached in a timely manner 1 Time Between Scanning and Indexing 1 Time Between Scanning and Tagging 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.8 Table A.4. Measures and Aggregate Data for Kiosks Number of States with Kiosks: 14 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Screenings Resulting in Application Submission: Kiosk 1 Aggregate Data Number of Uses to Submit Changes 3 Number of Uses to Access Online Account 2 Number of Screenings Completed: Kiosk 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.9 Table A.5. Measures and Aggregate Data for Partnering Number of States with Partners: 34 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Partners Providing Application Assistance 10 Average Cost of Partner Arrangement 5 Percent of Partners Providing Access to Terminals\/Kiosks 2 Aggregate Data Number of Partners 20 Number Providing Application Assistance 18 Number Accepting Applications 17 Number of Applications Received per Partner 15 Number Clients Assisted per Partner 9 Number with Terminals\/Kiosks to Submit Application 7 Number of Clients Assisted 2 Number of Applications Completed 1 Number of Applications Submitted per Month 1 Number of Clients Educated 1 Number of Clients served 1 Number of Days Applications are Pending 1 Number of Outreach Events 1 Number of Screenings per Partner 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.10 Table A.6. Measures and Aggregate Data for Waiver of Face-to-Face Interview Number of States with Waiver of Face-to-Face Interview: 40 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Error Rate for Cases with Telephone Interviews 16 Error Rate for Cases with Face to Face Interviews 14 Percent of Interviews Conducted by Telephone 13 Percent of Interviews Conducted Face to Face 13 Percent that are Missed and have Notice Mailed 11 Percent of Telephone Interview Requests Honored 5 Average Length of Interview 2 Average Total Interviews Per Worker 1 Percent of Closures Related to Telephone Interview 1 Percent of Interviews Conducted by Telephone for Redeterminations 1 Percent of Interviews that are automated 1 Percentage of Interviews Conducted by Phone without Documented Hardship Reason 1 Aggregate Data Total Number of Interviews 20 Number of Redetermination Interviews 19 Number of Face To Face Interviews 13 Number of Telephone Interviews 13 Number of Applicants Requesting a Phone Interview 12 Number of Missed Interviews 11 Notice of Missed Interview Mailed 11 Number of Applicants Requesting an In-Person Interview 8 Number of Home Visit Interviews 6 Number of Applicants who Did Not Answer to Type of Interview Requested 4 Number of Times Unable to Schedule Interview with Applicant 3 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.11 Table A.7. Measures and Aggregate Data for Shortened Interview Number of States with Waiver of Shortened Interview: 12 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Clients Electing Shortened Interview 2 Percent of Total Interviews that Are Shortened 2 Aggregate Data Number of Shortened Interviews 3 Number of Clients with Shortened Interviews 1 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.12 Table A.8. Measures and Aggregate Data for Complete Expedited Applications Online Number of States with Ability to Complete Expedited Applications Online: 20 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent of Applications Approved: Online All 10 Percent of Applications Approved: Online Expedited 9 Aggregate Data Number of Expedited Applications Received Online 9 Number of Applications Approved: Online Expedited 9 Number of Applications Approved: Online All 5 Note: Counts are based on responses from the 45 states that participated in the study. Performance Measures and Aggregate Data Mathematica Policy Research A.13 Table A.9. Measures and Aggregate Data for Application Tracking Number of States with Application Tracking: 45 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Performance Measures Percent Agency Caused Errors 41 Percent Client Caused Errors 41 Percent Errors with Reported Information Disregarded 40 Percent Errors where Information was Incorrect 40 Percent Errors where Policy was Incorrectly Applied 39 Percent Errors where Staff Failed to Follow-up on Inconsistent Data 39 Percent Errors where Information was Not Reported 39 Percent All Other Errors 38 Error Rate by Source 36 Percent of Total Applications Approved 33 Average Benefit Amount (for those eligible) 29 Percent of Complete Applications Denied 28 Percent of Total Recertifications Approved 28 Average Processing Time of Application Decision 27 Percent of Applicants that Appear Eligible for Expedited Benefits 21 Percent of Complete Recertifications Denied 20 Percent of Initial Applications Denied 19 Average Processing Time of Recertification Decision 19 Percent of Recertifications Denied 18 Percent of Applications Approved After Paper Submission to Local Office 14 Percent of Applications Not Completed 14 Percent of Applications: Paper Submission to Local Office 14 Percent of Recertifications Approved After Paper Submission to Local Office 13 Percent of Applications: Online 13 Percent of Recertifications: Paper Submission to Local Office 12 Percent of Community Partner Applications Approved 10 Percent of Mailed Recertifications Approved 10 Percent of Applications: Mailed 10 Percent of Mailed Applications Approved 9 Percent of Online Applications Approved 8 Percent of Applications: Community Partner 8 Percent of Applications with Incomplete Information 8 Percent of Applications: Faxed 7 Percent of Recertifications: Mailed 7 Percent of Online Recertifications Denied for Failure to Submit Documentation 6 Percent of One-page\/Requests for Assistance Denied 6 Percent of Recertifications with Incomplete Information 6 Percent of Community Partner Recertifications Approved 5 Percent of Recertifications: Online 5 Percent of Recertifications: Faxed 5 Percent of Online Applications Denied for Failure to Submit Documentation 5 Performance Measures and Aggregate Data Mathematica Policy Research Table A.9 (continued) A.14 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Percent of Applications: Call Center 4 Percent of Online Applications Denied for Failure to Complete Interview 4 Percent of Online Recertifications Approved 3 Percent of Call Center Applications Approved 3 Percent of Call Center Recertifications Approved 3 Percent of Recertifications: Community Partner 3 Percent of Recertifications: Call Center 3 Timeliness Rate 3 Percent of Applications: Kiosk 2 Average Timeliness Rate: Approvals 2 Average Timeliness Rate: Recertifications 2 Payment Accuracy Rate 2 Percent of Applications Approved Timely 2 Percent of Kiosk Applications Approved 1 Percent of Online Recertifications Denied for Failure to Complete Interview 1 Case Error Rate 1 Negative Error Rates by County 1 Percent of Accurate Cases 1 Percent of Cases Reviewed that Are Accurate 1 Percent of Negative Errors 1 QA Requirements Associated to Denial Decisions 1 QC \/ Case Review Timeliness Measure 1 QC Error Rate 1 QC Timeliness Measures 1 Timeliness Portion Of Case Review and QC Process 1 Percent of Applications Denied 1 Percent of Applications Pending 1 Percent Change in Applications Received by County 1 Percent of Applications Received Online 1 Percent of Applications: Expedited 1 Percent of Applications: In-Office 1 Percent of Total Recertifications Completed 1 Application Currency 1 Application Processing Time for Approvals for Initial Applications 1 Average Days to Process Approved Applications 1 Average Processing Time of Approvals (Application And Recertifications Combined) 1 Claims Processing Currency 1 Expedited Currency 1 Expedited Standard of Promptness Rate (County\/Worker Only) 1 Percent of Applications Processed Timely 1 Percent of Approved Applications Processed within 7, 15, 30, And 45 Days 1 Percent of Documents Processed Within 30 Days 1 Percent of Recertifications Approved Timely 1 Percent of Unexcused Applications Overdue at End of Month 1 Performance Measures and Aggregate Data Mathematica Policy Research Table A.9 (continued) A.15 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Unexpedited Standard of Promptness Rate (County\/Worker Only) 1 Aggregate Data Number of Agency Caused Errors 40 Number of Errors where Policy was Incorrectly Applied 39 Number of Errors with Reported Information Disregarded 39 Number of Client Caused Errors 37 Number of Errors where Information was Incorrect 36 Number of Errors where Information was Not Reported 36 Number of Errors where Staff Failed to Follow-up on Inconsistent Data 35 Number of All Other Errors 35 Total Number of Applications Completed 30 Total Number of Recertifications Completed 27 Number of Applications: Paper Submission to Local Office 21 Total Number of Applications Started 19 Number of Applications Approved: Paper Submission to Local Office 17 Number of Recertifications Approved: Paper Submission to Local Office 17 Number of Applications: Online 17 Number of Applications Denied: Paper Submissions to Local Office 17 Number of Recertifications Denied: Paper Submissions to Local Office 16 Total Number of Recertifications Started 15 Number of Cases with Complete Verification Submitted 15 Number of Applications Approved: Face to Face Interviewed 14 Number of Recertifications Approved: Face to Face Interviewed 14 Number of Applications Approved: Phone Interviewed 14 Number of Recertifications: Paper Submission to Local Office 14 Number of Recertifications Approved: Phone Interviewed 13 Number of Applications: Mailed 13 Number of Recertifications: Mailed 11 Number of Recertifications Approved: Mailed 10 Number of Applications Approved: Community Partner 9 Number of Applications Approved: Mailed 9 Number of Applications: Community Partner 9 Number of Requests for Assistance\/One-page Applications 9 Number of Applications Denied: Community Partner 9 Number of Applications Approved: Online 7 Number of Recertifications: Online 7 Number of Applications: Faxed 7 Number of Applications Denied: Mailed 7 Number of Recertifications Denied: Mailed 7 Number of Recertifications: Community Partner 6 Number of Applications Denied: Online 6 Number of Recertifications Approved: Community Partner 5 Number of Applications Approved: Faxed 5 Number of Recertifications: Faxed 5 Number of Recertifications Denied: Online 5 Performance Measures and Aggregate Data Mathematica Policy Research Table A.9 (continued) A.16 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Number of Applications Denied: Faxed 5 Number of Recertifications Denied: Faxed 5 Number of Recertifications Approved: Faxed 4 Number of Recertifications Denied: Community Partner 4 Number of Applications Approved: Call Center 3 Number of Recertifications Approved: Call Center 3 Number of Applications: Kiosk 3 Number of Applications: Call Center 3 Number of Recertifications: Call Center 3 Number of Applications Denied: Call Center 3 Total Number of Applications Approved 3 Total Number of Recertifications Approved 3 Number of Applications Denied 3 Number of Recertifications Approved: Online 2 Number of Recertifications Denied: Call Center 2 Number of Applications Approved 2 Number of Applications Approved: Kiosk 1 Number of Applications Denied: Kiosk 1 Contributing Causes of Errors 1 Number of Applications Approved: Total 1 Number of Expedited Applications Approved 1 Number of Initial Applications Approved Over 30 Days 1 Number of Second Party Reviews 1 Number of Total Applications and Recertifications Approved 1 Denials for Expedited Applications by Reason 1 Number of Applications Denied by Denial Reason 1 Number of Applications Denied: Total 1 Number of Expedited Applications Denied 1 Number of Recertifications Denied 1 Number of SNAP Cases Closed by Closure Reason 1 Total Number of Applications Denied 1 Total Number of Recertifications Denied 1 Number of Applicants that Appear Eligible for Expedited Benefits 1 Number of Applications Not Submitted 1 Number of Applications Submitted Outside Business Hours 1 Number of Applications that Appear Eligible for Expedited Benefits 1 Number of Applications with Incomplete Information 1 Number of Applications Withdrawn by Applicant 1 Number of Applications Withdrawn by System 1 Number of Cases Pending 1 Number of Cases Withdrawn 1 Number of Registered Applications 1 Number of Applications Online 1 Number of Applications Pending Decision 1 Number of Applications Processed: Paper Submission to Local Office 1 Performance Measures and Aggregate Data Mathematica Policy Research Table A.9 (continued) A.17 Name of Performance Measure or Aggregate Data Number of States with Measure or Aggregate Data Number of Applications Received 1 Number of Expedited Applications Pending 1 Number of Pending Applications 1 Number of Recertifications Approved Over 30 Days 1 Number of Recertifications Processed: Paper Submission to Local Office 1 Number of Resurrected Applications 1 Total Calls Busy 1 Total Number of Applications 1 Total Number of Applications To Be Processed 1 Total Number of Recertifications 1 Applications in Intake Mode over 30 days 1 Applications Not Timely 1 Applications Process Time 0-7 Days 1 Applications Process Time 8-29 Days 1 Number of Applicants Pre-Screened, by Worker 1 Number of Applications that Are Not Processed Timely 1 Number of Cases Ready To Go in <25 Days, by Worker 1 Number of Cases Ready To Go in >24 Days\/Resurrected, by Worker 1 Number of Cases Ready To Go, by Worker 1 Number of Days Application Pending 1 Number of Expedited Applications Approved in 5 Days or Less 1 Number of Expedited Applications Approved or Rejected in More than 5 Days 1 Number of Expedited Applications Pended in 5 Days or More 1 Number of Overdue Applications 1 Pending Applications by Days in Process 1 Pending Cases >30 Days, by Worker 1 Processing Time Report 1 Total Number of Pending Cases, by Worker 1 Note: Counts are based on responses from the 45 states that participated in the study. Although all states collect measures for the purposes of quality control, we did not require states to report these measures when they did not do so for purposes outside of the federal requirements. The totals of the quality control-based measures reflect a combination of those who collect them for federal reviews and those who collect them for their own purposes. www.mathematica-mpr.com Improving public well-being by conducting high-quality, objective research and surveys Princeton, NJ \u25a0 Ann Arbor, MI \u25a0 Cambridge, MA \u25a0 Chicago, IL \u25a0 Oakland, CA \u25a0 Washington, DC Mathematica\u00ae is a registered trademark of Mathematica Policy Research SNAPModernization Profiles .pdf Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: State Profiles Report Final Report Acknowledgments Executive Summary Diversity in State Measures Challenges of Comparing Measures Data Collection I. Study Background, objectives, and Analytical Approach A. Overview of Data Collection 1. Preliminary Assessment and Instrument Development 2. Respondent Selection and Data Collection 3. Results of Data Collection Efforts B. Data Analysis Approach 1. Constructing State Profiles 2. Identifying Challenges and Performance Across States II. How are States Performing? A. Observed Results on Measures Across States 1. Call Centers 2. Online Systems 3. Document Imaging 4. Kiosks 5. Partnering 6. Interview Initiatives 7. Application Tracking B. Setting Standards and Benchmarks 1. Preventing Corrective Action 2. Encouraging Staff Productivity 3. Monitoring and Sustaining Performance 4. Responding to Legal Action C. Conclusion III. Limitations to use of measures and standards A. Contextual Limitations 1. Initiative Scope and Features 2. System Limitations 3. Terminology Differences 4. Varying Measurement Motivations B. Data Limitations 1. Accuracy 2. Validity 3. Reliability C. Conclusion References Glossary Modernization Initiatives Measurement Terminology SNAP Modernization .pdf Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report Final Report Performance Measurement for Supplemental Nutrition Assistance Program Modernization Initiatives: Integrated Report Final Report ACKNOWLEDGMENT CONTENTS TABLES executive summary Methods Background Key Study Findings Limitations Setting Measurement Requirements: Recommendations and Limitations I. Introduction A. What Is Modernization? B. Why Modernize? C. What Modernization Initiatives Have States Put in Place? D. Why Is Performance Measurement Important? E. How Are Measures Currently Used for Federal Oversight? F. How Have States Used Performance Measures? 1. Early Stages of Implementation 2. Maintenance Stage of Implementation 3. Real Time \/ Daily Measures \/ 4. Focus on Quality and Timeliness G. How Are Measures Assessed? H. Study Objectives and Research Questions a. Describe Each State’s SNAP Performance Measures and Standards in Detail: b. Provide a Detailed Description of How Performance Measures Are Implemented, What Results Are Observed, and How the Results Are Used in Each State c. Assess the Pros and Cons of Applying Alternative Performance Measures and Standards Across States II. methods 1. Introduction 2. Who We Interviewed 3. What We Learned 4. A Limited Set of Initiatives to Examine 5. Data Collection Instruments 1. Selecting Respondents 2. Responses Received 3. Level of Response III. summary of Performance Measures Across Initiatives A. Purpose of Measures by Modernization Goal B. Key Performance Measures and Gaps, by Initiative 1. Call Center 2. Online System 3. Document Imaging 4. Kiosks 5. Partnering (for Application Assistance) 6. Waiver of Face-to-Face Interview 7. Shortened Interviews 8. Expedited Applications\u2014Submitted Online C. General Gaps in Performance Measurement D. Use of Standards, Benchmarks, and Incentives E. Relationship of Measures to SNAP Lifecycle IV. Limitations to use of measures and standards for cross-state comparisons A. Contextual Limitations 1. Initiative Scope and Features 2. System Limitations 3. Terminology Differences 4. Varying Measurement Motivations B. Data Limitations 1. Accuracy 2. Validity 3. Reliability V. Opportunities and Challenges for Uniformly Measuring initiatives A. Criteria for Inclusion in the Proposed Set of Measures 1. Addressing Goals for Modernization 2. Feasibility as a Reporting Requirement B. Proposed Set of Measures 1. Application Tracking 2. Call Centers 3. Online Systems 4. Document Imaging 5. Partnering (Application Assistance) 6. Waiver of Face-to-Face Interview VI. Conclusion A. Summary of Study Findings B. Setting Measurement Requirements: Recommendations and Limitations C. Next Steps References Glossary Modernization Initiatives Measurement Terminology appendix a Performance Measures and Aggregate Data ”

” Indicators of Welfare Dependence Twelfth Report to Congress U.S. Department of Health and Human Services This report was written and compiled by Gilbert Crouse and Annette Waters of the Office of Human Services Policy, Office of the Assistant Secretary for Planning and Evaluation. For online versions of this report, see http:\/\/aspe.hhs.gov\/hsp\/13\/Indicators\/rpt.cfm Office of Human Services Policy Office of the Assistant Secretary for Planning and Evaluation U.S. Department of Health and Human Services Hubert H. Humphrey Building, Room 404E 200 Independence Ave., S.W. Washington, D.C. 20201 http:\/\/aspe.hhs.gov\/hsp\/13\/Indicators\/rpt.cfm\ufffd i Table of Contents Executive Summary I. Introduction and Overview Organization of Report Measuring Welfare Dependence Measuring Economic Well-Being Data Sources x I-1 I-1 I-2 I-4 I-9 II. Indicators of Dependence Indicator 1. Degree of Dependence Indicator 2. Receipt of Means-Tested Assistance and Labor Force Attachment Indicator 3. Rates of Receipt of Means-Tested Assistance Indicator 4. Rates of Participation in Means-Tested Assistance Programs Indicator 5. Multiple Program Receipt Indicator 6. Dependence Transitions Indicator 7. Program Spell Duration Indicator 8. Welfare Spell Duration with No Labor Force Attachment Indicator 9. Long Term AFDC\/TANF Receipt Indicator 10. Events Associated with the Beginning and Ending of AFDC\/TANF Program Spells II-1 II-3 II-8 II-11 II-17 II-21 II-23 II-25 II-27 II-29 II-31 III. Predictors and Risk Factors Associated with Welfare Receipt Economic Security Risk Factors ECON 1. Poverty Rates ECON 2. Deep Poverty Rates ECON 3. Experimental Poverty Measures ECON 4. Poverty Rates with Various Means-Tested Transfers Counted as Income ECON 5. Poverty Spells ECON 6. Child Support ECON 7. Food Insecurity ECON 8. Lack of Health Insurance III-1 III-3 III-5 III-7 III-9 III-11 III-13 III-15 III-17 Employment and Work-Related Risk Factors WORK 1. Labor Force Attachment WORK 2. Employment among the Low-Skilled WORK 3. Earnings of Low-Skilled Workers WORK 4. Educational Attainment WORK 5. High School Dropout Rates WORK 6. Adult Alcohol and Substance Abuse WORK 7. Adult and Child Disability WORK 8. Labor Force Participation of Women with Children under 18 III-19 III-21 III-23 III-27 III-29 III-31 III-33 III-35 ii Nonmarital Birth Risk Factors BIRTH 1. Nonmarital Births BIRTH 2. Nonmarital Teen Births BIRTH 3. Nonmarital Teen Birth Rates BIRTH 4. Never-Married Family Status III-37 III-39 III-41 III-43 Appendices A. Program Data Aid to Families with Dependent Children (AFDC) and Temporary Assistance for Needy Families (TANF) Supplemental Nutrition Assistance Program Supplemental Security Income (SSI) B. Alternative Definition of Dependence Based on Income from TANF and SNAP A-1 A-1 A-23 A-36 B-1 C. Additional Nonmarital Birth Data D. Technical Notes C-1 D-1 iii List of Figures Chapter I SUM 1. Recipiency and Dependency Rates: 1993-2009 SUM 2. Percentage of Total Population in Poverty with Various Means-Tested Transfers Counted as Income: 1979-2009 SUM 3. Recipiency and Dependency Rates from Two Data Sources: 1987-2009 Chapter II IND 1a. Percentage of Total Income from Means-Tested Assistance Programs: 2009 IND 1b. Percentage of Total Income from Various Sources by Poverty Status: 2009 IND 2. Percentage of Recipients in Families with Labor Force Participants by Program: 2009 IND 3a. Percentage of the Total Population Receiving AFDC\/TANF by Age: 1970-2009 IND 3b. Percentage of the Total Population Receiving SNAP by Age: 1975-2009 IND 3c. Percentage of the Total Population Receiving SSI by Age: 1975-2009 IND 4. Participation Rates in the AFDC\/TANF, SNAP and SSI Programs: Selected Years IND 5. Percentage of Recipients Receiving Assistance from Multiple Programs TANF, SNAP and SSI: 2009 IND 6. Dependency Status in 2007 of Persons Who Received More than 50 Percent of Income from Means-Tested Assistance in 2006 by Race and Ethnicity IND 7. Percentage of TANF, SNAP and SSI Spells for Persons Entering Programs during the 2004-2007 Period by Length of Spell IND 8. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during the 2004-2007 Period by Length of Spell IND 9. Percentage of AFDC\/TANF Recipients by Years of Receipt during the 1999 2008 Period IND 10a. Events Associated with Single Mother TANF Exits during the 2004 2006 Period IND 10b. Events Associated with Single Mother TANF Entries during the 2004 2006 Period Chapter III ECON 1. Percentage of Persons in Poverty by Age: 1959-2009 ECON 2. Percentage of Total Population below 50, 100 and 125 Percent of Poverty Level ECON 3. Percentage of Persons in Poverty Using Various Experimental Poverty Measures by Age: 2008 iv ECON 4. Percentage of Total Population in Poverty with Various Means-Tested Transfers Counted as Income: 1979-2009 ECON 5. Percentage of Poverty Spells for Persons Entering Poverty during the 2004-2007 Period by Length of Spell ECON 6. Percentage of Families Receiving Child Support Collections by Receipt of IV-D Services and Other Public Assistance: 1993-2009 ECON 7. Percentage of Households Classified by Food Security Status: 2009 ECON 8. Percentage of Persons without Health Insurance by Poverty Status: 2009 WORK 1. Percentage of Persons in Families with Labor Force Participants by Race and Ethnicity: 2009 WORK 2. Percentage of Persons Ages 18 to 65 with No More than a High School Education Who Were Employed at Any Time during Year by Race and Ethnicity: 1968-2009 WORK 3. Mean Weekly Wages of Women and Men Working Full-Time, Full-Year with No More than a High School Education by Race and Ethnicity (2009 Dollars): 1980-2009 WORK 4. Percentage of Adults Ages 25 and over by Level of Educational Attainment: 1960-2009 WORK 5. Percentage of Students Enrolled in Grades 10 to 12 in the Previous Year Who Were Not Enrolled and Had Not Graduated in the Survey Year by Race and Ethnicity: 1995-2009 WORK 6. Percentage of Adults Who Used Cocaine or Marijuana or Abused Alcohol by Age: 2009 WORK 7. Percentage of the Non-Elderly Population Reporting an Activity Limitation by Selected Characteristics: 2009 WORK 8. Labor Force Participation of Women with Children under 18: 1975-2009 BIRTH 1. Percentage of Births that are Nonmarital by Age: 1940-2009 BIRTH 2. Percentage of All Births to Unmarried Teens Ages 15 to 19 by Race and Ethnicity: 1940- 2009 BIRTH 3a. Births per 1,000 Unmarried Teens Ages 15 to 17 by Race: 1960-2009 BIRTH 3b. Births per 1,000 Unmarried Teens Ages 18 and 19 by Race: 1960-2009 BIRTH 4. Percentage of All Children Living in Families with a Never-Married Female Head by Race and Ethnicity: 1982-2009 Appendix A TANF 1. AFDC\/TANF Families Receiving Income Assistance TANF 2. Average Monthly AFDC\/TANF Benefit per Recipient in Constant 2009 Dollars SNAP 1. Persons Receiving SNAP: 1962 2009 SSI 1. SSI Recipients by Age: 1974\u22122009 v List of Tables Chapter I SUM 1. Recipiency and Dependency Rates: Selected Years Chapter II IND 1a. Percentage of Total Income from Means-Tested Assistance Programs by Selected Characteristics: 2009 IND 1b. Percentage of Total Income from Means-Tested Assistance Programs: 1993-2009 IND 1c. Percentage of Total Income from Various Sources by Poverty Status and Selected Characteristics: 2009 IND 1d. Percentage of Total Income from Various Sources: Selected Years IND 2a. Percentage of Recipients in Families with Labor Force Participants by Program and Selected Characteristics: 2009 IND 2b. Percentage of AFDC\/TANF Recipients in Families with Labor Force Participants: 1993- 2009 IND 3a. Number and Percentage of the Total Population Receiving AFDC\/TANF by Age: 1970- 2009 IND 3b. Number and Percentage of the Total Population Receiving SNAP by Age: 1975-2009 IND 3c. Number and Percentage of the Total Population Receiving SSI by Age: 1975-2006 IND 4a. Number and Percentage of Eligible Families Participating in the AFDC\/TANF Cash Assistance Program: Selected Years IND 4b. Number and Percentage of Eligible Households Participating in the SNAP: Selected Years IND 4c. Percentage of Eligible Adult Units Participating in the SSI Program by Selected Characteristics: 1993-2009 IND 5a. Percentage of Population Receiving Assistance from Multiple Means-Tested Assistance Programs by Selected Characteristics: 2009 IND 5b. Percentage of Population Receiving Assistance from Multiple Means-Tested Assistance Programs: 1993-2009 IND 6a. Dependency Status in 2003 of Persons Who Received More than 50 Percent of Income from Means-Tested Assistance in 2002 by Selected Characteristics IND 6b. Dependency Status of All Persons Who Received More than 50 Percent of Income from Means-Tested Assistance in Previous Year IND 7a. Percentage of TANF, SNAP and SSI Spells for Persons Entering Programs during the 2001-2003 Period by Length of Spell and Selected Characteristics vi IND 7b. Percentage of AFDC\/TANF, SNAP and SSI Spells for Persons Entering Programs during Selected Periods by Length of Spell IND 8a. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during the 2001-2003 Period by Length of Spell and Selected Characteristics IND 8b. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during Selected Years IND 9. Percentage of AFDC\/TANF Recipients across Three Ten-Year Time Periods by Years of Receipt and Selected Characteristics IND 10a. Percentage of Single Mother AFDC\/TANF Spell Exits Associated with Specific Events: Selected Periods IND 10b. Percentage of Single Mother AFDC\/TANF Spell Entries Associated with Specific Events: Selected Periods Chapter III ECON 1. Percentage of Persons in Poverty by Age and Family Type: Selected Years ECON 2. Number and Percentage of Total Population below 50, 75, 100 and 125 Percent of Poverty Level: Selected Years ECON 3a. Percentage of Persons in Poverty Using Various Experimental Poverty Measures by Selected Characteristics: 2009 ECON 3b. Percentage of Persons in Poverty Using Various Experimental Poverty Measures: 1999- 2009 ECON 4. Percentage of Total Population in Poverty with Various Means-Tested Transfers Counted as Income: Selected Years ECON 5a. Percentage of Poverty Spells for Persons Entering Poverty during the 2004-2007 Period by Length of Spell and Selected Characteristics ECON 5b. Percentage of Poverty Spells for Persons Entering Poverty during Selected Time Periods by Length of Spell ECON 6. Percentage of Families Receiving Child Support Collections by Receipt of IV-D Services and Other Assistance: 1993-2009 ECON 7a. Percentage of Households Classified by Food Security Status and Selected Characteristics: 2009 ECON 7b. Percentage of Households Classified by Food Security Status: 1998-2009 ECON 8. Percentage of Persons without Health Insurance by Poverty Status and Selected Characteristics: 2009 WORK 1a. Percentage of Persons in Families with Labor Force Participants by Selected Characteristics: 2009 vii WORK 1b. Percentage of Persons in Families with Labor Force Participants: Selected Years WORK 2. Percentage of Persons Ages 18 to 65 with No More than a High School Education Who Were Employed by Race and Ethnicity: 1968-2009 WORK 3. Mean Weekly Wages of Women and Men Working Full-Time, Full-Year with No More than a High School Education by Race and Ethnicity (2006 Dollars): 1980-2009 WORK 4. Percentage of Adults Ages 25 and over by Level of Educational Attainment: Selected Years WORK 5. Percentage of Students Enrolled in Grades 10 to 12 in the Previous Year Who Were Not Enrolled and Had Not Graduated in the Survey Year by Race and Ethnicity: 1972-2009 WORK 6. Percentage of Adults Who Used Cocaine or Marijuana or Abused Alcohol by Age: 1999- 2009 WORK 7. Percentage of the Non-Elderly Population Reporting a Disability by Selected Characteristics: 2009 WORK 8. Employment Status of Women with Children under 18 Years of Age: 1975-2009 BIRTH 1. Percentage of Births that are Nonmarital by Age: Selected Years BIRTH 2. Percentage of All Births to Unmarried Teens Ages 15 to 19 by Race and Ethnicity: Selected Years BIRTH 3. Births per Thousand Unmarried Teen Women by Age and Race: 1950-2009 BIRTH 4. Number and Percentage of All Children Living in Families with a Never-Married Female Head by Race and Ethnicity: Selected Years Appendix A TANF 1. Trends in AFDC\/TANF Caseloads: 1962-2009 TANF 2. Number of AFDC\/TANF Recipients, and Recipients as a Percentage of Various Population Groups: 1970\u22122009 TANF 3. TANF and Separate State Program (SSP) Families and Recipients: 2000-2009 TANF 4. Total AFDC\/TANF Expenditures on Cash Benefits and Administration: 1970-2009 TANF 5. Federal and State TANF Program and Other Related Spending: 1997-2009 TANF 6. Trends in AFDC\/TANF Average Monthly Payments: 1962-2009 TANF 7. Characteristics of AFDC\/TANF Families: Selected Years 1969-2009 TANF 8. AFDC\/TANF Benefits by State: Selected Fiscal Years 1978-2009 viii TANF 9. Comparison of Federal Funding for AFDC and Related Programs and 2009 Family Assistance Grants Awarded under PRWORA TANF 10. AFDC\/TANF Caseload by State: October 1989 to March 2009 Peak TANF 11. Average Monthly AFDC\/TANF Recipients by State: Selected Fiscal Years TANF 12. AFDC\/TANF Recipiency Rates for Total Population by State: Selected Fiscal Years TANF 13. Average Number of AFDC\/TANF Child Recipients by State: Selected Fiscal Years TANF 14. AFDC\/TANF Recipiency Rates for Children by State: Selected Fiscal Years 1965-2009 TANF 15. TANF and Separate State Program (SSP) Families and Recipients: 2009 SNAP 1. Trends in SNAP Caseloads: Selected Years 1962-2009 SNAP 2. Trends in SNAP Expenditures: Selected Years 1975-2009 SNAP 3. Characteristics of SNAP Households: Selected Years 1980-2009 SNAP 4. Value of SNAP Issued by State: Selected Fiscal Years 1975-2009 SNAP 5. Average Number of SNAP Recipients by State: Selected Fiscal Years SNAP 6. SNAP Recipiency Rates by State: Selected Fiscal Years SSI 1. Number of Persons Receiving Federally Administered SSI Payments: 1974-2009 SSI 2. SSI Recipiency Rates: 1974-2009 SSI 3. Federally Administered SSI Benefits and Administration: 1974-2009 SSI 4. Average Monthly Federally Administered SSI Benefits: 1975-2009 SSI 5. Number of Persons Receiving Federally Administered SSI Payments by Eligibility Category SSI 6. Characteristics of SSI Recipients by Selected Characteristics: Selected Years 1980-2009 SSI 7. Total Federally Administered SSI Payments by State: Calendar Year 2009 SSI 8. SSI Recipiency Rates by State and Program Type: 1979 and 2009 SSI 9. SSI Recipiency Rates by State: Selected Fiscal Years: 1975-2009 Appendix B B-1. Percentage of the Total Population with More than 50 Percent of Income from Various Means-Tested Assistance Programs by Selected Characteristics: 2009 B-2. Percentage of the Total Population with More than 50 Percent of Income from Various Means-Tested Assistance Programs: 1995-2009 ix Appendix C C-1. Percentage of Births to Unmarried Women within Age Groups by Race and Ethnicity: 1940-2009 C-2. Percentage of Births that are to Unmarried Women by State: Selected Years 1960-2009 C-3. Percentage of Births that are to Unmarried Women by Race and Ethnicity and State: 1994 and 2009 C-4. Birth Rates of Teens 15-19 Years by State: Selected Years 1960-2009 C-5. Birth Rates of Teens 15-19 Years by Race and Ethnicity and State: Selected Years x Executive Summary The Welfare Indicators Act of 1994 requires the Department of Health and Human Services to prepare annual reports to Congress on indicators and predictors of welfare dependence. The twelfth Indicators of Welfare Dependence report provides welfare dependence indicators through 2009 for most indicators, reflecting changes that have taken place since the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) in August 1996. As directed by the Welfare Indicators Act, the report focuses on benefits under the Temporary Assistance for Needy Families (TANF) program, formerly the Aid to Families with Dependent Children (AFDC) program; the Supplemental Nutrition Assistance Program (SNAP, formerly Food Stamps); and the Supplemental Security Income (SSI) program. Welfare dependence, like poverty, is a continuum, with variations in degree and in duration. Families may be more or less dependent if larger or smaller shares of their total resources are derived from welfare programs. The amount of time over which families depend on welfare might also be considered in assessing their degree of dependence. Although recognizing the difficulties inherent in defining and measuring dependence, a bipartisan Advisory Board on Welfare Indicators proposed that: A family is dependent on welfare if more than 50 percent of its total income in a one-year period comes from TANF (formerly AFDC), SNAP (formerly food stamps) and\/or SSI, and this welfare income is not associated with work activities. Given data limitations, we are not able to identify which program benefits may be associated with recipient work activities. Thus, the definition of welfare dependence used in this report may characterize more individuals as welfare dependant than the Board had intended. We follow the Board’s proposal as closely as possible by adopting the following definition of welfare dependence among individuals in families1 Welfare dependence is the proportion of all individuals in families that receive more than half of their total family income in one year from TANF, SNAP and\/or SSI. for use in this report: This report uses data from the Current Population Survey (CPS) and administrative data for the TANF (formerly AFDC), SNAP (formerly Food Stamps) and SSI programs to provide updated measures through 2009 for several dependence indicators. Other measures are based on the Survey of Income and Program Participation (SIPP), the Panel Study of Income Dynamics (PSID) and other data sources. Based on these data, this report provides a number of key indicators of welfare recipiency, dependence and labor force attachment. Highlights from the twelfth report include the following: In 2009, 4.6 percent of the total population received more than half of their total family income from TANF, SNAP and\/or SSI (see Indicator 1). While falling steadily between 1996 2000, the dependency rate increased between 2000 and 2009. The 2009 rate, which coincides with the deepest point of the economic recession, is the highest reported rate since 1996, the year that welfare reform was enacted. SNAP receipt constitutes a larger share of income among the welfare dependent population. To a significant extent, this trend correlated with worsening economic conditions. The increase in SNAP recipiency between 2005 and 2009 reflects its intended responsiveness to economic changes, expanding to meet increased need when the economy is in recession. SNAP is an important support for working families\u201462 percent of SNAP recipients are in families with labor force participants. Furthermore, SNAP receipt does not necessarily imply long term dependency, as over 60 percent of SNAP entrants remain on the program for a year or less. As the economy continues to improve, SNAP is projected to respond as designed, with fewer people needing the program in the first place. In fact, the Congressional Budget Office’s latest projections show that once the economy fully recovers, SNAP is expected to return to pre-recession levels as a share of the gross domestic product. 1 Appendix D provides more information on the use of individuals, rather than families or households, as the unit of analysis for most of the statistics in this report. xi Trends in recipiency rates are similar to the more well-known changes in TANF, SNAP, and SSI caseloads. For example, the percentage of individuals receiving TANF cash assistance fell from 5.4 percent to 1.4 percent between 1993 and 2009 (see Indicator 3). SNAP recipiency rates fell from 10.4 percent in 1993 and 1994 to 6.1 percent in 2000 and 2001. By 2009, the SNAP recipiency rate had increased to 10.7 percent, the highest rate in the history of the program. SSI recipiency rates, on the other hand, were relatively flat between 1993 and 2009, fluctuating between 2.3 and 2.5 percent. Longitudinal measures show that program spells are typically short and long-term recipiency is rare. For example, approximately three-fourths of all TANF spells and 62 percent of all SNAP spells lasted one year or less (see Indicator 7). Among individuals receiving TANF at some point over a ten-year period ending in 2008, over 70 percent received AFDC\/TANF in only one or two years during this period (see Indicator 9). Since the causes of welfare receipt and dependence are not clearly known, the report also includes a larger set of traditional risk factors associated with welfare receipt. The risk factors are organized into three categories: economic security measures, measures related to employment and barriers to employment, and measures of nonmarital childbearing. The economic security risk factors include measures of poverty and well-being that are important not only as potential predictors of dependence, but also as a supplement to the dependence indicators, ensuring that dependence measures are not assessed in isolation. As such, the report includes data on the official poverty rate, one of the most common measures of economic well-being: Between 2000 and 2004, the poverty rate increased, but still remained lower than any year between 1980 and 1997. Between 2005 and 2009, the poverty rate increased from 12.6 percent to 14.3 percent of all individuals (see Economic Security Risk Factor 1). The measures related to employment and barriers to employment are important because families must generally receive an adequate income from employment in order to avoid dependence without severe deprivation. The majority of mothers in the U.S. are in the labor force. Of particular note is the sharp increase in labor force participation rates for never-married mothers (i.e., those historically at greatest risk of AFDC\/TANF dependency), rising from 52.5 percent in 1992 to a peak of 75.3 percent in 2002, and then gradually falling to 72.0 percent in 2009 (see Employment and Work-Related Risk Factor 8). In an average month in 2009, 56.7 percent of TANF recipients lived in families with at least one family member in the labor force. Comparable figures for SNAP and SSI recipients were 62.0 and 41.1 percent, respectively (see Indicator 2). Between 2005 and 2009 (see the 2008 Indicators of Welfare Dependence Report on line at http:\/\/aspe.hhs.gov\/hsp\/indicators08\/index.shtml for the 2005 numbers) there has been an increase in the percentage of recipients in families having at least one person in the labor force. Between 2005 and 2009, the percentage of recipients in families with at least one person in the labor force increased from 52.3 to 56.7 percent for TANF recipients, from 55.4 to 62.0 percent for SNAP recipients, and from 38.9 to 41.1 percent for SSI recipients. In addition, the percentage of non-elderly adult recipients who lived in families with at least one worker increased from 2005-2009 for all three programs. http:\/\/aspe.hhs.gov\/hsp\/indicators08\/index.shtml\ufffd xii Data on nonmarital births is important since historically a high proportion of AFDC\/TANF recipients first became parents outside of marriage. In 1940, 3.8 percent of births were to unmarried women. Beginning in 1960, this percentage began to increase, reaching 32.6 percent by 1992. It remained steady for a few years, before rising to 41.0 percent in 2009 (see Nonmarital Birth Risk Factor 1). Finally, the report has four appendices that provide additional data on major welfare programs, alternative measures of dependence and nonmarital births, as well as background information on several data and technical issues. Chapter I. Introduction and Overview The Welfare Indicators Act of 1994 (Public Law 103-432) directed the Secretary of Health and Human Services (HHS) to publish an annual report on welfare dependency. This twelfth indicators report provides data on measures of welfare recipiency, dependence, and predictors of welfare dependence. The purpose of this report is to address questions concerning the extent to which American families depend on income from welfare programs. Under the Welfare Indicators Act, HHS was directed to address the rate of welfare dependence, the degree and duration of welfare recipiency and dependence, and predictors of welfare dependence. The Act further specified that analyses of means-tested benefit programs should include benefits under the Temporary Assistance for Needy Families (TANF) program (formerly the Aid to Families with Dependent Children (AFDC) program),1 the Supplemental Security Income (SSI) program, and the Supplemental Nutrition Assistance Program (SNAP) (formerly the Food Stamp Program (FSP)).2 In this report we include information on cash assistance under the TANF and SSI programs and the cash value of food assistance benefits under SNAP. The American Recovery and Reinvestment Act (ARRA) of 2009 included provisions that changed (in most cases temporarily) some aspects of these three programs; these changes are discussed below. This twelfth report provides updated measures through 2009 for dependency measures based on the Current Population Survey (CPS), Annual Social and Economic Supplement. Data are available through 2009 for the Panel Study of Income Dynamics (PSID) measures, and through 2008 for several of the Survey of Income and Program Participation (SIPP) measures. Organization of Report This introductory chapter provides an overview of the specific summary measure of welfare dependence proposed by a bipartisan Advisory Board3 and how this measure was adopted for use in this report series. It also discusses summary measures of poverty, following the Advisory Board’s recommendation that dependence measures not be assessed in isolation from other measures of economic well-being. The introduction concludes with a discussion of data sources used for the report. Chapter II of this report, Indicators of Dependence, presents ten indicators of welfare dependence and recipiency. These indicators include dependence measures based on the share of total income derived from all three programs AFDC\/TANF, FSP\/SNAP, and SSI as well as measures of recipiency for each of the three programs. Labor force participation among families receiving welfare and benefit receipt across multiple programs also are shown. The second half of the chapter includes longitudinal data on the duration of welfare receipt and events associated with transitions on and off the AFDC\/TANF program. 1The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (P.L. 104-193) repealed the Aid to Families with Dependent Children (AFDC) program and created a block grant program of Temporary Assistance for Needy Families (TANF) in its place. The mandatory start date for TANF was July 1, 1997, but most states made the transition from AFDC before that date. Throughout the report we use AFDC\/TANF to refer to cash assistance benefits received under these two programs. 2 The Food, Conservation and Energy Act of 2008 (P.L. 110-246) re-named the Food Stamp Program as the Supplemental Nutrition Assistance Program (SNAP) as of October 1, 2008. The name change had no effect on the type of benefits or how they are made available to eligible households. 3 The first annual report was produced under the oversight of a bipartisan Advisory Board on Welfare Indicators, which assisted the Secretary in defining welfare dependence, developing indicators of welfare dependence, and choosing appropriate data. Under the terms of the original authorizing legislation, the Advisory Board was terminated in October 1997, prior to the submission of the first annual report. I-1 Chapter III, Predictors and Risk Factors Associated with Welfare Receipt, focuses on predictors of welfare dependence risk factors believed to be associated with welfare receipt. These predictors are shown in three different groups: (1) Economic security including various measures of poverty, receipt of child support, food insecurity and health insurance coverage is important in predicting dependence because families with fewer economic resources are more likely to rely on welfare programs for their support. (2) Measures of work status and potential barriers to employment for adults also are critical, because families must generally receive an adequate income from employment in order to avoid dependence without severe deprivation. (3) Finally, data on nonmarital births are important since historically a high proportion of welfare recipients first became parents outside of marriage. Additional data and technical notes are presented in four appendices. Appendix A provides basic program data on each of the main welfare programs and their recipients. Appendix B shows how dependence is affected by the inclusion of benefits from the SSI program; Appendix C includes additional data on non-marital childbearing; and Appendix D provides background information on several data and technical issues. The main welfare programs in Appendix A include the following: The Temporary Assistance for Needy Families (TANF) program provides monthly assistance (primarily cash benefits) and other benefits and services (referred to as non- assistance ) to eligible families with children and is run directly by the states. Prior to 1996 welfare cash benefits were provided through the Aid to Families with Dependent Children (AFDC) program. Data on assistance benefits under the TANF and AFDC programs are provided in Appendix A, with AFDC data provided from 1962 through June 1997, and TANF data from July 1997 through 2009. The Supplemental Nutrition Assistance Program (SNAP) provides monthly benefits to individuals living in households or alone, provided their income and assets are below limits set in federal law. It reaches more poor people over the course of a year than any other means-tested public assistance program. Prior to October 1, 2008, these food assistance benefits were provided through the Food Stamp Program. Appendix A provides historical data on food stamp\/SNAP benefits from 1962 to 2009. The Supplemental Security Income (SSI) program provides monthly cash payments to elderly, blind or disabled individuals or couples whose income and assets are below levels set in federal law. Though the majority of recipients are adults, disabled children also are eligible. Historical data from 1974 through 2009 are provided in Appendix A. Measuring Welfare Dependence As suggested by its title, this report focuses on welfare dependence as well as welfare recipiency. While recipiency can be defined fairly easily, based on the presence of benefits from AFDC\/TANF, FSP\/SNAP, or SSI, dependence is a more complex concept. Welfare dependence, like poverty, is a continuum, with variations in degree and in duration. Families may be more or less dependent if larger or smaller shares of their total resources are derived from welfare programs. The amount of time over which a family depends on welfare might also be considered in assessing its degree of dependence. Nevertheless, a summary measure of dependence to be used as an indicator for policy purposes must have some fixed parameters that allow one to determine which families should be counted as dependent, just as the poverty line defines who is poor under the official standard. The definition of dependence proposed by the Advisory Board for this purpose is as follows: A family is dependent on welfare if more than 50 percent of its total income in a one-year period comes from AFDC\/TANF, FSP\/SNAP, and\/or SSI, and this welfare income is not associated with work activities. In following the Board’s proposal, we adopt I-2 I-3 the following definition of welfare dependence among individuals in families4 for use in this report: Welfare dependence is the proportion of all individuals in families that receive more than half of their total family income in one year from TANF, SNAP, and\/or SSI. No definition of welfare dependence is without its limitations. The Advisory Board recognized that no single measure could capture fully all aspects of dependence and that their proposed measure should be examined in concert with other indicators of well-being. While the Board’s proposal would count unsubsidized and subsidized employment and work required to obtain benefits as work activities, existing data sources do not permit distinguishing between welfare income associated with work activities and non-work-related welfare benefits. As a result, the data shown in this report may overstate the incidence of dependence on these three programs.5 In FY 2009, 42.4 percent of welfare recipients were working or participating in work related activities compared to 7 percent in 1992.6 Also, any definition of dependence represents an arbitrary choice of a percentage of income from welfare beyond which families will be considered dependent. But using a single point in this case 50 percent yields a relatively straightforward measure that can be tracked easily over time, and is likely to be associated with any large changes in total dependence, however defined. Figure SUM 1. Recipiency and Dependency Rates: 1993-2009 Note: Recipiency is defined as living in a family with receipt of any amount of AFDC\/TANF, SSI or SNAP during the year. Dependency is defined as having more than 50 percent of annual income from AFDC\/TANF, SSI and\/or SNAP. Dependency rates would be lower if adjusted to exclude welfare assistance associated with working. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994-2009, analyzed using the TRIM3 microsimulation model. Welfare recipiency is defined as living in a family with receipt of any amount of AFDC\/TANF, FSP\/SNAP, or SSI during the year. The welfare recipiency rate, as used in this report, refers to the number of individuals in families that received benefits from any one of the three aforementioned programs during the year as a percent of the population. 4 The unit of analysis for most of the statistics in this report is individuals rather than families or households. Appendix D provides more information on the use of individuals as the unit of analysis. 5 While this report defines dependency in relation to TANF, SNAP and SSI, there are other forms of means-tested assistance that could be considered under other definitions. 6 Office of Family Assistance, an office of the Administration for Children and Families, Characteristics and Financial Circumstances of TANF Recipients, Fiscal Year 2009, Table 28. This 42.4 percent includes subsidized employment and work preparation activities (including subsidized jobs, on-the-job training, work experience or community services). The earnings of those in unsubsidized employment would be correctly captured as income from work in national surveys. Any welfare benefits associated with work experience, community service programs or other work activities, however, would be counted as income from welfare in most national surveys, a classification incompatible with the Advisory Board’s proposed definition. (In percent) 16.6 17.2 16.9 16.0 14.8 13.5 13.3 12.5 12.6 13.2 14.1 15.0 15.3 15.6 15.8 17.1 19.9 5.9 5.8 5.3 5.2 4.5 3.8 3.3 3.0 3.1 3.2 3.6 3.7 3.8 3.7 3.5 4.0 4.6 0 5 10 15 20 25 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Recipiency rate Dependency rate (In percent) Dependency and recipiency rates follow fairly similar trends and even before the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996 was passed, welfare recipiency and dependency were both in decline. The overall drop in the recipiency rates during the 1990s is consistent with low unemployment and lower poverty rates. The subsequent rise in the welfare program recipiency rate after 2000 however is associated more with increases in SSI and SNAP receipt than TANF, where caseloads continued a downward trend through 2008 (see Table TANF 1). The Great Recession, that officially began in late 2007 and lasted through mid 2009, exacerbated an upward trend in recipiency rates that began after 2000. As shown in Figure SUM 1, the dependency rate fell from 5.9 percent in 1993 to a low of 3.0 percent in 2000, and the recipiency rate declined from 17.2 percent in 1994 to a low of 12.5 percent in 2000. Yet, by 2009, these rates had risen to 4.6 percent for dependence and 19.9 percent for recipiency. To a significant extent, this trend correlated with worsening economic conditions. In particular, SNAP is designed to respond to such changes, automatically expanding to meet increased need when the economy is in recession with benefits that flow to communities, states, or regions of the country that face rising unemployment or poverty. The increase in SNAP recipiency between 2005 and 2009 reflects this responsiveness, as well as success in reaching a higher proportion of eligible people (see Figure IND 4). The program’s significance to these households is underscored by the fact that 17 percent of SNAP households had no other income in 2009.7 It is important to note that more than half of those that rely on SNAP are children, elderly, or disabled.8 SNAP is also an important support for working families\u201462 percent of SNAP recipients are in families with labor force participants. Furthermore, SNAP receipt does not necessarily imply long term dependency, as over 60 percent of SNAP entrants remain on the program for a year or less. The Congressional Budget Office’s latest projections show that once the economy fully recovers, SNAP is expected to return to pre-recession levels as a share of the gross domestic product. In 2009, as in previous years, general patterns in welfare receipt are apparent. Recipiency and dependency rates are higher for Non-Hispanic Blacks and Hispanics of any race than they are for Non- Hispanic Whites, as shown in Table SUM 1. These rates are also higher for young children than they are for adults, and they are higher for individuals in female-headed families than they are for those in married- couple families. However, of note are the rising recipiency rates for all demographic categories over a relatively short period of time, 2007 2009, and the magnitude of the increase. For example, for those living in female-headed families, the recipiency rate increased from 45.0 percent in 2007 to 50.4 percent in 2009, a 5.4 percentage point increase. And Hispanics of any race show an 8.3 percentage point increase in recipiency between 2007 and 2009. Adults 65 and older experienced smaller increases in welfare recipiency than did other demographic groups. Their recipiency rate increased 0.7 percentage points, from 10.6 percent to 11.3 percent over the 2007 and 2009 period. Another factor affecting dependence is the time period observed. The summary measures shown in Figure SUM 1 and Table SUM 1 focus on recipiency and dependency rates measured on an annual, cross-sectional basis. Longitudinal measures of AFDC\/TANF receipt (both annual and monthly) show that program spells are typically short and long-term recipiency is rare, see Chapter II. Indicator 9, for example, shows that among individuals receiving TANF at some point over a ten-year period ending in 2008, 8.0 percent received some AFDC\/TANF during six or more years. Another fifth (20.5 percent) were recipients in three to five years, and more than two-thirds (71.5 percent) received AFDC\/TANF in only one or two years during this period. Measuring Economic Well-Being To assess the social impacts of any change in dependence, changes in the level of poverty should be considered. This report focuses on the official poverty rate, the most common poverty measure. Additional measures of poverty and need also are included under the Economic Risk Factors found in Chapter III. 7 USDA-Food and Nutrition Service, Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2009. 8 USDA-Food and Nutrition Service, Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2009. I-4 As shown in Figure SUM 2a the official 2009 poverty rate (14.3 percent) is higher than any rate in the 2000s yet it is still lower than the 1993 rate of 15.1 and the 1983 rate of 15.2 percent, peak years for poverty in recent history. In examining poverty over the last decade, in 1999 there were 32.8 million people in poverty as compared to almost 43.6 million people in poverty in 20099. Some of this increase could be attributed to population increases. As shown in Figure Sum 2b, the child poverty rate for all persons under 18 was 20.1 percent in 2009, with 15.5 million poor children, and for related children 0 5 years of age the rate is 23.8 percent (see Table ECON 1). Table SUM 1. Recipiency and Dependency Rates: Selected Years 1993 1996 1997 1998 1999 2000 2002 2004 2006 2007 2008 2009 Recipiency Rates (Rates of Any Amount of AFDC\/TANF, SNAP or SSI) All Persons 16.6 16.0 14.8 13.5 13.3 12.5 13.2 15.0 15.6 15.8 17.1 19.9 Racial\/Ethnic Categories Non-Hispanic White 10.3 9.9 9.7 8.6 8.4 8.2 8.8 10.1 10.6 10.4 11.4 13.3 Non-Hispanic Black 38.0 35.6 30.2 29.6 29.8 27.0 27.7 32.4 32.0 33.4 34.1 37.6 Hispanic 34.6 32.0 28.0 24.5 23.4 21.0 21.7 22.6 23.8 24.6 27.6 32.9 Age Categories Children ages 0-5 30.5 28.2 25.1 22.4 21.5 19.8 21.4 24.6 25.7 27.0 28.9 34.3 Children ages 6-10 24.9 24.2 21.2 20.0 19.8 18.0 18.8 22.2 23.2 23.9 26.2 30.4 Children ages 11-15 22.1 21.1 19.4 17.0 17.3 16.3 16.8 20.5 21.5 22.5 23.1 27.4 Women ages 16-64 16.4 16.0 14.7 13.6 13.6 12.5 13.4 15.0 15.7 15.6 16.9 19.8 Men ages 16-64 11.5 11.7 11.1 10.0 9.6 9.2 10.3 11.6 12.0 12.1 13.5 16.0 Adults ages 65 and over 11.2 10.3 10.2 9.9 10.0 10.4 9.7 10.0 10.6 10.6 11.4 11.3 Family Categories Persons in: Married-couple families 10.5 9.6 8.7 8.3 7.9 7.2 7.5 8.6 8.9 8.8 9.9 12.5 Female-headed families 47.8 46.0 41.6 37.5 39.9 37.1 37.7 42.6 44.3 45.0 47.3 50.4 Male-headed families 27.6 25.3 24.3 19.7 19.3 21.8 21.2 21.9 25.8 26.4 27.3 33.1 Unrelated persons 9.7 11.5 11.9 10.9 10.0 10.1 11.5 12.7 12.6 12.4 14.1 15.5 Dependency Rates (More than 50 Percent of Income from AFDC\/TANF, SNAP and\/or SSI) All Persons 5.9 5.2 4.5 3.8 3.3 3.0 3.2 3.7 3.7 3.5 4.0 4.6 Racial\/Ethnic Categories Non-Hispanic White 3.0 2.6 2.5 2.1 1.8 1.9 1.8 2.2 2.3 2.1 2.4 2.7 Non-Hispanic Black 17.8 13.8 11.4 10.5 9.1 7.7 8.7 10.0 9.5 9.4 10.2 11.1 Hispanic 11.8 10.9 9.1 6.6 5.4 4.5 4.9 5.2 5.2 5.1 5.7 7.1 Age Categories Children ages 0-5 13.9 11.2 9.3 7.8 6.2 6.0 6.0 7.1 6.9 7.1 7.6 9.1 Children ages 6-10 11.2 9.5 8.4 6.7 6.1 5.1 5.1 6.0 5.7 5.3 6.3 7.5 Children ages 11-15 9.3 8.1 7.4 5.7 4.5 4.0 4.0 5.1 5.2 5.3 5.3 6.3 Women ages 16-64 5.9 5.2 4.6 3.9 3.5 3.0 3.4 3.7 3.9 3.7 4.2 4.8 Men ages 16-64 2.7 2.7 2.5 2.1 1.9 1.8 2.0 2.4 2.5 2.3 2.8 3.2 Adults ages 65 and 2.4 2.4 2.1 2.1 2.0 2.1 2.0 2.2 2.1 2.1 2.2 2.2 Family Categories Persons in: Married-couple families 1.8 1.7 1.4 1.1 1.0 1.0 1.0 1.0 1.2 1.1 1.3 1.6 Female-headed families 25.7 21.1 18.4 15.0 13.6 11.4 11.7 13.8 13.2 12.6 13.4 14.6 Male-headed families 6.8 5.4 5.6 4.2 3.0 4.4 3.8 4.0 4.5 4.5 4.7 6.4 Unrelated persons 3.8 4.2 4.2 4.2 3.4 3.8 4.1 4.5 4.7 4.3 5.2 5.8 Note: Recipiency is defined as living in a family with receipt of any amount of AFDC\/TANF, SSI or FSP\/SNAP during the year. Dependency is defined as having more than 50 percent of annual family income from AFDC\/TANF, SSI and\/or SNAP. Dependency rates would be lower if adjusted to exclude welfare assistance associated with working. Spouses are not present in the male-headed and female-headed family categories. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994-2010, analyzed using the TRIM3 microsimulation model. 9 U.S. Bureau of the Census, Income, Poverty, and Health Insurance Coverage in the United States: 2010, Current Population Reports, Series P60- 239 and data published online at www.census.gov\/hhes\/www\/poverty.html. I-5 Figure SUM 2a. Percentage of Total Population in Poverty with Various Means-Tested Transfers Counted as Income: 1979-2009 Note: The three measures of income are as follows: (1) Before means-tested cash transfers is earnings and other pre-transfer ( private or market ) cash income, plus social security, workers compensation, and other social insurance cash transfers. It does not include means-tested cash transfers; (2) The Official poverty measure uses the official Census Bureau income definition, which includes means-tested cash transfers, primarily AFDC\/TANF and SSI; (3) After means-tested non-cash benefits and taxes counts the cash value of means-tested food and housing benefits, adds the refundable Earned Income Tax Credit (EITC), and subtracts federal payroll and income taxes. The fungible value of Medicare and Medicaid is not included in any of the income measures. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1980 2010, analyzed by the Congressional Budget Office. See ECON 4 in Chapter III for the data underlying the table and further notes. Figure SUM 2a shows poverty estimates under the official poverty rate and two other measures that adjust income by adding or subtracting means-tested cash transfers, means-tested non-cash benefits, and federal taxes. While each of the three poverty measures in the graph uses a different definition of income, all three poverty measures use the Census Bureau’s official poverty thresholds. The Official poverty measure trend line shows the official poverty rate based on total cash income, including means-tested cash transfers. The official poverty rate was 14.3 percent in 2009. The Before means-tested cash transfers trend line shows that the poverty rate would be if means-tested cash transfers (primarily AFDC\/TANF and SSI) were excluded from income. Income in this measure includes earnings and other pre-transfer cash income, plus social security, workers compensation, and other social insurance cash transfers. The poverty rate under this measure would be higher than under the official measure, or 15.1 percent in 2009. The After means-tested non-cash benefits and taxes trend line shows what the poverty rate would be lower if the cash value of means-tested food and housing transfers and the effect of federal taxes were counted as income.11 11 The effects of food and housing benefits are shown separately from the effect of federal taxes in Figure ECON 4 in Chapter III. Prior to 1993, including the effect of federal taxes and increased poverty. Since 1993, federal taxes and tax credits (including refunds through the Earned Income Tax Credit) have had the net effect of reducing poverty rates. Under this definition, the poverty rate in 2009 would be 3.8 percentage points lower than the official measure, or 10.5 percent. (In percent) 15.1 14.3 10.5 6 8 10 12 14 16 18 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 Before means-tested cash transfers Official poverty measure After means-tested non-cash benefits & taxes I-6 Figure SUM 2b. Number of Poor Persons under 18 Years of Age & Their Poverty Rate, 1959-2009 Source: U.S. Bureau of the Census, Income, Poverty, and Health Insurance Coverage in the United States: 2010, Current Population Reports, Series P60-239 and data published online at http:\/\/www.census.gov\/hhes\/www\/poverty.html. The American Recovery and Reinvestment Act of 2009 and Welfare Benefits On February 13, 2009, Congress passed the American Recovery and Reinvestment Act, ARRA (Public Law 111-5) in response to the economic crisis, often referred to the Great Recession . The Recovery Act had three immediate goals: create new jobs and save existing ones, spur economic activity and invest in long-term growth, and foster levels of accountability and transparency in government spending. The Recovery Act intended to achieve these goals by providing $787 billion in 2009: tax cuts and benefits for working families and businesses, funding for federal contracts, grants and loans12 and funding for entitlement programs. The SNAP, TANF, and SSI programs all were impacted by the ARRA legislation. Supplemental Nutrition Assistance Program (SNAP) ARRA increased and expanded program eligibility.13 Households are eligible to receive SNAP benefits based on household income, assets, and certain basic expenses. The USDA’s Food and Nutrition Service (FNS), the agency that administers SNAP at the Federal level, reported that in fiscal year 2008, the year prior to ARRA, an estimated 41 million people were eligible for SNAP benefits in a typical month but only 27 million (66 percent) actually participated in the program. According to SNAP administrative data, the SNAP caseload increased from 28.4 million participants in 2008 to 33.7 million in 2009, an increase of about 19 percent, and one of the largest single-year increases in SNAP history. This large increase in SNAP participation might seem to demonstrate that the ARRA SNAP changes prompted increased participation. It is impossible however to determine from the administrative data alone how much of the participation increase was attributable to ARRA and how much was due to changing economic conditions and other factors. In an average month in fiscal year 2009 (ending September 30, 2009), SNAP provided benefits to 33.5 million people in the United States or 11 percent of the population. The average benefit was about $125 per person per month and the total federal expenditure for the program was $53.6 billion. ARRA also increased SNAP benefit levels based on the number of qualifying people in the household. Benefits for a family of four went up by $80 per month.14 12 http:\/\/www.recovery.gov\/About\/Pages\/The_Act.aspx 13 USDA, Economic Research Service, Report Number 116, Food Security Improved Following the 2009 ARRA Increase in SNAP Benefits. http:\/\/www.ers.usda.gov\/publications\/err-economic-research-report\/err116.aspx 14 http:\/\/www.ers.usda.gov\/amberwaves\/June11\/features\/foodsecuritysnap.htm 27.3 22.3 22.7 20.7 17.6 13.9 15.7 15.5 0 5 10 15 20 25 30 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2009 Poverty rate Rate (percent) Number (millions) Number in poverty I-7 http:\/\/www.census.gov\/hhes\/www\/poverty.html)\ufffd http:\/\/www.ers.usda.gov\/publications\/err-economic-research-report\/err116.aspx\ufffd The ARRA benefit increase was implemented as a constant dollar amount for each household size, so the percentage increase was greater for households that had some net income and were therefore eligible for less than the maximum benefit. For example, prior to ARRA, a household of four with a monthly net income of $980 qualified for $294 in SNAP benefits\u2014half the maximum benefit for a household of that size. Under ARRA, that household received $374 in SNAP benefits\u2014an increase of 27.2 percent. Households with no income net of allowable deductions received the maximum SNAP benefit, which varied depending on the number of qualifying persons in the household. Effective in April 2009, ARRA increased benefits of those households by 13.6 percent. ARRA suspended time-limited benefits for non-elderly, non-disabled adults without dependents through September 30, 2010. It also provided States with $300 million in additional administrative funds ($150 million in 2009 and the same amount in 2010) to cover the surging caseloads. Figure SUM 2c. Number & Percent of Children Receiving SNAP, 1980 2009 Source: U.S. Department of Agriculture, Food and Nutrition Service Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2009 and earlier reports, http:\/\/www.fns.usda.gov\/ora\/menu\/Published\/SNAP\/SNAPPartHH.htm ; U.S. Census Bureau, http:\/\/www.census.gov\/popest\/data\/index.html; calculations by ASPE. Temporary Assistance for Needy Families (TANF) The Recovery Act provided up to $5 billion in supplemental funding for an Emergency Contingency Fund (Emergency Fund), administered by the Health and Human Services Administration for Children and Families, Office of Family Assistance.15 The funds provided additional revenue to States, territories, and tribes that had an increase in caseloads and basic assistance expenditures, or had an increase in expenditures related to short-term benefits or subsidized employment. The funds could be used in the same way as the annual federal TANF block grant, except a jurisdiction could not transfer the funds to other block grant programs. States, tribes, and territories were eligible to qualify for funds based on increases in qualifying expenditures through September 30, 2010. Emergency Funds were provided to these jurisdictions to reimburse 80 percent of the cost of increased spending in three areas: basic assistance, non-recurrent short-term benefits, and subsidized employment for low-income parents and youth. Subsidized employment could have been in the private sector, in non-profit organizations or in the public sector. Jurisdictions could chose to subsidize all or part of the wages of a subsidized employee, and 15 Catalogue for Domestic Assistance, ARRA Emergency Contingency Fund for Temporary Assistance for Needy Families (TANF) State Program. https:\/\/www.cfda.gov\/index?s=program&mode=form&tab=step1&id=82b17b73ae63786a4dd9d3e212008aa8 15.5 21.0 20.9 9.9 14.4 15.6 0 5 10 15 20 25 1980 1985 1990 1995 2000 2005 2009 Percent receiving SNAP Number receiving SNAP Rate (percent) Number (millions) I-8 https:\/\/www.cfda.gov\/index?s=program&mode=form&tab=step1&id=82b17b73ae63786a4dd9d3e212008aa8\ufffd determine the length of the subsidy period. The expenditures could be for a newly-created job or to prevent a layoff in an existing job, as long as the jurisdiction ensured that it complied with requirements against the displacement of other workers, and ensured that the expenditures would provide a job opportunity that would not have otherwise existed to a needy parent or youth. Fourteen states placed over 5,000 people each in subsidized jobs. Four of those states \u2014 California, Illinois, Pennsylvania, and Texas \u2014 each placed more than 25,000 people, accounting for over half of the national total. Nationwide, over 138,000 placements were summer jobs for youth.16 Supplemental Security Income (SSI) The Recovery Act provided a one-time payment of $250 to adult Social Security beneficiaries and SSI recipients, except those receiving Medicaid in care facilities. To receive the payment, the person had to be eligible for Social Security or SSI during the months of November 2008, December 2008, or January 2009. Data Sources The primary data sources for this report are the Current Population Survey (CPS), the Survey of Income and Program Participation (SIPP), the Panel Study of Income Dynamics (PSID), and administrative data for the AFDC\/TANF, FSP\/SNAP, and SSI programs. Beginning with the 2001 report, there was a shift to using CPS rather than SIPP data for several indicators and predictors of welfare recipiency and dependence. This change was necessary because CPS data are updated annually, while SIPP updates are available less frequently. The current report includes updated estimates for most of the SIPP-based indicators and risk factors based on newly available data from the 2004 SIPP panel. For measures of receipt, dependency and poverty at a single point in time, the report primarily uses the Annual Social and Economic Supplement to the CPS, which measures income and poverty over an annual accounting period. As stated above, the CPS data are generally available on a more timely basis than the SIPP, and have been widely used to measure trends since the welfare reform legislation of 1996. However, because the CPS does not collect income information in the same detail as the SIPP, it has been subject to criticism for underreporting of income, particularly welfare income. To address this concern, some of the indicators in this report are based on CPS data that have been analyzed by the Transfer Income Model (TRIM3), a microsimulation model developed by the Urban Institute under contract to the Office of the Assistant Secretary for Planning and Evaluation. Although its primary purpose is to simulate program eligibility and the impact of policy proposals, the TRIM3 model also has been used to correct for underreporting of welfare receipt and benefits. Welfare caseloads in TRIM3 are based on CPS data, adjusted upward to ensure that total estimates of recipients equal the total counts from administrative data. To maintain consistency in data trends, we present estimates based on CPS data analyzed by TRIM3 beginning in 1993, the first year the TRIM3 microsimulation model became available. As shown in Figure SUM 3, the overall measures of dependence and recipiency have not been greatly affected by the change in data sources. Both data sources show a decline in dependence between 1996 and 1999 and increases in dependence during the 2000s. Still, readers are cautioned against comparing measures for 1987-1995 from the SIPP data in the first three annual reports with the measures for 1993- 2009 from the TRIM3-adjusted CPS data. The Panel Study of Income Dynamics (PSID) is another source of data used in this report. Like the SIPP it provides longitudinal data, but over a much longer time period than the three- to four-year time period of the SIPP. With annual data on program receipt since 1968, the PSID provides vital data for measuring longer-term welfare use over periods of many years. Because the PSID indicators cover time spans over decades, they are updated less frequently than the CPS-based and SIPP-based measures. 16 Subsidizing Employment Opportunities for Low-Income Families A Review of State Employment Programs Created Through the TANF Emergency Fund. OPRE Report 2011-38, December 2011. I-9 Figure SUM 3. Recipiency and Dependency Rates from Two Data Sources: 1987 2009 Note: Recipiency is defined as receipt of any amount of AFDC\/TANF, SSI or SNAP during the year. Dependency is defined as having more than 50 percent of annual family income from AFDC\/TANF, SSI and\/or SNAP. Dependency rates would be lower if adjusted to exclude welfare assistance associated with working. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income and veterans pension benefits are included in means-tested assistance income for SIPP-based receipt and dependency estimates prior to 2001. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994-2007, analyzed using the TRIM3 microsimulation model, and unpublished tabulations from the Survey of Income and Program Participation, 1987, 1990, 1992, 1993, 1996, 2001, and 2004, panels. The report also draws upon administrative data for the AFDC\/TANF, FSP\/SNAP, and SSI programs. These data are largely reported in Appendix A. Like the CPS data, administrative data are generally available with minimal time lags. For this report, data through 2009 are used. To the extent possible, TANF administrative data are reported in a consistent manner with data from the earlier AFDC program, as noted in the footnotes to the tables in Appendix A. The fact remains that assistance under locally designed TANF programs encompasses a diverse set of cash and non-cash benefits designed to support families in making a transition to work, and so direct comparisons between AFDC receipt and TANF receipt should be made with caution. This issue also affects reported data on AFDC and TANF receipt in national data sets such as the CPS and SIPP. For further technical information about the data presented in the report, specifically for information on race and ethnicity, the unit of analysis and annual versus monthly measures, please see Appendix D. (In percent) 14.9 19.3 4.7 3.5 19.9 4.6 0 4 8 12 16 20 1992 1995 1998 2001 2004 2007 Recipiency rate (SIPP) Dependency rate (SIPP) Recipiency rate (CPS\/TRIM) Dependency rate (CPS\/TRIM) 1987 2009 I-10 Chapter II. Indicators of Dependence Following the format of the previous annual reports to Congress, Chapter II presents summary data related to indicators of dependence. These indicators differ from other welfare statistics because of their emphasis on welfare dependence, rather than simply welfare receipt. As discussed in Chapter I, the Advisory Board on Welfare Indicators suggested that families be considered dependent if more than 50 percent of their total income in a one-year period comes from cash assistance through the Temporary Assistance for Needy Families (TANF) program (formerly the Aid to Families with Dependent Children (AFDC) program), Supplemental Nutrition Assistance Program (SNAP, formerly Food Stamps), and Supplemental Security Income (SSI) benefits. Furthermore, this welfare income was not to be associated with work activities. Existing data from administrative records and national surveys, however, do not generally distinguish welfare benefits received in conjunction with work from benefits received without work. Thus, it was not possible to construct one single indicator of dependence that captured fully the Advisory Board’s recommendation; that is, one indicator based on the percentage of income from means-tested assistance only if this income is not associated with work activities. As discussed in Chapter I, we adopt the following definition of welfare dependence among individuals in families17 for use in this report: Welfare dependence is the proportion of all individuals in families that receive more than half of their total family income in one year from TANF, SNAP and\/or SSI. The ten indicators in Chapter II were selected to provide information about the range and depth of dependence as proposed by the Advisory Board on Welfare Indicators, including indicators that measure the presence of employment activities. This chapter focuses on recipients of three major means-tested cash and nutritional assistance programs: cash assistance through the AFDC and TANF programs, benefits under the Food Stamp and SNAP programs, and SSI benefits for elderly and disabled recipients. For some indicators, summary data and characteristics are provided for all recipients, not just those defined as welfare-dependent. While a number of indicators focus on the percentage of recipients’ income from means-tested assistance, other indicators include measures of labor force attachment for those receiving welfare. Indicator Summary Indicator 1: Degree of Dependence. This indicator focuses most closely on those individuals who meet the Advisory Board’s proposed definition of dependence. In addition to examining the rate for individuals with more than 50 percent of their annual family income from AFDC\/TANF cash assistance, FSP\/SNAP benefits, and\/or SSI benefits, this indicator shows various levels of dependence by examining different thresholds (Indicators 1a and 1b). This indicator also shows the average percentage of income from the three means-tested assistance programs and earnings received by families with various levels of income relative to the poverty level (Indicators 1c and 1d). Indicator 2: Receipt of Means-Tested Assistance and Labor Force Attachment. This indicator looks further at the relationship between receipt of the three means-tested assistance programs and participation in the labor force. This is an important issue because of the significant number of low- income individuals that receive a combination of means-tested assistance and earnings from the labor force. Indicator 3: Rates of Receipt of Means-Tested Assistance. This indicator paints yet another picture of dependence by measuring average monthly recipiency rates, that is, the percentage of the population that receives AFDC\/TANF, FSP\/SNAP, and\/or SSI in an average month. Administrative data for the AFDC\/TANF, FSP\/SNAP and SSI programs make these figures readily available over time, allowing a better sense of historical trends than is available from the more specialized indicators of dependence. 17 Appendix D provides more information on the use of individuals, rather than families or households, as the unit of analysis for most of the statistics in this report. II-1 (This indicator differs from the recipiency rate reported in SUM 1, in several ways. First, it focuses on average monthly receipt rather than any receipt over the course of the year. Second, it is limited to actual recipients of assistance rather than including all members of a family unit that receive benefits from a particular welfare program. Third, it shows recipiency rates for individual programs rather than the joint receipt of any one of the three welfare programs.) Indicator 4: Rates of Participation in Means-Tested Assistance Programs. While means-tested public assistance programs can serve those that meet each program’s requirements, not all eligible individuals and households participate in the programs. This indicator uses AFDC\/TANF, FSP\/SNAP and SSI administrative data and microsimulation models to reflect average monthly take-up rates by year the number of families that actually participate in the programs as a percentage of those who are estimated to be legally eligible. Indicator 5: Multiple Program Receipt. Depending on their circumstances, individuals may choose a variety of different means-tested assistance packages. This indicator looks at the percentage of individuals receiving AFDC\/TANF, FSP\/SNAP and SSI in a month, examining how many rely on just one of these programs, and how many rely on a combination of two or more programs. (This indicator differs from SUM 1 because it focus on monthly receipt, rather than annual receipt, and examines program receipt for each program separately and in various combinations. This indicator differs from Indicator 3 in that it includes all members of a family that receive benefits from one of these programs, rather than just the actual recipients themselves as reflected in administrative data). Indicator 6: Dependence Transitions. This indicator uses data from the Survey of Income and Program Participation (SIPP) to look at whether individuals dependent on welfare (AFDC\/TANF, FSP\/SNAP, and\/or SSI) in one year make the transition out of dependence in the following year. Indicator 7: Program Spell Duration. One critical aspect of dependence is how long individuals receive means-tested assistance. This indicator provides information on short, medium and long spells of welfare receipt for each of the three major means-tested programs AFDC\/TANF, the SNAP, and SSI. Indicator 8: Welfare Spell Duration with No Labor Force Attachment. This indicator is concerned with dynamics of welfare receipt among persons in families with no attachment to the labor market. It differs from Indicator 7 in that it provides information on spells of TANF receipt during months where no one in the family worked or was officially unemployed. Indicator 9: Long Term AFDC\/TANF Receipt. Many individuals who leave welfare programs cycle back on after an absence of several months. Thus it is important to look beyond individual program spells, measured in Indicator 7, to examine the cumulative amount of time individuals receive assistance over a period of several years. Indicator 10: Events Associated with the Beginning and Ending of AFDC\/TANF Spells. To gain a better understanding of welfare dynamics, it is important to go beyond measures of spell duration and examine information regarding the major events in people’s lives that are correlated with the beginnings or endings of program spells. This measure focuses on receipt of TANF. II-2 INDICATOR 1. Degree of Dependence Figure IND 1a. Percentage of Total Income from Means-Tested Assistance Programs: 2009 Note: Means-tested assistance includes TANF, SSI and SNAP benefits. Total >50% includes all persons with more than 50 percent of their total annual family income from these means-tested programs. Income includes cash income and the value of SNAP benefits. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010, analyzed using the TRIM3 microsimulation model. Figure IND 1a shows the percentage of persons in families with varying degrees of dependence on the TANF, SNAP, and\/or SSI programs in 2009. The majority of persons (80.1 percent) lived in families that received no income from these means-tested assistance programs in 2009. One-fifth (19.9 percent) of all persons lived in families that received some income from one of these programs during the year. Almost 5 (4.6) percent of persons lived in families that received more than half of their annual income from these means-tested assistance programs. These persons would be considered welfare dependent under the definition of dependence used in this report.18 Table IND 1a shows the percentage of persons in families with varying degrees of reliance on income from these programs by demographic characteristics. Welfare dependence varies across demographic groups. 18 For a discussion on defining welfare dependence, please see Measuring Welfare Dependence in Chapter I. Among racial and ethnic groups, Non- Hispanic Blacks were more likely to be welfare dependent (11.1 percent) than were Non-Hispanic Whites (2.7 percent) or Hispanics of any race (7.1 percent). Among age categories, children, particularly from birth to 5 years of age, were more likely to live in families that were welfare dependent than were persons age 16 and older. Among family types, persons living in female-headed families were more likely to be welfare dependent than those in other family categories. Table IND 1b shows trends in welfare dependence between 1993 and 2009. Welfare dependence was highest in 1993 at 5.9 percent, but then declined to 3.0 percent in 2000. After 2000, dependence increased steadily, reaching 4.6 percent in 2009. 80.1 11.4 3.9 4.6 0% > 0% and <= 25% > 25% and <=50% Total > 50% II-3 Table IND 1a. Percentage of Total Annual Income from Means-Tested Assistance Programs by Selected Characteristics: 2009 0% > 0% and <= 25% > 25% and <= 50% > 50% and <= 75% > 75% and <= 100% Total > 50% All Persons 80.1 11.4 3.9 1.5 3.1 4.6 Racial\/Ethnic Categories Non-Hispanic White 86.7 8.2 2.4 0.8 1.9 2.7 Non-Hispanic Black 62.4 18.6 7.9 3.5 7.6 11.1 Hispanic 67.1 19.0 6.8 2.4 4.6 7.1 Age Categories Children ages 0-5 65.7 17.1 8.1 3.2 5.8 9.1 Children ages 6-10 69.6 16.0 7.0 2.8 4.7 7.5 Children ages 11-15 72.6 15.1 6.0 2.3 4.1 6.3 Women ages 16-64 80.2 11.2 3.7 1.5 3.4 4.8 Men ages 16-64 84.0 10.3 2.6 0.8 2.4 3.2 Adults ages 65 and over 88.7 7.1 2.0 0.7 1.5 2.2 Family Categories Persons in married-couple families 87.5 8.6 2.3 0.7 0.9 1.6 Persons in female-headed families 49.6 23.5 12.2 5.1 9.5 14.6 Persons in male-headed families 66.9 20.5 6.2 2.1 4.3 6.4 Unrelated persons 84.5 8.1 1.5 0.8 5.1 5.8 Note: Means-tested assistance includes TANF, SSI and SNAP. Total >50% includes all persons with more than 50 percent of their total annual family income from these means-tested programs. Income includes cash income and the value of SNAP benefits. Spouses are not present in the female- headed and male-headed family categories. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010, analyzed using the TRIM3 microsimulation model. Table IND 1b. Percentage of Total Income from Means-Tested Assistance Programs: 1993-2009 0% > 0% and <= 25% > 25% and <= 50% > 50% and <= 75% > 75% and <= 100% Total > 50% 1993 83.4 7.8 3.0 1.8 4.1 5.9 1994 82.8 8.4 3.1 1.8 4.0 5.8 1995 83.2 8.5 3.1 1.8 3.5 5.3 1996 84.0 7.8 3.1 1.9 3.3 5.2 1997 85.3 7.7 2.5 1.5 3.1 4.5 1998 86.5 7.3 2.5 1.3 2.5 3.8 1999 86.7 7.7 2.3 1.1 2.2 3.3 2000 87.5 7.3 2.2 1.0 2.0 3.0 2001 87.4 7.3 2.2 1.0 2.1 3.1 2002 86.8 7.8 2.3 1.0 2.1 3.2 2003 85.9 8.2 2.4 1.1 2.4 3.6 2004 85.0 8.8 2.5 1.1 2.5 3.7 2005 84.7 8.9 2.6 1.1 2.7 3.8 2006 84.4 9.3 2.6 1.1 2.6 3.7 2007 84.1 9.7 2.8 1.1 2.3 3.4 2008 82.9 10.3 2.8 1.1 2.8 4.0 2009 80.1 11.4 3.9 1.5 3.1 4.6 Note: Means-tested assistance includes TANF, SSI and SNAP. Total >50% includes all persons with more than 50 percent of their total annual family income from these means-tested programs. Income includes cash income and the value of SNAP benefits. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010, analyzed using the TRIM3 microsimulation model. II-4 Figure IND 1b. Percentage of Total Income from Various Sources by Poverty Status: 2009 Note: Total income is total annual family income, including the value of SNAP benefits. Other income is non-means-tested, non-earnings income such as child support, alimony, pensions, Social Security benefits, interest and dividends. Poverty status categories are not mutually exclusive. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010, analyzed using the TRIM3 microsimulation model. Figure IND 1b shows sources of income by poverty status in 2009. There is an association between poverty status and the percentage of total income received from the TANF, SNAP, and\/or SSI programs. Those who are poorer are more likely to receive more of their income from these three sources than they are from wages. Persons in families with incomes below the poverty line received 44.2 percent of their income from earnings and 35.8 percent from TANF, SNAP, and SSI. Persons in families with incomes at 200 percent or more of the poverty line received 85.8 percent of their income from earnings and 0.2 percent of their income from these means-tested assistance programs. The percentage of family income that comes from earnings is directly proportional to overall family income relative to the poverty line. For example, the percentage of income received from earnings for persons in families living in deep poverty (below 50 percent of the poverty line) was 25.2 percent compared to 44.2 percent. Table IND 1c shows the percentage of income from various sources by poverty status for various demographic groups. On average, persons in married-couple families and male heads of household rely on earnings more than do female heads of households. Table IND 1d shows the percentage of income from various sources across selected years. The percentage of income received from earnings for persons in families with incomes below the poverty line increased from 40.4 percent in 1995 to a high of 49.5 percent in 2000. In 2009, the rate was 44.2 percent. Over the same time period, the percentage of income from the AFDC\/TANF, FSP\/SNAP, and\/or SSI programs among persons in poor families decreased from 41.3 percent in 1995 to 30.3 percent in 2000. In 2009, the rate was 35.8 percent. 62.0 35.8 13.6 0.2 1.6 12.8 20.0 23.6 14.0 15.0 25.2 44.2 62.8 85.8 83.4 0 20 40 60 80 100 <50% of poverty <100% of poverty <200% of poverty 200%+ of poverty All income levels (In percent) TANF, SSI & SNAP Earnings Other income II-5 Table IND 1c. Percentage of Total Income from Various Sources by Poverty Status and Selected Characteristics: 2009 <50% Poverty <100% of Poverty <200% of Poverty 200%+ of Poverty All Persons All Persons TANF, SSI and SNAP 62.0 35.8 13.6 0.2 1.6 Earnings 25.2 44.2 62.8 85.8 83.4 Other income 12.8 20.0 23.6 14.0 15.0 Racial\/Ethnic Categories Non-Hispanic White 57.8 33.4 10.3 0.1 0.8 TANF, SSI and SNAP 27.2 40.0 58.1 84.8 83.0 Earnings 14.9 26.6 31.6 15.1 16.2 Other income Non-Hispanic Black TANF, SSI and SNAP 68.6 44.2 20.9 0.5 4.8 Earnings 18.2 33.8 55.3 85.6 79.1 Other income 13.2 22.0 23.8 13.9 16.0 Hispanic TANF, SSI and SNAP 60.6 31.8 13.7 0.6 3.9 Earnings 29.3 56.1 74.2 89.6 85.7 Other income 10.1 12.1 12.1 9.7 10.3 Age Categories Children ages 0-5 TANF, SSI and SNAP 66.9 39.3 17.6 0.2 3.2 Earnings 23.0 48.3 71.1 94.3 90.3 Other income 10.1 12.4 11.3 5.5 6.5 Children ages 6-10 TANF, SSI and SNAP 66.1 38.7 16.2 0.2 2.7 Earnings 23.4 47.6 70.8 93.4 89.8 Other income 10.5 13.7 13.1 6.4 7.5 Children ages 11-15 TANF, SSI and SNAP 65.0 39.4 15.6 0.2 2.4 Earnings 22.5 44.1 68.6 92.0 88.7 Other income 12.5 16.5 15.8 7.8 8.9 Women ages 16-64 TANF, SSI and SNAP 61.0 36.4 14.3 0.2 1.5 Earnings 25.3 43.2 65.4 88.8 86.7 Other income 13.7 20.3 20.3 10.9 11.8 Men ages 16-64 TANF, SSI and SNAP 54.0 30.9 11.0 0.2 1.0 Earnings 32.2 48.8 69.2 90.0 88.4 Other income 13.8 20.3 19.8 9.8 10.6 Adults ages 65 and over TANF, SSI and SNAP 39.9 25.9 7.7 0.3 1.1 Earnings 10.1 8.4 11.1 40.0 36.9 Other income 50.0 65.7 81.2 59.7 62.0 Family Categories Persons in married-couple families TANF, SSI and SNAP 56.4 28.8 9.2 0.2 0.8 Earnings 34.1 56.0 71.3 86.9 85.8 Other income 9.6 15.2 19.5 13.0 13.4 Persons in female-headed families TANF, SSI and SNAP 69.7 45.3 24.1 0.9 8.3 Earnings 17.3 35.6 54.2 80.6 72.2 Other income 13.0 19.1 21.7 18.5 19.5 Persons in male-headed families TANF, SSI and SNAP 62.9 37.8 15.3 0.8 3.1 Earnings 23.3 41.0 63.2 86.7 83.0 Other income 13.8 21.2 21.4 12.5 13.9 Note: Total income is total annual family income, including the value of SNAP benefits. Other income is non-means-tested, non-earnings income such as child support, alimony, pensions, Social Security benefits, interest and dividends. Poverty status categories are not mutually exclusive. Spouses are not present in the female-headed and male-headed family categories. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010, analyzed using the TRIM3 microsimulation model. II-6 Table IND 1d. Percentage of Total Income from Various Sources: Selected Years < 50% Poverty <100% of Poverty <200% of Poverty 200%+ of Poverty 1995 AFDC, SSI and SNAP 65.9 41.3 14.2 0.3 Earnings 22.5 40.4 64.8 85.4 Other income 11.6 18.3 21.0 14.3 1998 AFDC, SSI and SNAP 58.9 32.0 10.6 0.2 Earnings 27.0 47.9 67.8 85.3 Other income 14.1 20.1 21.6 14.5 2000 TANF, SSI and SNAP 54.3 30.3 9.8 0.2 Earnings 30.5 49.5 68.7 86.7 Other income 15.2 20.3 21.5 13.0 2004 TANF, SSI and SNAP 58.4 31.1 10.4 0.2 Earnings 25.7 48.2 67.2 86.8 Other income 15.9 20.7 22.4 13.0 2005 TANF, SSI and SNAP 58.5 32.5 10.4 0.2 Earnings 25.3 46.6 68.2 86.6 Other income 16.2 20.8 21.4 13.2 2006 TANF, SSI and SNAP 58.2 31.4 10.4 0.2 Earnings 27.7 48.3 68.6 86.5 Other income 14.1 20.3 21.0 13.3 2009 TANF, SSI and SNAP 62.0 35.8 13.6 0.2 Earnings 25.2 44.2 62.8 85.8 Other income 12.8 20.0 23.6 14.0 Note: Total income is total annual family income, including the value of SNAP benefits. Other income is non-means-tested, non-earnings income such as child support, alimony, pensions, Social Security benefits, interest and dividends. Poverty status categories are not mutually exclusive. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1996-2010, analyzed using the TRIM3 microsimulation model. II-7 INDICATOR 2. Receipt of Means-Tested Assistance and Labor Force Attachment Figure IND 2. Percentage of Recipients in Families with Labor Force Participants by Program: 2009 Note: Recipients are limited to those individuals or family members directly receiving benefits in a month. Full-time workers are those who usually work 35 hours or more per week. Part-time labor force participation includes part-time workers and those who are unemployed, laid off and\/or looking for work. This indicator measures, on an average monthly basis, the combination of individual benefit receipt and labor force participation by any family member in the same month. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009, analyzed using the TRIM3 microsimulation model. Figure IND 2 shows the average monthly percentage of recipients in families with labor force participants by program.19 In 2009, SSI recipients were more likely to live in families with no labor force participants (58.9 percent) than were TANF recipients (43.3 percent) or SNAP recipients (38.0 percent). Sixty-two percent of SNAP recipients live in families with someone in the labor force. Table IND 2a shows the average monthly percentage of recipients in families with labor force participants by program and demographic characteristics. Among TANF recipients, Non-Hispanic Whites were less likely to live in families with at least one full-time worker (17.7 percent) 19 Note that lower family employment rates are reported in TANF administrative data, which are limited to the employment of family members in the TANF assistance unit and employment reported to welfare agencies (see Table TANF 7 in Appendix A). than were Non-Hispanic Blacks (22.3 percent) or Hispanics of any race (35.9 percent). Among TANF recipients, 41.2 percent of persons in married-couple families lived with at least one full-time worker compared to 19.6 percent of persons in female-headed families, and 31.8 percent of persons in male-headed families. Table IND 2b shows the average monthly percentage of AFDC\/TANF recipients living in families with labor force participants by year. The percentage of recipients living in families with at least one full-time worker increased from 18.8 percent in 1993 to 35.3 percent in 2001 and then declined to 26.0 percent in 2009. (In percent) 43.3 38.0 58.9 30.7 29.7 13.7 26.0 32.3 27.4 0 20 40 60 80 100 TANF SNAP SSI At least one full-time worker At least one person in the labor force, no full-time participants No one in labor force II-8 Table IND 2a. Percentage of Recipients in Families with Labor Force Participants by Program and Selected Characteristics: 2009 No One in LF At Least One in LF, No One FT At Least One FT Worker TANF All Persons 43.3 30.7 26.0 Non-Hispanic White 48.3 34.1 17.7 Non-Hispanic Black 49.4 28.4 22.3 Hispanic 32.8 31.3 35.9 Children ages 0-5 40.9 29.8 29.3 Children ages 6-10 44.3 29.9 25.9 Children ages 11-15 49.5 28.4 22.0 Women ages 16-64 45.0 31.2 23.8 Men ages 16-64 33.0 38.4 28.6 Adults ages 65 and over 86.4 0.0 13.6 Persons in married-couple families 23.6 35.3 41.2 Persons in female-headed families 52.2 28.2 19.6 Persons in male-headed families 33.2 34.9 31.8 Unrelated persons 34.9 53.4 11.8 SNAP All Persons 38.0 29.7 32.3 Non-Hispanic White 41.0 31.0 28.0 Non-Hispanic Black 40.9 28.7 30.4 Hispanic 30.0 28.4 41.6 Children ages 0-5 27.3 31.1 41.6 Children ages 6-10 27.4 30.5 42.1 Children ages 11-15 31.3 29.7 39.0 Women ages 16-64 41.0 30.3 28.7 Men ages 16-64 38.5 33.3 28.2 Adults ages 65 and over 84.9 8.0 7.1 Persons in married-couple families 22.8 29.8 47.4 Persons in female-headed families 38.3 31.1 30.6 Persons in male-headed families 31.2 33.7 35.1 Unrelated persons 71.8 23.5 4.7 SSI All Persons 58.9 13.7 27.4 Non-Hispanic White 63.0 13.9 23.1 Non-Hispanic Black 63.2 13.4 23.4 Hispanic 48.2 14.3 37.6 Children ages 0-5 33.3 25.0 41.8 Children ages 6-10 41.7 23.9 34.4 Children ages 11-15 39.7 21.8 38.5 Women ages 16-64 66.1 13.1 20.9 Men ages 16-64 57.4 14.0 28.6 Adults ages 65 and over 63.4 8.7 27.9 Persons in married-couple families 33.3 16.3 50.5 Persons in female-headed families 52.5 18.0 29.5 Persons in male-headed families 44.3 17.3 38.4 Unrelated persons 92.5 6.0 1.5 Note: Recipients are limited to those individuals or family members directly receiving benefits in a month. Full-time workers are those who usually work 35 hours or more per week. Part-time labor force participation includes part-time workers and those who are unemployed, laid off and\/or looking for work. This indicator measures, on an average monthly basis, the combination of individual benefit receipt and labor force participation by any family member in the same month. Spouses are not present in the female-headed and male-headed family categories. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009, analyzed using the TRIM3 microsimulation model. II-9 Table IND 2b. Percentage of AFDC\/TANF Recipients in Families with Labor Force Participants: 1993-2009 No One in LF At Least One in LF, No One FT At Least One FT Worker 1993 57.0 24.2 18.8 1994 54.8 24.8 20.4 1995 50.6 24.3 25.1 1996 50.1 25.6 24.3 1997 47.6 28.0 24.4 1998 44.3 25.8 29.9 1999 40.8 24.1 35.1 2000 41.2 24.1 34.7 2001 38.7 26.0 35.3 2002 39.8 25.8 34.3 2003 47.4 24.1 28.5 2004 48.0 23.8 28.1 2005 47.7 25.4 26.9 2006 46.6 21.2 32.2 2007 46.4 23.4 30.2 2008 45.6 27.2 27.2 2009 43.3 30.7 26.0 Note: Recipients are limited to those individuals or family members directly receiving benefits in a month. Full-time workers are those who usually work 35 hours or more per week. Part-time labor force participation includes part-time workers and those who are unemployed, laid off and\/or looking for work. This indicator measures, on an average monthly basis, the combination of individual benefit receipt and labor force participation by any family member in the same month. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994 - 2009, analyzed using the TRIM3 microsimulation model. II-10 INDICATOR 3. Rates of Receipt of Means-Tested Assistance Figure IND 3a. Percentage of the Total Population Receiving AFDC\/TANF: 1970-2009 Note: See Appendix A, Tables TANF 2, TANF 12 and TANF 14, for more detailed data on recipiency rates, including recipiency rates by calendar year. Recipients are expressed as the fiscal year average of monthly caseloads from administrative data, excluding recipients in the territories. Tribal TANF recipients also are excluded. Child recipients include a small number of dependents ages 18 and older who are students. The average number of adult and child recipients in 1998 and 1999 are estimated using data from the National Emergency TANF Data Files and thereafter using the National TANF Data Files. Beginning in 2000, the data include both TANF and SSP (Separate State Program) recipients who have comprised as much as 11 percent of total recipients. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. Population denominators for the percents in each category are from the U.S. Census Bureau (available online at http:\/\/www.census.gov). Figure IND 3a shows the average monthly percentage of the population who received income from the AFDC\/TANF program overall and by age group from 1970 to 2009. Table IND 3a shows the average monthly number and percentage of the population receiving AFDC\/TANF, by age, between 1970 and 2009. In 1993, 5.4 percent of the population received income from AFDC. In 2008 the average monthly TANF recipiency rate was 1.3 percent. Average monthly AFDC\/TANF recipiency rates have been higher and have had more pronounced changes over time for children than recipiency rates for adults. Between 1993 and 2008, the average monthly AFDC\/TANF recipiency rate among children decreased from 13.9 percent to 4.1 percent. However for 2009, the downward trend ceased and the rate increased to 4.3 percent. Average monthly AFDC\/TANF recipiency rates dropped below 1970 levels in the late 1990s for both adults and children and have stayed well below those levels in the 2000s. However the rates for both adults and children increased slightly in 2009. 3.5 All persons 1.4 1.4 Adults 0.4 7.6 Children 4.3 0 2 4 6 8 10 12 14 16 1970 1975 1980 1985 1990 1995 2000 2005 2009 (In percent) II-11 http:\/\/www.census.gov\/\ufffd Table IND 3a. Number and Percentage of the Total Population Receiving AFDC\/TANF by Age: 1970-2009 Total Recipients Adult Recipients Child Recipients Fiscal Year Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent 1970 7,188 3.5 1,863 1.4 5,325 7.6 1971 9,281 4.5 2,516 1.8 6,765 9.7 1972 10,345 4.9 2,848 2.0 7,497 10.8 1973 10,760 5.1 2,984 2.1 7,776 11.3 1974 10,591 5.0 2,935 2.0 7,656 11.3 1975 10,854 5.0 3,102 2.1 7,753 11.5 1976 11,171 5.1 3,271 2.2 7,900 11.9 1977 10,933 5.0 3,230 2.1 7,703 11.8 1978 10,485 4.7 3,128 2.0 7,357 11.4 1979 10,146 4.5 3,068 1.9 7,071 11.0 1980 10,422 4.6 3,225 2.0 7,197 11.3 1981 10,979 4.8 3,491 2.1 7,488 11.8 1982 10,233 4.4 3,396 2.0 6,838 10.9 1983 10,467 4.5 3,548 2.1 6,919 11.1 1984 10,677 4.5 3,652 2.1 7,025 11.2 1985 10,630 4.5 3,589 2.0 7,041 11.2 1986 10,810 4.5 3,637 2.1 7,173 11.4 1987 10,878 4.5 3,625 2.0 7,254 11.5 1988 10,734 4.4 3,536 2.0 7,198 11.4 1989 10,741 4.4 3,503 1.9 7,238 11.4 1990 11,263 4.5 3,643 2.0 7,620 11.9 1991 12,391 4.9 4,016 2.1 8,375 12.8 1992 13,423 5.2 4,335 2.3 9,087 13.7 1993 13,943 5.4 4,520 2.3 9,424 13.9 1994 14,033 5.3 4,554 2.3 9,479 13.8 1995 13,480 5.1 4,323 2.2 9,157 13.2 1996 12,477 4.6 3,921 2.0 8,556 12.2 1997 10,779 4.0 3,106 1.5 7,673 10.8 1998 8,653 3.1 2,469 1.2 6,184 8.7 1999 7,068 2.5 1,838 0.9 5,231 7.3 2000 6,218 2.2 1,687 0.8 4,531 6.3 2001 5,673 2.0 1,503 0.7 4,171 5.7 2002 5,576 1.9 1,477 0.7 4,099 5.6 2003 5,452 1.9 1,415 0.7 4,037 5.5 2004 5,316 1.8 1,358 0.6 3,957 5.4 2005 5,064 1.7 1,276 0.6 3,788 5.1 2006 4,699 1.6 1,164 0.5 3,535 4.8 2007 4,099 1.4 962 0.4 3,138 4.2 2008 3,949 1.3 927 0.4 3,022 4.1 2009 4,217 1.4 1,021 0.4 3,196 4.3 Note: See Appendix A, Tables TANF 2, TANF 12 and TANF 14, for more detailed data on recipiency rates, including recipiency rates by calendar year. Recipients are expressed as the fiscal year average of monthly caseloads from administrative data, excluding recipients in the territories. Tribal TANF recipients also are excluded. Child recipients include a small number of dependents ages 18 and older who are students. The average number of adult and child recipients in 1998 and 1999 are estimated using data from the National Emergency TANF Data Files and thereafter using the National TANF Data Files. Beginning in 2000, the data include both TANF and SSP (Separate State Program) recipients who have comprised as much as 11 percent of total recipients. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. Population denominators for the percents in each category are from the U.S. Census Bureau (available online at http:\/\/www.census.gov). II-12 http:\/\/www.census.gov\/\ufffd Figure IND 3b. Percentage of the Total Population Receiving SNAP by Age: 1975-2009 Note: See Appendix A, Tables SNAP 1 and SNAP 6 for more detailed data on recipiency rates. Recipient totals exclude the territories and are the fiscal year averages of monthly caseloads from administrative data. From 1975 to 1983 the number of participants includes the Family Food Assistance Program (FFAP) that was largely replaced by the Food Stamp Program in 1975. From 1975 to 1983 the number of FFAP participants averaged only 88 thousand. Source: Recipient data by age from U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and Evaluation, Characteristics of Food Stamp Households, Fiscal Year 2009, No. SNAP-09-CHAR and earlier reports (available online at http:\/\/www.fns.usda.gov\/oane\/menu\/Published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf), and unpublished data from the Data Bank. Population denominators for the percents in each category are from U.S. Census Bureau (available online at http:\/\/www.census.gov). Figure IND 3b shows the average monthly percentage of the population who received FSP\/SNAP by age category from 1975 to 2009. The average monthly FSP\/SNAP recipiency rate for all persons increased to 10.7 percent in 2009 from a low of 6.1 percent in 2000 and 2001. The 2009 recipiency rate surpassed the peak rate of 10.4 percent experienced in 1993 and 1994. The 2009 FSP\/SNAP recipiency rate is the highest in the history of food assistance programs in the U.S. As with AFDC\/TANF, average monthly FSP\/SNAP recipiency rates have been higher over time for children than for adults. Between 1980 and 2009, the percentage of all children who received SNAP benefits was more than double that of the adult recipiency rate. Among adults ages 18- 59 years old, 9.1 percent received SNAP benefits compared to 20.9 percent of children 0 18 years of age in 2009. Table IND 3b shows the average monthly number and percentage of the population receiving Food Stamps\/SNAP by age group from 1975 to 2009. While the levels are different, the trend in Food Stamp\/SNAP recipiency for children and adults 18 59 years of age are similar over the time period. The trends may largely reflect changes in the rate of unemployment and programmatic changes. The average monthly percentage of all persons receiving SNAP benefits declined between 1983 and 1988 and then increased in the early 1990s reaching a peak rate in 1993 and 1994 (10.4 percent). The percentage then declined through 2000 and since then has risen to 10.7 percent in 2009 surpassing the 1993\/1994 peak rate. 7.6 All persons 10.7 4.9 Adults 60 & over 4.9 5.6 Adults 18-59 9.1 15.5 Children 21.0 0 5 10 15 20 25 1975 1980 1985 1990 1995 2000 2005 2009 (In percent) II-13 http:\/\/www.census.gov\/\ufffd Table IND 3b. Number and Percentage of the Total Population Receiving SNAP benefits: 1975-2009 Total Recipients Adult Recipients Ages 60 and over Adult Recipients Ages 18-59 Child Recipients Ages 0-18 Fiscal Year Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent 1975 16,320 7.6 1976 17,033 7.8 9,126 13.8 1977 15,604 7.1 1978 14,405 6.5 1979 15,942 7.1 1980 19,253 8.5 1,741 4.9 7,186 5.6 9,876 15.5 1981 20,655 9.0 1,845 5.0 7,811 6.0 9,803 15.5 1982 20,391 8.8 1,641 4.4 7,838 6.0 9,591 15.3 1983 21,668 9.3 1,654 4.4 8,960 6.7 10,910 17.4 1984 20,796 8.8 1,758 4.5 8,521 6.3 10,492 16.8 1985 19,847 8.3 1,783 4.5 8,258 6.1 9,801 15.8 1986 19,381 8.1 1,631 4.1 7,895 5.7 9,844 15.7 1987 19,072 7.9 1,589 3.9 7,684 5.5 9,771 15.5 1988 18,613 7.6 1,500 3.7 7,506 5.3 9,351 14.8 1989 18,778 7.6 1,582 3.8 7,560 5.3 9,429 14.9 1990 20,020 8.0 1,511 3.6 8,084 5.6 10,127 15.8 1991 22,599 8.9 1,593 3.8 9,190 6.3 11,952 18.3 1992 25,371 9.9 1,687 3.9 10,550 7.2 13,349 20.1 1993 26,957 10.4 1,876 4.3 11,214 7.5 14,196 21.0 1994 27,439 10.4 1,955 4.5 11,615 7.7 14,391 21.0 1995 26,579 10.0 1,920 4.4 11,105 7.3 13,860 20.0 1996 25,495 9.5 1,891 4.3 10,769 7.0 13,189 18.8 1997 22,820 8.4 1,831 4.1 9,373 6.0 11,847 16.7 1998 19,748 7.2 1,635 3.6 7,760 4.9 10,524 14.7 1999 18,114 6.5 1,696 3.7 7,079 4.4 9,332 13.0 2000 17,054 6.0 1,700 3.7 6,612 4.0 8,743 12.1 2001 17,262 6.1 1,658 3.6 6,778 4.1 8,819 12.1 2002 19,003 6.6 1,684 3.6 7,625 4.5 9,688 13.3 2003 20,898 7.2 1,786 3.7 8,503 5.0 10,605 14.5 2004 23,447 8.0 1,917 3.9 9,753 5.7 11,771 16.1 2005 24,841 8.4 2,044 4.1 10,390 6.0 12,405 16.9 2006 25,555 8.6 2,226 4.4 12,758 7.3 12,579 17.1 2007 25,887 8.6 2,263 4.3 13,030 7.4 12,695 17.2 2008 27,751 9.1 2,517 4.7 14,145 8.0 13,472 18.2 2009 32,842 10.7 2,724 4.9 16,181 9.1 15,589 21.0 Note: See Appendix A, Tables FSP 1 and FSP 6 for more detailed data on recipiency rates. Recipient totals exclude the territories and are the fiscal year averages of monthly caseloads from administrative data. From 1975 to 1983 the number of participants includes the Family Food Assistance Program (FFAP) that was largely replaced by the Food Stamp Program in 1975. From 1975 to 1983 the number of FFAP participants averaged only 88 thousand. Source: Recipient data by age from U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and Evaluation, Characteristics of Food Stamp Households, Fiscal Year 2009, No. SNAP-09-CHAR and earlier reports (available online at http:\/\/www.fns.usda.gov\/oane\/MENU\/published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf), and unpublished data from the Food Stamp National Data Bank. Individual age groups do not sum exactly to total recipients. The population denominators for the percentage in each category are from U.S. Census Bureau (available online at http:\/\/www.census.gov). II-14 http:\/\/www.census.gov\/\ufffd Figure IND 3c. Percentage of the Total Population Receiving SSI by Age: 1975-2009 Note: Population figures used as the denominators are obtained by averaging the U.S. Census Bureau's July 1 population estimates for the current and the following year. See Appendix A, Tables SSI 2, SSI 8 and SSI 9 for more detailed data on SSI recipiency rates. Source: Social Security Administration, Office of Research, Evaluation and Statistics, SSI Annual Statistical Report, 2009, (available online at http:\/\/www.ssa.gov\/policy). Population denominators for the percentage in each category are from the U.S. Census Bureau (available online at http:\/\/www.census.gov). Figure IND 3c shows the percentage of the population who received income assistance from the SSI program by age category in the month of December from 1975 through 2009. Unlike the average monthly recipiency rates for AFDC\/TANF and FSP\/SNAP, the December monthly SSI recipiency rates show less variation over time. After decreasing from 1975 to the early 1980s, the proportion of the total population that received SSI increased from 1.7 percent in 1985 to 2.4 percent in 1994. The rate has remained roughly constant since then, increasing to 2.5 percent in 2008 and 2009. The total number of recipients has increased more than 80 percent since the mid-1980s, from 4.1 million in 1985 to roughly 7.7 million people in 2009. Table IND 3c shows the December percentage of the population and number of persons receiving SSI by age group between 1975 and 2009. Elderly adults (ages 65 and older) have higher monthly recipiency rates than any other age group. The gap, however, has narrowed as the percentage of adults aged 65 and older receiving SSI has declined from 10.9 percent in 1975 to 5.1 percent in 2009. The proportion of children receiving SSI increased gradually between 1975 and 1990, and grew more rapidly in the early and mid-1990s, reaching 1.4 percent in 1996. The December rate then fell through 2000 before rising to 1.6 percent in 2008 where it has remained. 2.0 All persons 2.5 10.9 Adults 65 & over 5.1 1.3 Adults 18-64 2.3 0.2 Children 1.6 0 2 4 6 8 10 12 1975 1980 1985 1990 1995 2000 2005 2009 (In percent) II-15 http:\/\/www.ssa.gov\/policy\ufffd http:\/\/www.census.gov\/\ufffd Table IND 3c. Number and Percentage of the Total Population Receiving SSI by Age: 1975-2009 Total Recipients Adult Recipients Ages 65 & over Adult Recipients Ages 18-64 Child Recipients Ages 0-17 Date Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent Dec 1975 4,314 2.0 2,508 10.9 1,699 1.3 107 0.2 Dec 1976 4,236 1.9 2,397 10.2 1,714 1.3 125 0.2 Dec 1977 4,239 1.9 2,353 9.7 1,738 1.3 147 0.2 Dec 1978 4,217 1.9 2,304 9.3 1,747 1.3 166 0.3 Dec 1979 4,150 1.8 2,246 8.8 1,727 1.3 177 0.3 Dec 1980 4,142 1.8 2,221 8.6 1,731 1.3 190 0.3 Dec 1981 4,019 1.7 2,121 8.0 1,703 1.2 195 0.3 Dec 1982 3,858 1.7 2,011 7.4 1,655 1.2 192 0.3 Dec 1983 3,901 1.7 2,003 7.3 1,700 1.2 198 0.3 Dec 1984 4,029 1.7 2,037 7.2 1,780 1.2 212 0.3 Dec 1985 4,138 1.7 2,031 7.1 1,879 1.3 227 0.4 Dec 1986 4,269 1.8 2,018 6.9 2,010 1.4 241 0.4 Dec 1987 4,385 1.8 2,015 6.8 2,119 1.4 251 0.4 Dec 1988 4,464 1.8 2,006 6.6 2,203 1.5 255 0.4 Dec 1989 4,593 1.9 2,026 6.5 2,302 1.5 265 0.4 Dec 1990 4,817 1.9 2,059 6.5 2,450 1.6 309 0.5 Dec 1991 5,118 2.0 2,080 6.5 2,642 1.7 397 0.6 Dec 1992 5,566 2.2 2,100 6.4 2,910 1.8 556 0.8 Dec 1993 5,984 2.3 2,113 6.4 3,148 2.0 723 1.1 Dec 1994 6,296 2.4 2,119 6.3 3,335 2.1 841 1.2 Dec 1995 6,514 2.4 2,115 6.2 3,482 2.1 917 1.3 Dec 1996 6,634 2.4 2,110 6.2 3,568 2.2 955 1.4 Dec 1997 6,495 2.4 2,054 6.0 3,562 2.1 880 1.2 Dec 1998 6,566 2.4 2,033 5.9 3,646 2.1 887 1.2 Dec 1999 6,557 2.3 2,019 5.8 3,691 2.1 847 1.2 Dec 2000 6,602 2.3 2,011 5.7 3,744 2.1 847 1.2 Dec 2001 6,688 2.3 1,995 5.6 3,811 2.1 882 1.2 Dec 2002 6,788 2.4 1,995 5.6 3,878 2.2 915 1.3 Dec 2003 6,902 2.4 1,990 5.5 3,953 2.2 959 1.3 Dec 2004 6,988 2.4 1,978 5.4 4,017 2.2 993 1.4 Dec 2005 7,114 2.4 1,995 5.4 4,083 2.2 1,036 1.4 Dec 2006 7,236 2.4 2,004 5.3 4,152 2.2 1,079 1.5 Dec 2007 7,360 2.4 2,017 5.3 4,222 2.2 1,121 1.5 Dec 2008 7,521 2.5 2,034 5.2 4,333 2.3 1,154 1.6 Dec 2009 7,677 2.5 2,026 5.1 4,451 2.3 1,200 1.6 Note: December population figures used as the denominators are obtained by averaging the U.S. Census Bureau's July 1 population estimates for the current and the following year. See Appendix A, Tables SSI 2, SSI 8 and SSI 9 for more detailed data on SSI recipiency rates. Source: Social Security Administration, Office of Research, Evaluation and Statistics, SSI Annual Statistical Report, 2009, (available online at http:\/\/www.ssa.gov\/policy). Population denominators for the percents in each category are from the U.S. Census Bureau (available online at http:\/\/www.census.gov). II-16 http:\/\/www.ssa.gov\/policy\ufffd http:\/\/www.census.gov\/\ufffd INDICATOR 4. Rates of Participation in Means-Tested Assistance Programs Figure IND 4. Participation Rates in the AFDC\/TANF 1 , SNAP and SSI Programs: Selected Years 1 Unlike the SNAP and SSI programs, TANF is a block grant program for which there is no individual entitlement. One of the main goals of TANF is to move people from cash assistance to self-sufficiency. Note: AFDC\/TANF and SSI participation rates are estimated by an Urban Institute model (TRIM3) that uses CPS data to simulate program eligibility and participation for an average month, by calendar year. There have been small changes in estimating methodology over time, due to model improvements and revisions to the CPS. Most notably, since 1994 the model has been revised to more accurately estimate SSI participation among children, and in 1997 and 1998 the model was adjusted to more accurately exclude ineligible immigrants. For TANF, in contrast to editions prior to 2004, this table includes families receiving assistance under Separate State Programs (SSPs). Note that families subject to full-family sanctions are counted as nonparticipating eligible families due to modeling limitations. Although the coverage rate estimates take into account the number of families who lost aid due to the time limit (and do not count such families in the denominator of the coverage rate estimate), they do not make any allowance for families staying off TANF to conserve their time-limited assistance months. Also, the numbers of eligible and participating families include the territories and pregnant women without children, even though these two small groups are excluded from the TRIM model. The numbers shown here implicitly assume that participation rates for the territories and for pregnant women with no other children are the same as for all other eligibles. In 2004 the methods for identifying potential child-only units capture the fact that non-parent caretakers generally have a choice of whether or not to be included in the TANF unit. TRIM now excludes those caretakers whose income would make the unit ineligible, increasing the number of potential child-only units. SNAP eligible households are estimated from a Mathematica Policy Research, Inc. model that uses CPS data to simulate program eligibility. SNAP caseload data are from USDA, FNS program operations caseload data. There have been small changes in the methodology over time, due to model improvements and revisions to the CPS. Notably, the model was revised in 1994 to produce more accurate and lower estimates of eligible households. The estimates for previous years show higher estimates of eligibles and lower participation rates relative to the revised estimate for 1994 and estimates for subsequent years. The two estimates for 1999 are due to re-weighting of the March 2000 2003 CPS files to Census 2000 and revised methodologies for determining SNAP eligibility. The original estimate (September 1999) is consistent methodologically with estimates from September 1994 September 1998, while the revised estimate (FY 1999) is consistent with the estimates for FY 2000 FY 2009. Source: U.S. Department of Agriculture, Food and Nutrition Service, Trends in Supplemental Nutrition Assistance Program Participation Rates: Fiscal Year 2002 to Fiscal Year 2009 available online at www.fns.usda.gov\/ora\/MENU\/Published\/SNAP\/FILES\/Participation\/Trends2002-09.pdf, and unpublished tabulations from the TRIM3 microsimulation model. Figure IND 4 shows the participation rates of means-tested assistance programs for selected years. This indicator examines the average monthly number of participating families or households as a percentage of the estimated eligible population. It is a contrast to Indicator 3, which examines participants as an average monthly (December for SSI) percentage of the total population (recipiency rates). Thirty-two (32.3) percent of families estimated as eligible for TANF assistance, 64.6 percent of households estimated as eligible for SSI, and 72.2 percent of adults estimated as eligible for SNAP are estimated to have enrolled and received benefits in an average month in 2009. (In percent) 32.3 80.2 84.3 72.2 32.6 47.6 75.8 64.6 20 40 60 80 100 1976 1977 1979 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 AFDC\/TANF Cash Assistance Food Stamps\/SNAP SSI II-17 Table IND 4a. Number and Percentage of Eligible Families Participating in the AFDC\/TANF Cash Assistance Program: Selected Years Calendar Year Eligible Families (millions) Participating Families (millions) Participation Rate (percent) 1981 4.8 3.8 80.2 1983 4.8 3.7 77.7 1985 4.7 3.7 79.3 1987 4.9 3.8 76.7 1988 4.8 3.8 78.4 1989 4.5 3.8 83.6 1990 4.9 4.1 82.2 1992 5.6 4.8 85.7 1993 6.1 5.0 81.7 1994 (revised) 6.1 5.0 82.1 1995 5.7 4.8 84.3 1996 5.6 4.4 78.9 1997 (adjusted) 5.4 3.7 69.2 1998 (adjusted) 5.5 3.1 55.8 1999 5.1 2.7 52.3 2000 4.4 2.3 51.8 2001 4.6 2.2 48.0 2002 4.6 2.2 48.1 2003 4.8 2.2 45.7 2004 5.2 2.2 42.0 2005 5.3 2.1 40.4 2006 5.4 2.1 39.0 2007 5.3 1.9 36.0 2008 5.2 1.7 33.0 2009 5.7 1.8 32.3 Note: AFDC\/TANF participation rates are estimated by an Urban Institute model (TRIM3) that uses CPS data to simulate AFDC\/TANF eligibility and participation for an average month, by calendar year. There have been small changes in estimating methodology over time, due to model improvements and revisions to the CPS. Most notably, since 1994 the model has been revised to more accurately estimate SSI participation among children, and in 1997 and 1998 the model was adjusted to more accurately exclude ineligible immigrants. In contrast to editions prior to 2004, this table includes families receiving assistance under Separate State Programs (SSPs). Note that families subject to full-family sanctions are counted as nonparticipating eligible families due to modeling limitations. Although the coverage rate estimates take into account the number of families who lost aid due to the time limit (and do not count such families in the denominator of the coverage rate estimate), they do not make any allowance for families staying off of TANF to conserve their time-limited assistance months. Also, the numbers of eligible and participating families include the territories and pregnant women without children, even though these two small groups are excluded from the TRIM model. The numbers shown here implicitly assume that participation rates for the territories and for pregnant women with no other children are the same as for all other eligibles. In 2004 the methods for identifying potential child-only units capture the fact that non-parent caretakers generally have a choice of whether or not to be included in the TANF unit. TRIM now excludes those caretakers whose income would make the unit ineligible, increasing the number of potential child-only units. Source: U.S. Department of Health and Human Services, Administration for Children and Families, caseload tabulations and unpublished tabulations from the TRIM3 microsimulation model. Between 1981 and 1996, participation rates in the AFDC program ranged from 76.7 percent (in 1987) to 85.7 percent (in 1992). Participation rates in what is traditionally considered welfare (AFDC\/TANF) have steadily declined. In 1992, 85.7 percent of eligible families participated in the AFDC program. By 2009, 32.3 percent of eligible families participated in the TANF program. Since welfare reform (1996) through 2009, there was a steady decline in the number of eligible families participating in the TANF program. While the caseload slightly in 2009, the share of eligibles who participated still declined. Note that TANF is a flexible program with a flexible funding stream. As such, states provide substantial non assistance services and benefits that would not be included in the cash assistance caseload counts used to derive these participation rate estimates. Over the years families also may have received cash benefits or other services through general assistance and other solely state-funded programs20 20 As discussed in the note to Table IND 4a above, the model for estimating participation in the TANF cash assistance program does take into account benefits from separate state programs (SSPs) that are used to meet Maintenance of Effort (MOE) requirements. that are separate from the TANF program and are not shown here. II-18 Table IND 4b. Number and Percentage of Eligible Households Participating in SNAP: Selected Years Date Eligible Households (millions) Participating Households (millions) Participation Rate (percent) September 1976 16.3 5.3 32.6 February 1978 14.0 5.3 37.8 August 1980 14.0 7.4 52.5 August 1982 14.5 7.5 51.5 August 1984 14.2 7.3 51.6 August 1986 15.3 7.1 46.5 August 1988 14.9 7.0 47.1 August 1990 14.5 8.0 54.9 August 1991 15.6 9.2 59.1 August 1992 16.6 10.2 61.6 August 1993 17.0 10.9 64.0 August 1994 17.0 11.0 64.6 September 1994 (revised) 15.3 10.7 69.6 September 1995 15.0 10.4 69.2 888September 1996 15.3 9.9 65.1 September 1997 14.7 8.5 57.5 September 1998 14.0 7.6 54.2 September 1999 13.7 7.3 53.0 Fiscal Year 1999 14.5 7.5 51.6 Fiscal Year 2000 14.2 7.2 50.0 Fiscal Year 2001 15.1 7.3 47.8 Fiscal Year 2002 16.7 8.0 47.6 Fiscal Year 2003 17.1 8.9 52.1 Fiscal Year 2004 17.5 10.0 57.1 Fiscal Year 2005 17.7 10.7 60.6 Fiscal Year 2006 17.1 11.2 65.3 Fiscal Year 2007 17.5 11.4 65.5 Fiscal Year 2008 18.0 12.3 68.4 Fiscal Year 2009 20.3 14.7 72.2 Note: SNAP eligible households are estimated from a Mathematica Policy Research, Inc. model that uses CPS data to simulate the Supplemental Nutrition Assistance Program (SNAP). SNAP caseload data are from USDA, FNS program operations caseload data. There have been small changes in the methodology over time, due to model improvements and revisions to the CPS. Notably, the model was revised in 1994 to produce more accurate and lower estimates of eligible households. The estimates for previous years show higher estimates of eligibles and lower participation rates relative to the revised estimate for 1994 and estimates for subsequent years. The two estimates for 1999 are due to re-weighting of the March 2000 2003 CPS files to Census 2000 and revised methodologies for determining SNAP eligibility. The original estimate (September 1999) is consistent methodologically with estimates from September 1994 September 1998, while the revised estimate (FY 1999) is consistent with the estimates for FY 2000 FY 2006. Source: U.S. Department of Agriculture, Food and Nutrition Service, Trends in Supplemental Nutrition Assistance Program Participation Rates: Fiscal Year 2002 to Fiscal Year 2009 available online at www.fns.usda.gov\/ora\/MENU\/Published\/SNAP\/FILES\/Participation\/Trends2002-09.pdf. Table IND 4b shows the average monthly number and percentage of eligible households participating in FSP\/SNAP for selected years. Since fiscal year 2002, the participation rate for SNAP has increased from 47.6 percent in fiscal year 2002 to 72.2 percent in fiscal year 2009. Between fiscal years 1999 and 2009 there was a 40.1 percent increase in households eligible for the Food Stamp\/Supplemental Nutrition Assistance Program (from 14.5 to 20.3 million households). Caseloads grew by 96.4 percent over the same period, with notable increases occurring between fiscal years 2008 and 2009. There were 14.7 million households participating in the SNAP in fiscal year 2009, the highest number recorded in the history of the program. During the mid to late 1990s, there was a 34.5 percent drop in SNAP caseloads, from a peak of 11 million households in 1994 to 7.2 million households in 2000. This decline in caseloads occurred during a time when both the eligible population and the program participation rates were generally decreasing. II-19 Table IND 4c. Percentage of Eligible Adult Units Participating in the SSI Program by Selected Characteristics: 1993-2009 All Adult Units One-Person Units Married-Couple Units Aged Disabled 1993 62.0 57.0 71.0 37.0 1994 65.0 58.4 73.0 43.9 1995 69.1 64.9 74.0 52.2 1996 66.6 60.4 73.5 46.7 1997 71.1 62.7 79.4 49.1 1998 70.7 63.6 77.9 48.1 1999 74.3 65.8 83.3 47.8 2000 75.8 70.9 82.3 49.9 2001 69.7 64.4 75.9 45.7 2002 70.4 61.9 78.3 47.9 2003 68.2 62.3 73.8 47.6 2004 65.7 63.3 69.2 46.0 2005 67.7 63.4 73.5 41.1 2006 68.8 69.1 72.5 39.9 2007 66.8 61.6 72.3 43.0 2008 65.6 67.3 68.0 39.8 2009 64.6 64.8 67.4 40.0 Note: SSI participation rates are estimated using the TRIM3 microsimulation model that uses CPS data to simulate SSI eligibility for an average month, by calendar year. There have been small changes in estimating methodology over time, due to model improvements and revisions to the CPS. In particular, the model was revised in 1997 and 1998 to more accurately exclude ineligible immigrants. Thus the increased participation rate in 1997 is partly due to a revision in estimating methodology. In 2004 the TRIM methods for identifying individuals eligible for SSI due to disability were improved resulting in more eligibles for this category. Still it is important to note that the TRIM model utilizes the limited information on disability status available from the Current Population Survey and thus may be underestimating the eligible non-elderly adult population resulting in participation rates that are too high. For example unpublished tabulations from the Social Security Administration based on data from the Survey of Income and Program Participation suggest that the rate of SSI participation among eligible non-elderly adults may be somewhere between a low estimate of around 40 percent and a high estimate of 80 percent a fairly wide range. Also note that the figures for married-couple units are based on very small sample sizes for example, married-couple units were only about 7.5 percent of the eligible adult units and 5.1 percent of the units receiving SSI in the average month of 1998. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994-2010, analyzed using the TRIM3 microsimulation model. Table IND 4c shows the average monthly number and percentage of eligible adult units participating in the SSI program by select demographic categories. After rising to 75.8 percent of adults estimated to be eligible for SSI in 2000, the SSI participation rate decreased to 64.6 percent of those estimated to be eligible for SSI in 2009. This rate is substantially higher than recent TANF rates but has been eclipsed by the SNAP participation rate in 2009 (see Tables IND 4a and IND 4b). For aged adults in one-person units, the estimated SSI participation rate increased from 57.0 percent in 1993 to a high of 70.9 percent in 2000. After some declines in the early 2000s, the estimated SSI participation rate among aged one-person units increased from 61.9 percent in 2002 to 64.8 percent in 2009. II-20 INDICATOR 5. Multiple Program Receipt Figure IND 5. Percentage of the Population Receiving Assistance from Multiple Programs TANF, SNAP and SSI: 2009 Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; TANF and SNAP receipt are based on the full recipient unit. Recipients are defined as those individuals who receive SSI or live in a family that receives either TANF or SNAP benefits. In practice, individuals typically do not receive both TANF and SSI; hence, no individual receives benefits from all three programs. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009, analyzed using the TRIM3 microsimulation model. Figure IND 5 shows the average monthly percentage of the population receiving benefits from TANF, SNAP, or SSI or a combination of benefits from these programs in 2009. More than 86 (86.5) percent of all individuals received no benefits from any of these programs, while 13.5 percent did. Seventy-one (70.6) percent of recipients received only SNAP benefits and 9.6 percent of recipients received both TANF and SNAP benefits. Table IND 5a shows the average monthly percentage of the population receiving assistance from TANF, SNAP, and SSI by demographic characteristics. Almost five (4.7) percent of children from birth to 5 years lived in families that received both TANF and SNAP as compared with 1.0 percent of women aged 16 to 64 and 0.3 percent of men aged 16-64. Among family categories, persons in female- headed families were more likely than those living in other types of families to receive support from multiple means-tested assistance programs. Among persons in female-headed families, 5.8 percent received support from TANF and SNAP, as compared to .5 percent of those in married- couple families, and 1.3 percent of those in male-headed families. Table IND 5b shows the average monthly percentage of the population receiving assistance from multiple means-tested assistance programs between 1993 and 2009. Reliance on multiple means-tested programs has decreased over time. In 1993, 4.8 percent of the population received AFDC and food stamps. In 2009, the percent that received both TANF and SNAP decreased to 1.3 percent. 10.3% 9.6% 1.5% 70.6% 8.1% SSI & SNAP TANF & SNAP TANF only SNAP only SSI only Recipients 13.5 Non-recipients 86.5 II-21 Table IND 5a. Percentage of Recipients Receiving Assistance from Multiple Programs by Selected Characteristics: 2009 Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; AFDC\/TANF and Food Stamps\/SNAP receipt are based on the full recipient unit. In practice, individuals do not tend to receive both AFDC\/TANF and SSI; hence, no individual receives benefits from all three programs. The percentage of individuals receiving assistance from any one program in an average month (shown here) is lower than the percentage residing in families receiving assistance at some point over the course of a year (shown in Table SUM 1 in Chapter I and Table IND 1a in Chapter II). Spouses are not present in the female-headed and male-headed family categories. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009, analyzed using the TRIM3 microsimulation model. Table IND 5b. Percentage of Recipients Receiving Assistance from Multiple Means-Tested Assistance Programs: 1993-2009 Any Receipt One Program Only Two Programs AFDC\/TANF FS\/ SNAP SSI AFDC\/ TANF & SNAP SNAP & SSI 1993 12.6 0.6 5.2 1.1 4.8 1.0 1994 12.8 0.5 5.3 1.2 4.6 1.1 1995 12.3 0.4 5.0 1.2 4.5 1.1 1996 12.0 0.3 5.3 1.2 4.0 1.1 1997 10.2 0.4 4.3 1.3 3.1 1.0 1998 9.0 0.4 3.9 1.4 2.4 0.9 1999 8.5 0.4 3.8 1.3 2.0 1.0 2000 8.1 0.2 3.8 1.4 1.7 1.0 2001 8.1 0.3 3.9 1.4 1.5 1.0 2002 8.5 0.3 4.5 1.3 1.4 1.0 2003 9.7 0.2 5.5 1.3 1.6 1.0 2004 10.3 0.2 6.1 1.2 1.6 1.1 2005 10.2 0.2 6.2 1.3 1.5 1.2 2006 10.4 0.2 6.5 1.3 1.3 1.2 2007 10.6 0.2 6.8 1.3 1.2 1.2 2008 11.4 0.2 7.7 1.2 1.2 1.2 2009 13.5 0.2 9.6 1.1 1.3 1.4 Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; AFDC\/TANF and Food Stamps\/SNAP receipt are based on the full recipient unit. In practice, individuals do not tend to receive both AFDC\/TANF and SSI; hence, no individual receives benefits from all three programs. The percentage of individuals receiving assistance from any one program in an average month (shown here) is lower than the percentage residing in families receiving assistance at some point over the course of a year (shown in Table SUM 1 in Chapter I and Table IND 1a in Chapter II). Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1994-2009, analyzed using the TRIM3 microsimulation model. Any Receipt One Program Only Two Programs TANF SNAP SSI TANF & SNAP SNAP& SSI All Persons 13.5 0.2 9.6 1.1 1.3 1.4 Racial\/Ethnic Categories Non-Hispanic White 8.9 0.1 6.6 0.8 0.5 1.0 Non-Hispanic Black 28.8 0.4 19.9 1.6 3.5 3.4 Hispanic 20.3 0.5 14.0 1.8 2.5 1.4 Age Categories Children ages 0-5 27.6 0.6 21.1 0.6 4.7 0.6 Children ages 6-10 23.7 0.6 17.7 0.8 3.6 1.0 Children ages 11-15 20.5 0.6 15.0 1.2 2.6 1.2 Women ages 16-64 12.6 0.1 9.1 0.9 1.0 1.5 Men ages 16-64 9.2 0.1 6.8 1.0 0.3 1.1 Adults ages 65 and over 8.5 0.0 3.4 2.4 0.0 2.6 Family Categories Persons in married-couple families 7.2 0.2 5.5 0.7 0.5 0.4 Persons in female-headed families 38.0 0.4 26.5 2.3 5.8 3.0 Persons in male-headed families 20.3 0.3 15.1 2.0 1.3 1.6 Unrelated persons 12.3 0.0 7.8 1.2 0.0 3.3 II-22 INDICATOR 6. Dependence Transitions Figure IND 6. Dependency Status in 2007 of Persons Who Received More than 50 Percent of Annual Income from Means-Tested Assistance in 2006 by Race and Ethnicity (In percent) Note: Means-tested assistance is defined as AFDC\/TANF, Food Stamps\/SNAP, and SSI. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Individuals are defined as dependent if they reside in families with more than 50 percent of total annual family income from these means-tested programs. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Figure IND 6 shows the 2007 dependency status of persons who were welfare dependent in 2006 by race and ethnicity. Welfare dependence is defined as receiving more than half of one's total family income in the year from TANF, FSP\/SNAP, and\/or SSI. For further discussion of defining welfare dependency, see Chapter I. Of the recipients who received more than 50 percent of their total family income from TANF, FSP\/SNAP, and\/or SSI in 2006, 74.7 percent of Non-Hispanic Whites, 75.5 percent of Non-Hispanic Blacks, and 80.8 percent of Hispanics were welfare dependent in 2007. Table IND 6a shows the 2007 dependency status of persons who were welfare dependent in 2006 by demographic groups. Men ages 16 to 64 who received more than half of their total income from means-tested assistance programs in 2006 remained dependent in 2007 in higher percentages than women. Table IND 6b shows the dependency status of all persons who received more than 50 percent of their income from means-tested assistance programs in the previous year. Recipients of assistance from these three programs were more likely to move out of dependency status in the early 2000s than in the early 1990s. 2.4 3.4 2.4 1.6 20.9 21.9 22.1 17.5 76.7 74.7 75.5 80.8 0 20 40 60 80 100 All persons Non-Hispanic White Non-Hispanic Black Hispanic No aid Up to 50% Over 50% II-23 Table IND 6a. Dependency Status in 2007 of Persons Who Received More than 50 Percent of Income from Means-Tested Assistance in 2006 by Selected Characteristics Percentage of Persons Receiving Persons Receiving More than 50 Percent of Income from Assistance in 2006 Total (thousands) No aid in 2007 Up to 50% in 2007 Over 50% in 2007 All Persons 6,969 2.4 20.9 76.7 Racial\/Ethnic Categories Non-Hispanic White 2,495 3.4 21.9 74.7 Non-Hispanic Black 2,429 2.4 22.1 75.5 Hispanic 1,300 1.6 17.5 80.8 Age Categories Children ages 0-5 913 3.1 18.4 78.5 Children ages 6-10 756 2.8 25.9 71.3 Children ages 11-15 893 0.0 23.8 76.2 Women ages 16-64 2,502 2.8 21.1 76.2 Men ages 16-64 1,389 3.3 17.5 79.2 Adults ages 65 and over 497 0.0 20.1 79.9 Note: Means-tested assistance is defined as AFDC\/TANF, Food Stamps\/SNAP, and SSI. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Individuals are defined as dependent if they reside in families with more than 50 percent of total annual family income from these means-tested programs. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Individual age categories do not add to total because of a small number of people not reporting age. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Table IND 6b. Dependency Status of All Persons Who Received More than 50 Percent of Income from Means-Tested Assistance in Previous Year Percentage of Persons Receiving Total (thousands) No aid in second year Up to 50% in second year Over 50% in second year Transitions from: 1993 to 1994 14,810 1.6 18.6 79.8 1994 to 1995 13,986 2.7 18.8 78.5 1997 to 1998 9,672 3.1 28.8 68.1 1998 to 1999 8,163 2.9 27.1 70.0 2001 to 2002 6,258 1.5 29.2 69.3 2002 to 2003 6,023 2.6 25.8 71.6 2004 to 2005 7,682 4.1 31.7 64.2 2005 to 2006 7,339 2.4 24.2 73.5 2006 to 2007 6,969 2.4 20.9 76.7 Note: Means-tested assistance is defined as AFDC\/TANF, Food Stamps\/SNAP, and SSI. Individuals are defined as dependent if they reside in families with more than 50 percent of total annual family income from these means-tested programs. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income in all years and veterans' pension benefits are included in means-tested assistance income for receipt and dependence estimates prior to 2001. Because full calendar year data for 1995 were not available for all SIPP respondents, some transitions between 1994 and 1995 were based on twelve-month periods that did not correspond exactly to calendar years. Source: Unpublished tabulations from the Survey of Income and Program Participation, 1993, 1996, 2001, and 2004 panels. II-24 INDICATOR 7. Program Spell Duration Figure IND 7. Percentage of TANF, Food Stamps\/SNAP and SSI Spells for Persons Entering Programs during the 2004 SIPP Panel by Length of Spell Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Due to the length of the observation period, actual spell lengths for spells that lasted more than 20 months cannot be observed. Program spells are defined as those starting during the 2004 SIPP panel (2004 2007). For certain age categories, data are not available (NA) because of insufficient sample size. The Food, Conservation and Energy Act of 2008 (P.L. 110-246) re-named the Food Stamp Program as the Supplemental Nutrition Assistance Program (SNAP) as of October 1, 2008. The name change had no effect on the type of benefits or how they are made available to eligible households. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Figure IND 7 shows the percentage of TANF, SNAP, and SSI spells by spell length categories for persons entering programs in the mid 2000s. Between 2004 and 2007, spells lasting four months or less accounted for 44 percent of TANF spells, 33 percent of SNAP spells, and 24 percent of SSI spells. Approximately three-fourths of all TANF spells (73.7 percent) and 62 percent of SNAP spells lasted one year or less compared to 44 percent of SSI spells. Table IND 7a shows the percentage of program spells for persons entering programs during the 2004 2007 period by length of spell and demographic characteristics. Among child recipients of TANF, most children experienced shorter spells of receipt than longer spells of receipt. Table IND 7b shows how the percentage of program spells of varying lengths for persons entering programs during selected periods has changed. Spells of welfare receipt were shorter in the early 2000s than in the early 1990s. For instance, 14.1 percent of TANF spells for persons entering TANF between 2004 and 2007 lasted 20 months or longer as compared to 34.4 percent of AFDC spells beginning between 1992 and 1994. 43.8 33.1 24.2 29.9 29.0 19.8 12.2 9.1 9.1 14.1 28.8 47.0 0 20 40 60 80 TANF SNAP SSI Spells <=4 months Spells 5-12 months Spells 13-20 months Spells >20 months (In percent) II-25 Table IND 7a. Percentage of TANF, Food Stamps\/SNAP and SSI Spells for Persons Entering Programs during the 2004 SIPP Panel by Length of Spell and Selected Characteristics Program Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months TANF All Recipients 43.8 29.9 12.2 14.1 Non-Hispanic White 46.3 32.6 9.3 11.8 Non-Hispanic Black 47.9 22.1 14.0 16.1 Hispanic 34.3 37.8 14.6 13.4 Children ages 0-5 48.2 21.7 12.4 17.7 Children ages 6-10 33.7 35.3 9.1 21.9 Children ages 11-15 32.6 32.6 12.7 22.2 Adults ages 16-64 48.9 30.3 13.0 7.9 Adults ages 65 and over 56.4 43.6 0.0 0.0 SNAP All Recipients 33.1 29.0 9.1 28.8 Non-Hispanic White 34.5 28.5 9.6 27.4 Non-Hispanic Black 36.7 27.4 9.1 26.8 Hispanic 29.9 29.3 10.0 30.8 Children ages 0-5 24.2 31.9 10.7 33.2 Children ages 6-10 30.3 30.7 10.7 28.3 Children ages 11-15 34.6 26.5 10.8 28.1 Adults ages 16-64 35.1 29.4 8.7 26.9 Adults ages 65 and over 31.8 17.9 1.6 48.7 SSI All Recipients 24.2 19.8 9.1 47.0 Non-Hispanic White 23.4 19.6 6.8 50.3 Non-Hispanic Black 22.7 22.0 13.9 41.4 Hispanic 29.1 17.3 7.5 46.1 Children ages 0-5 31.0 37.5 17.4 14.1 Children ages 6-10 46.6 24.2 6.6 22.7 Children ages 11-15 35.0 25.7 18.6 20.7 Adults ages 16-64 19.3 18.9 8.6 53.2 Adults ages 65 and over 22.0 7.4 3.5 67.0 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Program spells are defined as those starting during the 2004 SIPP panel (2004 2007). Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Table IND 7b. Percentage of AFDC\/TANF, Food Stamps\/SNAP, and SSI Spells for Persons Entering Programs during Selected SIPP Panels by Length of Spell Period Program Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months 1992 1994 AFDC 30.4 24.7 10.5 34.4 Food Stamps 33.4 24.9 10.2 31.5 SSI 25.7 8.9 4.8 60.6 1993 1995 AFDC 30.7 25.4 12.5 31.4 Food Stamps 33.1 26.8 10.1 30.0 SSI 24.0 7.9 4.7 63.4 1996 1999 AFDC\/TANF 46.6 29.2 11.5 12.7 Food Stamps 43.1 27.7 9.3 19.8 SSI 34.1 19.2 9.1 37.6 2001 2003 TANF 49.6 23.7 10.0 16.8 Food Stamps 35.9 24.4 8.9 30.7 SSI 27.9 21.4 7.3 43.5 2004 2007 TANF 43.8 29.9 12.2 14.1 Food Stamps 33.1 29.0 9.1 28.8 SSI 24.2 19.8 9.1 47.0 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Due to the length of the observation period, actual spell lengths for spells that lasted more than 20 months cannot be observed. Program spells are defined as those starting during the 2004 SIPP panel (2004 2007). Source: Unpublished tabulations from the Survey of Income and Program Participation, 1992, 1993, 1996, 2001, 2004 panels. II-26 INDICATOR 8. Welfare Spell Duration with No Labor Force Attachment Figure IND 8. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during the 2004 SIPP Panel by Length of Spell Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Due to the length of the observation period, actual spell lengths for spells that lasted more than 20 months cannot be observed. TANF spells with no family labor force attachment are defined as those spells starting during the 2004 SIPP panel (2004 2007) for persons who received TANF and lived in families with no labor force participants in each month. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Figure IND 8 shows the percentage of TANF spells with no family labor force attachment for persons entering the TANF program between 2004 and 2007 by length of spell. Welfare spells with no family labor force attachment are measured as consecutive months that a person received TANF benefits and lived in a family with no labor force participants. Welfare spells with no family labor force attachment may end when a person leaves the TANF program or when a person remains on TANF but at least one person in the family enters the labor market. Fifty-two (51.6) percent of welfare spells with no family labor force attachment lasted four months or less as measured in the SIPP. Table IND 8a shows the percentage of TANF spells with no family labor force attachment by spell length for different demographic groups. The percentage of spells ending in four months or less was larger for Non-Hispanic Whites (59.7 percent) than it was for Non-Hispanic Blacks (44.5 percent) and Hispanics (55.0 percent). 51.6 25.0 9.4 14.0 Spells <=4 months Spells 5-12 months Spells 13-20 months Spells >20 months II-27 Table IND 8a. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during the 2004 SIPP Panel by Length of Spell and Selected Characteristics Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months All Persons 51.6 25.0 9.4 14.0 Racial\/Ethnic Categories Non-Hispanic White 59.7 19.9 11.0 9.4 Non-Hispanic Black 44.5 24.1 8.4 23.0 Hispanic 55.0 28.8 8.3 7.9 Age Categories Children ages 0-15 48.0 24.9 9.0 18.1 Adults ages 16-64 56.2 24.8 10.4 8.7 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. TANF spells with no family labor force attachment are defined as those spells starting during the 2004 SIPP panel (2004 2007) for persons who received TANF and lived in families with no labor force participants in each month. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Table IND 8b. Percentage of TANF Spells with No Family Labor Force Attachment for Persons Entering Programs during the 2004 SIPP Panel by Selected Years Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months 1993 1995 42.6 26.4 8.5 22.5 1996 1999 54.2 28.3 9.3 8.3 2001 2003 56.1 23.0 10.6 10.2 2004 2007 51.6 25.0 9.4 14.0 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. TANF spells with no family labor force attachment are defined as those spells starting during the 2004 SIPP panel (2004 2007) for persons who received TANF and lived in families with no labor force participants in each month. Source: Unpublished tabulations from the Survey of Income and Program Participation, 1993, 1996, 2001 and 2004 panels. Table IND 8b shows the percentage of TANF spells with no family labor force attachment for persons entering the program during selected periods by spell length. In the middle 2000s, 51.6 percent of TANF spells with no family labor force attachment ended within four months and 76.6 percent ended within a year. The percentage of spells with no family labor force attachment lasting more than 20 months was higher in the early 1990s than in the middle 2000s (22.5 percent compared to 14.0 percent, respectively). Indicators 7 and 8 provide similar information; however, the percentages of spell lengths differ because the two Indicators are computed differently. Indicator 7 shows spells for all recipients while Indicator 8 restricts welfare spells to recipients in families without any labor force participants. This difference results in a higher percentage of spells longer than 20 months in Indicator 7, where TANF and employment may be combined, and compared to Indicator 8 where no one in the family may be in the labor force. II-28 INDICATOR 9. Long Term AFDC\/TANF Receipt Figure IND 9. Percent of AFDC\/TANF Recipients by Years of Receipt in the 1999 2008 Period Note: The base for the percentages consists of mothers who received at least $1 of AFDC\/TANF in any year in the ten-year period. Child recipients are defined by age in the first year of the 10-year period. This indicator measures years of recipiency over the specified ten-year time periods and does not take into account years of recipiency that may have occurred before or after each ten-year period. Source: Unpublished tabulations from the Panel Study of Income Dynamics, public release data files, 1999-2008. Figure IND 9 shows the percentage of AFDC\/TANF recipients by years of receipt between 1999 and 2008. Among all persons receiving AFDC\/TANF at some point within the ten-year period, 71.5 percent received assistance in only one or two of these years. In contrast, 1.1 percent received assistance in 9 or 10 of the years. Table IND 9 shows the percentage of AFDC\/TANF recipients with varying years of receipt across three ten-year time periods by demographic characteristics. Long spells of welfare receipt were more common in earlier time periods than they were in later time periods. For example, for the 1969 1978 time period, 12.8 percent of AFDC recipients received benefits in at least 9 of the 10 years as compared to 1.1 percent of TANF recipients for the 1999 – 2008 time period. Among child recipients, for the 1969 1978 time period, 17.3 percent of children birth to age 5 lived in families that received AFDC\/TANF in 9 10 years as compared to 2.4 percent for the 1999 – 2008 time period. Short spells of TANF receipt were more prevalent in the 1999 – 2008 period compared to earlier periods. Between 1999 – 2008, 71.5 percent of TANF recipients received benefits in only one or two years compared to 47.9 percent in the 1989 to 1998 period, 44.6 percent in the 1979 1988 period, and 43.6 percent in the 1969 1978 period. Among racial groups, the percentage of Non-Hispanic Black recipients receiving TANF benefits for 9 10 years has decreased from a high of 18.4 percent in the 1979 1988 period to a low of 2.9 percent in the 1999 2008 period. For the 1999 2008 period, there were no Non-Hispanic White recipients receiving TANF for 9 10 years as compared to 10.2 percent in the 1969-1978 period. 71.5 20.5 6.9 1.1 1 – 2 Years 3 – 5 Years 6 – 8 Years 9 – 10 Years II-29 Table IND 9. Percentage of AFDC\/TANF Recipients across Three Ten-Year Time Periods by Years of Receipt and Selected Characteristics All Persons All Recipients Child Recipients Ages 0-5 1969-1978 1979-1988 1989-1998 1999-2008 1969-1978 1979-1988 1989-1998 1999-2008 Years received AFDC\/TANF 1-2 years 43.6 44.6 47.9 71.5 33.3 36.8 40.4 73.0 3-5 years 23.1 25.0 31.5 20.5 28.3 25.0 27.1 18.4 6-8 years 20.5 17.3 12.4 6.9 21.1 18.4 17.3 6.2 9-10 years 12.8 13.1 8.2 1.1 17.3 19.8 15.2 2.4 Non-Hispanic Whites All Recipients Child Recipients Ages 0-5 1969-1978 1979-1988 1989-1998 1999-2008 1969-1978 1979-1988 1989-1998 1999-2008 Years received AFDC\/TANF 1-2 years 51.0 54.0 51.3 76.4 41.4 47.4 50.9 78.2 3-5 years 21.1 21.2 36.8 18.0 29.1 23.3 31.3 15.2 6-8 years 17.7 15.1 7.4 5.6 16.8 15.5 8.7 5.2 9-10 years 10.2 9.7 4.5 0.0 12.7 13.8 9.1 1.4 Non-Hispanic Blacks All Recipients Child Recipients Ages 0-5 1969-1978 1979-1988 1989-1998 1999-2008 1969-1978 1979-1988 1989-1998 1999-2008 Years received AFDC\/TANF 1-2 years 30.2 31.2 44.1 62.6 19.4 20.8 33.0 60.0 3-5 years 26.1 29.1 25.4 25.5 28.8 27.7 23.3 25.1 6-8 years 26.2 21.3 18.0 9.0 28.3 23.0 24.4 9.1 9-10 years 17.5 18.4 12.5 2.9 23.5 28.5 19.3 5.8 Note: The base for the percentages consists of mothers who received at least $1 of AFDC\/TANF in any year in the ten-year period. Child recipients are defined by age in the first year of the 10-year period. This indicator measures years of recipiency over the specified ten-year time periods and does not take into account years of recipiency that may have occurred before or after each ten-year period. Due to small sample size, Hispanics, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the estimates for all persons but are not shown separately. Source: Unpublished tabulations from the Panel Study of Income Dynamics and public release data files, 1969-2008, II-30 INDICATOR 10. Events Associated with the Beginning and Ending of Program Spells Figure IND 10a. Events Associated with Single Mother TANF Exits during the 2004 2006 Period Note: Welfare exits are defined as moving from receipt to non-receipt between two successive SIPP interviews (conducted 4 months apart); an event was associated with a welfare transition if the event was observed within two interviews (i.e., 8 months) of the interview marking the welfare exit. In general, events are neither mutually exclusive nor exhaustive, and transition events may sum to more than 100 percent. Two exceptions are that Increase in other Household Earnings was limited to cases when there were increases in household earnings without an increase in recipient earnings, and Increase in Adults (not marriage) was limited to cases where the adult joining the household was not marrying the head of the household. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Other government benefits include Unemployment Insurance, Foster Care, Railroad Retirement, veterans’ payments and Workers Compensation. An increase in earnings must be an increase of at least $50 per month. A work limitation is defined as a condition that limits the kind or amount of work. The category \”None of above in recent past\” represents the percentage of all spells ending during the period that were not associated with any of the events measured. Spells of welfare receipt and associated events are measured using monthly data from the SIPP. In the 2003 Indicators of Welfare Dependence volume (and earlier volumes), events associated with the beginning and ending of program spells were measured using annual data from the Panel Study of Income Dynamics (PSID). Thus, the estimates shown above are not comparable to estimates reported in volumes prior to 2008. Events sum to more than 100 percent because the same household could experience more than one event associated with a specific welfare entry or exit. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Figure IND 10a shows events associated with single mother TANF exits during the 2004 SIPP panel, 2004 – 2006. Welfare exits were most often associated with an increase in recipient earnings. Thirty (30.3) percent of welfare spells that ended during the 2004 to 2006 time period were associated with an increase in the recipient’s earnings. Almost thirteen (12.5) percent of welfare exits were associated with an increase in the earnings of other household members. Forty-six percent of welfare exits during the 2004 2006 time period were not associated with any of the events listed above within the time period observed. Table IND 10a shows the events associated with welfare exits among single mother recipients for selected years. Exits associated with an increase in recipient earnings have decreased over time. For the 1993 1995 time period, 54.8 percent of exits were associated with an increase in recipient earnings, yet for the 2004 – 2006 time period 30.3 percent were associated with increases in recipient earnings. 46.0 4.3 5.2 13.4 2.7 3.1 .4 4.4 12.5 30.3 0 10 20 30 40 50 60 None of above in recent past Moved across state lines End of work limitation Increase in adults (not marriage) Married Last child left or turned 19 Became recipient other govt benefits Became SSI recipient Increase in other household earnings Increase in own earnings Percent II-31 Table IND 10a. Percentage of Single Mother AFDC\/TANF Spell Exits Associated with Specific Events: Selected Periods Spell Ended Spell Ended Spell Ended Spell Ended 1993-1995 1996-1999 2001-2003 2004-2006 Increase in own earnings 54.8 44.6 34.3 30.3 Increase in other household earnings 10.3 11.9 12.4 12.5 Became SSI recipient 1.6 5.9 5.1 4.4 Became recipient of other government benefits 2.2 2.6 2.9 0.4 Last child left or turned 19 5.6 2.4 1.6 3.1 Married 5.4 2.1 2.3 2.7 Increase in number of adults (not marriage) 17.6 12.4 12.8 13.4 Ended work limitation 3.0 10.9 8.8 5.2 Moved across state lines 2.4 1.4 2.8 4.3 None of above in recent past 24.0 31.1 37.3 46.0 Note: Welfare exits are defined as moving from receipt to non-receipt between two successive SIPP interviews (conducted 4 months apart); an event was associated with a welfare transition if the event was observed within two interviews (i.e., 8 months) of the interview marking the welfare exit. In general, events are neither mutually exclusive nor exhaustive, and transition events may sum to more than 100 percent. Two exceptions are that Increase in other Household Earnings was limited to cases when there were increases in household earnings without an increase in recipient earnings, and Increase in Adults (not marriage) was limited to cases where the adult joining the household was not marrying the head of the household. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Other government benefits include Unemployment Insurance, Foster Care, Railroad Retirement, veterans payments and Workers Compensation. An increase in earnings must be an increase of at least $50 per month. A work limitation is defined as a condition that limits the kind or amount of work. The category \”None of above in Recent Past\” represents the percentage of all spells ending during the period that were not associated with any of the events measured. Spells of welfare receipt and associated events are measured using monthly data from the SIPP. In the 2003 Indicators of Welfare Dependence volume (and earlier volumes), events associated with the beginning and ending of program spells were measured using annual data from the Panel Study of Income Dynamics (PSID). Thus, the estimates shown above are not comparable to estimates reported in volumes prior to 2008. Events sum to more than 100 percent because the same household could experience more than one event associated with a specific welfare entry or exit. Source: Unpublished tabulations from the Survey of Income and Program Participation, 1993, 1996, 2001, and 2004 panels. Welfare exits associated with changes in household composition have also decreased over time. For the 1993 1995 time period, 5.6 percent of welfare exits were related to the last child in a household leaving home or turning 19 years old as compared to 3.1 percent for the 2004 2006 time period. Welfare exits associated with marriage also declined over the two time periods. For the 1993 1995 time period, 5.4 percent of exits were related to marriage, for the 2004 2006 time period, the rate was 2.7 percent. Forty-six percent of welfare exits were not associated with any of the events listed above within the time period observed. II-32 Figure IND 10b. Events Associated with Single Mother TANF Entries during the 2004-2006 Period Note: Welfare entries are defined as moving from non-receipt to receipt between two successive SIPP interviews (conducted 4 months apart); an event was associated with a welfare transition if the event was observed within two interviews (i.e., 8 months) of the interview marking the welfare entry. In general, events are neither mutually exclusive nor exhaustive, and transition events may sum to more than 100 percent. Two exceptions are that Other Household Earnings Decreased was limited to cases when there were decreases in household earnings without a decrease in recipient earnings, and Decrease in Number of Adults (not divorce) was limited to cases where the adult leaving the household was not married to the head of the household. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Other government benefits include Unemployment Insurance, Foster Care, Railroad Retirement, veterans payments and Workers Compensation. A decrease in earnings must be a decrease of at least $50 per month. A work limitation is defined as a condition that limits the kind or amount of work. The category \”None of above in Recent Past\” represents the percentage of all spell beginnings during the period that were not associated with any of the events measured. Spells of welfare receipt and associated events are measured using monthly data from the SIPP. In the 2003 Indicators of Welfare Dependence volume (and earlier volumes), events associated with the beginning and ending of program spells were measured using annual data from the Panel Study of Income Dynamics (PSID). Thus, the estimates shown above are not comparable to estimates reported in volumes prior to 2008. Events sum to more than 100 percent because the same household could experience more than one event associated with a specific welfare entry or exit. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel. Figure IND 10b shows the events associated with the beginning of TANF spells among single mother recipients in the 2004 2006 time period. A decrease in earnings was the most common event associated with welfare entries. For spells beginning between 2004 and 2006, 48.6 percent were associated with a decrease in the recipient’s earnings and 23.8 percent were associated with a decrease in the earnings of other household members. Changes in household composition also were associated with the beginning of welfare spells. Almost 23 (22.9) percent of welfare entries were associated with a new child joining the family while 18.1 percent of TANF entries were the result of a decrease in the number of adults in a household not due to divorce. Almost six (5.9) percent of TANF entries were associated with divorce or separation. Sixteen (15.9) percent of welfare entries were not associated with any of the events listed above within the time period observed. 15.9 5.5 22.9 3.2 5.1 23.8 48.6 10.6 18.1 5.9 0 10 20 30 40 50 60 None of above in recent past Moved across state lines Onset of work limitation Decrease in number of adults (not divorce) Divorced\/separated from spouse New child in family Lost other government benefits (own) Lost SSI benefits (own) Other household earnings decreased Recipients’ earnings decreased Percent II-33 Table IND 10b. Percentage of Single Mother AFDC\/TANF Spell Entries Associated with Specific Events: Selected Periods Spell Began Spell Began Spell Began Spell Began 1993-1995 1996-1999 2001-2003 2004-2006 Recipients’ earnings decreased 57.1 52.6 50.3 48.6 Other household earnings decreased 24.0 21.0 20.1 23.8 Lost SSI benefits (own) 1.4 5.1 4.4 5.1 Lost other government benefits (own) 8.1 5.1 6.1 3.2 New child in family 22.0 17.1 20.5 22.9 Divorced\/separated from spouse 8.7 6.7 4.3 5.9 Decrease in number of adults (not divorce) 19.2 17.6 15.4 18.1 Onset of work limitation 7.2 10.9 11.5 10.6 Moved across state lines 1.7 1.4 2.2 5.5 None of above in recent past 8.8 14.1 16.7 15.9 Note: Welfare entries are defined as moving from non-receipt to receipt between two successive SIPP interviews (conducted 4 months apart); an event was associated with a welfare transition if the event was observed within two interviews (i.e., 8 months) of the interview marking the welfare entry. In general, events are neither mutually exclusive nor exhaustive, and transition events may sum to more than 100 percent. Two exceptions are that Other Household Earnings Decreased was limited to cases when there were decreases in household earnings without a decrease in recipient earnings, and Decrease in Number of Adults (not divorce) was limited to cases where the adult leaving the household was not married to the head of the household. While only affecting a small number of cases, General Assistance income is included within AFDC\/TANF income. Other government benefits include Unemployment Insurance, Foster Care, Railroad Retirement, veterans’ payments and Workers Compensation. A decrease in earnings must be a decrease of at least $50 per month. A work limitation is defined as a condition that limits the kind or amount of work. The category \”None of above in Recent Past\” represents the percentage of all spell beginnings during the period that were not associated with any of the events measured. Spells of welfare receipt and associated events are measured using monthly data from the SIPP. In the 2003 Indicators of Welfare Dependence volume (and earlier volumes), events associated with the beginning and ending of program spells were measured using annual data from the Panel Study of Income Dynamics (PSID). Thus, the estimates shown above are not comparable to estimates reported in volumes prior to 2008. Events sum to more than 100 percent because the same household could experience more than one event associated with a specific welfare entry or exit. Source: Unpublished tabulations from the Survey of Income and Program Participation, 1993, 1996, 2001, and 2004 panels. Table IND 10b shows the events associated with the beginning of welfare spells among single mother recipients by selected time periods. For the 1993 1995 time period, 57.1 percent of AFDC spell entries were associated with a decrease in recipient earnings. The percentage was 48.6 percent for the 2004 2006 time period. A decrease in other household members’ earnings also was related to the beginning of welfare spells. For the 1993 1995 time period, 24.0 percent of welfare entries were associated with a decrease in other household members’ earnings. For the 2004 2006 time period, 23.8 percent of welfare entries were associated with a decrease in other household members’ earnings. II-34 Chapter III. Predictors and Risk Factors Associated with Welfare Receipt The Welfare Indicators Act challenges the U.S. Department of Health and Human Services to identify and set forth not only indicators of welfare dependence and welfare duration but also predictors and causes of welfare receipt. However, welfare research has not established clear and definitive causes of welfare receipt and dependence. Instead, it has identified a number of risk factors associated with welfare use. For the purposes of this report, the terms predictors and risk factors are used somewhat interchangeably. Following the recommendation of the Advisory Board, this chapter includes a wide range of possible predictors and risk factors. As research advances, some of the predictors included in this chapter may turn out to be simply correlates of welfare receipt, some may have a causal relationship, some may be consequences, and some may have predictive value. The predictors\/risk factors included in this chapter are grouped into three categories: economic security risk factors, employment-related risk factors, and risk factors associated with nonmarital childbearing. Economic Security Risk Factors (ECON) The first group includes eight measures associated with economic security. This group encompasses five measures of poverty, as well as measures of child support receipt, food insecurity, and lack of health insurance. The tables and figures illustrating measures of economic security are labeled with the prefix ECON throughout this chapter. Poverty measures are important predictors of dependence, because families with fewer economic resources are more likely to be dependent on means-tested assistance. In addition, poverty and other measures of deprivation, such as food insecurity, are important to assess in conjunction with the measures of dependence outlined in Chapter II. Reductions in caseloads and dependence can reduce poverty, to the extent that such reductions are associated with greater work activity and higher economic resources for former welfare families. However, if former welfare families are left with fewer economic resources, reductions in welfare caseloads may not lead to decreases in poverty. Several aspects of poverty are examined in this chapter. Those that can be updated annually using the Current Population Survey include: overall poverty rates (ECON 1); the percentage of individuals in deep poverty (ECON 2), and poverty rates using alternative definitions of income (ECON 3 and 4). The chapter also includes data on the length of poverty episodes or spells (ECON 5). This chapter also includes data on child support collections (ECON 6), which can play an important role in reducing dependence on government assistance and thus serve as a predictor of dependence. Household food insecurity (ECON 7) is an important measure of deprivation that, although correlated with general income poverty, provides an alternative measure of tracking the incidence of material hardship and need, and how it may change over time. Finally, lack of health insurance (ECON 8) is tied to the income level of the family, and may be a precursor to future health problems among adults and children. Employment and Work-Related Risk Factors (WORK) The second grouping, labeled with the WORK prefix, includes eight factors related to employment and barriers to employment. These measures include data on overall labor force attachment and employment and earnings for low-skilled workers, as well as data on barriers to work. The latter category includes incidence of adult and child disabilities, adult substance abuse, and levels of educational attainment and school drop-out rates. Employment and earnings provide many families with an escape from dependence. It is important, therefore, to look both at overall labor force attachment (WORK 1), and at employment and earnings for those with low education levels (WORK 2 and WORK 3). The economic condition of the low-skill labor market is a key predictor of the ability of men and women to support families without receiving means- tested assistance. III-1 The next two measures in this group (WORK 4 and WORK 5) focus on educational attainment. Individuals with less than a high school education have the lowest amount of human capital and are at the greatest risk of being poor, despite their work effort. Measures of barriers to employment provide indicators of potential work limitations, which may be predictors of greater dependence. Substance abuse (WORK 6) and disabling conditions among children and adults (WORK 7) all have the potential of limiting the ability of the adults in the household to work. In addition, debilitating health conditions and high medical expenditures can strain a family’s economic resources. The labor force participation of women with children (WORK 8) is also a predictor of dependence. Nonmarital Birth Risk Factors (BIRTH) The final group of risk factors addresses nonmarital childbearing. The tables and figures in this subsection are labeled with the BIRTH prefix. This category includes long-term time trends in nonmarital births (BIRTH 1), nonmarital teen births (BIRTH 2 and BIRTH 3), and children living in families with never- married parents (BIRTH 4). Children living in families with never-married mothers are at high risk of becoming dependent as adults, and it is therefore important to track changes in the size of this vulnerable population. As noted above, the predictors\/risk factors included in this chapter do not represent an exhaustive list of measures. They are merely a sampling of available data that address in some way the question of how a family is faring on the scale of deprivation and well-being. Such questions are a necessary part of the discussion on dependence as researchers assess the effects of welfare reform. III-2 ECONOMIC SECURITY RISK FACTOR 1. Poverty Rates Figure ECON 1. Percentage of Persons in Poverty by Age: 1959-2009 Note: All persons under 18 include related children (own children, including stepchildren and adopted children, plus all other children in the household who are related to the householder by birth, marriage, or adoption), unrelated individuals under 18 (persons who are not living with any relatives), and householders or spouses under age 18. Source: U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60-238, and data published online at http:\/\/www.census.gov\/hhes\/www\/poverty.html. Figure ECON 1 shows the percentage of persons in poverty by age from 1959 to 2009. The official poverty rate was 14.3 percent in 2009, an increase of 1.1 percentage points over the previous year’s rate of 13.2 percent. The poverty rate has increased every year since 2006. The percentage of persons living in poverty in 2000 was the lowest poverty rate since 1973. Children under 18 had a poverty rate of 20.7 percent in 2009. As in past years, the child poverty rate is higher than the overall poverty rate. Table ECON 1 shows the percentage of persons in poverty by age and family type for selected years. The poverty rate for the elderly (persons ages 65 and over) was 8.9 percent and the poverty rate for other adults (persons ages 18 to 64) was 12.9 percent in 2009. Related children from birth to age five have had the highest poverty rate among all age groups throughout the 1980s, 1990s, and into the 2000s. In 2009, 23.8 percent of related children from birth to age 5 lived below the poverty line. The poverty rates for persons in both married-couple families and female-headed families have decreased since the 1960’s. In 1959, 18.2 percent of persons in married- couple families and 49.4 percent of persons in female-headed families were poor. By 2009, 7.2 percent of persons in married- couple families and 32.5 percent of persons in female-headed families were poor. 22.4 14.3 15.2 27.3 20.7 22.7 15.3 23.8 25.7 10 15 20 25 30 1959 1964 1969 1974 1979 1984 1989 1994 1999 2004 2009 Related children 0-5 All persons under 18 All persons (In percent) III-3 http:\/\/www.census.gov\/hhes\/www\/poverty.html)\ufffd Table ECON 1. Percentage of Persons in Poverty by Age and Family Type: Selected Years Related Children All Persons Calendar Year Ages 0-5 Ages 6-17 Total Under 18 18 to 64 65 & over In married- couple families In female- headed families 1959 NA NA 22.4 27.3 17.0 35.2 18.2 49.4 1963 NA NA 19.5 23.1 NA NA 14.9 47.7 1966 NA NA 14.7 17.6 10.5 28.5 10.3 39.8 1969 15.3 13.1 12.1 14.0 8.7 25.3 7.4 38.2 1973 15.7 13.6 11.1 14.4 8.3 16.3 6.0 37.5 1976 17.7 15.1 11.8 16.0 9.0 15.0 6.4 37.3 1979 17.9 15.1 11.7 16.4 8.9 15.2 6.3 34.9 1980 20.3 16.8 13.0 18.3 10.1 15.7 7.4 36.7 1981 22.0 18.4 14.0 20.0 11.1 15.3 8.1 38.7 1982 23.3 20.4 15.0 21.9 12.0 14.6 9.1 40.6 1983 24.6 20.4 15.2 22.3 12.4 13.8 9.3 40.2 1984 23.4 19.7 14.4 21.5 11.7 12.4 8.5 38.4 1985 22.6 18.8 14.0 20.7 11.3 12.6 8.2 37.6 1986 21.6 18.8 13.6 20.5 10.8 12.4 7.3 38.3 1987 22.3 18.3 13.4 20.3 10.6 12.5 7.2 38.1 1988 21.8 17.5 13.0 19.5 10.5 12.0 6.6 37.2 1989 21.9 17.4 12.8 19.6 10.2 11.4 6.7 35.9 1990 23.0 18.2 13.5 20.6 10.7 12.2 6.9 37.2 1991 24.0 19.5 14.2 21.8 11.4 12.4 7.2 39.7 1992 25.7 19.4 14.8 22.3 11.9 12.9 7.7 38.5 1993 25.6 20.0 15.1 22.7 12.4 12.2 8.0 38.7 1994 24.5 19.5 14.5 21.8 11.9 11.7 7.4 38.6 1995 23.7 18.3 13.8 20.8 11.4 10.5 6.8 36.5 1996 22.7 18.3 13.7 20.5 11.4 10.8 6.9 35.8 1997 21.6 18.0 13.3 19.9 10.9 10.5 6.4 35.1 1998 20.6 17.1 12.7 18.9 10.5 10.5 6.2 33.1 1999 18.4 15.7 11.9 17.1 10.1 9.7 5.9 30.5 2000 17.8 14.7 11.3 16.2 9.6 9.9 5.5 27.9 2001 18.2 14.6 11.7 16.3 10.1 10.1 5.7 28.6 2002 18.5 15.3 12.1 16.7 10.6 10.4 6.1 28.8 2003 19.8 15.9 12.5 17.6 10.8 10.2 6.2 30.0 2004 20.0 16.0 12.7 17.8 11.3 9.8 6.4 30.5 2005 20.0 15.7 12.6 17.6 11.1 10.1 5.9 31.1 2006 20.0 15.4 12.3 17.4 10.8 9.4 5.7 30.5 2007 20.8 16.0 12.5 18.0 10.9 9.7 5.8 30.7 2008 21.3 17.1 13.2 19.0 11.7 9.7 6.7 31.4 2009 23.8 18.2 14.3 20.7 12.9 8.9 7.2 32.5 Note: All persons under 18 include related children (own children, including stepchildren and adopted children, plus all other children in the household who are related to the householder by birth, marriage, or adoption), unrelated individuals under 18 (persons who are not living with any relatives), and householders or spouses under age 18. In 1959-1987, persons in married-couple families include a small number of persons in male-headed families with no spouse present. In 1988, the first year for which we have separate data for these families, poor persons in male-headed families with no spouse present comprised just over 8 percent of the combined total of all persons below the poverty level. Spouses are not present in the female-headed family category. Source: U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60- 238, and data published online at http:\/\/www.census.gov\/hhes\/www\/poverty.html. III-4 http:\/\/www.census.gov\/hhes\/www\/poverty.html)\ufffd ECONOMIC SECURITY RISK FACTOR 2. Deep Poverty Rates Figure ECON 2. Percentage of Total Population below 50, 100 and 125 Percent of Poverty Level: Selected Years 1975-2006 Source: U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60-238, and data published online at http:\/\/www.census.gov\/hhes\/www\/poverty.html. Figure ECON 2 shows the percentage of the population below 50, 100, and 125 percent of the poverty level over time. The percentage of the population in deep poverty (with incomes below 50 percent of the federal poverty level) was 6.3 percent in 2009, compared to an overall poverty rate of 14.3 percent. Less than five (4.4) percent of the population was near-poor; they had incomes at or above 100 percent but below 125 percent of the federal poverty level in 2009. Table ECON 2 shows the number and percentage of the population below 50, 75, and 125 percent of the poverty level for selected years. In general, the percentage of the population with incomes below 50 percent of the poverty level has followed a pattern that reflects the trend in the overall poverty rate. The percentage of people below 50 percent of the poverty level rose in the late 1970s and early 1980s to 5.9 percent, and then after falling, has risen past its 1993 peak of 6.2 percent. The rates for 100 percent and 125 percent of the poverty level followed a somewhat similar pattern with more pronounced peaks and valleys. Over the past three decades, the proportion of the poverty population in deep poverty has increased substantially. The percent of the poverty population in deep poverty went from a low of 28 percent in 1976 to 44 percent in 2009. 0 5 10 15 20 1975 1980 1985 1990 1995 2000 2005 Below 50 percent Below 100 percent Below 125 percent 17.6 12.3 20.3 15.2 20.0 15.1 18.7 14.3 (In percent) \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf \u25cf 4139 30 44 75 80 85 90 95 00 05 09 Year Percent of Poor in Deep Poverty 3.7 5.9 6.2 6.3 2009 III-5 http:\/\/www.census.gov\/hhes\/www\/poverty.html)\ufffd Table ECON 2. Number and Percentage of Total Population below 50, 75, 100 and 125 Percent of Poverty Level: Selected Years Total Below 50 Percent Below 75 Percent Below 100 Percent Below 125 Percent Population Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent Number (thousands) Percent Year (thousands) 1959 176,600 NA NA NA NA 39,500 22.4 54,900 31.1 1961 181,300 NA NA NA NA 39,600 21.9 54,300 30.0 1963 187,300 NA NA NA NA 36,400 19.5 50,800 27.1 1965 191,400 NA NA NA NA 33,200 17.3 46,200 24.1 1967 195,700 NA NA NA NA 27,800 14.2 39,200 20.0 1969 199,500 NA NA 14,600 7.3 24,100 12.1 34,700 17.4 1971 204,600 NA NA NA NA 25,600 12.5 36,500 17.8 1973 207,600 NA NA NA NA 23,000 11.1 32,800 15.8 1975 210,900 7,700 3.7 15,400 7.3 25,900 12.3 37,200 17.6 1976 212,300 7,000 3.3 14,900 7.0 25,000 11.8 35,500 16.7 1977 213,900 7,500 3.5 15,000 7.0 24,700 11.6 35,700 16.7 1978 215,700 7,700 3.6 14,900 6.9 24,500 11.4 34,200 15.8 1979 222,900 8,600 3.8 16,300 7.3 26,100 11.7 36,600 16.4 1980 225,000 9,800 4.4 18,700 8.3 29,300 13.0 40,700 18.1 1981 227,200 11,200 4.9 20,700 9.1 31,800 14.0 43,700 19.3 1982 229,400 12,800 5.6 23,200 10.1 34,400 15.0 46,500 20.3 1983 231,700 13,600 5.9 23,600 10.2 35,300 15.2 47,200 20.3 1984 233,800 12,800 5.5 22,700 9.7 33,700 14.4 45,300 19.4 1985 236,600 12,400 5.2 22,200 9.4 33,100 13.6 44,200 18.7 1986 238,600 12,700 5.3 22,400 9.4 32,400 14.0 43,500 18.7 1987 241,000 12,500 5.2 21,700 9.0 32,200 13.4 43,000 17.9 1988 243,500 12,700 5.2 21,400 8.8 31,700 13.0 42,600 17.5 1989 246,000 12,000 4.9 20,700 8.4 31,500 12.8 42,700 17.3 1990 248,600 12,900 5.2 22,600 9.1 33,600 13.5 44,800 18.0 1991 251,200 14,100 5.6 24,400 9.7 35,700 14.2 47,500 18.9 1992 256,500 15,500 6.1 26,200 10.2 38,000 14.8 50,600 19.7 1993 259,300 16,000 6.2 27,200 10.5 39,300 15.1 51,800 20.0 1994 261,600 15,400 5.9 26,400 10.1 38,100 14.5 50,400 19.3 1995 263,700 13,900 5.3 24,500 9.3 36,400 13.8 48,800 18.5 1996 266,200 14,400 5.4 24,800 9.3 36,500 13.7 49,300 18.5 1997 268,500 14,600 5.4 24,200 9.0 35,600 13.3 47,900 17.8 1998 271,100 13,900 5.1 23,000 8.5 34,500 12.7 46,000 17.0 1999 276,200 12,900 4.7 21,800 7.9 32,800 11.9 45,000 16.3 2000 278,900 12,600 4.5 20,900 7.5 31,600 11.3 43,600 15.6 2001 281,500 13,400 4.8 22,000 7.8 32,900 11.7 45,300 16.1 2002 285,300 14,100 4.9 23,100 8.1 34,600 12.1 47,100 16.5 2003 287,700 15,300 5.3 24,500 8.5 35,900 12.5 48,700 16.9 2004 290,600 15,700 5.4 25,000 8.6 37,000 12.7 49,700 17.1 2005 293,100 15,900 5.4 25,200 8.6 37,000 12.6 49,300 16.8 2006 296,500 15,400 5.2 25,200 8.5 36,500 12.3 49,700 16.8 2007 298,700 15,600 5.2 25,100 8.4 37,300 12.5 50,900 17.0 2008 301,000 17,100 5.7 27,400 9.1 39,800 13.2 53,800 17.9 2009 303,800 19,000 6.3 30,100 9.9 43,600 14.3 56,800 18.7 Note: In previous editions of this report, the number of persons below 50 percent and 75 percent of poverty for 1969 were calculated based on data from the 1970 decennial census. In this report the estimate of the number of persons below 75 percent of poverty for 1969 comes from Current Population Survey data published in Current Population Reports, Series P60-76. Source: U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60- 238, and data published online at http:\/\/www.census.gov\/hhes\/www\/poverty.html. III-6 http:\/\/www.census.gov\/hhes\/www\/poverty.html)\ufffd ECONOMIC SECURITY RISK FACTOR 3. Experimental Poverty Measures Figure ECON 3. Percentage of Persons in Poverty Using Various Experimental Poverty Measures by Age: 2009 Note: These measures use versions of 1999 Consumer Expenditure-based poverty thresholds that are updated annually using the CPI-U. These experimental poverty measures implement changes recommended by a 1995 National Academy of Sciences panel, including: counting certain non-cash benefits as income; subtracting from income certain work-related, health and child care expenses; introducing new poverty thresholds; and adjusting those thresholds for geographic differences in housing costs. The three alternative measures are similar, except that each accounts for medical out-of-pocket expenses (MOOP) differently. The first alternative (MOOP subtracted from income or MSI) subtracts out-of-pocket medical expenses from income. The second alternative (MOOP in the threshold or MIT) increases the poverty thresholds to take MOOP expenses into account. The third measure, CMB for combined methods, combines attributes of the previous two measures. Each of the three measures is calculated with and without accounting for geographic adjustments (GA and NGA). Pleases note that the estimates for 2009 are not strictly comparable with earlier estimates because capital gains and losses are not included in this year’s estimate. Source: U.S. Census Bureau, Alternative Poverty Estimates Based on National Academy of Sciences Recommendations, by Geographic and Inflationary Adjustments, available online at http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html and unpublished CPS data from the U.S. Census Bureau. Figure ECON 3 shows the percentage of persons in poverty using various experimental poverty measures by age in 2009. Three experimental measures of poverty (developed by the U.S. Census Bureau in response to the recommendations of a 1995 panel of the National Academy of Sciences) yield poverty rates that are similar to the official poverty measure overall, but differ by age and other characteristics. Experimental measures generally show lower poverty rates among children than the official measure, partly because they take into account non-cash benefits that many children receive. Conversely, experimental measures show higher rates of poverty among the elderly than the official measure, in part due to taking into account certain out- of-pocket health costs for these measures. All three alternative measures shown in Figure ECON 3 are versions that do not take into account geographic adjustments for housing costs (NGA); there also are versions that do take into account those geographic adjustments (GA), as shown in Tables ECON 3a and 3b. 8.9 14.3 20.7 12.8 14.0 13.913.3 15.1 11.6 13.5 14.8 14.6 0 4 8 12 16 20 24 All persons Children ages 0 – 17 Adults ages 65 and over Official poverty measure Alternative 1-NGA Alternative 2-NGA Alternative 3-NGA (In percent) III-7 http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html\ufffd Table ECON 3a. Percentage of Persons in Poverty Using Various Experimental Poverty Measures by Selected Characteristics: 2009 No Geographic Adjustment Geographic Adjustment Official Alternative 1 (MSI-NGA) Alternative 2 (MIT-NGA) Alternative 3 (CMB-NGA) Alternative 1 (MSI-GA) Alternative 2 (MIT-GA) Alternative 3 (CMB-GA) All Persons 14.3 12.8 13.3 13.5 12.9 13.2 13.6 Racial\/Ethnic Categories Non-Hispanic White 9.4 9.3 9.5 9.7 8.7 8.8 9.2 Non-Hispanic Black 25.6 20.4 21.0 21.4 19.7 20.0 20.6 Hispanic 25.3 21.0 22.3 22.1 23.5 24.9 25.0 Age Categories Children ages 0-17 20.7 14.0 15.1 14.8 14.2 15.1 15.0 Adults ages 18-64 12.9 12.2 12.9 12.7 12.3 12.9 12.9 Adults ages 65 and over 8.9 13.9 11.6 14.6 13.4 11.1 14.3 Note: These measures use versions of 1999 Consumer Expenditure-poverty thresholds that are updated annually using the CPI-U. These experimental poverty measures implement changes recommended by a 1995 National Academy of Sciences panel, including: counting certain non-cash benefits as income; subtracting from income certain work-related, health and child care expenses; introducing new poverty thresholds; and adjusting those thresholds for geographic differences in housing costs. The three alternative measures are similar, except that each accounts for medical out-of-pocket expenses (MOOP) differently. The first alternative (MOOP subtracted from income or MSI) subtracts out-of-pocket medical expenses from income. The second alternative (MOOP in the threshold or MIT) increases the poverty thresholds to take MOOP expenses into account. The third measure, CMB for combined methods, combines attributes of the previous two measures. Each of the three measures is calculated with and without accounting for geographic adjustments (GA and NGA). Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in all persons but not shown separately. Source: U.S. Census Bureau, Alternative Poverty Estimates Based on National Academy of Sciences Recommendations, by Geographic and Inflationary Adjustments, available online at http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html and unpublished CPS data from the U.S. Census Bureau. Table ECON 3b. Percentage of Persons in Poverty Using Various Experimental Poverty Measures: 1999-2009 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Official Poverty Measure 11.9 11.3 11.7 12.1 12.5 12.7 12.6 12.3 12.5 13.2 14.3 No Geographic Adjustment of Thresholds Medical costs alternative 1 (MSI-NGA) 12.2 12.1 12.4 12.4 12.4 12.7 12.6 12.4 12.6 12.8 12.8 Medical costs alternative 2 (MIT-NGA) 12.8 12.7 12.8 13.0 12.8 13.1 13.0 12.8 12.9 13.1 13.3 Medical costs alternative 3 (CMB-NGA) 12.9 12.8 13.0 13.0 13.0 13.3 13.3 13.0 13.2 13.4 13.5 Geographic Adjustment of Thresholds Medical costs alternative 1 (MSI-GA) 12.1 12.0 12.3 12.3 12.3 12.5 12.5 12.2 12.6 12.8 12.9 Medical costs alternative 2 (MIT-GA) 12.7 12.5 12.7 12.8 12.7 13.0 13.0 12.6 13.0 13.2 13.2 Medical costs alternative 3 (CMB-GA) 12.8 12.6 12.9 12.9 12.9 13.3 13.1 12.9 13.3 13.4 13.6 Note: These measures use versions of 1999 Consumer Expenditure-based poverty thresholds that are updated annually using the CPI-U. These experimental poverty measures implement changes recommended by a 1995 National Academy of Sciences panel, including: counting certain non-cash benefits as income; subtracting from income certain work-related, health and child care expenses; introducing new poverty thresholds; and adjusting those thresholds for geographic differences in housing costs. The three alternative measures are similar, except that each accounts for medical out-of-pocket expenses (MOOP) differently. The first alternative (MOOP subtracted from income or MSI) subtracts out-of-pocket medical expenses from income. The second alternative (MOOP in the threshold or MIT) increases the poverty thresholds to take MOOP expenses into account. The third measure, CMB for combined methods, combines attributes of the previous two measures. Each of the three measures is calculated with and without accounting for geographic adjustments (GA and NGA). Source: U.S. Census Bureau, Alternative Poverty Estimates Based on National Academy of Sciences Recommendations, by Geographic and Inflationary Adjustments, available online at http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html and unpublished CPS data from the U.S. Census Bureau. III-8 http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html\ufffd http:\/\/www.census.gov\/hhes\/povmeas\/data\/nas\/tables\/2009\/index.html\ufffd (In percent) ECONOMIC SECURITY RISK FACTOR 4. Poverty Rates with Various Means-Tested Transfers Counted as Income Figure ECON 4. Percentage of Total Population Below the Official Poverty Line with Various Means-Tested Transfers Counted as Income: 1979-2009 Note: The four measures of income are as follows: (1) Cash income plus all social insurance is earnings and cash income, plus social security, workers compensation, disability, unemployment, public and private pensions, veterans benefits and other social insurance cash transfers. It does not include means-tested cash transfers; (2) Plus means-tested cash transfers is the official Census Bureau income definition, which includes means- tested cash transfers, primarily AFDC\/TANF and SSI; (3) Plus food and housing benefits counts the cash value of means-tested food and housing benefits as income; and (4) Plus EITC and federal taxes is the most comprehensive income measure used. It adds the refundable Earned Income Tax Credit (EITC) to income, while subtracting federal payroll and income taxes. The fungible value of Medicare and Medicaid is not included in any of the income measures. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1980-2009, analyzed by the Congressional Budget Office. Figure ECON 4 shows the percentage of the population below the official poverty line with various means-tested transfers counted as income for the years 1979 to 2009. The official poverty rate using the official income definition, which includes means-tested cash transfers (primarily TANF and SSI) in addition to pre-transfer cash income and social insurance cash transfers was 14.3 percent in 2009. Without cash welfare, the 2009 poverty rate would be 15.1 percent.1 1 Unlike the new research Supplemental Poverty Measure published by the Census Bureau, this analysis maintains both the official poverty measurement definition of household and thresholds while expanding the number and type of resources beyond the cash income resources counted as part of the official measure. Adding non-cash, means-tested transfers to the official income definition has the effect of lowering the percentage of people with incomes below the official poverty line. Including the value of food and housing benefits in total income would reduce the poverty rate to 12.4 percent in 2009. 15.1 14.3 12.4 10.5 8 10 12 14 16 18 1982 1985 1988 1991 1994 1997 2000 2003 2006 20091979 Cash income plus social insurance Plus means-tested cash transfers (official poverty rate) Plus EITC and federal taxes Plus food and housing benefits III-9 When income is defined to include the Earned Income Tax Credit (EITC) and the effect of federal taxes, the percentage of people below the official poverty line would decrease to 10.5 percent in 2009. Federal taxes and the EITC have had the net effect of reducing poverty rates following the EITC expansions in 1993 and 1995. Table ECON 4 shows the percentage of the population below the official poverty line with various means-tested transfers counted as income for selected years. The combined effect of means-tested cash transfers, food and housing benefits, the EITC, and federal taxes was to reduce the poverty rate in 2009 by 4.6 percentage points. Net reductions in poverty rates were smaller during the 1981 – 1982 recession, and higher in the mid-1990s, largely due to expansions in the EITC. Table ECON 4. Percentage of Total Population Below the Official Poverty Line with Various Means- Tested Transfers Counted as Income: Selected Years 1979 1983 1986 1989 1992 1995 1998 2000 2002 2005 2007 2008 2009 Cash income plus all social insurance 12.8 16.0 14.5 13.8 15.6 14.9 13.5 12.0 12.8 13.3 13.2 13.9 15.1 Plus means-tested cash transfers (official poverty measure) 11.6 15.2 13.6 12.8 14.5 13.8 12.7 11.3 12.1 12.6 12.5 13.2 14.3 Plus food and housing benefits 9.7 13.7 12.2 11.2 12.9 12.0 11.3 10.1 10.9 11.2 11.1 11.7 12.4 Plus EITC and federal taxes 10.0 14.7 13.1 11.8 13.0 11.5 10.4 9.5 10.0 10.3 10.1 10.1 10.5 Reduction in poverty rate 2.8 1.3 1.4 2.0 2.6 3.4 3.1 2.5 2.8 3.0 3.1 3.8 4.6 Note: The four measures of income are as follows: (1) Cash income plus all social insurance is earnings and cash income, plus social security, workers compensation, disability, unemployment, public and private pensions, veterans benefits and other social insurance cash transfers. It does not include means-tested cash transfers; (2) Plus means-tested cash transfers is the official Census Bureau income definition, which includes means- tested cash transfers, primarily AFDC\/TANF and SSI; (3) Plus food and housing benefits counts the cash value of means-tested food and housing benefits as income; and (4) Plus EITC and federal taxes is the most comprehensive income measure used. It adds the refundable Earned Income Tax Credit (EITC) to income, while subtracting federal payroll and income taxes. The fungible value of Medicare and Medicaid is not included in any of the income measures. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1980-2009, analyzed by the Congressional Budget Office. III-10 ECONOMIC SECURITY RISK FACTOR 5. Poverty Spells Figure ECON 5. Percentage of Poverty Spells for Persons Entering Poverty during the 2004 SIPP Panel by Length of Spell Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel (2004 2007). Figure ECON 5 shows the percentage of poverty spells that are of various lengths for persons who became poor during the 2004 – 2007 period. Nearly half (47.8 percent) of poverty spells that began between 2004 and 2007 ended within 4 months. Almost three- quarters (74.5 percent) of poverty spells during this period ended within one year while 13.4 percent of spells lasted more than 20 months. Table ECON 5a shows the percentage of poverty spells for persons entering poverty during the 2004 – 2007 period by length of spell and demographic characteristics. Among racial and ethnic groups, a larger percentage of Non-Hispanic Whites had short spells of poverty (50.0 percent) than Non-Hispanic Blacks (46.5 percent) or Hispanics of any race (42.8 percent). For poverty spells greater than 20 months, a larger percentage of Non-Hispanic Blacks had long poverty spells (18.3 percent) compared to Non-Hispanic Whites (10.5 percent) and Hispanics of any race (17.5 percent). When examining long spells of poverty, greater than 20 months, by age group, children 11-15 years of age had the highest rate (16.6 percent) and men 16-64 years of age had the lowest rate (10.6 percent). 48% 27% 12% 13% Spells <= 4 months Spells 5-12 months Spells 13-20 months Spells > 20 months III-11 Table ECON 5a. Percentage of Poverty Spells for Persons Entering Poverty during the 2004 SIPP Panel by Length of Spell and Selected Characteristics Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months All Persons 47.8 26.7 12.2 13.4 Racial\/Ethnic Categories Non-Hispanic White 50.0 32.1 7.3 10.5 Non-Hispanic Black 46.5 20.6 14.5 18.3 Hispanic 42.8 17.6 22.1 17.5 Age Categories Children ages 0-5 years 45.8 21.9 16.1 16.2 Children ages 6-10 years 45.1 21.0 19.2 14.7 Children ages 11-15 years 46.9 23.6 13.0 16.6 Women ages 16-64 years 47.5 25.6 12.8 14.1 Men ages 16-64 years 50.9 34.0 4.6 10.6 Adults ages 65 years and over 42.5 17.8 27.1 12.6 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Survey of Income and Program Participation, 2004 panel (2004 2007). Table ECON 5b. Percentage of Poverty Spells for Persons Entering Poverty during Selected SIPP Panels by Length of Spell Spells <=4 Months Spells 5-12 Months Spells 13-20 Months Spells >20 Months 1993 1995 47.3 28.1 8.9 15.7 1996 1999 51.3 29.0 8.3 11.4 2001 2003 49.2 27.7 7.7 15.5 2004 2007 47.8 26.7 12.2 13.4 Note: Spell length categories are mutually exclusive. Spells separated by only 1 month are not considered separate spells. Source: Unpublished tabulations from the Survey of Income and Program Participation, 1993, 1996 , 2001, and 2004 panels. III-12 ECONOMIC SECURITY RISK FACTOR 6. Child Support Figure ECON 6. Total Current Child Support Collections Distributed by Receipt of IV-D Services and Other Public Assistance: 1993-2009 Note: AFDC\/TANF families are families who have reported receiving cash assistance for any month during the 12-month period. Therefore, not all the child support reported received was necessarily received while the family was receiving cash assistance. Data limitations do not allow a month-by- month breakdown. Families receiving SSI, food stamps\/SNAP, Medicaid or housing assistance are limited to families not receiving AFDC\/TANF. Families receiving services through the IV-D system are estimated according to the methodology described in technical appendices to the ASPE- published report Characteristics of Families Using Title IV-D Services in 1999 and 2001, available at: http:\/\/aspe.hhs.gov\/hsp\/CSE-Char04\/index.htm and previous reports. Source: Unpublished tabulations from the Current Population Survey, Child Support Supplement, 1994-2009. Figure ECON 6 shows total child support collections distributed by receipt of IV-D services and other public assistance between 1993 and 2009. Title IV-D of the Social Security Act authorizes state programs to assist custodial parents in establishing paternity and child support awards, and collecting child support payments. The total amount of child support received by custodial parents through the IV-D system in 2009 was $15.3 billion or 64.6 percent of all child support payments received by custodial parents.2 2 As noted in the Data Sources section, the CPS has been subject to criticism for underreporting of income. The CPS-CSS, a supplement to the CPS, underreports the amount of current support income received by custodial parents, especially among those in the IVD system. The Federal Office of Child Support Enforcement reports that the total amount of current support collected through the IVD system in FY 2009 was $19.9 billion. Only $715 million of that was collected on behalf of families on current assistance, some of which was retained by the government to recoup welfare costs. Thus, custodial families in the IV-D system received over $19 billion in current support in FY 2009. This figure is about 25 percent higher than the amount reported in the CPS-CSS. See: Department of Health and Human Services, Administration for Children and Families, Office of Child Support Enforcement. FY 2009 Annual Report to Congress. Appendix III. Table 84 for total current support collections. Unpublished figures indicate the amount collected on behalf of current assistance cases. http:\/\/www.acf.hhs.gov\/programs\/css\/resource\/fy2009-annual-report- table-84 In total for 2009, custodial parents reported receiving $23.7 billion in child support payments from non-resident parents.3 3 This amount represents current year support received for a twelve-month period and does not include amounts paid for prior periods (arrearages) or amounts retained by the federal and state governments to recoup welfare costs. Total child support collections have fluctuated between 1993 and 2009. The 2009 collection rate is similar to the 1993 collection rate, $23.7 billion in 2009 compared to $24.1 billion in 1993 (in constant 2009 dollars). (2009 constant dollars in billions) 3.6 3.3 3.4 2.2 1.8 3.0 2.0 1.5 1.8 2.4 2.8 3.7 3.7 4.4 6.2 6.5 6.0 7.2 6.8 9.4 7.9 8.7 10.1 9.6 10.3 7.0 6.3 11.3 12.3 11.3 11.4 10.9 9.8 9.6 8.4 12.4 0 10 20 30 1993 1995 1997 1999 2001 2003 2005 2007 2009 Outside of IV-D system IV-D services (but not other assistance) IV-D services and non-cash assistance or SSI IV-D services and AFDC\/TANF III-13 http:\/\/aspe.hhs.gov\/hsp\/CSE-Char04\/index.htm\ufffd http:\/\/www.acf.hhs.gov\/programs\/css\/resource\/fy2009-annual-report-table-84\ufffd http:\/\/www.acf.hhs.gov\/programs\/css\/resource\/fy2009-annual-report-table-84\ufffd Table ECON 6. Total and Percent of Child Support Collections by Receipt of IV-D Services and Other Assistance: Selected Years 1993-2009 Collections 1993 1995 1997 1999 2001 2003 2005 2007 2009 Receiving Title IV-D Child Support Services and: (Billions of current dollars) AFDC\/TANF 2.5 2.4 2.5 1.7 1.5 2.6 1.8 1.5 1.8 SNAP, SSI, Medicaid or Housing 1.7 2.0 2.8 2.9 3.7 5.3 5.9 5.8 7.2 Child Support Services Only 4.7 6.7 5.9 6.7 8.3 8.3 9.4 6.8 6.3 Subtotal Families Receiving IV-D Services 8.8 11.1 11.2 11.3 13.5 16.2 17.2 14.0 15.3 Not Receiving IV-D Child Support Services 7.7 8.8 9.3 8.8 9.4 9.4 9.0 9.3 8.4 Total 16.5 19.9 20.6 20.1 22.9 25.6 26.1 23.3 23.7 Receiving Title IV-D Child Support Services and: (Billions of constant 2009 dollars) AFDC\/TANF 3.6 3.3 3.4 2.2 1.8 3.0 2.0 1.5 1.8 SNAP, SSI, Medicaid or Housing 2.4 2.8 3.7 3.7 4.4 6.2 6.5 6.0 7.2 Child Support Services Only 6.8 9.4 7.9 8.7 10.1 9.6 10.3 7.0 6.3 Subtotal Families Receiving IV-D Services 12.9 15.5 15.0 14.5 16.4 18.9 18.8 14.5 15.3 Not Receiving IV-D Child Support Services 11.3 12.3 12.4 11.3 11.4 10.9 9.8 9.6 8.4 Total 24.1 27.8 27.4 25.8 27.7 29.8 28.7 24.1 23.7 Receiving Title IV-D Child Support Services and: (In percent) AFDC\/TANF 15.0 12.0 12.3 8.4 6.6 10.1 6.9 6.2 7.6 SNAP, SSI, Medicaid or Housing 10.1 9.9 13.6 14.3 16.0 20.9 22.8 24.8 30.3 Child Support Services Only 28.3 33.8 28.7 33.7 36.3 32.3 36.1 29.1 26.6 Subtotal Families Receiving IV-D Services 53.3 55.8 54.6 56.4 58.9 63.3 65.7 60.1 64.6 Not Receiving IV-D Child Support Services 46.7 44.2 45.4 43.6 41.1 36.7 34.3 39.9 35.4 Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 Note: AFDC\/TANF families are families who have reported receiving cash assistance for any month during the 12-month period. Therefore, not all the child support reported received was necessarily received while the family was receiving cash assistance. Data limitations do not allow a month-by- month breakdown. Families receiving SSI, SNAP, Medicaid or housing assistance are limited to families not receiving AFDC\/TANF. Families receiving services through the IV-D system are estimated according to the methodology described in technical appendices to the ASPE- published report Characteristics of Families Using Title IV-D Services in 1999 and 2001, available at: http:\/\/aspe.hhs.gov\/hsp\/CSE-Char04\/index.htm and previous reports. Source: Unpublished tabulations from the Current Population Survey, Child Support Supplement, 1994-2009. Table ECON 6 shows greater detail on child support collections by receipt of IV-D services and other assistance. Child support payments received through IV-D by custodial parents who also received AFDC\/TANF cash assistance, declined from $3.6 billion (constant 2009 dollars) in 1993 to $1.8 billion in 2009.4 4 The decline partly reflects the decrease in AFDC\/TANF caseloads. Also, some states no longer pass-through any child support payments to custodial parents receiving TANF. Prior to the enactment of PRWORA in 1996, states were required to pass-through the first $50 of any child support collected. Child support payments to custodial parents who did not receive TANF but received another form of public assistance (SNAP, SSI, Medicaid or housing assistance) increased from $2.4 billion (in constant 2009 dollars) to $7.2 billion between 1993 and 2009. This group of custodial parents includes former TANF recipients as well as those eligible for cash assistance. The increased collections for this group offset the decline in payments to TANF families. III-14 http:\/\/aspe.hhs.gov\/hsp\/CSE-Char04\/index.htm\ufffd ECONOMIC SECURITY RISK FACTOR 7. Food Insecurity Figure ECON 7. Percentage of Households Classified by Food Security Status: 2009 Note: Food secure households had consistent access to enough food for active, healthy lives for all household members at all times during the year. Households with low food security obtained enough food to avoid substantial disruptions in eating patterns and food intake, using a variety of coping strategies, such as eating less varied diets, participating in Federal food assistance programs, or getting emergency food from community food pantries or emergency kitchens. Households with very low food security reported reduced food intake of some household members and their normal eating patterns were disrupted because of the lack of money and other resources. Source: U.S. Department of Agriculture, Economic Research Service, Household Food Security in the United States, 2009. Figure ECON 7 shows the percentage of households that were food secure, had low food security, and had very low food security in 2009. The majority of U.S. households (85.3 percent) were food secure in 2009; that is, they showed little or no evidence of concern about food supply or reduction in food intake. Nine percent of U.S. households experienced low food security and 5.7 percent were classified as having very low food security. Very low food security is defined as having reduced food intake and having normal eating patterns disrupted because of financial constraints. The percentage of households reporting very low food security remained the same between 2008 and 2009. Table ECON 7a shows the percentage of households classified by food security status by selected demographic characteristics. Households with elderly were more food secure (92.5 percent) than were households with children under six (77.1 percent) or households with children under 18 (78.7 percent). There is a relationship between poverty and food security. Fifty-seven percent of poor households were food secure compared to 60.3 percent of households with income below 130 percent of the poverty level, and 65.2 percent of households below 185 percent of the poverty level. Married-couple households with children were less likely to experience food insecurity than female-headed households with children. Almost 15 percent (14.7) percent of married-couple households with children were food insecure in 2009 compared to 36.6 percent of female-headed households with children. Table ECON 7b shows the percentage of households classified by food security status between 1998 and 2009. The percentage of households with food insecurity (both low and very low food insecurity) has fluctuated since 1998 from a low of 10.1 percent in 1999 to a high of 14.7 percent in 2009. 85.3 9.0 5.7 Food secure Low food security Very low food security III-15 Table ECON 7a. Percentage of Households Classified by Food Security Status and Selected Characteristics: 2009 Food Secure Food Insecurity All Low Very Low All Households 85.3 14.7 9.0 5.7 Racial\/Ethnic Categories Non-Hispanic White 89.0 11.0 6.5 4.6 Non-Hispanic Black 75.1 24.9 15.6 9.3 Hispanic 73.1 26.9 17.6 9.3 Age Categories Households with children under 6 77.1 22.9 16.5 6.5 Households with children under 18 78.7 21.3 14.7 6.6 Households with elderly 92.5 7.5 4.9 2.6 Family Categories Married-couple households with children 85.3 14.7 10.7 4.0 Female-headed households with children 63.4 36.6 23.7 12.9 Male-headed households with children 72.2 27.8 19.5 8.3 Household Income-to-Poverty Ratio Under 1.00 57.0 43.0 24.4 18.5 Under 1.30 60.3 39.7 22.7 17.0 Under 1.85 65.2 34.8 20.4 14.4 1.85 and over 92.4 7.6 4.9 2.7 Note: Food secure households had consistent access to enough food for active, healthy lives for all household members at all times during the year. Households with low food security obtained enough food to avoid substantial disruptions in eating patterns and food intake, using a variety of coping strategies, such as eating less varied diets, participating in Federal food assistance programs, or getting emergency food from community food pantries or emergency kitchens. Households with very low food security reported reduced food intake of some household members and their normal eating patterns were disrupted because of the lack of money and other resources. Spouses are not present in the female-headed and male-headed household categories. Race and ethnicity categories for households are determined by the race and ethnicity of the reference person for the household. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all households but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all households but are not shown separately. Source: U.S. Department of Agriculture, Economic Research Service, Household Food Security in the United States, 2009. http:\/\/www.ers.usda.gov\/publications\/err-economic-research-report\/err108.aspx. Data are from the Current Population Survey, Food Security Supplement. Table ECON 7b. Percentage of Households Classified by Food Security Status: 1998-2009 Food Secure Food Insecurity All Low Very Low 1998 88.2 11.8 8.1 3.7 1999 89.9 10.1 7.1 3.0 2000 89.5 10.5 7.3 3.1 2001 89.3 10.7 7.4 3.3 2002 88.9 11.1 7.6 3.5 2003 88.8 11.2 7.7 3.5 2004 88.1 11.9 8.0 3.9 2005 89.0 11.0 7.1 3.9 2006 89.1 10.9 6.9 4.0 2007 88.9 11.1 7.0 4.1 2008 85.4 14.6 8.9 5.7 2009 85.3 14.7 9.0 5.7 Note: Food secure households had consistent access to enough food for active, healthy lives for all household members at all times during the year. Households with low food security obtained enough food to avoid substantial disruptions in eating patterns and food intake, using a variety of coping strategies, such as eating less varied diets, participating in Federal food assistance programs, or getting emergency food from community food pantries or emergency kitchens. Households with very low food security reported reduced food intake of some household members and their normal eating patterns were disrupted because of the lack of money and other resources. Source: U.S. Department of Agriculture, Economic Research Service, Household Food Security in the United States, 2009. III-16 http:\/\/www.ers.usda.gov\/publications\/err-economic-research-report\/err108.aspx\ufffd ECONOMIC SECURITY RISK FACTOR 8. Lack of Health Insurance Figure ECON 8. Percentage of Persons without Health Insurance by Poverty Status: 2009 Note: \”Poor persons\” are defined as those with total family incomes at or below the federal poverty threshold. Health insurance rates for the education categories include only adults age 18 and over. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Some of the race categories presented for ECON 8 have been changed slightly from prior year reports to provide more internal consistency throughout this report; in reports prior to 2006, the race categories for Black and White included persons of Hispanic origin. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009. Figure ECON 8 shows the percentage of persons without health insurance by race and ethnicity, educational attainment, and poverty status for 2009. Thirty-one (31.2) percent of poor persons were without health insurance as compared to 13.6 percent of non-poor persons. Among race and ethnic groups, poor Hispanics of any race had higher rates of being uninsured (39.9 percent) than did poor Non-Hispanic Whites (28.5 percent) and poor Non-Hispanic Blacks (27.4 percent). As education increases, the rate of being uninsured decreases. Among the non-poor who were not high school graduates, 27.6 percent were uninsured compared to 18.9 percent of high school graduates, and 7.2 percent of college graduates. Among the poor, 43.0 percent of persons who were not high school graduates, 42.7 percent of high school graduates, and 33.3 percent of college graduates were uninsured. Table ECON 8 shows the percentage of persons without health insurance by poverty status and demographic characteristics. Across all demographic categories, poor persons were more likely than non-poor persons to be uninsured regardless of race and ethnicity, gender, educational attainment, age, or family category. For poor persons, 15.0 percent of children 17 years of age or less were without health insurance as compared to 51.3 percent of poor adults 25 to 34 years of age. The 25 to 34 year age category had the highest percentage (51.3 percent) of uninsured among poor persons. For non-poor persons, 8.3 percent of the children 17 years of age or less were without health insurance as compared to 25.9 percent of adults 18 to 24 years of age. The 18 to 24 year age category had the highest percentage of uninsured among non-poor persons. 13.6 9.7 17.6 28.8 18.9 7.2 31.2 28.5 27.4 39.9 42.7 33.3 0 10 20 30 40 50 All persons Non-Hispanic White Non-Hispanic Black Hispanic Not a high school graduate High school graduate, no college College graduate Non-Poor Poor 27.6 43.0 (In percent) III-17 Table ECON 8. Percentage of Persons without Health Insurance by Poverty Status and Selected Characteristics: 2009 All Persons Poor Persons Non-Poor Persons All Persons 16.1 31.2 13.6 Men 17.8 34.1 15.3 Women 14.5 29.1 11.8 Race and Ethnicity Categories Non-Hispanic White 11.5 28.5 9.7 Non-Hispanic Black 20.1 27.4 17.6 Hispanic 31.6 39.9 28.8 Educational Attainment Categories Not a high school graduate 31.9 43.0 27.6 High school graduate, no college 22.2 42.7 18.9 College graduate 8.4 33.3 7.2 Age Categories 5 and under 9.0 12.4 7.8 6-11 9.3 14.3 7.9 12-17 11.0 19.6 9.2 17 and under 9.7 15.0 8.3 18-24 29.3 42.2 25.9 25-34 28.1 51.3 24.0 35-44 21.0 49.9 17.2 45-54 17.3 43.5 14.4 55-64 13.4 33.1 11.4 Under 65 years 18.2 33.4 15.5 65 years and over 1.7 6.9 1.1 Family Categories Persons in married-couple families 11.8 30.8 10.3 Persons in female-headed families 22.4 27.9 20.1 Persons in male-headed families 25.0 26.4 24.5 Unrelated persons 22.2 38.7 17.5 Note: \”Poor persons are defined as those with total family incomes at or below the federal poverty threshold. Health insurance rates for the education categories include only adults age 18 and over. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Some of the race categories presented for ECON 8 have been changed slightly from prior year reports to provide more internal consistency throughout this report; in reports prior to 2006, the race categories for Black and White included persons of Hispanic origin. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2009. III-18 EMPLOYMENT AND WORK-RELATED RISK FACTOR 1. Labor Force Attachment Figure WORK 1. Percentage of Persons in Families with Labor Force Participants by Race and Ethnicity: 2009 Note: Full-time, full-year workers (FT\/FY) are defined as those who usually worked for 35 or more hours per week, for at least 50 weeks in a given year. Part-time and part-year labor force participation includes part-time workers and individuals who are unemployed, laid off, and\/or looking for work for part or all of the year. This indicator represents annual measures of labor force participation, and thus cannot be compared to monthly measures of labor force participation in Indicator 2. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010. Figure WORK 1 shows the percentage of persons in families with labor force participants by race and ethnicity. In 2009, Hispanics of any race were more likely to live in families with at least one full-time, full- year labor force participant (69.1 percent) than were Non-Hispanic Whites (68.2 percent) or Non-Hispanic Blacks (60.9 percent). Table WORK 1a shows the percentage of persons in families with labor force participants by demographic characteristics. In 2009, children ages 6 to 15 were more likely to live in families with at least one full- time, full-year labor force participant than were children from birth to 5 years of age. Among family types, persons living in married-couple families were more likely than persons living in other family types to live in families with at least one full-time, full- year labor force participant. Table WORK 1b shows the percentage of persons in families with labor force participants for select years between 1990 and 2009. The percentage of persons living in families with at least one full-time, full- year labor force participant has fluctuated over time. The percentage increased from a low of 67.6 percent in 1992 to a high of 73.3 percent in 2000. In 2009, 67.8 percent of persons lived in families with at least one full-time, full-year worker. (In percent) 15.0 17.0 9.1 68.2 60.9 69.1 22.2 16.8 21.8 0 20 40 60 80 100 Non-Hispanic White Non-Hispanic Black Hispanic At least one FT\/FY labor force participant At least one in labor force, no FT\/FY participants No one in labor force during year III-19 Table WORK 1a. Percentage of Persons in Families with Labor Force Participants by Selected Characteristics: 2009 No One in LF During Year At Least One in LF No One FT\/FY At Least One FT\/FY Worker All Persons 14.0 18.2 67.8 Racial\/Ethnic Categories Non-Hispanic White 15.0 16.8 68.2 Non-Hispanic Black 17.0 22.2 60.9 Hispanic 9.1 21.8 69.1 Age Categories Children ages 0-5 6.4 21.7 71.9 Children ages 6-10 6.5 18.2 75.3 Children ages 11-15 6.6 18.0 75.5 Women ages 16-64 8.5 18.5 73.0 Men ages 16-64 6.3 17.6 76.1 Adults ages 65 and over 60.5 17.1 22.4 Family Categories Persons in married families 9.6 13.8 76.7 Persons in female-headed families 15.5 28.7 55.8 Persons in male-headed families 15.1 29.8 55.1 Unrelated persons 29.5 22.0 48.5 Note: Full-time, full-year (FT\/FY) workers are defined as those who usually worked for 35 or more hours per week, for at least 50 weeks in a given year. Part-time and part-year labor force participation includes part-time workers and individuals who are unemployed, laid off, and\/or looking for work for part or all of the year. This indicator represents annual measures of labor force participation, and thus cannot be compared to monthly measures of labor force participation in Indicator 2. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2010. Table WORK 1b. Percentage of Persons in Families with Labor Force Participants: Selected Years No One in LF During Year At Least One in LF No One FT\/FY At Least One FT\/FY Worker 1990 13.7 17.6 68.7 1992 14.4 18.1 67.6 1994 14.1 17.1 68.8 1996 13.6 16.1 70.3 1998 13.3 14.6 72.1 1999 12.6 14.4 73.1 2000 12.8 13.8 73.3 2001 13.3 14.4 72.4 2002 13.4 14.6 72.0 2003 13.8 15.0 71.2 2004 13.9 14.4 71.7 2005 13.7 14.1 72.2 2006 13.6 13.7 72.8 2007 13.5 14.1 72.5 2008 13.7 16.0 70.4 2009 14.0 18.2 67.8 Note: Full-time, full-year workers (FT\/FY) are defined as those who usually worked for 35 or more hours per week, for at least 50 weeks in a given year. Part-time and part-year labor force participation includes part-time workers and individuals who are unemployed, laid off, and\/or looking for work for part or all of the year. This indicator represents annual measures of labor force participation, and thus cannot be compared to monthly measures of labor force participation in Indicator 2. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1991-2010. III-20 EMPLOYMENT AND WORK-RELATED RISK FACTOR 2. Employment among the Low-Skilled Figure WORK 2. Percentage of Persons Ages 18 to 65 with No More than a High School Education Who Were Employed at Any Time during Year by Race and Ethnicity: 1968-2009 Note: All data include both full and partial year employment for the given calendar year. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are not shown separately. Hispanic origin was not available until 1975. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1969-2009. Figure WORK 2 shows the employment rate of low-skilled workers ages 18 to 65 (those with a high school education or less) by gender and race and ethnicity between 1968 and 2009. This measure of low skill is based only on educational attainment and does not take into account other skills based on work experience, training or other credentials.5 In 1968, 65.8 percent of Non-Hispanic Black women, 55.8 percent of Non-Hispanic White women, and 49.7 percent of Hispanic women of any race with a high school education or less were employed. In the 1970s, however, Non-Hispanic White women reached parity with their Non-Hispanic Black counterparts and then surpassed them. Employment rates for women with a high school education or less increased during the 1980s and 1990s. By the 2000s, however, the employment rate for women with no more than a high school education started to decline. In 2009, the rate was 63.4 percent for Non- Hispanic White women, 57.1 percent for Non- Hispanic Black women, and 55.6 percent for Hispanic women of any race. 5 This education based measure of low skill is from the work of Rebecca Blank in It Takes a Nation: A New Agenda for Fighting Poverty, 1998. In 1968, 92.8 percent of Non-Hispanic White men, 89.9 percent of Non-Hispanic Black men, and 86.2 percent of Hispanic men of any race with a high school education or less were employed. Beginning in the 1970s, the employment rates for men with a high school education or less declined and the employment rates among men with a high school education or less began to diverge. In 2009 76.7 percent of Non-Hispanic White men as compared to 60.0 percent of Non-Hispanic Black men and 80.1 percent of Hispanic men of any race with a high school education or less were employed. Over the time period, Hispanic men with a high school education or less have had employment rates similar to Non-Hispanic White men. (In percent) Women Non-Hispanic Black 76.7 92.8 60.0 89.9 80.1 86.2 40 50 60 70 80 90 100 1968 1975 1981 1985 1989 1993 1997 2001 2005 2009 63.4 55.8 57.1 65.8 55.6 49.7 40 50 60 70 80 90 100 1968 1975 1981 1985 1989 1993 1997 2001 2005 2009 (In percent) (In percent) Women Hispanic Non-Hispanic White Non-Hispanic Black Hispanic Men Non-Hispanic White Non-Hispanic Black III-21 Table WORK 2. Percentage of Persons Ages 18 to 65 with No More than a High School Education Who Were Employed by Race and Ethnicity: 1968-2009 Women Men Non-Hispanic White Non-Hispanic Black Hispanic Non-Hispanic White Non-Hispanic Black Hispanic 1968 55.8 65.8 NA 92.8 89.9 NA 1969 56.1 64.9 NA 92.1 89.2 NA 1971 55.2 59.4 NA 90.9 86.1 NA 1972 55.6 58.1 NA 91.1 84.3 NA 1975 58.3 57.2 49.7 88.2 78.8 86.2 1977 61.4 57.6 52.2 88.3 78.1 89.2 1979 62.9 58.9 55.0 88.5 78.7 89.4 1980 64.1 57.6 53.7 88.0 75.2 86.8 1981 64.0 57.5 53.0 87.4 74.5 87.6 1982 62.7 56.6 51.1 85.6 71.1 85.3 1983 63.5 55.3 51.7 84.8 70.2 85.2 1984 65.0 58.9 54.0 86.5 71.9 83.9 1985 66.0 59.4 52.9 86.1 74.6 83.9 1986 66.8 61.0 54.0 86.4 74.3 86.5 1987 67.3 59.9 54.0 86.7 73.9 85.6 1988 68.0 61.4 54.6 86.3 74.0 87.8 1989 68.8 61.1 55.8 87.7 75.3 86.6 1990 68.5 60.7 55.0 87.7 75.6 85.4 1991 68.3 61.0 54.6 86.4 73.9 85.0 1992 67.8 57.8 53.3 85.7 71.5 83.7 1993 68.6 60.0 52.2 84.6 71.2 83.5 1994 69.0 60.9 53.3 85.0 69.1 83.2 1995 69.6 60.1 53.9 85.9 70.1 83.3 1996 70.2 64.1 55.4 85.9 70.3 84.0 1997 69.9 66.6 56.9 85.3 72.0 85.0 1998 70.4 67.1 57.1 85.3 71.8 85.5 1999 71.4 68.4 58.8 84.5 72.0 86.4 2000 70.6 67.7 61.0 84.7 72.7 86.4 2001 69.8 64.8 59.2 83.4 69.9 85.5 2002 69.5 64.4 57.5 82.5 67.3 85.1 2003 66.9 65.2 56.9 81.1 65.7 84.6 2004 66.3 62.9 56.1 80.8 66.7 84.9 2005 66.3 63.3 56.1 80.7 66.3 85.6 2006 66.5 63.2 56.8 80.6 65.6 86.4 2007 66.1 62.4 56.0 80.3 65.8 85.6 2008 65.6 61.3 57.2 79.0 64.5 83.6 2009 63.4 57.1 55.6 76.7 60.0 80.1 Note: All data include both full and partial year employment for the given calendar year. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are not shown separately. Hispanic origin was not available until 1975. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1969-2009. III-22 EMPLOYMENT AND WORK-RELATED RISK FACTOR 3. Earnings of Low- Skilled Workers Figure WORK 3a. Median Weekly Wages of Women and Men Working Full-Time with Less than 4 Years of High School Education by Race and Ethnicity (2009 Dollars): 1980-2009 Note: Last data point is 2009. Full-time workers usually work 35 hours per week. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are not shown separately. Source: Current Population Survey, Bureau of Labor Statistics. Figure WORK 3a shows the median weekly wages in 2009 dollars of low-skilled women and men (those with less than 4 years of high school education) working full-time by race and ethnicity for selected years. This measure of low skill is based only on educational attainment and does not take other skills based on work experience, training or other credentials into account. In 2009, Non-Hispanic White women with less than a high school education working full-time had median weekly earnings of $378 compared to $391 for similar Non- Hispanic Black women and $355 for similar Hispanic women of any race. Among men working full-time with less than 4 years of high school education, Non-Hispanic White men had median weekly earnings of $504, compared to $453 for Non-Hispanic Black men and $469 for Hispanic men of any race. Table WORK 3a provides the detailed estimates used for Figure WORK 3a expressed in constant dollars. In 2009, low- skilled Non-Hispanic Black women working full-time had the highest median weekly wages among women working full-time with less than four years of a high school education at $391. This represents an 8.9 percent increase in their median weekly wages between 1995 and 2009. Over the same time period, similar Non-Hispanic White women experienced a 2.4 percent increase in their median weekly wages while similar Hispanic women of any race experienced an 8.9 percent increase. Among low-skilled men working full-time, median weekly wages increased 0.4 percent among Non-Hispanic White men but increased 3.0 percent among Non-Hispanic Black men between 1995 and 2009. Low- skilled Hispanic men working full-time had a 14.7 percent increase in median weekly wages over the same time period. 504 453 469 300 400 500 600 700 800 1980 1984 1989 1994 1999 2004 2009 378 391 355 300 350 400 450 1980 1984 1989 1994 1999 2004 2009 (In 2009 $) (In 2009 $) Women Hispanic Non-Hispanic White Non-Hispanic Black Hispanic Men Non-Hispanic White Non-Hispanic Black III-23 Table WORK 3.a. Median Weekly Wages of Women and Men Working Full-Time with less than 4 Years of High School Education by Race and Ethnicity (2009 Dollars): 1980-2009 Women Men Non-Hispanic White Non-Hispanic Black Hispanic2 Non-Hispanic White Non-Hispanic Black Hispanic2 1979 $424 $394 $385 $724 $575 $575 1980 411 387 367 689 538 555 1981 403 380 378 668 536 525 1982 399 371 371 649 512 512 1983 403 385 356 639 512 506 1984 399 374 358 625 496 494 1985 390 369 344 618 498 492 1986 394 372 344 626 510 493 1987 390 376 365 609 517 491 1988 389 373 357 599 502 467 1989 394 359 356 603 486 476 1990 385 369 350 576 487 463 1991 387 369 344 551 468 444 1992 1 385 377 \u2014 541 470 \u2014 1993 386 383 \u2014 535 469 \u2014 1994 372 355 332 502 458 418 1995 369 359 326 502 440 409 1996 365 368 334 494 441 417 1997 368 361 341 498 438 416 1998 373 363 343 514 451 422 1999 373 369 341 514 476 438 2000 380 377 360 509 501 447 2001 384 371 368 511 481 463 2002 387 374 362 509 478 466 2003 386 378 366 504 491 458 2004 380 370 354 512 472 456 2005 374 372 355 510 444 455 2006 378 382 346 507 446 447 2007 381 387 355 503 464 443 2008 377 381 359 500 447 470 2009 378 391 355 504 453 469 Note: Full-time usually work 35 hours per week. Data adjusted to constant 2009 dollars by ASPE using the CPI-U-RS. 1Beginning in 1992, data on educational attainment have been based on the \”highest diploma or degree received,\” rather than the \”number of years of school completed.\” Data for 1994 forward are not directly comparable with data for 1993 and earlier years due to a redesign of the Current Population Survey. Data for 2000-2002 have been revised to incorporate population controls from Census 2000 and new industry and occupational classification systems. The earnings data presented in this table may differ slightly from other published estimates due to methodological differences in calculating medians. 2For 1992 and 1993, earnings data by educational attainment are not available for persons of Hispanic or Latino ethnicity age 25 and over. Beginning in 2003, data refer to persons who selected this race group only; previously, persons identified a group as their main race. In addition, persons whose ethnicity is identified as Hispanic or Latino may be of any race and, therefore, are classified by ethnicity as well as by race. SOURCE: Current Population Survey, Bureau of Labor Statistics. III-24 EMPLOYMENT AND WORK-RELATED RISK FACTOR 3. Earnings of Low- Skilled Workers Figure WORK 3b. Median Weekly Wages of Women and Men Working Full-Time with 4 Years of High School Education with No College by Race and Ethnicity (2009 Dollars) : 1980-2009 Note: Last data point is 2009. Full-time workers usually work 35 hours per week. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are not shown separately. Source: Current Population Survey, Bureau of Labor Statistics. Figure WORK 3b shows the median weekly wages in 2009 dollars of low-skilled women and men (those with 4 years of high school education, no college) working full-time by race and ethnicity for selected years. This measure of low skill is based only on educational attainment and does not take other skills based on work experience, training or other credentials into account. In 2009, Non-Hispanic White women with only 4 years of high school education working full-time had median weekly earnings of $556 compared to $497 for similar Non-Hispanic Black women and $495 for similar Hispanic women of any race. Among men working full-time with only 4 years of high school education, median weekly earnings of Non-Hispanic White men were $740 compared to $588 for Non-Hispanic Black men and $594 for Hispanic men of any race. Table WORK 3b provides the detailed estimates used for Figure WORK 3b expressed in constant dollars. In 2009, low-skilled Non-Hispanic White women working full-time had the highest average weekly wages among women working full-time with a high school education at $556. This represents a 9.0 percent increase in their median weekly wages between 1995 and 2009. Over the same time period, similar Non-Hispanic Black women experienced a 13.7 percent increase in their median weekly wages while similar Hispanic women of any race experienced an 11.5 percent increase. Among low-skilled men working full-time, median weekly wages increased 1.2 percent among Non-Hispanic White men and 5.2 percent among Non-Hispanic Black men between 1995 and 2009. Low-skilled Hispanic men working full-time had a 1.7 percent increase in median weekly wages over the same time period. 740 588 594 400 500 600 700 800 900 1980 1984 1988 1992 1996 2000 2004 2009 556 497 495 400 450 500 550 600 1980 1984 1988 1992 1996 2000 2004 2009 (In 2009 $) (In 2009 $) Women Non-Hispanic White Non-Hispanic Black Hispanic Men Non-Hispanic White Non-Hispanic Black Hispanic III-25 Table WORK 3.b. Median Weekly Wages of Women and Men Working Full-Time with 4 Years of High School Education with No College by Race and Ethnicity (2009 Dollars) : 1979-2009 Women Men White Black Hispanic2 White Black Hispanic2 1979 $512 $479 $485 $865 $691 $763 1980 501 468 478 830 677 721 1981 496 466 477 826 656 722 1982 510 467 489 815 634 711 1983 512 463 489 808 639 690 1984 515 472 499 800 625 684 1985 515 470 483 795 601 663 1986 523 480 484 797 607 657 1987 526 480 475 791 612 647 1988 526 474 486 788 608 643 1989 514 476 483 778 591 621 1990 508 458 485 757 566 617 1991 515 464 476 745 559 605 1992 1 515 458 \u2014 735 545 \u2014 1993 519 452 \u2014 731 554 \u2014 1994 517 435 467 731 548 581 1995 510 437 444 731 559 584 1996 510 440 442 734 545 566 1997 517 438 446 750 564 588 1998 531 468 472 765 578 610 1999 532 465 469 770 590 611 2000 538 478 471 757 612 607 2001 550 481 489 758 617 603 2002 560 486 482 762 602 604 2003 564 506 484 760 605 609 2004 563 519 493 761 590 592 2005 554 479 478 744 580 582 2006 543 484 455 749 578 605 2007 541 486 485 743 568 604 2008 533 478 477 735 579 601 2009 556 497 495 740 588 594 Note: Full-time usually work 35 hours per week. Data adjusted to constant 2009 dollars by ASPE using the CPI-U-RS. 1Beginning in 1992, data on educational attainment have been based on the \”highest diploma or degree received,\” rather than the \”number of years of school completed.\” Data for 1994 forward are not directly comparable with data for 1993 and earlier years due to a redesign of the Current Population Survey. Data for 2000-2002 have been revised to incorporate population controls from Census 2000 and new industry and occupational classification systems. The earnings data presented in this table may differ slightly from other published estimates due to methodological differences in calculating medians. 2For 1992 and 1993, earnings data by educational attainment are not available for persons of Hispanic or Latino ethnicity age 25 and over. Beginning in 2003, data refer to persons who selected this race group only; previously, persons identified a group as their main race. In addition, persons whose ethnicity is identified as Hispanic or Latino may be of any race and, therefore, are classified by ethnicity as well as by race. SOURCE: Current Population Survey, Bureau of Labor Statistics. III-26 EMPLOYMENT AND WORK-RELATED RISK FACTOR 4. Educational Attainment Figure WORK 4. Percentage of Adults Ages 25 and over by Level of Educational Attainment: 1960-2009 Note: Completing the GED is not considered completing high school for this table. Beginning with data for 1992, a new survey question results in different categories than for prior years. Data shown as High school graduate, no college were previously from the category High school, 4 years and are now from the category High school graduate. Data shown as One to three years of college were previously from the category College 1 to 3 years and are now the sum of the categories: Some college and two separate Associate degree categories. Data shown as Four or more years of college were previously from the category College 4 years or more, and are now the sum of the categories: Bachelor’s degree, Master’s degree, Doctorate degree and Professional degree. Source: U.S. Census Bureau, Educational Attainment in the United States, 2009, Current Population Reports and earlier reports. Figure WORK 4 shows educational attainment for adults 25 years and older between 1960 and 2009. Table WORK 4 shows the corresponding point estimates for select years. The percentage of the population without at least a high school education has declined over the past 45 years, from 59.0 percent in 1960 to 13.3 percent in 2009. The percentage of the population receiving a high school education (with no post secondary education) was 24.6 percent in 1960 and rose to 38.9 percent in 1988. Since 1988, this figure has fallen to 31.1 percent in 2009. Between 1960 and 1990, the percentage of the population with some college (one to three years) more than doubled, from 8.8 percent to 17.9 percent. The increase in 1992 is partially the result of a change in survey methodology, but the trend continued upward, reaching a high of 26.1 percent in 2009. The percentage of the population completing four or more years of college has more than tripled between 1960 and 2009 rising from 7.7 percent to 29.5 percent. 59.0 13.3 24.6 31.1 8.8 26.1 7.7 29.5 0 10 20 30 40 50 60 70 1960 1965 1968 1971 1974 1977 1980 1983 1986 1989 1992 1995 1998 2001 2004 2007 Not a high school graduate High school graduate, no college 4 or more years of college 1 to 3 years of college (In percent) 2009 III-27 Table WORK 4. Percentage of Adults Ages 25 and over by Level of Educational Attainment: Selected Years Not a High High School Graduate, One to Three Four or More Year School Graduate No College Years of College Years of College 1940 75.9 14.1 5.4 4.6 1950 66.7 20.1 7.1 6.0 1960 59.0 24.6 8.8 7.7 1965 51.0 30.7 8.9 9.4 1970 44.8 34.0 10.2 11.0 1975 37.5 36.2 12.4 13.9 1980 31.4 36.8 14.9 17.0 1981 30.3 37.6 15.1 17.1 1982 29.0 37.9 15.3 17.7 1983 27.9 37.7 15.6 18.8 1984 26.7 38.4 15.8 19.1 1985 26.1 38.2 16.3 19.4 1986 25.3 38.4 16.9 19.4 1987 24.4 38.7 17.1 19.9 1988 23.8 38.9 17.0 20.3 1989 23.1 38.5 17.3 21.1 1990 22.4 38.4 17.9 21.3 1991 21.6 38.6 18.4 21.4 1992 20.6 36.0 22.1 21.4 1993 19.8 35.4 23.0 21.9 1994 19.1 34.4 24.3 22.2 1995 18.3 33.9 24.8 23.0 1996 18.3 33.6 24.6 23.6 1997 17.9 33.8 24.5 23.9 1998 17.2 33.8 24.7 24.4 1999 16.6 33.3 24.8 25.2 2000 15.9 33.1 25.4 25.6 2001 15.9 32.3 25.7 26.2 2002 15.9 32.1 25.3 26.7 2003 15.4 32.0 25.3 27.2 2004 14.8 32.0 25.5 27.7 2005 14.8 32.2 25.4 27.7 2006 14.5 31.7 25.7 28.0 2007 14.3 31.6 25.3 28.7 2008 13.4 31.2 26.0 29.4 2009 13.3 31.1 26.1 29.5 Note: Completing the GED is not considered completing high school for this table. Beginning with data for 1992, a new survey question results in different categories than for prior years. Data shown as High school graduate, no college were previously from the category High school, 4 years and are now from the category High school graduate. Data shown as One to three years of college were previously from the category College 1 to 3 years and are now the sum of the categories: Some college and two separate Associate degree categories. Data shown as Four or more years of college were previously from the category College 4 years or more, and are now the sum of the categories: Bachelor’s degree, Master’s degree, Doctorate degree and Professional degree. Source: U.S. Census Bureau, Educational Attainment in the United States: 2009. http:\/\/www.census.gov\/hhes\/socdemo\/education\/data\/cps\/2010\/tables.html and earlier reports. III-28 http:\/\/www.census.gov\/hhes\/socdemo\/education\/data\/cps\/2010\/tables.html\ufffd EMPLOYMENT AND WORK-RELATED RISK FACTOR 5. High School Dropout Rates Figure WORK 5. Percentage of Students Enrolled in Grades 10 to 12 in the Previous Year Who Were Not Enrolled and Had Not Graduated in the Survey Year by Race and Ethnicity: 1995-2009 Note: Beginning in 1987, the U.S. Census Bureau instituted new editing procedures for cases with missing data on school enrollment. Beginning in 1992, the data reflect new wording of the educational attainment item in the Current Population Survey (CPS). Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total but are not shown separately. Source: U.S. Department of Education, National Center for Education Statistics. Trends in High School Dropout and Completion Rates in the United States: 2011. Data are from the Current Population Survey, October Supplement. Figure WORK 5 shows the percentage of students who were enrolled in grades 10 through 12 in the previous year but were not enrolled and had not graduated in the survey year by race and ethnicity for the time period 1995 to 2009. Over the time period, there has been a general downward trend in dropout rates. In 2009, the dropout rate was 5.8 percent for Hispanic students of any race, 4.8 percent for Non-Hispanic Black students, and 2.4 percent for Non-Hispanic White students. Table WORK 5 provides trend data on dropout rates beginning in 1972. The dropout rate for all races was highest in 1978 and 1979 (6.7 percent) and then declined to 3.4 percent in 2009, the lowest rate since 1972. Data for the time period 2007 2009 are noteworthy when considered by sex. In 2007, the percentage for females of all races who dropped out was 3.3 percent, the lowest since 1972. In 2008 however, the rate increases to 4.0 percent, and falls back to 3.4 percent in 2009. By contrast, in 2007, 3.7 percent of males dropped out of school. The percentage decreases to 3.1 percent in 2008, before rising to 3.5 percent in 2009. Dropout rates among Hispanic students of any race have fluctuated since 1972. Despite this fluctuation, Hispanic dropout rates were higher than rates for Non-Hispanic White students in all years since 1972 and higher than rates for Non- Hispanic Black students in all reported years except 2005 and 2008. 5.7 3.4 4.5 2.4 6.4 4.8 12.4 5.8 1 4 7 10 13 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 (In percent) All races Non-Hispanic White Non-Hispanic Black Hispanic III-29 Table WORK 5. Percentage of Students Enrolled in Grades 10 to 12 in the Previous Year Who Were Not Enrolled and Had Not Graduated in the Survey Year by Race and Ethnicity: 1972 – 2009 All Races Non-Hispanic White Non-Hispanic Black Hispanic Male Female 1972 6.1 5.3 9.5 11.2 5.9 6.3 1973 6.3 5.5 9.9 10.0 6.8 5.7 1974 6.7 5.8 11.6 9.9 7.4 6.0 1975 5.8 5.0 8.7 10.9 5.4 6.1 1976 5.9 5.6 7.4 7.3 6.6 5.2 1977 6.5 6.1 8.6 7.8 6.9 6.1 1978 6.7 5.8 10.2 12.3 7.5 5.9 1979 6.7 6.0 9.9 9.8 6.8 6.7 1980 6.1 5.2 8.2 11.7 6.7 5.5 1981 5.9 4.8 9.7 10.7 6.0 5.8 1982 5.5 4.7 7.8 9.2 5.8 5.1 1983 5.2 4.4 7.0 10.1 5.8 4.7 1984 5.1 4.4 5.7 11.1 5.4 4.8 1985 5.2 4.3 7.8 9.8 5.4 5.0 1986 4.7 3.7 5.4 11.9 4.7 4.7 1987 4.1 3.5 6.4 5.4 4.3 3.8 1988 4.8 4.2 5.9 10.4 5.1 4.4 1989 4.5 3.5 7.8 7.8 4.5 4.5 1990 4.0 3.3 5.0 7.9 4.0 3.9 1991 4.0 3.2 6.0 7.3 3.8 4.2 1992 4.4 3.7 5.0 8.2 3.9 4.9 1993 4.5 3.9 5.8 6.7 4.6 4.3 1994 5.3 4.2 6.6 10.0 5.2 5.4 1995 5.7 4.5 6.4 12.4 6.2 5.3 1996 5.0 4.1 6.7 9.0 5.0 5.1 1997 4.6 3.6 5.0 9.5 5.0 4.1 1998 4.8 3.9 5.2 9.4 4.6 4.9 1999 5.0 4.0 6.5 7.8 4.6 5.4 2000 4.8 4.1 6.1 7.4 5.5 4.1 2001 5.0 4.1 6.3 8.8 5.6 4.3 2002 3.6 2.6 4.9 5.8 3.7 3.4 2003 4.0 3.2 4.8 7.1 4.2 3.8 2004 4.7 3.7 5.7 8.9 5.1 4.3 2005 3.8 2.8 7.3 5.0 4.2 3.4 2006 3.8 2.9 3.8 7.0 4.1 3.4 2007 3.5 2.2 4.5 6.0 3.7 3.3 2008 3.5 2.3 6.4 5.3 3.1 4.0 2009 3.4 2.4 4.8 5.8 3.5 3.4 Note: Beginning in 1987, the U.S. Census Bureau instituted new editing procedures for cases with missing data on school enrollment. Beginning in 1992, the data reflect new wording of the educational attainment item in the Current Population Survey (CPS). Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total but are not shown separately. Source: U.S. Department of Education, National Center for Education Statistics, Trends in High School Dropout and Completion Rates in the United States: 2011. Data are from the Current Population Survey, October Supplement. III-30 EMPLOYMENT AND WORK RISK FACTOR 6. Adult Alcohol and Substance Abuse Figure WORK 6. Percentage of Adults Who Used Cocaine or Marijuana or Abused Alcohol by Age: 2009 Note: Cocaine and marijuana use is defined as use during the past month. Binge alcohol use is defined as drinking five or more drinks on the same occasion on at least one day in the past 30 days. Heavy alcohol use is defined as drinking five or more drinks on the same occasion on each of five or more days in the past 30 days; all heavy alcohol users are also binge alcohol users. Source: U.S. Department of Health and Human Services, National Survey on Drug Use and Health, 2009. Figure WORK 6 shows the percentage of adults who used cocaine, the percentage who used marijuana, and the percentage who abused alcohol by age group in 2009. Adults 18 to 25 years of age were more likely than older adults to report cocaine, marijuana, binge alcohol or heavy alcohol use in the prior month. For example, 18.1 percent reported using marijuana in the past month during 2009, compared with 9.6 percent of adults 26 to 34 years of age and 3.4 percent of adults 35 years and over. The percentage of adults reporting binge alcohol use was larger than the percentages for all other reported behaviors across all age groups. Among people reporting binge alcohol use, however, this behavior was most prevalent among adults 18 to 34 years of age compared to adults 35 and over. Marijuana use has been trending upward since 1999. Between 2008 and 2009, marijuana use has increased for all the age groups while heavy alcohol use has decreased among those less than 34 years of age. The rate of heavy alcohol use remained the same for those 35 years of age and older since 2007. (In percent) 1.4 18.1 9.6 10.1 0.5 3.4 19.2 5.3 13.7 41.7 1.0 36.3 0 10 20 30 40 50 Cocaine use Marijuana use Binge alcohol use Heavy alcohol use Ages 18-25 Ages 26-34 Ages 35 and over III-31 Table WORK 6. Percentage of Adults Who Used Cocaine or Marijuana or Abused Alcohol by Age: 1999-2009 Cocaine Marijuana Binge Alcohol Use Heavy Alcohol Use Year Ages 18-25 Ages 26- 34 Ages 35 & over Ages 18- 25 Ages 26- 34 Ages 35 & over Ages 18- 25 Ages 26- 34 Ages 35 & over Ages 18- 25 Ages 26- 34 Ages 35 & over 1999 1.7 1.2 0.4 14.2 5.4 2.2 37.9 29.3 16.0 13.3 7.5 4.2 2000 1.4 0.8 0.3 13.6 5.9 2.3 37.8 30.3 16.4 12.8 7.6 4.1 2001 1.9 1.1 0.5 16.0 6.8 2.4 38.7 30.1 16.2 13.6 7.8 4.2 2002 2.0 1.2 0.6 17.3 7.7 3.1 40.9 33.1 18.6 14.9 9.0 5.2 2003 2.2 1.5 0.6 17.0 8.4 3.0 41.6 32.9 18.1 15.1 9.4 5.1 2004 2.1 1.4 0.5 16.1 8.3 3.1 41.2 32.2 18.5 15.1 9.4 5.3 2005 2.6 1.3 0.6 16.6 8.6 3.0 41.9 32.9 18.3 15.3 9.6 4.7 2006 2.2 1.7 0.6 16.3 8.5 3.2 42.2 34.2 18.4 15.6 10.0 5.1 2007 1.7 1.4 0.6 16.4 7.9 3.0 41.8 35.1 18.9 14.7 9.7 5.3 2008 1.5 1.5 0.4 16.5 8.8 3.2 41.0 36.4 18.8 14.5 10.6 5.3 2009 1.4 1.0 0.5 18.1 9.6 3.4 41.7 36.3 19.2 13.7 10.1 5.3 Note: Cocaine and marijuana use is defined as use during the past month. Binge alcohol use is defined as drinking five or more drinks on the same occasion on at least one day in the past 30 days. Heavy alcohol use is defined as drinking five or more drinks on the same occasion on each of five or more days in the past 30 days; all heavy alcohol users are also binge alcohol users. Source: U.S. Department of Health and Human Services, National Survey on Drug Use and Health, 2000-2010. III-32 EMPLOYMENT AND WORK-RELATED RISK FACTOR 7. Adult and Child Disability Figure WORK 7. Percentage of the Non-Elderly Population Reporting an Activity Limitation by Selected Characteristics: 2009 Note: Work disability is defined as limitations in or the inability to work as a result of a physical, mental or emotional health condition. Individuals are identified as having long-term care needs if they need the help of others in handling either personal care needs (eating, bathing, dressing, getting around the home) or routine needs (household chores, shopping, getting around for business or other purposes). Disability program recipients include persons covered by Supplemental Security Income (SSI), Social Security Disability Insurance (SSDI), Special Education Services, Early Intervention Services and\/or disability pensions. Respondents were defined as having an activity limitation if they answered positively to any of the questions regarding: (1) work disability (see definition above; (2) long-term care needs (see definition above); (3) difficulty walking; (4) difficulty remembering; (5) for children under 5, limitations in the amount of play activities they can participate in because of physical, mental or emotional problems; (6) for children 3 and over, receipt of Special Educational or Early Intervention Services; and, (7) any other limitations due to physical, mental or emotional problems. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the National Health Interview Survey, 2009. Figure WORK 7 shows the percentage of non- elderly adults and children reporting an activity limitation by race and ethnicity in 2009. Non- elderly adults were more likely than children to have an activity limitation, 12.0 percent compared to 8.5 percent. Table WORK 7 shows the percentage of the non-elderly population reporting a disability by selected demographic characteristics. While non-elderly adults were more likely than children to report an activity limitation, a higher percentage of children (7.5 percent) than adults (5.4 percent) were actually recipients of disability program benefits in 2009. For both non-elderly adults and children, the percentage of Non-Hispanic Blacks with an activity limitation was higher than the percentages for Non-Hispanic Whites and Hispanics. Among adults ages 18 64, rates of work disability were lower for Hispanics (6.0 percent) than they were for Non-Hispanic Whites (9.9 percent) and Non-Hispanic Blacks (12.9 percent). 12.0 12.5 8.5 9.0 7.0 16.1 7.9 9.7 0 3 6 9 12 15 18 All persons Non-Hispanic White Non-Hispanic Black Hispanic Adults ages 18-64 Children ages 0-17 (In percent) III-33 Table WORK 7. Percentage of the Non-Elderly Population Reporting a Disability by Selected Characteristics: 2009 Disability Activity Work Long-Term Program Limitation Disability Care Needs Recipient All Persons Adults ages 18-64 12.0 9.4 2.5 5.4 Children ages 0-17 8.5 NA NA 7.5 Racial\/Ethnic Categories (Adults Ages 18-64) Non-Hispanic White 12.5 9.9 2.4 5.5 Non-Hispanic Black 16.1 12.9 4.0 8.6 Hispanic 7.9 6.0 1.7 3.2 Racial\/Ethnic Categories (Children Ages 0-17) Non-Hispanic White 9.0 NA NA 8.0 Non-Hispanic Black 9.7 NA NA 8.3 Hispanic 7.0 NA NA 6.0 Note: Work disability is defined as limitations in or the inability to work as a result of a physical, mental or emotional health condition. Individuals are identified as having long-term care needs if they need the help of others in handling either personal care needs (eating, bathing, dressing, getting around the home) or routine needs (household chores, shopping, getting around for business or other purposes). Disability program recipients include persons covered by Supplemental Security Income (SSI), Social Security Disability Insurance (SSDI), Special Education Services, Early Intervention Services and\/or disability pensions. Respondents were defined as having an activity limitation if they answered positively to any of the questions regarding: (1) work disability (see definition above); (2) long-term care needs (see definition above); (3) difficulty walking; (4) difficulty remembering; (5) for children under 5, limitations in the amount of play activities they can participate in because of physical, mental or emotional problems; (6) for children 3 and over, receipt of Special Educational or Early Intervention Services; and, (7) any other limitations due to physical, mental or emotional problems. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the National Health Interview Survey, 2009. III-34 EMPLOYMENT AND WORK-RELATED RISK FACTOR 8. Labor Force Participation of Women with Children under 18 Figure WORK 8. Labor Force Participation of Women with Children under 18: 1975-2009 Note: The labor force participation rate includes all women who are employed, laid off or unemployed but looking for work. The employment rate includes only those women who are employed. The population of mothers with children under age 18 includes those 16 years of age and older. Source: U.S. Department of Labor, Bureau of Labor Statistics, unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, March 2009 and earlier reports. Figure WORK 8 shows the labor force participation rates for mothers with children under 18 years of age by marital status between 1975 and 2009. In 2007, regardless of marital status, the majority of mothers in the U.S. were engaged in the labor force. Historically, divorced, widowed and separated mothers have had the highest rates of labor force participation among mothers. In 1975, 62.8 percent of divorced, widowed or separated mothers were in the labor force as compared to 44.9 percent of married mothers with spouses present and 42.2 percent of never-married mothers. In 2009, divorced, widowed and separated mothers remained more likely than other mothers to participate in the labor force. Between 1992 and 2002, labor force participation rates for never-married mothers with children under 18 markedly increased\u2014 rising from 52.5 percent in 1992 to 75.3 percent in 2002. Since 1998, labor force participation rates for never-married mothers have exceeded the rates for married mothers. The labor force participation rate of married mothers with children under 18 followed an upward trend from 1975 until 1997 when it peaked at 71.1 percent. In 2009, 69.8 percent of married mothers with spouses present were in the labor force. Table WORK 1 shows both the labor force participation rates and the employment rates of mothers with children less than 18 years of age between 1975 and 2009. The employment rates for all mothers have increased over the time but plateaued in the early 2000’s and have declined slightly in recent years. The employment rate for married mothers with a spouse present was 40.5 percent in 1975; in 2009 the employment rate was 66.0 percent. The employment rate for divorced, widowed and separated mothers was 54.9 percent in 1975; in 2009 the employment rate was 70.3 percent. The employment rate for never- married mothers showed the largest increase from 32.1 percent in 1975 to 60.9 percent in 2009. 69.8 44.9 79.2 62.8 72.0 42.2 30 40 50 60 70 80 90 1976 1979 1982 1985 1988 1991 1994 1997 2000 2003 2006 2009 Married, spouse present Divorced, widowed, or separated Never-married (In percent) III-35 Table WORK 8. Employment Status of Women with Children under 18 Years of Age: 1975-2009 Labor Force Participation Rate (percent of population) Employment Rate (percent of population) Married, Spouse Present Divorced, Separated or Widowed Never Married Married, Spouse Present Divorced, Separated or Widowed Never Married 1975 44.9 62.8 42.2 40.5 54.9 32.1 1976 46.1 64.3 46.2 42.4 56.9 36.3 1977 48.2 66.4 43.4 44.6 58.7 29.6 1978 50.2 68.1 51.1 47.0 61.2 38.9 1979 51.9 67.8 54.4 48.6 61.4 42.6 1980 54.1 69.9 52.0 50.9 63.4 39.9 1981 55.7 70.5 52.3 52.1 63.0 38.3 1982 56.3 71.1 50.4 51.6 62.3 36.2 1983 57.2 70.1 49.8 52.4 58.5 34.5 1984 58.8 72.7 50.7 54.9 63.4 36.3 1985 60.8 72.9 51.6 56.8 64.0 39.3 1986 61.3 74.1 52.9 57.6 66.3 37.8 1987 63.8 74.0 54.1 60.4 66.5 40.2 1988 65.0 72.8 51.6 61.9 66.9 40.0 1989 65.6 72.0 54.7 63.1 66.0 43.1 1990 66.3 74.2 55.3 63.5 67.9 45.1 1991 66.8 72.7 53.6 63.2 66.1 44.0 1992 67.8 73.2 52.5 63.9 65.3 43.4 1993 67.5 72.1 54.4 64.2 65.9 44.0 1994 69.0 73.1 56.9 65.6 65.9 45.8 1995 70.2 75.3 57.5 67.1 69.1 47.9 1996 70.0 77.0 60.5 67.6 72.1 49.3 1997 71.1 79.1 68.1 68.6 72.0 56.6 1998 70.6 79.7 72.5 68.0 74.3 61.5 1999 70.1 80.4 73.4 68.0 75.4 64.8 2000 70.6 82.7 73.9 68.5 78.5 65.8 2001 70.4 83.1 73.5 68.0 78.7 64.6 2002 69.6 82.1 75.3 66.7 75.6 65.8 2003 69.2 82.0 73.1 66.3 74.7 63.2 2004 68.2 80.7 72.6 65.4 75.0 63.1 2005 68.1 79.8 72.9 66.0 74.4 62.0 2006 68.4 80.4 71.5 66.2 75.4 62.5 2007 69.3 80.0 71.4 67.4 75.2 63.7 2008 69.4 79.3 71.0 67.1 74.6 62.9 2009 69.8 79.2 72.0 66.0 70.3 60.9 Notes: The labor force participation rate includes all women who are employed, laid off or unemployed but looking for work. The employment rate includes only those women who are employed. The population of mothers with children under age 18 includes those 16 years of age and older. Source: U.S. Department of Labor, Bureau of Labor Statistics, unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, March 2009 and earlier reports. III-36 NONMARITAL BIRTH RISK FACTOR 1. Nonmarital Births Figure BIRTH 1. Percentage of Births that are Nonmarital by Age: 1940-2009 Note: Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non-marital births when marital status is not reported. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Statistics Reports, Vol. 48 (16), 2000; Births: Preliminary Data for 2009, National Vital Statistics Reports, Vol. 59 (3), December 2010, http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm. Figure BIRTH 1 shows the percentage of births that were nonmarital by age group from 1940 to 2009 and Table BIRTH 1 shows corresponding estimates for selected years. Changes in nonmarital births reflect changes in the rate at which unmarried women have children, the rate at which married women have children and the rate at which women marry. The percentage of children born outside of marriage to women of all ages has increased over the past 70 years. In 1940, 3.8 percent of births were to unmarried women. In 2009, the percentage increased to 41.0 percent. Teen births, as shown in Figure BIRTH 1 and Table BIRTH 1, show nonmarital teen births as a percentage of all teen births. In 1940, 14.0 percent of births to teens were nonmarital. While the percentage of all teen births that are nonmarital has increased since the mid-1960s, growth in the percentage slowed in the mid- to late- 1990s before rising to 87.4 percent in 2009. Over the past several years, the percentage of nonmarital births among all births to women 20 to 24 years of age increased by 36.0 percent from 45.6 percent in 1996 to 62.1 percent in 2009. This compares to an increase of 14.5 percent of nonmarital births among teen births over the same period. Since 1994, the percentage of births that are nonmarital remains steady among Black teens and all Black women. Among White teens and all White women, the trend continues upward (see Table C-1 in Appendix C for nonmarital birth data by age and race). 87.4 14.0 62.1 41.0 3.8 0 20 40 60 80 100 1940 1950 1960 1970 1980 1990 2000 2009 3.7 (In percent) All teens Ages 20-24 All women III-37 Table BIRTH 1. Percentage of Births that are Nonmarital by Age: Selected Years Year Under 15 15-17 Years 18-19 Years All Teens 20-24 Years All Women 1940 64.5 NA NA 14.0 3.7 3.8 1945 70.0 NA NA 18.2 4.7 4.3 1950 63.7 22.6 9.4 13.9 3.8 4.0 1955 66.3 23.2 10.3 14.9 4.4 4.5 1960 67.9 24.0 10.7 15.4 4.8 5.3 1965 78.5 32.8 15.3 21.6 6.8 7.7 1970 80.8 43.0 22.4 30.5 8.9 10.7 1975 87.0 51.4 29.8 39.3 12.3 14.3 1980 88.7 61.5 39.8 48.3 19.4 18.4 1981 89.2 63.3 41.4 49.9 20.4 18.9 1982 89.2 65.0 43.0 51.4 21.4 19.4 1983 90.4 67.5 45.7 54.1 22.9 20.3 1984 91.1 69.2 48.1 56.3 24.5 21.0 1985 91.8 70.9 50.7 58.7 26.3 22.0 1986 92.5 73.3 53.6 61.5 28.7 23.4 1987 92.9 76.2 55.8 64.0 30.8 24.5 1988 93.6 77.1 58.5 65.9 32.9 25.7 1989 92.4 77.7 60.4 67.2 35.1 27.1 1990 91.6 77.7 61.3 67.6 36.9 28.0 1991 91.3 78.7 63.2 69.3 39.4 29.5 1992 91.3 79.2 64.6 70.5 40.7 30.1 1993 91.3 79.9 66.1 71.8 42.2 31.0 1994 94.5 84.1 70.0 75.9 44.9 32.6 1995 93.5 83.7 69.8 75.6 44.7 32.2 1996 93.8 84.4 70.8 76.3 45.6 32.4 1997 95.7 86.7 72.5 78.2 46.6 32.4 1998 96.6 87.5 73.6 78.9 47.7 32.8 1999 96.5 87.7 74.0 79.0 48.5 33.0 2000 96.5 87.7 74.3 79.1 49.5 33.2 2001 96.3 87.8 74.6 79.2 50.4 33.5 2002 97.0 88.5 75.8 80.2 51.6 34.0 2003 97.1 89.7 77.3 81.6 53.2 34.6 2004 97.4 90.3 78.7 82.6 54.8 35.8 2005 98.0 90.9 79.7 83.5 56.2 36.9 2006 98.3 91.9 80.6 84.4 57.9 38.5 2007 98.8 92.8 82.2 85.7 59.6 39.7 2008 99.1 93.7 83.5 86.8 60.9 40.6 2009 99.0 94.2 84.2 87.4 62.1 41.0 Note: Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non- marital births when marital status is not reported. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Statistics Reports, Vol. 48 (16), 2000; Births: Preliminary Data for 2009, National Vital Statistics Reports, Vol. 59 (3), December 2009, http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm. III-38 NONMARITAL BIRTH RISK FACTOR 2. Nonmarital Teen Births Figure BIRTH 2. Percentage of All Births to Unmarried Teens Ages 15 to 19 by Race and Ethnicity: 1940-2009 Note: Trends in nonmarital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring nonmarital births when marital status is not reported. Beginning in 1980, data are tabulated by the race of the mother. Prior to 1980, data are tabulated by the race of the child. Race categories include those of Hispanic ethnicity. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Prior to 1969, race data were available for Whites and Non-Whites only. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940 – 1999, National Vital Health Statistics Reports, Vol. 48 (16), 2000; Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011. http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm. Figure BIRTH 2 shows the percentage of all births to unmarried teens 15 to 19 years of age by race and ethnicity, and Table BIRTH 2 shows corresponding estimates for selected years between 1940 and 2009. Unlike BIRTH 1, which showed nonmarital teen births as a percentage of all teen births, BIRTH 2 shows births to unmarried teens as a percentage of births to all women. This percentage is affected by several factors: the age distribution of women, the marriage rate among teens, the birth rate among unmarried teens and the birth rate among all other women. The percentage of all births that were to unmarried teens rose between 2003 and 2008, from 8.2 percent in 2003 to 8.9 percent in 2008. The rate decreased to 8.7 percent in 2009. Among Non-Hispanic Black women, the percentage of all births that were nonmarital teen births has been declining over the last three years. In 2009 the percentage was 15.6, the lowest percentage estimate since 1969, which was the first year in which data on Non-Hispanic Black women were collected. Among Non-Hispanic White women, the percentage of all births that were births to unmarried teens rose between 2005 and 2008 before declining to 7.6 percent in 2009. Among Hispanic women, the percentage of all births that were to unmarried teens increased from a low of 9.8 percent in 1990 to a high of 12.1 percent in 1994 and 1998. Over the last five years, the rate has fluctuated and now is 11.6 percent. 8.7 1.7 7.6 0.8 7.3 15.6 11.6 9.8 0 5 10 15 20 25 1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2009 (In percent) Non-White Non-Hispanic White Non-Hispanic Black Hispanic All races III-39 Table BIRTH 2. Percentage of All Births to Unmarried Teens Ages 15 to 19 by Race and Ethnicity: Selected Years Year All Races Non-Hispanic White Non-Hispanic Black Hispanic 1940 1.7 0.8 NA NA 1950 1.6 0.6 NA NA 1955 1.7 0.7 NA NA 1960 2.0 0.9 NA NA 1965 3.3 1.6 NA NA 1970 5.1 2.6 18.8 NA 1975 7.1 3.7 24.2 NA 1980 7.3 4.4 22.2 NA 1981 7.1 4.5 21.5 NA 1982 7.1 4.5 21.2 NA 1983 7.2 4.6 21.2 NA 1984 7.1 4.6 20.7 NA 1985 7.2 4.8 20.3 NA 1986 7.5 5.1 20.1 NA 1987 7.7 5.3 20.0 NA 1988 8.0 5.6 20.3 NA 1989 8.3 5.9 20.6 NA 1990 8.4 6.1 20.4 9.8 1991 8.7 6.4 20.4 10.3 1992 8.7 6.5 20.2 10.3 1993 8.9 6.8 20.2 10.6 1994 9.7 7.5 21.1 12.1 1995 9.6 7.6 21.1 11.7 1996 9.6 7.7 20.9 11.5 1997 9.7 7.8 20.5 11.9 1998 9.7 7.9 19.9 12.1 1999 9.5 7.8 19.1 11.9 2000 9.1 7.6 18.3 11.5 2001 8.7 7.3 17.5 11.0 2002 8.5 7.2 16.7 10.8 2003 8.2 7.1 16.2 10.7 2004 8.3 7.2 16.0 10.9 2005 8.3 7.2 15.8 11.0 2006 8.6 7.4 16.1 11.3 2007 8.8 7.7 16.3 11.5 2008 8.9 7.8 16.2 11.7 2009 8.7 7.6 15.6 11.6 Note: Trends in nonmarital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring nonmarital births when marital status is not reported. Beginning in 1980, data are tabulated by the race of the mother. Prior to 1980, data are tabulated by the race of the child. Race categories include those of Hispanic ethnicity. Persons of Hispanic ethnicity may be of any race. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Prior to 1969, race data were available for Whites and Non-Whites only. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Health Statistics Reports, Vol. 48 (16), 2000; Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011. http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm. III-40 http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm\ufffd NONMARITAL BIRTH RISK FACTOR 3. Nonmarital Teen Birth Rates Figure BIRTH 3a. Births per 1,000 Unmarried Teens Ages 15 to 17 by Race: 1960-2009 Figure BIRTH 3b. Births per 1,000 Unmarried Teens Ages 18 and 19 by Race: 1960-2009 Note: Rates are per 1,000 unmarried women in specified group. Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non-marital births when marital status is not reported. Beginning in 1980, data are tabulated by the race of the mother. Prior to 1980, data are tabulated by the race of the child. Race categories include those of Hispanic ethnicity. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Prior to 1969, race data were available for Whites and Non-Whites only. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Statistics Reports, Vol. 48 (16), 2000; Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011. Birthrates for 1950 to 1965 computed by ASPE staff from NCHS birth and Census population estimates. Figures BIRTH 3a and 3b show births per thousand unmarried teens between the ages of 15 to 17 and 18 to 19 from 1960 to 2009. Table BIRTH 3 shows corresponding estimates for selected years between 1950 and 2009. The birth rate per thousand unmarried teens ages 15 to 17 decreased in 2009 for both Non- Hispanic Black and White teens. The rate for Non-Hispanic Black teens ages 15 to 17 has been cut by more than half from 79.9 per thousand in 1991 to 32.6 per thousand in 2009 and this rate is lower than in any other year since 1969, the first year in which data on Non-Hispanic Black women were collected. The birth rates of unmarried teens in the older age group (18 and 19 years) fluctuated over the last five years. However the rate in 2009 was 58.2 births per thousand, the lowest since 2004. For Non-Hispanic Black teens ages 18 and 19, the birth rate fell from a high of 147.7 per thousand unmarried teens in 1991 to a low of 96.8 births per thousand unmarried teens in 2009, the lowest rate since data on Non- Hispanic Black women were collected. Prior to 1994, birth rates among unmarried Non-Hispanic White teens in both age groups rose steadily for over four decades. For Non- Hispanic White teens 15 to 17 years of age, the birth rate increased from 3.4 births per thousand unmarried teens in 1950 to a high of 23.9 births per thousand unmarried teens in 1994. For 18 to 19 year olds, the rate increased from 8.5 births per thousand unmarried teens in 1950 to a high of 55.8 births per thousand unmarried teens in 1994. In 2009 the rate was 51.1 births per thousand unmarried teens ages 18-19. Non-White All Races (Rate per 1,000) (Rate per 1,000) 33 11 19 4 17 59 0 20 40 60 80 100 120 140 1961 1967 1973 1979 1985 1991 1997 2003 2009 58 11 97 113 24 51 0 20 40 60 80 100 120 140 1961 1967 1973 1979 1985 1991 1997 2003 2009 White Black Non-White White Black All races Non-White All races III-41 Table BIRTH 3. Births per Thousand Unmarried Teen Women by Age and Race: 1950-2009 Ages 15 to 17 Ages 18 and 19 Year All Races Non-Hispanic White Non-Hispanic Black All Races Non-Hispanic White Non-Hispanic Black 1950 9.9 3.4 NA 18.3 8.5 NA 1955 11.1 3.9 NA 23.6 10.3 NA 1960 11.1 4.4 NA 25.0 11.4 NA 1965 12.5 5.0 NA 25.8 13.9 NA 1966 13.1 5.4 NA 25.6 14.1 NA 1967 13.8 5.6 NA 27.6 15.3 NA 1968 14.7 6.2 NA 29.6 16.6 NA 1969 15.2 6.6 72.0 30.8 16.6 128.4 1970 17.1 7.5 77.9 32.9 17.6 136.4 1971 17.5 7.4 80.7 31.7 15.8 135.2 1972 18.5 8.0 82.8 30.9 15.1 128.2 1973 18.7 8.4 81.2 30.4 14.9 120.5 1974 18.8 8.8 78.6 31.2 15.3 122.2 1975 19.3 9.6 76.8 32.5 16.5 123.8 1976 19.0 9.7 73.5 32.1 16.9 117.9 1977 19.8 10.5 73.0 34.6 18.7 121.7 1978 19.1 10.3 68.8 35.1 19.3 119.6 1979 19.9 10.8 71.0 37.2 21.0 123.3 1980 20.6 12.0 68.8 39.0 24.1 118.2 1981 20.9 12.6 65.9 39.0 24.6 114.2 1982 21.5 13.1 66.3 39.6 25.3 112.7 1983 22.0 13.6 66.8 40.7 26.4 111.9 1984 21.9 13.7 66.5 42.5 27.9 113.6 1985 22.4 14.5 66.8 45.9 31.2 117.9 1986 22.8 14.9 67.0 48.0 33.5 121.1 1987 24.5 16.2 69.9 48.9 34.5 123.0 1988 26.4 17.6 73.5 51.5 36.8 130.5 1989 28.7 19.3 78.9 56.0 40.2 140.9 1990 29.6 20.4 78.8 60.7 44.9 143.7 1991 30.8 21.7 79.9 65.4 49.4 147.7 1992 30.2 21.4 77.2 66.7 51.2 146.4 1993 30.3 21.9 75.9 66.2 52.0 140.0 1994 31.7 23.9 73.9 69.1 55.8 139.6 1995 30.1 23.3 67.4 66.5 54.7 129.2 1996 28.5 22.3 62.6 64.9 53.5 127.2 1997 27.7 22.0 59.0 63.9 52.9 124.8 1998 26.5 21.5 55.0 63.6 53.1 121.5 1999 25.0 20.6 50.0 62.3 52.9 115.8 2000 23.9 19.7 48.3 62.2 53.1 115.0 2001 22.0 18.1 43.8 60.6 52.1 110.2 2002 20.8 17.5 39.9 58.6 51.0 104.1 2003 20.3 17.2 38.1 57.6 50.4 100.4 2004 20.1 17.1 37.0 57.7 50.4 100.9 2005 19.7 16.8 35.4 58.4 50.9 101.6 2006 20.4 17.4 36.6 61.8 53.9 107.8 2007 20.8 18.0 36.3 63.9 55.9 109.1 2008 20.6 18.0 35.5 61.9 54.2 104.4 2009 19.3 16.9 32.6 58.2 51.1 96.8 Note: Rates are per 1,000 unmarried women in specified group. Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non-marital births when marital status is not reported. Beginning in 1980, data are tabulated by the race of the mother. Prior to 1980, data are tabulated by the race of the child. Race categories include those of Hispanic ethnicity. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Statistics Reports, Vol. 48 (16), 2000; Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011. Birthrates for 1950 to 1965 computed by ASPE staff from NCHS birth data and Census population estimates. III-42 NONMARITAL BIRTH RISK FACTOR 4. Never-Married Family Status Figure BIRTH 4. Percentage of All Children Living in Families with a Never-Married Female Head by Race and Ethnicity: 1982-2009 Note: Data are for all children under 18 who are not family heads (excludes householders, subfamily reference persons and their spouses). Inmates of institutions also are excluded. Children who are living with neither of their parents are excluded from the denominator. Based on Current Population Survey (CPS) data. Race categories include those of Hispanic ethnicity. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: U.S. Census Bureau, Marital Status and Living Arrangements, Current Population Reports, Series P20-212, 287, 365, 380, 399, 418, 423, 433, 445, 450, 461, 468, 478, 484, 491, 496, 506, 514 and America’s Families and Living Arrangements, Current Population Reports, http:\/\/www.census.gov\/population\/www\/socdemo\/hh-fam.html. Figure BIRTH 4 shows the percentage of all children living in families with a never- married female head of household by race and ethnicity from 1982 to 2009. Table BIRTH 4 shows corresponding estimates for selected years between 1960 and 2009. From 1982 to 2009, the percentage of children living in families with a never- married female head more than doubled from 4.6 percent in 1982 to 10.5 percent in 2009. Among Non-Hispanic Whites, the percentage of children living in families with never-married female heads nearly quadrupled over the past 26 years from 1.6 percent in 1982 to 6.0 percent in 2009. Among Hispanics of all races, the percentage of children living with a never- married female head of household more than doubled from 5.7 percent in 1982 to 12.2 percent in 2009. The percentage of Non-Hispanic Black children living in families with a never- married female head of household has been higher than the percentages for other groups throughout the time period. In 2009, 35.3 percent of Non-Hispanic Black children lived in families with a never-married female head of household compared to 6.0 percent for Non-Hispanic White children and 12.2 percent for Hispanic children. 4.6 10.5 1.6 6.0 22.7 35.3 5.7 12.2 0 5 10 15 20 25 30 35 40 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 All races Non-Hispanic Black Hispanic (In percent) Non-Hispanic White III-43 Table BIRTH 4. Number and Percentage of All Children Living in Families with a Never-Married Female Head by Race and Ethnicity: Selected Years Number of Children (thousands) Percentage Year All Races Non- Hispanic White Non-Hispanic Black Hispanic 3 All Races on-Hispanic White on-Hispanic Black Hispanic 1960 221 49 173 NA 0.4 0.1 2.2 NA 1970 527 110 442 NA 0.8 0.2 5.2 NA 1975 1,166 296 864 NA 1.8 0.5 9.9 NA 1980 1,745 501 1,193 210 2.9 1.0 14.5 4.0 1981 1,807 527 1,245 202 3.0 1.0 15.0 4.0 19821 2,768 793 1,947 291 4.6 1.6 22.7 5.7 1983 3,212 958 2,203 357 5.3 1.9 24.9 6.7 1984 3,131 959 2,109 357 5.2 1.9 23.9 6.5 1985 3,496 1,086 2,355 391 5.8 2.2 26.6 6.7 1986 3,606 1,174 2,375 451 5.9 2.3 26.6 7.2 1987 3,985 1,385 2,524 587 6.5 2.8 28.2 9.2 1988 4,302 1,482 2,736 600 7.0 3.0 30.4 9.2 1989 4,290 1,483 2,695 592 6.9 2.9 29.6 8.7 1990 4,365 1,527 2,738 605 7.0 3.0 29.6 8.7 1991 5,040 1,725 3,176 644 8.0 3.4 33.3 9.0 1992 5,410 2,016 3,192 757 8.4 3.9 33.1 10.3 1993 5,511 2,015 3,317 848 8.5 3.9 33.6 11.3 1994 6,000 2,412 3,321 1,083 9.0 4.5 32.9 12.0 1995 5,862 2,317 3,255 1,017 8.7 4.3 32.3 10.8 1996 6,365 2,563 3,567 1,161 9.4 4.8 34.4 12.0 1997 6,598 2,788 3,575 1,242 9.7 5.1 34.3 12.4 1998 6,700 2,850 3,644 1,254 9.8 5.2 35.1 12.2 1999 6,736 2,826 3,643 1,297 9.8 5.2 35.3 12.2 2000 6,591 2,881 3,413 1,255 9.5 5.3 32.9 11.4 2001 6,736 3,002 3,481 1,397 9.8 5.5 33.2 11.9 20022 6,872 3,048 3,573 1,400 9.9 5.6 33.4 11.5 2003 7,006 3,029 3,451 1,495 10.0 5.6 33.3 11.9 2004 7,218 3,113 3,541 1,577 10.3 5.8 34.1 12.0 2005 7,413 3,284 3,617 1,627 10.6 6.0 35.5 12.0 2006 7,443 3,263 3,557 1,677 10.6 6.0 35.0 12.0 2007 6,945 2,928 3,501 1,569 9.8 5.4 33.2 10.8 2008 7,236 2,994 3,707 1,649 10.2 5.3 35.6 11.0 2009 7,450 3,254 3,642 1,918 10.5 6.0 35.3 12.2 Note: Data are for all children under 18 who are not family heads (excludes householders, subfamily reference persons and their spouses). Inmates of institutions also are excluded. Children who are living with neither of their parents are excluded from the denominator. Based on Current Population Survey (CPS) except 1960, which is based on decennial census data. 1 In 1982, improved data collection and processing procedures helped to identify parent-child subfamilies (See Current Population Reports, P-20, 399, Marital Status and Living Arrangements: March 1984). Some of the increase between 1981 and 1982 is a result of these changes. 2 Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Nonwhite data are shown for Black in 1960. 3 Race categories include those of Hispanic ethnicity. Persons of Hispanic ethnicity may be of any race. Source of CPS data: U.S. Census Bureau, Marital Status and Living Arrangements, Current Population Reports, Series P20-212, 287, 365, 380, 399, 418, 423, 433, 445, 450, 461, 468, 478, 484, 491, 496, 506, 514 and America’s Families and Living Arrangements, Current Population Reports, http:\/\/www.census.gov\/population\/www\/socdemo\/hh-fam.html. Source of 1960 data: U.S. Census Bureau, 1960 Census of Population, PC(2)-4B, Persons by Family Characteristics, Tables 1 and 19. III-44 Appendix A Program Data A-1 Appendix A. Program Data The Welfare Indicators Act of 1994 specifies that the annual welfare indicators reports shall include analyses of families and individuals receiving assistance under three means-tested benefit programs: The Temporary Assistance for Needy Families (TANF) program authorized under part A of title IV of the Social Security Act (which replaced the Aid to Families with Dependent Children (AFDC) program in 1996); The Supplemental Nutrition Assistance Program under the Food Stamp Act of 1977, as amended (which was renamed from the Food Stamp Program by P.L. in October 2008); The Supplemental Security Income (SSI) program under title XVI of the Social Security Act. This chapter includes information on these three programs, derived primarily from administrative data reported by state and federal agencies instead of the national survey data presented in previous chapters. National caseloads and expenditure trend information on each of the three programs is included, as well as state-by-state trend tables and information on the characteristics of program participants. Temporary Assistance for Needy Families (TANF) and Aid to Families with Dependent Children (AFDC) The Aid to Families with Dependent Children (AFDC) program \u2014 originally named the Aid to Dependent Children program \u2014 was established by the Social Security Act of 1935 as a grant program to enable states to provide cash welfare payments for needy children who had been deprived of parental support or care because their fathers or mothers were absent from the home, incapacitated, deceased, or unemployed. All 50 states, the District of Columbia, Guam, Puerto Rico, and the Virgin Islands operated an AFDC program. States defined need, set their own benefit levels, established (within federal limitations) income and resource limits, and administered the program or supervised its administration. States were entitled to unlimited federal funds for reimbursement of benefit payments, at matching rates that were inversely related to state per capita income. States were required to provide aid to all persons who were in classes eligible under federal law and whose income and resources were within state-set limits. During the 1990s, the federal government increasingly used its authority under section 1115 of the Social Security Act to waive portions of the federal requirements under AFDC. This allowed states to test such changes as expanded earned income disregards, family caps, education and adult oversight requirements for minor mothers, increased work requirements and stronger sanctions for failure to comply with them, time limits on benefits, and expanded access to transitional benefits such as child care and medical assistance. As a condition of receiving waivers, states were required to conduct rigorous evaluations of the impacts of these changes on the welfare receipt, employment, and earnings of participants. Public Law 104-193, the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), replaced AFDC, AFDC administration, the Job Opportunities and Basic Skills Training (JOBS) program and the Emergency Assistance (EA) program with a block grant called the Temporary Assistance for Needy Families (TANF) program. Key elements of TANF include a lifetime limit of 60 months1 on the amount of time a family with an adult can receive assistance funded with federal funds, increasing work participation rate requirements that states must meet for families receiving assistance, and broad state flexibility on program design and use of funds. Spending through the TANF block grant for state family assistance grants is capped and funded at $16.5 billion per year, slightly above FY 1995 federal expenditures for the four component programs without adjusting for subsequent inflation. States also must meet a maintenance of effort (MOE) requirement by spending on needy families at least 80 percent of the amount of state funds used in FY 1994 on these programs (75 percent if they meet their work participation rate requirements). 1 Many states limit TANF assistance to less than the 60-month federal maximum. A-2 TANF gives states wide latitude in spending both federal TANF funds and state MOE funds. Subject to a few restrictions, TANF funds may be used in any way that supports one of the four statutory purposes of TANF: to provide assistance to needy families so that children can be cared for at home; to end the dependence of needy parents on government benefits by promoting job preparation, work and marriage; to prevent and reduce the incidence of out-of-wedlock pregnancies; and to encourage the formation and maintenance of two-parent families. Legislative Changes The current legislative authority for the TANF block grant is from the Deficit Reduction Act of 2005 (Public Law 109-171). Enacted in February 2006, the Deficit Reduction Act of 2005, or DRA (Public Law 109- 171), reauthorized the original 1996 legislation at an annual funding level of $16.5 billion for state family assistance grants and made changes to the state work participation requirements (effective FY 2007). Under TANF, states must engage a certain percentage of the families in countable activities for a minimum average number of hours per week or face financial penalty. Nominally, the requirement is 50 percent; however, a provision known as the caseload reduction credit allows a state to reduce the rate it must meet by the decline in its caseload (net of decline due to federal or state eligibility changes) between a base year and a comparison year (the year prior to the year of whose rate it affects). The DRA revised the base year of the caseload reduction credit from FY 1995 to FY 2005. Prior to the DRA, states had experienced dramatic caseload declines (many in excess of 40 percent) and the caseload reduction credit had virtually eliminated the work participation requirements for most states. In addition, the DRA made families with an adult receiving assistance in a separate state program subject to the work participation rate. A separate state program is operated outside the rules of TANF but funded entirely with qualified state maintenance-of-effort expenditures. Additionally, HHS regulations created consistent definitions of countable work activities, specified the circumstances under which parents who reside with a child who is a recipient of assistance should be required to participate in work activities, and required states to establish and maintain work participation verification procedures. Finally, the DRA included $150 million for the Healthy Marriage Promotion and Responsible Fatherhood Grants in FY 2006 through FY 2010; the Claims Resolution Act of 2010 and other subsequent legislation continued to provide $150 million for this purpose, specifying that funding should be equally split between healthy marriage and responsible fatherhood activities. Data Issues Relating to the TANF Program and the AFDC-TANF Transition States had the option of beginning their TANF programs as soon as PRWORA was enacted in August 1996, and a few states began TANF programs as early as September 1996. All states were required to implement TANF by July 1, 1997. Because states implemented TANF at different times, the FY 1997 data reflect a combination of the AFDC and TANF programs. In some states, limited data are available for FY 1997 because states were given a transition period of six months after they implemented TANF before they were required to report data on the characteristics and work activities of TANF participants. Because of the greatly expanded range of allowable uses of funds under TANF, a substantial portion of TANF funds are being spent on activities other than cash payments to families and associated services. Table TANF 4 in this Appendix which tracks overall expenditure trends includes only those TANF funds spent on cash and work-based assistance and administrative costs, not on work activities, supportive services, or other allowable uses of funds. Spending on these other activities is detailed in Table TANF 5. Note that TANF administrative costs include funds spent administering all activities, not just cash and work-based assistance. (Administrative costs under AFDC had included a small amount of funds for administering AFDC child care programs; such programs, and the costs of administering them, were transferred to the Child Care and Development Fund as part of PRWORA.) There also is potential for discontinuity between the AFDC and the TANF caseload figures. For example, under TANF there is no longer a separate Unemployed Parent (UP) program, as there was under AFDC. While a separate work participation rate is calculated for two-parent families, this population is not identical to the UP caseload under AFDC. It also is possible that a limited number of families will be A-3 considered recipients of TANF assistance, even if they do not receive a monthly cash benefit. The vast majority of families receiving assistance 2 are, in fact, receiving cash payments. Another data issue concerns the treatment of families who receive cash and other forms of assistance under Separate State Programs (SSPs), funded by MOE dollars rather than federal TANF funds. Under TANF, some states use SSP programs to serve specific categories of families (e.g., two-parent families, families who have exhausted their time limits). Initially, however, states did not have to include them in calculating of their work participation rates. As of October 2006, such families are included in the work participation rate calculation, but continue to be excluded from the application of the federal time limits on receipt of assistance. Starting with the 2004 edition, this Indicators report adds recipients in SSPs into the caseload totals3 AFDC\/TANF Program Data (the split between TANF and SSP caseloads is shown in Table TANF 3, nationally, and in Table TANF 15, by state). Native Americans served through state TANF and SSP programs are included in these caseload counts, but families served through TANF programs operated by Tribal governments are excluded. Expenditures for SSPs are shown in Table TANF 5. The following tables and figures present data on caseloads, expenditures, and recipient characteristics of the AFDC and TANF programs. Trends in national caseloads and expenditures are shown in Figures TANF 1 and TANF 2, and the first set of tables (Tables TANF 1 through 6). These are followed by information on characteristics of AFDC\/TANF families (Table TANF 7)4 and a series of tables presenting state-by-state data on trends in the AFDC\/TANF program (Tables TANF 8 through 15). These data complement the data on trends in AFDC\/TANF recipiency and participation rates shown in Tables IND 3a and IND 4a in Chapter II. AFDC\/TANF Caseload Trends (Tables TANF 1 through TANF 3 and Figure TANF 1). After dramatic declines during the 1990s, welfare caseloads reached their lowest point since FY 1969 in FY 2008 and increased in FY 2009. With increases in the need for cash assistance due to the 2007-2009 recession, the average monthly number of recipients increased by almost 7 percent from FY 2008 to FY 2009. In FY 2009, the average monthly number of TANF recipients was 4.254 million persons. From the peak of 14.2 million in FY 1994, the number of AFDC\/TANF recipients dropped by 72 percent in FY 2009.5 AFDC\/TANF Expenditures (Figure TANF 2 and Tables TANF 4 through TANF 6). Tables TANF 4 and 5 show trends in expenditures on AFDC and TANF. Table TANF 4 tracks both programs, breaking out the costs of benefits and administrative expenses. It also shows the division between federal and state spending. Table TANF 5 shows the variety of activities funded under the TANF program. Figure TANF 2 and Table TANF 6 show that inflation has had a significant effect in eroding the value of the average monthly AFDC\/TANF benefit. In real dollars, by 2009 the average monthly benefit per recipient had declined by 35 percent from what it was at its peak in the late 1970s. AFDC\/TANF Recipient Characteristics (Table TANF 7). With the dramatic declines in the welfare rolls since the implementation of TANF, there has been discussion regarding how the composition of the caseload has changed over time. Two trends that emerged are the increases in the proportion of families with no adult in the assistance unit and employment among adult recipients. One notable trend that occurred in the early years of TANF is the increase in the proportion of adult recipients who are working. From the peak in FY 1999 of 27.6 percent, adult employment status declined 2 States are allowed to use TANF funds on a variety of services, including employment and training services, domestic violence services, child care, transportation, and other support services. Families receiving such services, however, generally should not be counted as recipients of TANF assistance. Under the final regulations for TANF, assistance primarily includes payments directed at ongoing basic needs. It includes payments when individuals are participating in community service and work experience (or other work activities) as a condition of receiving payments (e.g., workfare). In addition, the definition also includes certain child care and transportation benefits when families are not employed. It excludes, however, such things as: non-recurrent, short-term benefits; services without a cash value, such as education and training, case management, job search, and counseling; and benefits such as child care and transportation when provided to employed families. These are classified as non-assistance. 3 States began submitting caseload data on SSPs in FY 2000. 4 Family characteristics in Table TANF 7 may differ from those reported in Chapter II because the administrative data focus on recipients of assistance, whereas the survey-based data in Chapter II generally include all family members, regardless of whether they receive assistance themselves or not. For example, grandparents, adult siblings, aunts, uncles, and other adult relatives living in the same household as the recipient children may not receive assistance and thus may be excluded from the administrative data, yet they generally would be included in survey data on the family in which the TANF recipient resides. 5 Note that these figures include recipients in SSPs unless otherwise noted. A-4 to a low of 21.6 percent before rebounding to 25.8 percent in FY 2008.6 This rate of employed adult recipients represents more than twice the 1996 rate of 11.3 percent and more than three and one-half times the FY 1992 rate of 6.6 percent, as shown in Table TANF 7. Another notable change in the TANF caseload is the increasing number of cases without an adult recipient. Such cases occur when the adults are ineligible (because they are a caretaker relative, SSI parent, immigrant parent, or sanctioned parent). Families with no adults receiving assistance have increased from 15 percent of the caseload in FY 1992 to 48 percent in FY 2009.6 This dramatic growth has been due to an increase in the number of cases without recipient adults during the early 1990s, followed by a decline in the number of cases that included adults in the assistance unit. In other areas, TANF administrative data show few changes in composition. Analyses of program data have not found much evidence of an increase or decrease in readily observed barriers to employment in the current caseload. The question of whether the caseload has become more disadvantaged cannot be answered simply through TANF administrative data provided by the states, which do not contain detailed information on such barriers to employment as lack of basic skills, alcohol and drug abuse, domestic violence, and disabilities. AFDC\/TANF State-by-State Trends (Tables TANF 8 through TANF 15). There is a great deal of state- to-state variation in the trends discussed above. For example, as shown in Table TANF 10, while every state has experienced a caseload decline since the 1990s, the percentage change between the state’s caseload peak and December 2009 ranges from 96 percent (Wyoming) to 41 percent (Washington). Sixteen states have experienced caseload declines of 75 percent or more. Table TANF 10 also shows that states reached their peak caseloads as early as May 1990 (Louisiana) and as late as June 1997 (Hawaii). Table TANF 15 shows TANF and Separate State Program (SSP) families and recipients, by state. Eighteen states had such programs. 6 The percentages in this paragraph do not include cases served by SSP programs. A-5 Figure TANF 1. Average Monthly AFDC\/TANF Families Receiving Assistance Note: Basic Families are single-parent families and UP Families are two-parent cases receiving benefits under AFDC Unemployed Parent programs that operated in certain states before FY 1991 and in all states after October 1, 1990. The AFDC Basic and UP programs were replaced by TANF as of July 1, 1997 under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. Shaded areas indicate NBER designated periods of recession from peak to trough; NBER has established December 2007 as the beginning month of the current recession. The decrease in number of families receiving assistance during the 1981-82 recession stems from changes in eligibility requirements and other policy changes mandated by OBRA 1981. Beginning in 2000, Total Families includes TANF and SSP families. Beginning in 2000, Total Families includes TANF and SSP families. Last data point plotted is December 2009. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. 12\/69 11\/70 11\/73 3\/75 1 7\/80 7\/81 11\/82 7\/90 4\/91 3\/01 11\/01 12\/07 6\/09 (In millions) Total families AFDC Basic families AFDC UP families TANF 2-Parent families 0 1 2 3 4 5 6 1\/61 1\/64 1\/67 1\/70 1\/73 1\/76 1\/79 1\/82 1\/85 1\/88 1\/91 1\/94 1\/97 1\/00 1\/03 1\/06 1\/09 A-6 Figure TANF 2. Average Monthly AFDC\/TANF Benefit per Recipient in Constant 2009 Dollars Note: See Table TANF 6 for underlying data. Comparison of trends in the average monthly AFDC\/TANF benefit per recipient in constant 2009 dollars with the weighted average maximum benefit in constant 2009 dollars. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Quarterly Public Assistance Statistics, 1992 & 1993 and earlier years along with unpublished data. 193 254 164 120 160 200 240 280 1965 1970 1975 1980 1985 1990 1995 2000 2005 2009 M on th ly B en ef it 0 A-7 Table TANF 1. Trends in AFDC\/TANF Caseloads: 1962-2009 Average Monthly Number (thousands) Children as a Percent of Total Recipients Average 1 Number of Children per Family Total Families 1 AFDC UP 2 Two-Parent Families TANF Two-Parent Families Total Recipients Child Recipients Fiscal Year 1962……. . 924 48 NA 3,593 2,778 77.3 3.0 1964……….. 984 60 NA 4,059 3,043 75.0 3.1 1966……….. 1,074 62 NA 4,472 3,369 75.3 3.1 1968……….. 1,310 67 NA 5,349 4,013 75.0 3.1 1969……….. 1,539 66 NA 6,146 4,591 74.7 3.0 1970……….. 1,906 78 NA 7,415 5,484 74.0 2.9 1971……….. 2,531 143 NA 9,557 6,963 72.9 2.8 1972……….. 2,918 134 NA 10,632 7,698 72.4 2.6 1973……….. 3,123 120 NA 11,038 7,967 72.2 2.6 1974……….. 3,170 93 NA 10,845 7,825 72.2 2.5 1975……….. 3,357 100 NA 11,067 7,952 71.9 2.4 1976……….. 3,575 135 NA 11,386 8,054 70.7 2.3 1977……….. 3,593 149 NA 11,130 7,846 70.5 2.2 1978……….. 3,539 128 NA 10,672 7,492 70.2 2.1 1979……….. 3,496 114 NA 10,318 7,197 69.8 2.1 1980……….. 3,642 141 NA 10,597 7,320 69.1 2.0 1981……….. 3,871 209 NA 11,160 7,615 68.2 2.0 1982……….. 3,569 232 NA 10,431 6,975 66.9 2.0 1983……….. 3,651 272 NA 10,659 7,051 66.1 1.9 1984……….. 3,725 287 NA 10,866 7,153 65.8 1.9 1985……….. 3,692 261 NA 10,813 7,165 66.3 1.9 1986……….. 3,748 254 NA 10,997 7,300 66.4 1.9 1987……….. 3,784 236 NA 11,065 7,381 66.7 2.0 1988……….. 3,748 210 NA 10,920 7,325 67.1 2.0 1989……….. 3,771 193 NA 10,934 7,370 67.4 2.0 1990……….. 3,974 204 NA 11,460 7,755 67.7 2.0 1991……….. 4,374 268 NA 12,592 8,513 67.6 1.9 1992……….. 4,768 322 NA 13,625 9,226 67.7 1.9 1993……….. 4,981 359 NA 14,143 9,560 67.6 1.9 1994……….. 5,046 363 NA 14,226 9,611 67.6 1.9 1995……….. 4,871 335 NA 13,660 9,280 67.9 1.9 1996……….. 4,543 301 NA 12,645 8,671 68.6 1.9 1997 2……… 3,937 256 NA 10,935 7,781 3 71.2 3 2.0 3 1998……….. 3,200 NA 162 8,790 6,273 71.4 2.0 1999……….. 2,674 NA 125 7,188 5,319 74.0 2.0 2000……….. 2,356 NA 132 6,324 4,598 72.7 2.0 2001……….. 2,200 NA 119 5,761 4,233 73.4 1.9 2002……….. 2,195 NA 118 5,656 4,149 73.3 1.9 2003……….. 2,181 NA 116 5,518 4,075 73.9 1.9 2004……….. 2,161 NA 114 5,377 3,993 74.3 1.8 2005……….. 2,090 NA 108 5,118 3,818 74.6 1.8 2006……….. 1,960 NA 98 4,741 3,565 75.2 1.8 2007……….. 1,754 NA 62 4,138 3,165 76.5 1.8 2008……….. 1,693 NA 63 3,982 3,044 76.5 1.8 2009……….. 1,796 NA 86 4,254 3,233 75.8 1.8 Note: Beginning in 2000, all caseload numbers include SSP families. 1 Includes unemployed parent families under AFDC and two-parent families under TANF. 2 The AFDC Unemployed Parent program was replaced when the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 repealed AFDC and set up the Temporary Assistance for Needy Families (TANF) program. 3 Based on data from the AFDC reporting system that were available only for the first 9 months of the fiscal year. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. A-8 Table TANF 2. Number of AFDC\/TANF Recipients, and Recipients as a Percentage of Various Population Groups: 1970-2009 Calendar Year 1 Total Recipients in the States & DC (thousands) Child Recipients in the States & DC (thousands) Recipients as a Percent of Total Population 2 Recipients as a Percent of Poverty Population 3 Child Recipients as a Percent of Total Child Population 2 Child Recipients as a Percent of Children in Poverty 3 1970 8,303 6,104 4.0 32.7 8.7 58.5 1971 10,043 7,303 4.8 39.3 10.5 69.2 1972 10,736 7,766 5.1 43.9 11.2 75.5 1973 10,738 7,763 5.1 46.7 11.3 80.5 1974 10,621 7,637 5.0 45.4 11.2 75.2 1975 11,131 7,928 5.2 43.0 11.8 71.4 1976 11,098 7,850 5.1 44.4 11.8 76.4 1977 10,856 7,632 4.9 43.9 11.7 74.2 1978 10,387 7,270 4.7 42.4 11.2 73.2 1979 10,140 7,057 4.5 38.9 11.0 68.0 1980 10,599 7,295 4.7 36.2 11.5 63.2 1981 10,893 7,397 4.7 34.2 11.7 59.2 1982 10,161 6,767 4.4 29.5 10.8 49.6 1983 10,569 6,967 4.5 29.9 11.1 50.1 1984 10,643 7,017 4.5 31.6 11.2 52.3 1985 10,672 7,073 4.5 32.3 11.3 54.4 1986 10,850 7,206 4.5 33.5 11.5 56.0 1987 10,841 7,240 4.5 33.6 11.5 56.4 1988 10,728 7,201 4.4 33.8 11.4 57.8 1989 10,798 7,286 4.4 34.3 11.5 57.9 1990 11,497 7,781 4.6 34.2 12.1 57.9 1991 12,728 8,601 5.0 35.6 13.2 60.0 1992 13,571 9,189 5.3 35.7 13.8 60.1 1993 14,007 9,460 5.4 35.7 14.0 60.2 1994 13,970 9,448 5.3 36.7 13.8 61.8 1995 13,242 9,013 5.0 36.4 13.0 61.5 1996 12,156 8,355 4.5 33.3 11.9 57.8 1997 10,224 7,077 4 3.7 28.7 10.0 50.1 1998 8,215 5,781 3.0 23.8 8.1 42.9 1999 6,709 4,836 2.4 20.5 6.7 39.4 2000 6,043 4,415 2.1 19.1 6.1 38.1 2001 5,631 4,140 2.0 17.1 5.7 35.3 2002 5,534 4,073 1.9 16.0 5.6 33.6 2003 5,424 4,024 1.9 15.1 5.5 31.3 2004 5,283 3,935 1.8 14.3 5.4 30.2 2005 4,975 3,726 1.7 13.5 5.1 28.9 2006 4,537 3,428 1.5 12.4 4.6 26.7 2007 4,038 3,093 1.3 10.8 4.2 23.2 2008 3,972 3,036 1.3 10.0 4.1 21.6 2009 4,331 3,268 1.4 9.9 4.4 21.6 1 Total recipients are calculated here as the monthly average for the calendar year in order to compare with the calendar year counts of the poverty populations used to compute the recipiency rates. From 2000 onward, total recipients includes SSP recipients as well as TANF recipients. See Table IND 3a for fiscal year recipiency rates. 2 Population numbers used as denominators are resident population. See Current Population Reports, Series P25-1106 . 3 For poverty population data see Current Population Reports, Series P60-231 (available online at http:\/\/www.census.gov\/hhes\/www\/poverty.html). 4 Estimated based on the ratio of children recipients to total recipients for January through June of 1997. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance and U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60-238. http:\/\/www.census.gov\/hhes\/www\/poverty.html\ufffd A-9 Table TANF 3. TANF and Separate State Program (SSP) Families and Recipients: 2000-2009 [In thousands] TANF SSP Total Fiscal Year Families 2000 2,265 91 2,356 2001 2,117 82 2,200 2002 2,065 129 2,195 2003 2,032 149 2,181 2004 1,987 174 2,161 2005 1,920 170 2,090 2006 1,805 155 1,960 2007 1,699 55 1,754 2008 1,628 65 1,693 2009 1,727 69 1,796 All Recipients 2000 5,943 380 6,324 2001 5,423 338 5,761 2002 5,149 508 5,656 2003 4,967 551 5,518 2004 4,784 593 5,377 2005 4,549 569 5,118 2006 4,222 520 4,742 2007 3,961 177 4,138 2008 3,782 199 3,982 2009 4,041 213 4,254 Child Recipients 2000 4,370 228 4,598 2001 4,025 202 4,227 2002 3,841 308 4,149 2003 3,731 344 4,075 2004 3,617 376 3,993 2005 3,459 360 3,818 2006 3,237 328 3,565 2007 3,050 115 3,165 2008 2,914 130 3,044 2009 3,084 138 3,222 Note: Some states provide cash and other forms of assistance to specific categories of families under Separate State Programs (SSPs) which are funded out of Maintenance of Effort (MOE) dollars rather than federal TANF funds. See Table TANF 15 for SSPs by state. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. A-10 Table TANF 4. Federal and State TANF Program and Other Related Spending: 1970 2009 [In millions of dollars] Federal Funds (Current Dollars) State Funds (Current Dollars) Total (Current Dollars) Total (Constant 2009 Dollars1) Fiscal Year Benefits Admin Benefits Admin Benefits Admin Benefits Admin 1970 $2,187 $572 2 $1,895 $309 $4,082 $881 2 $20,509 $4,426 1971 3,008 271 2,469 254 5,477 525 26,344 2,525 1972 3,612 240 3 2,942 241 6,554 481 3 30,442 2,234 1973 3,865 313 3,138 296 7,003 610 31,241 2,721 1974 4,071 379 3,300 362 7,371 740 30,287 3,041 1975 4,625 552 3,787 529 8,412 1,082 31,503 4,052 1976 5,258 541 4,418 527 9,676 1,069 33,921 3,748 1977 5,626 595 4,762 583 10,388 1,177 33,900 3,841 1978 5,724 631 4,898 617 10,621 1,248 32,516 3,821 1979 5,825 683 4,954 668 10,779 1,350 30,346 3,801 1980 6,448 750 5,508 729 11,956 1,479 30,290 3,747 1981 6,928 835 5,917 814 12,845 1,648 29,582 3,795 1982 6,922 878 5,934 878 12,857 1,756 27,699 3,783 1983 7,332 915 6,275 915 13,607 1,830 28,026 3,769 1984 7,707 876 6,664 822 14,371 1,698 28,425 3,359 1985 7,817 890 6,763 889 14,580 1,779 27,839 3,397 1986 8,239 993 6,996 967 15,235 1,960 28,432 3,658 1987 8,914 1,081 7,409 1,052 16,323 2,133 29,669 3,877 1988 9,125 1,194 7,538 1,159 16,663 2,353 29,204 4,124 1989 9,433 1,211 7,807 1,206 17,240 2,417 28,986 4,064 1990 10,149 1,358 8,390 1,303 18,539 2,661 29,812 4,279 1991 11,165 1,373 9,191 1,300 20,356 2,673 31,322 4,113 1992 12,258 1,459 9,993 1,378 22,250 2,837 33,418 4,261 1993 12,270 1,518 10,016 1,438 22,286 2,956 32,644 4,330 1994 12,512 1,680 10,285 1,621 22,797 3,301 32,690 4,734 1995 12,019 1,770 10,014 1,751 22,032 3,521 30,860 4,932 1996 11,065 1,633 9,346 1,633 20,411 3,266 27,892 4,463 1997 4 9,748 1,273 7,799 1,098 17,547 2,371 23,398 3,161 1998 7,518 1,231 7,096 1,028 14,614 2,259 19,201 2,969 1999 6,475 1,407 6,975 884 13,449 2,291 17,359 2,957 2000 5,444 1,570 5,736 1,032 11,180 2,302 13,993 3,257 2001 4,772 1,598 5,390 1,042 10,163 2,639 12,327 3,201 2002 4,554 1,633 4,854 983 9,408 2,617 11,242 3,127 2003 5,820 1,592 4,398 859 10,219 2,451 11,929 2,861 2004 4,717 1,471 5,652 828 10,368 2,300 11,831 2,624 2005 5,193 1,507 5,546 870 10,739 2,377 11,865 2,626 2006 4,926 1,525 4,980 886 9,906 2,411 10,555 2,569 2007 4,533 1,553 4,583 955 9,116 2,508 9,488 2,611 2008 4,755 1,523 3,894 1,054 8,649 2,577 8,622 2,569 2009 4,504 1,572 4,820 911 9,324 2,483 9,324 2,483 Note: Benefits do not include emergency assistance payments and have not been reduced by child support collections. Foster care payments are included from 1971 to 1980. State funds for benefits include benefits under Separate State Programs. Beginning in fiscal year 1984, the cost of certifying AFDC households for food stamps is shown in the food stamp program’s appropriation under the U.S. Department of Agriculture. Administrative costs include: Work Program, ADP, FAMIS, Fraud Control, Child Care administration (through 1996), SAVE and other State and local administrative expenditures. 1 Constant dollar adjustments to 2009 level were made using a CPI-U-RS fiscal year price index. 2 Includes expenditures for services. 3 Administrative expenditures only. 4 The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 repealed the AFDC program as of July 1, 1997 and replaced it with the Temporary Assistance for Needy Families (TANF) program. Under PRWORA, spending categories are not entirely equivalent to those under AFDC: for example administrative expenses under TANF do not include IV-A child care administration (which accounted for 4 percent of 1996 administrative expense). Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Administration. A-11 Table TANF 5. Federal TANF and State MOE Spending: 2000 2009 [In millions of dollars] Fiscal Year Basic Assistance Work Activities Child Care Trans- portation Admini- stration Systems Other Expenditures Total Expenditures Federal TANF Grants 2000 5,444 1,606 1,553 496 1,328 242 2,715 13,384 2001 4,772 1,983 1,583 522 1,375 223 4,325 14,782 2002 4,554 2,121 1,572 339 1,339 294 4,368 14,588 2003 5,820 1,937 1,698 434 1,307 285 4,772 16,254 2004 4,717 1,613 1,427 354 1,220 251 4,811 14,393 2005 5,193 1,702 1,279 393 1,277 230 4,089 14,164 2006 4,926 1,681 1,238 341 1,294 231 3,859 13,570 2007 4,532 1,678 1,168 354 1,317 236 4,352 13,637 2008 4,755 1,696 1,622 399 1,305 219 4,478 14,474 2009 4,504 1,778 1,787 420 1,365 207 5,118 15,179 State Maintenance of Effort Expenditures in the TANF Program 2000 5,432 884 1,893 150 921 92 1,170 10,541 2001 4,887 685 1,730 113 920 83 1,195 9,613 2002 3,994 582 1,860 221 877 66 1,554 9,154 2003 3,597 596 1,993 73 766 60 1,441 8,526 2004 4,729 501 1,878 119 721 55 1,330 9,333 2005 4,537 429 1,761 111 776 46 1,489 9,148 2006 4,105 630 2,120 102 793 41 1,323 9,114 2007 4,098 643 2,355 101 879 51 2,264 10,390 2008 3,499 552 2,419 91 987 54 2,791 10,523 2009 4,745 561 2,183 102 825 72 5,839 14,327 State Maintenance of Effort Expenditures in Separate State Programs 2000 305 11 73 17 19 0 431 856 2001 503 28 34 20 38 1 499 1,125 2002 860 24 72 24 41 -.5 652 1,673 2003 801 66 -223 36 33 -.3 848 1,560 2004 922 40 45 19 52 1.1 1,016 2,095 2005 1,009 36 157 19 46 1.9 999 2,268 2006 875 53 184 29 51 1.3 1,716 2,910 2007 485 18 194 19 25 0.6 2,154 2,896 2008 394 22 195 19 12 1.0 2,488 3,133 2009 75 20 164 25 11 1.7 775 1,072 Total Expenditures 2000 11,180 2,501 3,519 663 2,267 335 4,316 24,781 2001 10,163 2,696 3,347 655 2,333 306 6,019 25,520 2002 9,408 2,727 3,504 584 2,258 359 6,574 25,414 2003 10,219 2,599 3,468 543 2,106 345 7,060 26,340 2004 10,368 2,154 3,350 492 1,992 307 7,157 25,821 2005 10,739 2,167 3,197 523 2,099 278 6,577 25,580 2006 9,906 2,364 3,542 472 2,138 273 6,898 25,594 2007 9,115 2,338 3,717 474 2,221 287 8,770 26,922 2008 8,649 2,270 4,236 510 2,304 274 9,888 28,130 2009 9,324 2,359 4,134 547 2,202 281 11,732 30,578 Note: Administration and Systems, shown separately here in Table TANF 5, can be combined to show total administrative costs, as in Table TANF 3. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Administration. A-12 Table TANF 6. Trends in AFDC\/TANF Average Monthly Payments: 1962 2009 Monthly Benefit per Recipient Average Number of Persons per Family Monthly Benefit per Family (not reduced by Child Support) Weighted Average 1 Maximum Benefit (per 3-person Family) Fiscal Year Current Dollars 2009 Dollars Current Dollars 2009 Dollars Current Dollars 2009 Dollars 1962 $31 $193 3.9 $121 $752 NA NA 1963 31 191 4.0 126 772 NA NA 1964 32 193 4.1 131 795 NA NA 1965 34 200 4.2 140 836 NA NA 1966 35 204 4.2 146 850 NA NA 1967 36 206 4.1 150 851 NA NA 1968 40 217 4.1 162 887 NA NA 1969 43 228 4.0 173 911 $186 2 $983 1970 46 230 3.9 178 895 194 2 976 1971 48 230 3.8 180 867 201 2 967 1972 51 239 3.6 187 869 205 2 954 1973 53 236 3.5 187 834 213 2 949 1974 57 233 3.4 194 796 229 2 940 1975 63 237 3.3 209 782 243 910 1976 71 248 3.2 226 791 257 900 1977 78 254 3.1 241 786 271 884 1978 83 254 3.0 250 766 284 870 1979 87 245 3.0 257 723 301 847 1980 94 238 2.9 274 693 320 811 1981 96 221 2.9 277 637 326 750 1982 103 221 2.9 300 647 331 712 1983 106 219 2.9 311 640 336 692 1984 110 218 2.9 322 636 352 695 1985 112 215 2.9 329 628 369 705 1986 115 215 2.9 339 632 383 715 1987 123 223 2.9 359 653 393 715 1988 127 223 2.9 370 649 403 707 1989 131 221 2.9 381 641 413 694 1990 135 217 2.9 389 625 420 675 1991 135 207 2.9 388 597 424 653 1992 136 204 2.9 389 584 419 629 1993 131 192 2.8 373 546 414 607 1994 134 191 2.8 376 540 416 596 1995 134 188 2.8 377 528 418 586 1996 135 184 2.8 374 512 419 573 1997 3 130 174 2.8 362 483 418 558 1998 130 171 2.7 358 470 429 564 1999 133 171 2.7 357 461 450 581 2000 130 163 2.7 349 437 446 558 2001 134 163 2.6 351 426 448 543 2002 141 169 2.6 364 435 452 540 2003 140 163 2.5 354 413 455 531 2004 145 165 2.5 360 411 462 528 2005 151 167 2.4 370 408 468 517 2006 154 164 2.4 372 397 489 521 2007 160 166 2.4 377 392 499 519 2008 163 162 2.4 383 382 510 508 2009 164 164 2.4 389 389 507 507 Note: AFDC benefit amounts have not been reduced by child support collections. Constant dollar adjustments to 2009 level were made using a CPI-U- RS fiscal-year price index. 1 The maximum benefit for a 3-person family in each state is weighted by that state’s share of total AFDC\/TANF families. 2 Estimated based on the weighted average benefit for a 4-person family. 3 The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 repealed the AFDC program as of July 1, 1997 and replaced it with the Temporary Assistance for Needy Families (TANF) program. Beginning in 1997, average monthly benefits are calculated from case-level data rather than by dividing aggregate expenditures on cash assistance by aggregate caseloads, as in the past. This change was necessary due to uncertainty about the extent to which states may be reporting non-cash basic assistance as well as cash assistance in the expenditure data formerly used to calculate average cash benefits. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Quarterly Public Assistance Statistics, 1992 & 1993 and earlier years along with unpublished data. A-13 Table TANF 7. Characteristics of AFDC\/TANF Families: Selected Years 1969 2009 May May March Fiscal year 1 1969 1975 1979 1983 1988 1992 1996 2000 2004 2009 Avg. Family Size (persons) 4.0 3.2 3.0 3.0 3.0 2.9 2.8 2.6 2.4 2.3 Number of Child Recipients One 26.6 37.9 42.3 43.4 42.5 42.5 43.9 44.2 48.9 50.8 Two 23.0 26.0 28.1 29.8 30.2 30.2 29.9 28.4 27.7 26.9 Three 17.7 16.1 15.6 15.2 15.8 15.5 15.0 15.3 13.2 12.9 Four or More 32.5 20.0 13.9 10.1 9.9 10.1 9.2 10.1 8.4 7.5 Unknown NA NA NA 1.5 1.7 0.7 1.3 2.0 1.8 1.8 Families with No Adult in Asst. Unit 10.1 12.5 14.6 8.3 9.6 14.8 21.5 34.4 43.6 48.1 Child-Only Families 2 32.7 40.9 45.2 Families with Non-Recipients 33.1 34.8 NA 36.9 36.8 38.9 49.9 Median Months on AFDC\/TANF Since Most Recent Opening 23.0 31.0 29.0 26.0 26.3 22.5 23.6 Presence of Assistance Living in Public Housing 12.8 14.6 NA 10.0 9.6 9.2 8.8 17.7 18.8 13.7 Participating in Food Stamp or Donated Food Program 52.9 75.1 75.1 83.0 84.6 87.3 89.3 79.9 81.5 80.7 Presence of Income With Earnings NA 14.6 12.8 5.7 8.4 7.4 11.1 23.6 3 18.9 3 21.8 3 No Non-AFDC\/TANF Income 56.0 71.1 80.6 86.8 79.6 78.9 76.0 71.6 3 75.8 3 74.5 3 Adult Employment Status (percent of adults) Employed 6.6 11.3 26.4 22.0 23.5 Unemployed 49.2 50.2 47.3 Not in Labor Force 24.3 27.8 29.2 Adult Women’s Employment Status (percent of adult female recipients):4 Full-time job 8.2 10.4 8.7 1.5 2.2 2.2 4.7 Part-time job 6.3 5.7 5.4 3.4 4.2 4.2 5.4 Marital Status (percent of adults) Single 65.3 69.1 69.5 Married 12.4 10.3 14.4 Separated 13.1 11.9 9.9 Widowed 0.7 0.6 0.3 Divorced 8.5 8.1 6.1 Basis for Child’s Eligibility (percent children): Incapacitated 11.7 5 7.7 5.3 3.4 3.7 4.1 4.3 Unemployed 4.6 5 3.7 4.1 8.7 6.5 8.2 8.3 Death 5.5 5 3.7 2.2 1.8 1.8 1.6 1.6 Divorce or Separation 43.3 5 48.3 44.7 38.5 34.6 30.0 24.3 Absent, No Marriage Tie 27.9 5 31.0 37.8 44.3 51.9 53.1 58.6 Absent, Other Reason 3.5 5 4.0 5.9 1.4 1.6 2.0 2.4 Unknown 1.7 0.9 0.6 Note: Figures are percentages of families\/cases unless noted otherwise. 1 Percentages are based on the average monthly TANF caseload during the year. Hawaii and the territories are not included in 1983. Data after 1986 include the territories and Hawaii. Unlike most of the figures in this report, this table does not include families from Separate State Programs (SSP). 2 Adults that live in TANF families with children are sometimes excluded from the assistance unit because they have been sanctioned, receive disability income from Supplemental Security Income (SSI), have been time-limited, do not qualify based on citizenship requirements, or are non-parental caretakers such as relatives or other adults taking responsibility for the children. 3 Presence of income is measured as a percentage of adult recipients (not families) in FY 1998 and subsequent years. 4 For years prior to 1983, data are for mothers only. 5 Calculated on the basis of total number of families. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, unpublished data and Characteristics and Financial Circumstances of TANF Recipients: TANF Annual Report to Congress selected years. A-14 Table TANF 8. AFDC\/TANF Benefits by State: Selected Fiscal Years 1978 2009 [In millions of dollars] 1978 1984 1986 1988 1990 1994 1998 2000 2004 2009 Alabama $78 $74 $68 $62 $62 $92 $44 $36 $45 $42 Alaska 17 37 46 54 60 113 77 55 43 32 Arizona 30 67 79 103 138 266 145 107 183 138 Arkansas 51 39 48 53 57 57 26 34 17 17 California 1,813 3,207 3,574 4,091 4,955 6,088 4,128 3,643 3,286 3,510 Colorado 74 107 107 125 137 158 80 48 65 52 Connecticut 168 226 223 218 295 397 305 166 126 89 Delaware 28 28 25 24 29 40 24 20 20 18 Dist. of Columbia 91 75 77 76 84 126 97 72 70 23 Florida 145 251 261 318 418 806 357 234 239 180 Georgia 103 149 223 266 321 428 313 180 162 55 Hawaii 83 83 73 77 99 163 153 141 87 70 Idaho 21 21 19 19 20 30 6 3 7 6 Illinois 699 845 886 815 839 914 771 269 110 61 Indiana 118 153 148 167 170 228 104 87 122 109 Iowa 107 159 170 155 152 169 104 79 80 62 Kansas 73 87 91 97 105 123 41 43 61 46 Kentucky 122 135 104 143 179 198 147 104 106 117 Louisiana 97 145 162 182 188 168 103 58 65 43 Maine 51 69 84 80 101 108 80 73 77 75 Maryland 166 229 250 250 296 314 192 196 110 107 Massachusetts 476 406 471 558 630 730 442 336 341 325 Michigan 780 1,214 1,248 1,231 1,211 1,132 589 386 401 336 Minnesota 164 287 322 338 355 379 276 193 167 90 Mississippi 33 58 74 85 86 82 60 18 32 19 Missouri 152 196 209 215 228 287 180 139 138 104 Montana 15 27 37 41 40 49 30 21 21 16 Nebraska 38 56 62 56 59 62 41 41 64 26 Nevada 8 10 16 20 27 48 39 28 32 47 New Hampshire 21 16 20 21 32 62 39 32 34 34 New Jersey 489 485 509 459 451 531 372 222 267 182 New Mexico 32 49 51 56 61 144 104 113 73 60 New York 1,689 1,916 2,099 2,140 2,259 2,913 2,149 1,554 1,586 1,458 North Carolina 138 149 138 206 247 353 211 140 119 89 North Dakota 14 16 20 22 24 26 22 12 12 9 Ohio 441 725 804 805 877 1,016 546 368 320 432 Oklahoma 74 85 100 119 132 165 72 78 43 22 Oregon 148 101 120 128 145 197 141 34 85 115 Pennsylvania 726 724 389 747 798 935 523 573 385 198 Rhode Island 59 71 79 82 99 136 117 105 79 45 South Carolina 52 75 103 91 96 115 52 91 18 40 South Dakota 18 17 15 21 22 25 14 10 11 14 Tennessee 77 83 100 125 168 215 108 146 120 128 Texas 122 229 281 344 416 544 315 248 213 84 Utah 41 52 55 61 64 77 50 40 45 33 Vermont 21 40 40 40 48 65 47 39 35 17 Virginia 136 165 179 169 177 253 123 186 112 74 Washington 175 294 375 401 438 610 450 312 322 318 West Virginia 53 75 109 107 110 126 52 49 69 32 Wisconsin 260 519 444 506 440 425 145 7 136 113 Wyoming 6 13 16 19 19 21 7 9 5 11 United States $10,621 $14,371 $15,236 $16,663 $18,543 $22,798 $14,614 $11,180 $10,368 $9,324 Note: Benefits refers to total cash benefits paid, (see Table TANF 4) but does not include emergency assistance payments. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Program Support, Office of Management Services, data from the ACF-196 TANF Report and ACF-231 AFDC Line by Line Report. A-15 Table TANF 9. Comparison of Federal Funding for AFDC and Related Programs and 2009 Total Family Assistance Grants Awarded Under PRWORA [In millions of dollars] State FY 1996 Grants for AFDC, EA & JOBS 1 FY 2009 Family Assistance Grants & Supplemental 2 FY 2009 Contingency Fund Awards 3 FY 2009 Total Awards Change from FY 1996 Level To FY 2009 Percent Change from FY 1996 Level Alabama $79.0 $104.4 \u2014 104.4 25.4 32 Alaska 60.7 70.5 \u2014 70.5 9.8 16 Arizona 200.6 246.3 40.0 302.3 101.7 51 Arkansas 54.3 63.0 11.3 74.3 20.0 37 California 3,545.6 3,733.8 \u2014 3,719.9 174.3 5 Colorado 138.9 149.6 24.9 174.6 35.6 26 Connecticut 221.1 266.8 \u2014 266.8 45.7 21 Delaware 30.2 32.3 6.5 38.7 8.5 28 Dist. of Columbia 77.1 92.6 \u2014 92.6 15.5 20 Florida 504.7 622.7 \u2014 622.7 118.0 23 Georgia 301.2 368.0 \u2014 368.0 66.8 22 Hawaii 98.4 98.9 11.5 110.4 12.1 12 Idaho 31.3 35.4 \u2014 35.4 4.1 13 Illinois 593.8 585.1 \u2014 585.1 -8.8 -1 Indiana 121.4 206.8 \u2014 206.8 85.4 70 Iowa 129.3 131.5 \u2014 131.0 1.7 1 Kansas 86.9 101.9 18.7 120.6 33.7 39 Kentucky 171.6 181.3 \u2014 181.3 9.6 6 Louisiana 122.4 181.0 \u2014 181.0 58.6 48 Maine 73.2 78.1 \u2014 78.1 4.9 7 Maryland 207.6 229.1 38.2 267.3 59.6 29 Massachusetts 372.0 459.4 91.9 551.2 179.2 48 Michigan 581.5 775.4 155.1 930.4 348.9 60 Minnesota 239.3 268.0 \u2014 267.9 28.6 12 Mississippi 68.6 95.8 \u2014 95.8 27.2 40 Missouri 207.9 217.1 \u2014 217.1 9.2 4 Montana 39.2 46.7 \u2014 46.7 7.5 19 Nebraska 56.2 58.0 \u2014 58.5 2.3 4 Nevada 41.2 47.7 6.6 68.3 27.0 66 New Hampshire 36.0 38.5 \u2014 38.5 2.5 7 New Jersey 353.4 404.0 \u2014 404.0 50.7 14 New Mexico 129.9 132.7 22.1 140.0 10.1 8 New York 2,332.7 2,442.9 407.2 2,850.1 517.4 22 North Carolina 311.9 338.3 60.4 398.8 86.9 28 North Dakota 24.5 26.4 \u2014 26.4 1.9 8 Ohio 564.5 728.0 \u2014 728.0 163.5 29 Oklahoma 125.1 148.0 \u2014 148.0 22.9 18 Oregon 146.4 167.9 \u2014 167.9 21.5 15 Pennsylvania 780.1 719.5 \u2014 719.5 -60.6 -8 Rhode Island 82.9 95.0 \u2014 95.0 12.2 15 South Carolina 99.4 100.0 20.0 120.0 20.5 21 South Dakota 19.7 21.9 \u2014 21.9 2.2 11 Tennessee 178.9 213.1 38.3 251.4 72.5 41 Texas 437.1 539.0 \u2014 539.0 101.9 23 Utah 68.0 85.5 15.1 99.4 31.5 46 Vermont 42.4 47.4 \u2014 47.4 5.0 12 Virginia 134.6 158.3 \u2014 158.3 23.6 18 Washington 393.2 404.3 76.1 480.5 87.3 22 West Virginia 95.1 110.2 \u2014 110.2 15.0 16 Wisconsin 241.6 318.2 62.9 381.1 139.5 58 Wyoming 14.4 21.8 \u2014 21.8 7.4 51 United States $15,067 $16,808 $1,107 $17,915 $2,848 19 1 Includes Administration and FAMIS but excludes IV-A child care. AFDC benefits include the Federal share of child support collections to be comparable to the Family Assistance Grant. The 1996 figures have been revised since earlier versions of this report, to reflect upward revisions in states’ reports of expenditures on the JOBS program. 2 The FY 2009 Family Assistance Grants and Supplemental differs from previous editions and includes the Tribal Family Assistance Grants. 3 Includes Contingency Fund Grants but not penalties assessed; does not include funds awarded from Emergency Contingency Fund. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Financial Services. A-16 Table TANF 10. AFDC\/TANF Peak Caseload by State: October 1989 to December 2009 [In thousands] State Peak Caseload Oct ’89 to Dec ’09 Date Peak Occurred Oct ’89 to Dec ’09 Sept ’96 AFDC Caseload Dec ’09 TANF & SSP Caseload Percent Decline f from Sept ’96 to Dec ’09 Percent Decline from the Peak to Dec ’09 Alabama 52.3 Mar-93 40.7 20.9 49 60 Alaska 13.4 Apr-94 12.3 3.1 75 77 Arizona 72.8 Dec-93 61.8 38.5 38 47 Arkansas 27.1 Mar-92 22.1 9.1 59 67 California 933.1 Mar-95 870.3 570.9 34 39 Colorado 43.7 Dec-93 33.6 11.4 66 74 Connecticut 61.9 Mar-95 57.1 17.4 70 72 Delaware 11.8 Apr-94 10.5 4.9 53 58 Dist. of Columbia 27.5 Apr-94 25.1 9.2 63 66 Florida 259.9 Nov-92 200.3 61.1 69 76 Georgia 142.8 Nov-93 120.9 21.4 82 85 Hawaii 23.4 Jun-97 21.9 8.7 60 63 Idaho 9.5 Mar-95 8.4 1.6 80 83 Illinois 243.1 Aug-94 217.8 21.8 90 91 Indiana 76.1 Sep-93 49.7 37.4 25 51 Iowa 40.7 Apr-94 31.1 21.4 31 47 Kansas 30.8 Aug-93 23.4 14.6 38 53 Kentucky 84.0 Mar-93 70.4 30.2 57 64 Louisiana 94.7 May-90 66.5 11.3 83 88 Maine 24.4 Aug-93 19.7 14.4 27 41 Maryland 81.8 May-95 68.9 25.6 63 69 Massachusetts 115.7 Aug-93 84.3 60.8 28 47 Michigan 233.6 Apr-91 167.5 70.1 58 70 Minnesota 66.2 Jun-92 57.2 22.9 60 65 Mississippi 61.8 Nov-91 45.2 12.6 72 80 Missouri 93.7 Mar-94 79.1 39.6 50 58 Montana 12.3 Mar-94 9.8 3.9 61 68 Nebraska 17.2 Mar-93 14.4 9.0 38 48 Nevada 16.3 Mar-95 13.2 10.1 24 38 New Hampshire 11.8 Apr-94 8.9 6.2 31 48 New Jersey 132.6 Nov-92 100.8 34.3 66 74 New Mexico 34.9 Nov-94 33.0 19.7 40 43 New York 463.7 Dec-94 412.7 156.7 62 66 North Carolina 134.1 Mar-94 107.5 25.7 76 81 North Dakota 6.6 Apr-93 4.7 2.2 54 68 Ohio 269.8 Mar-92 201.9 103.7 49 62 Oklahoma 51.3 Mar-93 35.3 9.9 72 81 Oregon 43.8 Apr-93 28.5 29.4 -3 33 Pennsylvania 212.5 Sep-94 180.1 52.0 71 76 Rhode Island 22.9 Apr-94 20.5 7.8 62 66 South Carolina 54.6 Jan-93 42.9 18.8 56 65 South Dakota 7.4 Apr-93 5.7 3.3 43 56 Tennessee 112.6 Nov-93 96.2 62.8 35 44 Texas 287.5 Dec-93 238.8 51.4 78 82 Utah 18.7 Mar-93 14.0 7.1 50 62 Vermont 10.3 Apr-92 8.7 3.3 62 68 Virginia 76.0 Apr-94 60.5 37.2 38 51 Washington 104.8 Feb-95 96.8 68.6 29 35 West Virginia 41.9 Apr-93 37.6 9.7 74 77 Wisconsin 82.9 Jan-92 49.9 20.2 60 76 Wyoming 7.1 Aug-92 4.3 0.3 92 95 United States 5,098 Mar-94 4,346 1,914 55 62 Note: these data do not include Tribal TANF families (about 8,000) in number). This makes little difference nationally, but in States like Wyoming, New Mexico, and Arizona, their exclusion under TANF overstates the real decline from AFDC years. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Division of Data Collection and Analysis. A-17 Table TANF 11. Average Monthly AFDC\/TANF Recipients by State: Selected Fiscal Years [In thousands] 1965 1970 1980 1990 1995 2000 2005 2009 Percent Change 1995-00 2000-09 Alabama 78 123 180 130 118 46 48 43 -61 -7 Alaska 5 8 15 20 37 22 12 8 -39 -63 Arizona 40 51 51 124 190 87 99 82 -54 -6 Arkansas 30 45 85 71 63 29 19 19 -54 -34 California 528 1,148 1,387 1,902 2,680 1,574 1,256 1,308 -41 -17 Colorado 42 66 77 102 109 29 38 23 -74 -21 Connecticut 59 83 139 120 171 73 53 33 -57 -54 Delaware 12 20 32 21 25 13 13 13 -47 -4 Dist. of Columbia 20 40 85 49 73 47 43 19 -36 -60 Florida 106 204 256 370 622 158 112 98 -75 -38 Georgia 71 198 221 293 383 129 91 38 -66 -70 Guam 1 2 5 4 8 10 11 3 31 -67 Hawaii 14 25 60 44 66 75 31 24 14 -67 Idaho 10 16 21 17 24 2 3 2 -90 3 Illinois 262 368 672 636 696 256 98 52 -63 -80 Indiana 48 73 157 154 189 103 136 103 -45 -0 Iowa 44 64 104 98 101 54 52 50 -46 -8 Kansas 36 53 68 77 80 32 46 33 -60 6 Kentucky 81 129 167 175 189 89 75 60 -53 -33 Louisiana 104 202 213 282 251 75 37 22 -70 -70 Maine 19 36 60 56 60 32 32 35 -46 7 Maryland 80 131 212 186 223 77 64 53 -65 -31 Massachusetts 94 208 350 263 274 102 104 138 -63 35 Michigan 162 253 685 655 598 207 215 158 -65 -24 Minnesota 51 76 135 171 180 116 87 47 -36 -59 Mississippi 83 115 173 179 144 34 35 23 -77 -31 Missouri 107 140 199 211 254 131 118 91 -48 -30 Montana 7 13 19 29 34 13 12 9 -62 -33 Nebraska 16 30 35 43 41 28 33 20 -33 -27 Nevada 5 12 12 23 41 16 19 21 -61 34 New Hampshire 4 9 22 16 28 14 15 12 -50 -14 New Jersey 104 286 459 309 316 138 114 77 -56 -44 New Mexico 30 51 53 57 104 72 45 43 -30 -41 New York 517 1,052 1,100 981 1,256 724 490 376 -42 -48 North Carolina 111 124 198 223 313 100 68 50 -68 -50 North Dakota 8 11 13 16 14 8 7 5 -48 -27 Ohio 183 266 513 632 612 245 179 201 -60 -18 Oklahoma 73 95 89 112 124 36 28 19 -71 -46 Oregon 31 75 102 89 104 39 44 62 -62 58 Pennsylvania 303 426 629 521 596 250 253 115 -58 -54 Puerto Rico 202 223 168 190 168 92 42 33 -45 -64 Rhode Island 24 38 52 46 61 50 35 20 -19 -59 South Carolina 30 52 153 111 129 41 43 40 -68 -4 South Dakota 11 16 20 19 17 7 6 6 -61 -9 Tennessee 76 129 162 211 276 147 191 152 -47 3 Texas 91 214 308 611 743 342 214 107 -54 -69 Utah 22 33 37 45 46 23 23 16 -50 -31 Vermont 5 12 23 22 27 16 13 7 -41 -59 Virgin Islands 1 2 3 3 5 3 1 1 -30 -58 Virginia 46 87 166 151 184 75 87 76 -59 1 Washington 71 109 154 228 286 168 144 144 -41 -14 West Virginia 116 93 77 111 105 32 31 20 -69 -37 Wisconsin 45 79 213 237 209 40 49 40 -81 -1 Wyoming 4 5 7 14 15 1 1 1 -92 -51 United States 4,323 7,415 10,597 11,460 13,659 6,324 5,118 4,254 -54 -33 Note: Recipients in 2000 and beyond include both TANF and SSP recipients. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. A-18 Table TANF 12. AFDC\/TANF Recipiency Rates for Total Population by State: Selected Fiscal Years [In percent] 1965 1970 1980 1990 1995 2000 2005 2009 Percent Change 1995-00 2000-09 Alabama 2.2 3.6 4.6 3.2 2.7 1.0 1.1 0.9 -62 -12 Alaska 1.8 2.6 3.7 3.7 6.1 3.6 1.8 1.2 -42 -67 Arizona 2.6 2.9 1.9 3.4 4.3 1.7 1.7 1.2 -61 -26 Arkansas 1.5 2.3 3.7 3.0 2.5 1.1 0.7 0.7 -56 -39 California 2.9 5.7 5.8 6.3 8.5 4.6 3.5 3.5 -45 -24 Colorado 2.2 3.0 2.6 3.1 2.8 0.7 0.8 0.5 -77 -32 Connecticut 2.1 2.7 4.5 3.6 5.1 2.1 1.5 0.9 -59 -56 Delaware 2.4 3.6 5.4 3.2 3.4 1.7 1.6 1.4 -51 -14 Dist. of Columbia 2.5 5.3 13.3 8.1 12.6 8.2 7.4 3.1 -35 -62 Florida 1.8 3.0 2.6 2.8 4.3 1.0 0.6 0.5 -77 -47 Georgia 1.6 4.3 4.0 4.5 5.2 1.6 1.0 0.4 -70 -75 Hawaii 1.9 3.2 6.2 3.9 5.5 6.1 2.5 1.9 12 -70 Idaho 1.4 2.2 2.2 1.6 2.0 0.2 0.2 0.2 -91 -13 Illinois 2.5 3.3 5.9 5.6 5.8 2.1 0.8 0.4 -65 -80 Indiana 1.0 1.4 2.9 2.8 3.2 1.7 2.2 1.6 -47 -5 Iowa 1.6 2.3 3.6 3.5 3.5 1.9 1.8 1.7 -47 -10 Kansas 1.6 2.4 2.9 3.1 3.1 1.2 1.7 1.2 -62 1 Kentucky 2.5 4.0 4.6 4.7 4.9 2.2 1.8 1.4 -55 -37 Louisiana 2.9 5.6 5.0 6.7 5.7 1.7 0.8 0.5 -71 -70 Maine 1.9 3.6 5.4 4.5 4.8 2.5 2.5 2.6 -47 4 Maryland 2.2 3.3 5.0 3.9 4.4 1.5 1.2 0.9 -67 -36 Massachusetts 1.8 3.7 6.1 4.4 4.5 1.6 1.6 2.1 -64 31 Michigan 2.0 2.9 7.4 7.0 6.2 2.1 2.1 1.6 -66 -24 Minnesota 1.4 2.0 3.3 3.9 3.9 2.3 1.7 0.9 -39 -62 Mississippi 3.6 5.2 6.9 6.9 5.3 1.2 1.2 0.8 -78 -33 Missouri 2.4 3.0 4.0 4.1 4.7 2.3 2.0 1.5 -51 -35 Montana 1.0 1.9 2.4 3.6 3.9 1.4 1.3 0.9 -63 -38 Nebraska 1.1 2.0 2.2 2.7 2.5 1.6 1.9 1.1 -35 -30 Nevada 1.2 2.4 1.5 1.9 2.6 0.8 0.8 0.8 -70 2 New Hampshire 0.7 1.2 2.4 1.5 2.4 1.1 1.1 0.9 -53 -20 New Jersey 1.5 4.0 6.2 4.0 3.9 1.6 1.3 0.9 -58 -46 New Mexico 3.0 5.0 4.1 3.8 6.0 4.0 2.4 2.1 -34 -46 New York 2.9 5.8 6.3 5.4 6.8 3.8 2.5 1.9 -44 -50 North Carolina 2.2 2.4 3.4 3.4 4.3 1.2 0.8 0.5 -71 -57 North Dakota 1.2 1.7 2.0 2.4 2.2 1.2 1.2 0.8 -47 -28 Ohio 1.8 2.5 4.8 5.8 5.5 2.2 1.6 1.7 -61 -19 Oklahoma 3.0 3.7 2.9 3.6 3.7 1.0 0.8 0.5 -72 -50 Oregon 1.6 3.6 3.9 3.1 3.3 1.1 1.2 1.6 -65 42 Pennsylvania 2.6 3.6 5.3 4.4 4.9 2.0 2.1 0.9 -58 -55 Rhode Island 2.7 4.0 5.5 4.6 6.0 4.7 3.2 1.9 -22 -59 South Carolina 1.2 2.0 4.9 3.2 3.4 1.0 1.0 0.9 -70 -15 South Dakota 1.6 2.4 2.9 2.7 2.3 0.9 0.8 0.8 -61 -16 Tennessee 2.0 3.3 3.5 4.3 5.2 2.6 3.2 2.4 -50 -7 Texas 0.9 1.9 2.1 3.6 3.9 1.6 0.9 0.4 -58 -74 Utah 2.2 3.1 2.5 2.6 2.3 1.0 0.9 0.6 -55 -45 Vermont 1.4 2.6 4.4 3.9 4.6 2.7 2.0 1.1 -43 -59 Virginia 1.0 1.9 3.1 2.4 2.8 1.1 1.2 1.0 -61 -9 Washington 2.4 3.2 3.7 4.7 5.2 2.8 2.3 2.2 -45 -24 West Virginia 6.4 5.3 4.0 6.2 5.7 1.8 1.7 1.1 -69 -37 Wisconsin 1.1 1.8 4.5 4.8 4.0 0.8 0.9 0.7 -81 -6 Wyoming 1.1 1.5 1.4 3.1 3.0 0.2 0.1 0.1 -92 -56 United States 2.1 3.5 4.6 4.5 5.1 2.2 1.7 1.4 -56 -38 Note: Recipiency rate refers to the average monthly number of AFDC recipients in each state during the given fiscal year expressed as a percent of the total resident population as of July 1 of that year. The numerators are from Table TANF 11. Sources: U. S. Department of Health and Human Services and U.S. Census Bureau (resident population by state available online at http:\/\/www.census.gov\/popest\/states\/). http:\/\/www.census.gov\/popest\/states\/\ufffd A-19 Table TANF 13. Average Number of AFDC\/TANF Child Recipients by State: Selected Fiscal Years [In thousands] 1965 1970 1980 1990 1995 2000 2005 2009 Percent Change 1995-00 2000-09 Alabama 62 96 129 93 87 37 37 33 -57 -11 Alaska 4 6 10 13 24 15 8 6 -36 -62 Arizona 31 39 38 87 130 66 73 62 -49 -7 Arkansas 23 34 62 51 45 22 14 14 -52 -36 California 391 816 932 1,294 1,833 1,163 1,002 1,031 -37 -11 Colorado 33 50 53 69 74 22 28 18 -71 -19 Connecticut 43 62 97 81 114 50 37 23 -56 -54 Delaware 9 15 22 14 17 9 10 8 -45 -15 Dist. of Columbia 16 31 59 34 51 34 32 14 -32 -60 Florida 85 160 184 264 432 124 91 79 -71 -37 Georgia 54 150 161 206 269 101 74 35 -63 -65 Guam 1 1 4 3 5 na na 2 na na Hawaii 10 18 40 29 43 50 21 17 16 -66 Idaho 7 11 14 11 16 2 3 2 -88 18 Illinois 202 283 473 436 478 193 78 48 -59 -75 Indiana 36 55 111 105 129 74 102 77 -43 4 Iowa 32 46 69 64 66 36 34 34 -45 -5 Kansas 28 41 49 52 55 23 31 23 -58 0 Kentucky 58 93 118 117 128 64 56 47 -50 -27 Louisiana 79 157 156 199 173 59 31 20 -66 -66 Maine 14 26 40 35 38 22 22 23 -42 4 Maryland 61 100 145 124 152 56 47 39 -63 -30 Massachusetts 71 153 228 168 176 73 72 93 -59 28 Michigan 119 190 460 427 398 153 157 119 -62 -22 Minnesota 39 58 91 110 121 81 61 36 -33 -55 Mississippi 66 93 128 129 106 27 26 18 -75 -34 Missouri 82 106 135 139 175 94 81 63 -47 -33 Montana 6 10 13 19 22 9 8 6 -61 -29 Nebraska 12 23 25 29 29 20 23 16 -32 -20 Nevada 4 9 8 16 29 12 14 16 -58 33 New Hampshire 3 7 15 11 18 10 10 9 -47 -10 New Jersey 79 209 318 213 213 102 81 55 -52 -46 New Mexico 23 39 35 37 67 51 32 32 -25 -38 New York 380 759 759 658 811 491 343 273 -39 -44 North Carolina 83 94 141 152 211 76 54 41 -64 -46 North Dakota 6 8 9 10 10 5 5 4 -43 -26 Ohio 136 198 348 414 415 180 136 149 -57 -17 Oklahoma 55 71 65 77 86 28 22 16 -68 -43 Oregon 23 52 65 60 71 29 33 43 -59 51 Pennsylvania 217 307 432 345 403 184 179 88 -54 -52 Puerto Rico 161 166 118 130 114 64 29 22 -44 -65 Rhode Island 18 27 36 30 41 34 24 14 -17 -58 South Carolina 24 40 109 80 96 32 32 30 -67 -5 South Dakota 8 12 15 13 12 5 5 5 -56 -5 Tennessee 58 99 115 144 190 107 136 110 -43 2 Texas 68 162 225 428 522 252 172 93 -52 -63 Utah 16 23 24 31 31 16 17 11 -47 -33 Vermont 4 8 14 14 17 10 8 5 -39 -55 Virgin Islands 1 2 2 2 3 2 1 1 -33 -57 Virginia 35 66 116 104 128 55 61 54 -57 -1 Washington 50 76 97 148 184 115 101 98 -38 -14 West Virginia 80 65 58 68 67 22 22 15 -67 -33 Wisconsin 34 60 142 158 146 34 39 33 -77 -3 Wyoming 3 4 5 9 10 1 0 0 -91 -50 United States 3,242 5,483 7,320 7,755 9,280 4,598 3,818 3,222 -50 -30 Note: From FY 2000 onward, TANF child recipients include both TANF and SSP child recipients. Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. A-20 Table TANF 14. AFDC\/TANF Recipiency Rates for Children by State: Selected Fiscal Years 1965 2009 [In percent] 1965 1970 1980 1990 1995 2000 2005 2009 Percent Change 1995-00 2000-09 Alabama 4.6 7.7 11.1 8.8 8.0 3.3 3.4 2.9 -59 -11 Alaska 3.1 5.0 8.0 7.4 12.6 7.9 4.4 3.1 -37 -60 Arizona 4.8 6.0 4.8 8.6 11.0 4.8 4.7 3.6 -56 -26 Arkansas 3.1 5.2 9.3 8.2 7.0 3.2 2.1 2.0 -53 -39 California 6.0 12.3 14.6 16.2 20.9 12.6 10.6 10.9 -40 -13 Colorado 4.4 6.4 6.5 7.8 7.6 2.0 2.4 1.4 -74 -27 Connecticut 4.4 6.1 11.8 10.8 14.4 6.0 4.4 2.9 -58 -52 Delaware 4.7 7.5 13.4 8.7 9.6 4.8 4.9 3.8 -50 -20 Dist. of Columbia 6.0 13.8 40.9 30.7 44.6 30.1 28.4 12.2 -33 -59 Florida 4.3 7.6 7.8 8.8 12.9 3.4 2.3 1.9 -74 -43 Georgia 3.2 9.1 9.8 11.8 14.0 4.6 3.1 1.4 -67 -71 Hawaii 3.6 6.5 14.5 10.5 14.2 17.1 7.2 5.8 20 -66 Idaho 2.7 4.2 4.7 3.6 4.7 0.5 0.7 0.5 -89 4 Illinois 5.3 7.5 14.6 14.8 15.3 6.0 2.4 1.5 -61 -75 Indiana 2.0 3.0 6.9 7.3 8.7 4.7 6.5 4.9 -46 3 Iowa 3.2 4.7 8.4 8.8 9.1 4.9 4.8 4.8 -46 -2 Kansas 3.5 5.4 7.5 7.9 8.0 3.2 4.5 3.2 -60 1 Kentucky 4.9 8.3 10.9 12.4 13.1 6.5 5.6 4.6 -51 -28 Louisiana 5.5 11.3 11.8 16.5 14.1 4.8 2.7 1.8 -66 -64 Maine 3.9 7.7 12.5 11.5 12.4 7.3 7.6 8.4 -42 16 Maryland 4.6 7.3 12.4 10.6 12.0 4.1 3.4 2.9 -65 -30 Massachusetts 3.8 8.1 15.3 12.4 12.3 4.8 4.9 6.5 -61 34 Michigan 3.7 5.8 16.7 17.4 15.7 5.9 6.3 5.1 -62 -14 Minnesota 2.9 4.2 7.7 9.4 9.8 6.3 4.9 2.9 -36 -54 Mississippi 7.0 11.1 15.7 17.6 14.0 3.5 3.4 2.3 -75 -33 Missouri 5.2 6.9 9.9 10.6 12.7 6.6 5.7 4.4 -48 -33 Montana 2.0 4.0 5.7 8.4 9.5 3.7 3.8 2.8 -60 -25 Nebraska 2.3 4.4 5.5 6.8 6.5 4.3 5.1 3.5 -33 -20 Nevada 2.5 5.2 3.8 5.0 7.3 2.3 2.3 2.3 -68 1 New Hampshire 1.4 2.6 5.8 3.9 6.2 3.1 3.3 3.0 -50 -4 New Jersey 3.4 8.8 16.0 11.7 10.8 4.9 3.9 2.7 -55 -45 New Mexico 5.2 9.5 8.5 8.3 13.5 10.0 6.5 6.2 -26 -38 New York 6.3 13.0 16.2 15.4 17.9 10.5 7.5 6.2 -41 -41 North Carolina 4.4 5.3 8.5 9.3 11.7 3.9 2.5 1.8 -67 -53 North Dakota 2.3 3.6 4.7 6.0 5.7 3.4 3.6 2.8 -40 -18 Ohio 3.6 5.3 11.2 14.9 14.6 6.2 4.9 5.5 -57 -12 Oklahoma 6.4 8.5 7.6 9.1 9.8 3.1 2.5 1.7 -68 -45 Oregon 3.3 7.4 9.0 8.1 8.8 3.4 3.9 5.0 -62 47 Pennsylvania 5.5 8.0 13.8 12.3 13.9 6.3 6.3 3.2 -55 -50 Rhode Island 5.9 9.1 14.7 13.4 17.1 13.5 10.1 6.2 -21 -54 South Carolina 2.3 4.2 11.6 8.7 10.1 3.1 3.1 2.8 -69 -11 South Dakota 3.1 5.0 7.1 6.7 6.0 2.7 2.6 2.6 -55 -4 Tennessee 4.2 7.5 8.9 11.8 14.5 7.7 9.5 7.4 -47 -4 Texas 1.7 4.1 5.2 8.7 9.7 4.3 2.7 1.3 -56 -69 Utah 3.7 5.4 4.4 4.9 4.5 2.3 2.1 1.3 -50 -44 Vermont 2.7 5.4 9.9 9.5 11.5 7.0 5.9 3.7 -39 -47 Virginia 2.2 4.1 7.9 6.8 7.9 3.1 3.4 2.9 -60 -7 Washington 4.7 6.5 8.5 11.3 13.0 7.6 6.7 6.3 -42 -17 West Virginia 12.2 11.2 10.4 15.7 15.7 5.5 5.6 3.9 -65 -30 Wisconsin 2.2 3.8 10.5 12.1 10.8 2.5 2.9 2.5 -77 2 Wyoming 2.1 3.2 3.4 7.0 7.5 0.7 0.4 0.4 -90 -51 United States 4.4 7.6 11.3 11.9 13.4 6.3 5.2 4.3 -53 -32 Note: Recipiency rate refers to the average monthly number of AFDC child recipients in each State during the given fiscal year as a percent of the resident population under 18 years of age as of July 1 of that year. The numerators are from Table TANF 13. Sources: U. S. Department of Health and Human Services and U.S. Census Bureau (resident population by state and age available online at http:\/\/www.census.gov\/popest\/states\/). http:\/\/www.census.gov\/popest\/states\/\ufffd A-21 Table TANF 15. TANF and Separate State Program (SSP) Average Monthly Families and Recipients: FY 2009 [In thousands] Families All Recipients Child Recipients TANF SSP Total TANF SSP Total TANF SSP Total Alabama 18.4 18.4 43.2 43.2 33.1 33.1 Alaska 3.0 3.0 8.3 8.3 5.8 5.8 Arizona 37.9 37.9 82.1 82.1 61.8 61.8 Arkansas 8.5 8.5 19.2 19.2 14.0 14.0 California 532.9 532.9 1,307.8 1,307.8 1,030.8 1,030.8 Colorado 9.3 9.3 22.8 22.8 17.7 17.7 Connecticut 16.7 16.7 33.0 33.0 23.5 23.5 Delaware 4.5 4.5 12.8 12.8 7.9 7.9 D.C. 8.0 8.0 18.6 18.6 13.9 13.9 Florida 55.1 55.1 97.6 97.6 78.9 78.9 Georgia 21.1 21.1 38.0 38.0 35.1 35.1 Guam 1.4 1.4 3.3 3.3 2.4 2.4 Hawaii 7.9 0.6 8.5 21.6 2.7 24.2 15.0 1.8 16.9 Idaho 1.6 1.6 2.4 2.4 2.2 2.2 Illinois 19.6 19.6 52.4 52.4 47.9 47.9 Indiana 40.0 40.0 103.2 103.2 77.2 77.2 Iowa 16.2 3.6 19.7 40.7 9.3 50.1 28.2 6.1 34.3 Kansas 13.1 13.1 33.4 33.4 22.8 22.8 Kentucky 29.5 29.5 59.6 59.6 46.9 46.9 Louisiana 10.2 10.2 22.5 22.5 19.7 19.7 Maine 10.6 2.9 13.5 24.9 9.8 34.6 16.7 6.1 22.8 Maryland 22.4 0.0 22.4 53.3 0.0 53.3 39.2 0.0 39.2 Massachusetts 47.3 14.6 61.9 93.3 44.4 137.7 63.3 29.3 92.6 Michigan 62.2 62.2 157.5 157.5 118.9 118.9 Minnesota 21.8 21.8 47.2 47.2 36.2 36.2 Mississippi 11.3 11.3 23.5 23.5 17.8 17.8 Missouri 35.0 2.9 37.9 84.1 7.3 91.4 58.4 4.4 62.8 Montana 3.4 3.4 8.7 8.7 6.1 6.1 Nebraska 7.4 0.9 8.2 17.8 2.5 20.3 14.0 1.7 15.6 Nevada 8.3 0.0 8.3 21.2 0.0 21.3 15.9 0.0 15.9 New Hampshire 5.6 0.0 5.6 12.0 0.1 12.1 8.6 0.1 8.6 New Jersey 32.5 32.5 77.3 77.3 54.9 54.9 New Mexico 16.1 16.1 42.7 42.7 31.5 31.5 New York 116.7 34.4 151.1 259.7 116.1 375.9 195.4 77.8 273.2 North Carolina 25.7 25.7 50.1 50.1 41.3 41.3 North Dakota 2.2 2.2 5.5 5.5 4.0 4.0 Ohio 90.1 90.1 201.4 201.4 148.9 148.9 Oklahoma 8.7 8.7 19.2 19.2 15.8 15.8 Oregon 21.9 3.2 25.1 52.6 9.1 61.7 37.6 5.8 43.5 Pennsylvania 48.0 48.0 115.4 115.4 87.8 87.8 Puerto Rico 12.2 12.2 32.8 32.8 22.2 22.2 Rhode Island 8.4 0.1 8.5 20.3 0.2 20.5 13.9 0.1 14.0 South Carolina 17.1 17.1 39.7 39.7 30.3 30.3 South Dakota 3.0 3.0 6.1 6.1 5.2 5.2 Tennessee 58.1 0.8 58.9 148.8 3.2 152.0 108.1 1.9 109.9 Texas 48.1 48.1 107.3 107.3 92.7 92.7 Utah 6.0 0.2 6.2 15.0 0.6 15.6 10.5 0.4 10.9 Vermont 2.9 0.1 3.0 6.3 0.4 6.7 4.5 0.2 4.7 Virgin Islands 0.5 0.5 1.4 1.4 1.0 1.0 Virginia 32.3 1.4 33.7 72.7 3.4 76.2 52.3 1.7 54.0 Washington 58.5 3.2 61.7 140.7 3.3 144.0 98.4 98.4 West Virginia 9.2 9.2 20.5 20.5 14.9 14.9 Wisconsin 18.3 0.2 18.5 39.4 0.8 40.2 32.7 0.5 33.1 Wyoming 0.3 0.3 0.6 0.6 0.5 0.5 U.S. Total 1,727 69 1,796 4,041 213 4,254 3,084 138 3,222 Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance. A-22 SNAP The Supplemental Nutrition Assistance Program (SNAP) (formerly the Food Stamp Program)7 is administered by the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service. SNAP is the largest food assistance program in the country, reaching more poor individuals over the course of a year than any other public assistance program. Unlike other public assistance programs, SNAP has few categorical requirements for eligibility, such as the presence of children, elderly, or disabled individuals in a household. As a result, the program offers assistance to a large and diverse population of needy persons, many of whom are not eligible for other forms of assistance. SNAP was designed primarily to supplement the food purchasing power of eligible low-income households so they can buy a nutritionally adequate low-cost diet. Participating households are expected to be able to devote 30 percent of their counted monthly cash income (after adjusting for various deductions) to food purchases. SNAP benefits then make up the difference between the household’s expected contribution to its food costs and an amount judged to be sufficient to buy an adequate low-cost diet. This amount, the maximum food stamp benefit level, is derived from USDA’s lowest-cost food plan, the Thrifty Food Plan (TFP). The federal government is responsible for the rules that govern the program, and with limited variations, these rules are nationally uniform, as are the benefit levels. Nonetheless, states, the District of Columbia, Guam, and the Virgin Islands, through their local welfare offices, have primary responsibility for the day- to-day administration of the program. They determine eligibility, calculate benefits, and issue SNAP allotments. The Food Stamp Act provides 100 percent federal funding of SNAP benefits. States and other jurisdictions have responsibility for about half the cost of state and local SNAP agency administration. In addition to the regular SNAP, the Food Stamp Act authorizes alternative programs in Puerto Rico, the Northern Mariana Islands, and American Samoa. The largest of these, the Nutrition Assistance Program (NAP) in Puerto Rico, was funded under a federal block grant of nearly $2.0 billion in 2009. Unless noted otherwise, the SNAP caseload and expenditure data in this Appendix exclude costs for the Nutrition Assistance Program (NAP) in Puerto Rico. (Prior to 2004, editions of this Appendix included NAP, but caseload and expenditure data in this Appendix are now limited to the SNAP, to be consistent with SNAP data published by the USDA.) The SNAP is available to nearly all financially needy households. To be eligible for SNAP, a household must meet eligibility criteria for gross and net income, asset holdings, work requirements, and citizenship or immigration status. The SNAP benefit unit is the household. Generally, individuals living together constitute a household if they customarily purchase and prepare meals together. The income, expenses and assets of the household members are combined to determine program eligibility and benefit allotment. Certain households are categorically eligible for SNAP and therefore not subject to income or asset limits. Households are categorically eligible if all of their members receive SSI, cash or in-kind TANF benefits, or General Assistance. States have options on which in-kind TANF programs can confer categorical eligibility. Monthly income is the most important determinant of household eligibility. Except for categorically- eligible households, or households containing elderly or disabled members, gross income cannot exceed 130 percent of poverty. After certain amounts are deducted for living expenses, working expenses, dependent care expenses, excess shelter expenses, child support payment, and – for elderly\/disabled households – medical expenses, net income cannot exceed 100 percent of poverty. Non categorically- eligible households also must not have more than $2,000 in assets comprised of cash, savings, stocks and bonds, and in some states some vehicles. (States have the option of using the federal rules for vehicles, or, in cases where TANF rules are more generous, TANF vehicle rules.) Households with an 7 The Food, Conservation and Energy Act of 2008 (P.L. 110-246) re-named the Food Stamp Program as the Supplemental Nutrition Assistance Program (SNAP) as of October 1, 2008. The name change had no effect on the type of benefits or how they are made available to eligible households. We use the name SNAP throughout this section. A-23 elderly or disabled member can have up to $3,000 in countable assets. (The Food and Nutrition Act of 2008, (Public Law 110-246) provided that beginning in 2008 the resource limits will be indexed to inflation, rounded down to the nearest $250 increment each fiscal year.) All nonexempt adult applicants for SNAP must register for work. To maintain eligibility, they must accept a suitable job, if offered one, and fulfill any work, job search, or training requirements established by the SNAP office. Nondisabled adults living in households without children can receive benefits for three months only, unless they work or participate in work-related activities. Participation is restricted for certain groups, including students, strikers, and people who are institutionalized. Legal immigrants who are disabled, under age 18, were admitted as refugees or granted asylum, or have at least five years of legal U.S. residency are eligible; all other noncitizens are not. SNAP benefits are a function of a household’s size, its net monthly income, and maximum monthly benefit levels. Allotments are not taxable and SNAP purchases may not be charged sales taxes. Receipt of SNAP does not affect eligibility for or benefits provided by other welfare programs, although some programs use SNAP participation as a trigger for eligibility and others take into account the general availability of SNAP in deciding what level of benefits to provide. Legislative Changes Title IV and subtitle A of title VIII of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) made major changes to the Food Stamp Program, including strong work requirements on able-bodied adults without dependent children, restricted eligibility of legal immigrants, and a reduction in maximum benefits. These three provisions, and subsequent amendments, are discussed below; their impact on program participation and expenditures begins to appear in food stamp administrative data for 1997, with the fuller impact shown in data for 1998 and beyond. First, a work requirement was added for able-bodied adult food stamp recipients without dependents (ABAWDs). Unless exempt, ABAWDs between the ages of 18 and 59 are not eligible for benefits for more than 3 months in every 36-month period unless they are: (1) working at least 20 hours a week; (2) participating in and complying with a work program for at least 20 hours a week; or (3) participating in and complying with a workfare program. Under the original legislation, the Department of Agriculture was authorized to waive application of the work requirement to any group of individuals at the request of the state agency, if a determination was made that the area where they reside has an unemployment rate over 10 percent or does not have a sufficient number of jobs to provide them employment. The provision was further moderated under the Balanced Budget Act of 1997 (Public Law 105-33), which allowed states to exempt up to 15 percent of the ABAWD caseload (beyond those subject to waivers) and which increased funds for the food stamp employment and training program for the creation of job slots for able- bodied adults subject to time limits. Separately, title IV of PRWORA (Public Law 104-193) made significant changes in the eligibility of noncitizens for food stamp benefits. As first enacted, most qualified aliens, including legal immigrants (illegal aliens and nonimmigrant visitors were already ineligible) were barred from receiving SNAP until citizenship or until they had attained 40 quarters of work history. Subsequently, the Agriculture Research, Extension and Education Reform Act of 1998 (Public Law 105-185) restored food stamp eligibility to certain groups of qualified aliens who were legally residing in the United States before passage of PRWORA on August 22, 1996 and were over 65 years of age on that date or were under age 18 or disabled. Finally, the 1996 legislation restrained growth in future program expenditures by making changes in the benefit structure for eligible participants, including a reduction in the maximum food stamp allotment. Other provisions of the 1996 act disqualified from eligibility those convicted of drug-related felonies and gave states the option to disqualify individuals, both custodial and non-custodial parents, from SNAP when they do not cooperate with child support agencies or are in arrears in their child support. Between 1996 and 2001, regulatory and legislative changes were made to increase access to SNAP among working poor families. Regulatory changes announced in July 1999 and expanded in November 2000 allowed states to reduce reporting requirements and made it easier for working families to report income changes on a semiannual basis. Under the November 2000 regulations, states also were given A-24 the option of providing a three-month transitional food stamp benefit to most families leaving TANF. Regulations that went into effect in 2001 expanded categorical eligibility to those receiving noncash TANF benefits, excluded vehicles with little equity from the assets test, and eliminated the equity test for most vehicles. In addition, the Agriculture Appropriations Bill for 2001 (Public Law 106-387) provided states with the option of liberalizing the treatment of vehicle assets to align with the states’ TANF rules on vehicle eligibility. These changes were intended to address concerns that some of the decline in food stamp caseloads may be leaving poor families without nutritional assistance as they make the transition from welfare dependence to full self-sufficiency. The Farm Security and Rural Investment Act of 2002 also known as the 2002 Farm Bill (Public Law 107-171) reauthorized the SNAP through fiscal year 2007. This law brought a number of significant changes to the program, including some that supersede earlier changes made through PRWORA and subsequent SNAP legislation and regulations. Specifically, the 2002 Farm Bill restores food stamp eligibility to legal immigrants who have lived in the country at least five years and to legal immigrants receiving disability benefits, regardless of entry date. Legal immigrants under age 18 also are eligible for SNAP regardless of entry date. Effective in fiscal year 2004, the requirement that income and resources of an immigrant’s sponsor be counted in determining the eligibility and benefit amounts for immigrant children was eliminated. Each provision became effective at a different time, but all restorations were in effect by October 1, 2003. The 2002 Farm Bill also increased the asset limit from $2,000 to $3,000 for households with a disabled member, making it consistent with the limit for households with elderly, and replaced the fixed standard deduction with a deduction that varies according to household size and is indexed to cost-of-living increases, in recognition of the higher expenses larger households incur. For households in the 48 contiguous states and DC, Alaska, Hawaii and the Virgin Islands, the deduction is set at 8.31 percent of the applicable net income limit based on household size. (Households in Guam will receive a slightly higher deduction.) No household receives an amount less than the previous fixed standard deduction or more than the standard deduction for a household of six. Other 2002 Farm Bill changes include the authorization of $5 million per year for education and outreach grants to help inform the low-income public of their eligibility for SNAP, and increased flexibility for states in spending Employment and Training program funds to promote work. States also are now allowed to extend from three months to up to five months the period of time households may receive transitional food stamp benefits when they lose TANF cash assistance. Benefits are equal to the amount the household received prior to termination of TANF with adjustments in income for the loss of TANF. This change helps individuals moving off cash assistance to make the transition from welfare to work. The 2002 Farm Bill also implemented a number of administrative reforms and program simplifications, including: changing the quality control system so that only those states with persistently high error rates will face liabilities; awarding bonuses to states that improve the quality and accuracy of their service; allowing states to exclude certain types of income and resources not counted under TANF or Medicaid, such as educational assistance, when determining SNAP eligibility; allowing states to deem child support payments as income exclusions rather than deductions as an incentive for parents to pay child support; allowing states to simplify the standard utility allowance (SUA) if the state elects to use the SUA rather than actual utility costs for all households, thus reducing administrative burden, costs and errors; permitting states to use a standard deduction from income of $143 per month for homeless households with some shelter expenses; allowing states to extend simplified reporting procedures to all households, not just households with earnings; eliminating the requirement that the Electronic Benefit Transfer (EBT) system be cost-neutral to the federal government to help support the EBT conversion process; allowing USDA to use alternative methods for issuing SNAP benefits during times of disaster when use of EBT is impractical; requiring food stamp applications be made available through the Internet; and A-25 combining Puerto Rico and American Samoa’s block grants into one grant and indexing both with inflation. The Food, Conservation and Energy Act of 2008 also known as the 2008 Farm Bill (P.L. 110-246) reauthorized the SNAP program through fiscal year 2012. It renamed the Food Stamp Program to SNAP, and brought a number of significant changes to the program: Raised the minimum standard deduction for households with one to three members from $134 to $144 effective FY 2009, with annual inflation adjustments. Removed the cap on the dependent care deduction. Raised the minimum benefit that one and two person households received from $10 a month to 8 percent of the Thrifty Food Plan (TFP) for a household of one. Excluded special pay received by service members deployed to a combat zone from countable income. Began adjusting the resource limits for inflation, rounded down to the nearest $250. Excluded tax-preferred retirement and educational savings accounts from the resource limit. The American Recovery and Reinvestment Act of 2009 also known as ARRA (P.L. 111-5) increased the maximum allotment to 113.6 percent of the cost of the June 2008 Thrifty Food Plan. The legislation originally froze it at that level until the cost of the Thrifty Food Plan increased to that level. However, in August 2010, Congress passed and the President signed P.L. 111-226, which accelerated the sunset of the ARRA benefit increase to April 2014 and used the estimated savings to provide additional federal funding for education jobs and maintaining a higher federal match for Medicaid costs. Four months later, the Healthy Hunger-Free Kids Act (P.L. 111-296), which reauthorized the Child Nutrition programs, further accelerated the sunset date of ARRA to October 31, 2013, to offset the cost of that legislation. As a result, beginning on November 1, 2013, SNAP benefit levels will be based on the cost of the June 2013 TFP, which is expected to be lower than ARRA levels. ARRA also suspended time-limited benefits for nonelderly nondisabled adults without dependents until September 2010. SNAP Data The following six tables and accompanying figure provide information about SNAP: Tables SNAP 1 and SNAP 2 and Figure SNAP 1 present national caseload and expenditure trend data on the SNAP as discussed below; Table SNAP 3 presents some demographic characteristics of the SNAP caseload; and Tables SNAP 4 through SNAP 6 present some state-by-state trend data on the SNAP through fiscal year 2009. SNAP Caseload Trends (Table SNAP 1). Average monthly SNAP participation was 32.8 million persons in fiscal year 2009, excluding the participants in Puerto Rico’s block grant. This represents a significant increase over the fiscal year 2000 record-low average of 17.1 million participants and exceeds the previous peak of 27.4 million recipients in fiscal year 1994. See also Table IND 3b and Table IND 4b in Chapter II for further data trends in SNAP caseload, specifically, SNAP recipiency and participation rates. Considerable research has demonstrated that the SNAP is responsive to economic changes, with participation increasing in times of economic downturns and decreasing in times of economic growth (see Figure SNAP 1). Economic conditions alone did not explain the caseload growth in the late 1980s and early 1990s however. Studies suggest that a variety of factors contributed to this caseload growth, including a weak economy and higher rates of unemployment, expansions in Medicaid eligibility, the legalization of 3 million undocumented immigrants, and longer participation spells (McConnell, 1991; Gleason, 1998). The decline in participation from 1994 to 2000 was caused by several factors, according to studies of this period. Part of the decline is associated with the strong economy in the second half of the 1990s. However, participation fell more sharply than expected during this period of sustained economic growth. A-26 Some of the decline reflected restrictions on the eligibility of noncitizens and time limits for unemployed nondisabled childless adults. Participation fell most rapidly among the following three groups: noncitizens and their US-born children, unemployed nondisabled childless adults, and persons receiving cash welfare benefits. As people left the welfare rolls, many also stopped participating in SNAP, even while remaining eligible (Genser, 1999; Wilde et al., 2000; Gleason et al., 2001; Kornfeld, 2002). The increase in SNAP participation from 2000 to 2005 occurred during a period when unemployment increased modestly from four percent to five percent, eligibility was restored to many legal immigrants, states took advantage of opportunities to expand categorical eligibility to those receiving noncash TANF benefits and services and to liberalize the treatment of vehicles, and the Food and Nutrition Service was encouraging states to conduct outreach efforts and simplify the program. In response to outreach efforts and the 2007-2009 recession, by 2009 the SNAP participation rate exceeded 72 percent. Between 2000 and 2009, SNAP participation increased by 6.1 million households (see Table IND 4b). Part of this increase was associated with an increase in the number of eligible households and part was associated with an increased participation rate among those households that were eligible. SNAP Expenditures. Total program costs, shown in Table SNAP 2, were nearly $16 billion higher in 2009 than in 2008, reflecting the increase in participation during that period as well as an increase in average benefits. Total federal program costs were $53.6 billion in 2009, $37.5 billion in 2008, and $34.5 billion in 2007 (after adjusting for inflation). Average monthly benefits per person, also shown in Table SNAP 2, were $125.30 per person in 2009, $101.90 in 2008 and $100.10 in 2007 (after adjusting for inflation). The monthly benefit per person increased 23 percent between 2008 and 2009. SNAP Household Characteristics. As shown in Table SNAP 3, the proportion of SNAP households with earnings has increased, from about 20 percent for most of the 1980s and early 1990s, to 29 percent in 2009. At the same time, the proportion of households with income from AFDC\/TANF has declined, from 42 percent in 1990 to 10 percent in 2009, following the dramatic decline in AFDC\/TANF caseloads. Over half of all SNAP households have children, although the proportion has declined from over 60 percent in most of the 1980s and early 1990s to 50 percent in 2009. The majority (86 percent in 2009) of households have incomes below the federal poverty guidelines. A-27 Figure SNAP 1. Persons Receiving SNAP: 1962 2009 Note: Total persons includes participants receiving assistance in Guam and the Virgin Islands. Shaded areas are periods of recession as determined by the National Bureau of Economic Research. Sources: U.S. Department of Agriculture, Food and Nutrition Service, published online at www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf and unpublished data from the Food Stamps National Data Bank. 12\/69 11\/70 11\/73 3\/75 1 7\/80 7\/81 11\/82 7\/90 4\/91 3\/01 11\/01 12\/07 6\/09 (In millions) 6.6 33.5 0 10 20 30 40 1962 1966 1970 1975 1980 1985 1990 1995 2000 2005 2009 Including Puerto Rico Without Puerto Rico http:\/\/www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf\ufffd A-28 Table SNAP 1. Trends in SNAP Caseloads: Selected Years 1962 2009 SNAP Participants Participants as a Percent of: Child Participants as a Percent of: Fiscal Year Including Territories 1 (thousands) Excluding Territories (thousands) Children Excld. Terr. (thousands) Total Population 2 All Poor Persons 2 Total Child Population 2 Children in Poverty 2 1962 6,554 6,554 NA 3.5 17.0 NA NA 1965 5,167 5,167 NA 2.7 15.6 NA NA 1970 8,317 8,317 NA 4.1 32.7 NA NA 1971 13,010 13,010 NA 6.3 50.9 NA NA 1972 14,111 14,111 NA 6.7 57.7 NA NA 1973 14,607 14,607 NA 6.9 63.6 NA NA 1974 14,268 14,268 NA 6.7 61.1 NA NA 1975 4 17,152 16,320 NA 7.6 63.1 NA NA 1976 18,628 17,033 9,126 7.8 68.2 13.8 88.8 1977 17,161 15,604 NA 7.1 63.1 NA NA 1978 16,077 14,405 NA 6.5 58.8 NA NA 1979 5 17,758 15,942 NA 7.1 61.1 NA NA 1980 21,173 19,253 9,876 8.5 65.8 15.5 85.6 1981 22,518 20,655 9,803 9.0 64.9 15.5 78.4 1982 21,808 20,391 9,591 8.8 59.3 15.3 70.3 1983 21,727 20,095 10,910 8.6 56.9 17.4 78.4 1984 20,854 20,796 10,492 8.8 61.7 16.8 78.2 1985 19,899 19,847 9,801 8.3 60.0 15.7 75.3 1986 19,429 19,381 9,844 8.1 59.9 15.7 76.5 1987 19,113 19,072 9,771 7.9 59.2 15.5 76.1 1988 18,645 18,613 9,351 7.6 58.6 14.8 75.1 1989 18,806 18,777 9,429 7.6 59.6 14.9 74.9 1990 20,049 20,020 10,127 8.0 59.6 15.8 75.4 1991 22,625 22,599 11,952 8.9 63.3 18.3 83.3 1992 25,407 25,371 13,349 9.9 66.7 20.1 87.3 1993 26,987 26,957 14,196 10.4 68.7 21.0 90.3 1994 27,474 27,439 14,391 10.4 72.1 21.0 94.1 1995 26,619 26,579 13,860 10.0 73.0 20.0 94.5 1996 25,543 25,495 13,189 9.5 69.8 18.8 91.2 1997 22,858 22,820 11,847 8.4 64.1 16.7 83.9 1998 19,791 19,748 10,520 7.2 57.3 14.7 78.1 1999 18,183 18,114 9,332 6.5 55.2 13.0 76.0 2000 17,194 17,054 8,743 6.0 54.0 12.1 75.5 2001 17,318 17,262 8,820 6.1 52.5 12.1 75.2 2002 19,096 19,003 9,688 6.6 55.0 13.3 79.8 2003 21,250 20,898 10,605 7.2 58.3 14.5 82.4 2004 23,811 23,447 11,771 8.0 63.3 16.1 90.3 2005 25,628 24,841 12,404 8.4 67.2 16.9 96.2 2006 26,549 25,555 12,579 8.6 70.1 17.1 98.1 2007 26,316 25,887 12,695 8.6 69.4 17.2 95.3 2008 28,223 27,751 13,472 9.1 69.7 18.2 95.8 2009 33,490 32,842 15,589 10.7 75.4 21.0 100.9 1 Total participants includes all participating states, the District of Columbia, and the territories (including Puerto Rico from 1975 to 1982 a separate Nutrition Assistance Grant for Puerto Rico was begun in July 1982). From 1962 to 1983 the number of participants includes the Family Food Assistance Program (FFAP) that was largely replaced by the FSP in 1975. The FFAP participants (as of December) for the seven years shown during the period from 1962 to 1974 were respectively: 6,411; 4,742; 3,977; 3,642; 3,002; 2,441; and 1,406 (all in thousands). From 1975 to 1983 the number of FFAP participants averaged only 88 thousand. 2 Includes all participating states and the District of Columbia only the territories are excluded from both numerator and denominator. Population numbers used as denominators are the resident population. 3 The pre-transfer poverty population used as denominator is the number of all persons in families or living alone whose income (cash income plus social insurance plus Social Security but before taxes and means-tested transfers) falls below the relevant poverty threshold. See Appendix J, Table 20, 1992 Green Book; data for subsequent years are unpublished Congressional Budget Office tabulations. 4 The first fiscal year in which SNAP was available nationwide. 5 The fiscal year in which the food stamp purchase requirement was eliminated, on a phased-in basis. Sources: U.S. Department of Agriculture, data published online at www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf and unpublished data from the Food Stamps National Data Bank, the House Ways and Means Committee, 1996 Green Book, and U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009, Current Population Reports, Series P60-238. http:\/\/www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2009Characteristics.pdf\ufffd A-29 Table SNAP 2. Trends in SNAP Expenditures: Selected Years 1975 2009 Total Federal Cost (Benefits + Administration) Benefits Administration1 Total Program Cost Average Monthly Benefit per Person Federal State & Local Fiscal Year Current Dollars 2009 Dollars2 (Federal) Current Dollars 2009 Dollars2 (millions) (millions] (millions) (millions) (millions) (millions) 1975 $4,619 $17,328 $4,386 $233 $175 $4,794 $21.40 $79.90 1980 9,206 23,325 8,721 486 375 9,581 34.50 87.40 1981 11,225 25,852 10,630 595 504 11,729 39.50 91.00 1982 10,837 23,347 10,208 628 557 11,394 39.20 83.20 1983 11,847 24,402 11,152 695 612 12,459 43.00 88.60 19843 11,579 22,902 10,696 883 805 12,384 42.70 84.50 1985 11,703 22,346 10,744 960 871 12,574 45.00 85.90 1986 11,638 21,720 10,605 1,033 935 12,573 45.50 84.90 1987 11,604 21,092 10,500 1,104 996 12,600 45.80 83.20 1988 12,317 21,587 11,149 1,168 1,080 13,397 49.80 87.30 1989 12,902 21,692 11,670 1,232 1,101 14,003 51.70 86.90 1990 15,447 24,841 14,143 1,305 1,174 16,621 58.80 94.60 1991 18,747 28,847 17,316 1,432 1,247 19,994 63.80 98.20 1992 22,462 33,736 20,906 1,557 1,375 23,837 68.60 103.00 1993 23,653 34,646 22,006 1,647 1,572 25,225 68.00 99.60 1994 24,493 35,123 22,749 1,745 1,643 26,136 69.00 98.90 1995 24,620 34,486 22,764 1,856 1,748 26,368 71.30 99.90 1996 24,331 33,250 22,440 1,891 1,842 26,173 73.20 100.00 1997 21,508 28,680 19,549 1,959 1,904 23,412 71.30 95.10 1998 18,988 24,949 16,891 2,098 1,988 20,976 71.10 93.40 1999 17,821 23,002 15,769 2,052 1,874 19,695 72.30 93.30 2000 17,054 21,345 14,983 2,071 2,086 19,140 72.60 90.90 2001 17,789 21,577 15,547 2,242 2,233 20,022 74.80 90.70 2002 20,637 24,659 18,256 2,381 2,397 23,034 79.70 95.20 2003 23,816 27,802 21,404 2,412 2,633 26,450 83.90 97.90 2004 27,099 30,921 24,619 2,480 2,645 29,744 86.20 98.40 2005 31,072 34,331 28,568 2,504 2,713 33,785 92.90 102.60 2006 32,904 35,060 30,187 2,717 2,866 35,770 94.80 101.00 2007 33,190 34,544 30,373 2,817 2,947 36,137 96.20 100.10 2008 37,645 37,525 34,608 3,036 3,202 40,846 102.20 101.90 2009 53,639 53,639 50,360 3,279 3,460 57,099 125.30 125.30 Note: Total federal cost and the cost of benefits does include SNAP in Puerto Rico from 1975 to 1982 but does not include the funding for the Puerto Rico nutrition assistance grant from the last quarter of FY 1982 (when it replaced Puerto Rico’s food stamp program) to the present. (Puerto Rico’s nutrition assistance grant was $778 million in 1983 and rose to $2.0 billion in 2009.) 1 Amounts include the federal share of state administrative and Employment and Training costs and certain direct federal administrative costs. They do not generally include approximately $60 million in food stamp-related federal administrative costs budgeted under a separate appropriation account (although estimates prior to 1989 do include estimates of food stamp related federal administrative expenses paid out of other Agriculture Department accounts). State and local costs are estimated based on the known federal shares and represent an estimate of all administrative expenses of participating states. 2 Constant dollar adjustments to 2009 level were made using a CPI-U-RS fiscal year average price index. 3 Beginning in 1984 USDA took over from DHHS the administrative cost of certifying public assistance households for SNAP. Source: U.S. Department of Agriculture, Food and Nutrition Service unpublished data (available at online at http:\/\/www.fns.usda.gov\/pd\/SNAPsummary.htm); and the House Ways and Means Committee, 2004 Green Book (available online at http:\/\/www.gpoaccess.gov\/wmprints\/green\/2004.html). http:\/\/www.gpoaccess.gov\/wmprints\/green\/2004.html\ufffd A-30 Table SNAP 3. Characteristics of SNAP Households: Selected Years 1980 2009 Year 1 1980 1984 1988 1990 1994 1996 1998 2000 2004 2009 With Gross Monthly Income: (In Percent) Below the Federal Poverty Levels. … 87 93 92 92 90 91 90 89 88 86 Between the Poverty Levels and 130 percent of the Poverty Levels 10 6 8 8 9 8 9 10 11 11 Above 130 Percent of Poverty…….. .. 2 1 * * 1 1 1 1 2 3 With Earnings………………………….. . 19 19 20 19 21 23 26 27 29 29 With Public Assistance Income 2….. .. 61 59 56 45 35 With AFDC\/TANF Income……….. … NA 42 42 42 38 37 31 26 16 10 With SSI Income……………………… … 18 18 20 19 21 24 28 32 27 24 With Children…………………………….. .. 60 61 61 60 61 60 58 54 54 50 And Female Heads of Household.. … NA 47 50 51 51 50 47 44 45 NA With No Spouse Present ……. NA NA 39 37 43 43 41 38 37 NA With Elderly Members 3………. …… 23 22 19 18 16 16 18 21 17 17 Average Household Size…………… ….. 2.8 2.8 2.6 2.6 2.5 2.5 2.4 2.3 2.3 2.2 1 Data were gathered in August in the years 1980-84 and during the summer in the years from 1986 to 1994. Reports from 1995 to the present are based on fiscal year averages. 2 Public assistance income includes: AFDC\/TANF, SSI, and general assistance. 3 Elderly members and heads of household include those of age 60 or older. The total percentage of households with public assistance income is approximately equal to the sum of those with AFDC\/TANF and SSI income with some small percentage of households receiving both due to having individual members eligible for different forms of assistance (in 1996 just under 6 percent of households received assistance from multiple sources). * Less than 0.5 percent. Source: U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition, and Evaluation, Characteristics of Supplemental Nutrition Assistance Households, Fiscal Year 2009, Report No. SNAP-09-CHAR (available online at http:\/\/www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2008Characteristics.pdf and earlier reports. http:\/\/www.fns.usda.gov\/oane\/MENU\/Published\/SNAP\/FILES\/Participation\/2008Characteristics.pdf\ufffd A-31 Table SNAP 4. Value of SNAP Issued by State: Selected Fiscal Years 1975 2009 [In millions] Percent Change 1975 1980 1985 1990 1995 2000 2005 2009 1995-00 2000-09 Alabama $103 $246 $318 $328 $441 $344 $616 971 -22 182 Alaska 6 27 25 25 50 46 80 130 -8 183 Arizona 41 97 121 239 414 240 634 1,224 -42 409 Arkansas 78 122 126 155 212 206 401 570 -3 176 California 361 530 639 968 2,473 1,639 2,315 4,382 -34 167 Colorado 44 71 94 156 217 127 313 503 -42 297 Connecticut 36 59 62 72 169 138 223 417 -18 202 Delaware 6 21 22 25 47 31 65 129 -33 315 Dist. of Columbia 31 41 40 43 92 77 103 160 -17 108 Florida 207 421 368 609 1,307 771 1,598 2,968 -41 285 Georgia 129 264 290 382 700 489 1,048 1,944 -30 298 Guam 2 15 18 15 24 36 54 79 48 120 Hawaii 23 60 93 81 177 166 156 274 -6 65 Idaho 11 29 36 40 59 46 103 201 -21 335 Illinois 238 394 713 835 1,056 777 1,400 2,323 -26 199 Indiana 58 154 242 226 382 268 627 1,071 -30 300 Iowa 28 54 107 109 142 100 220 420 -29 319 Kansas 12 38 64 96 144 83 180 302 -43 265 Kentucky 135 211 332 334 413 337 611 1,002 -18 198 Louisiana 148 243 365 549 629 448 979 1,119 -29 150 Maine 31 60 62 63 112 81 162 293 -28 260 Maryland 76 140 171 203 365 199 320 669 -45 235 Massachusetts 75 171 173 207 315 182 363 926 -42 410 Michigan 124 263 541 663 806 457 1,099 2,107 -43 361 Minnesota 40 62 105 165 240 165 275 473 -31 187 Mississippi 110 199 264 352 383 226 463 691 -41 206 Missouri 82 142 212 312 488 358 736 1,136 -27 217 Montana 11 18 31 41 57 51 89 135 -11 163 Nebraska 11 25 44 59 77 61 120 179 -20 194 Nevada 10 15 22 41 91 57 129 286 -38 405 New Hampshire 11 22 15 20 44 28 51 116 -37 312 New Jersey 125 226 260 289 506 304 437 750 -40 147 New Mexico 48 81 88 117 196 140 251 411 -29 194 New York 209 726 938 1,086 2,065 1,361 2,136 3,955 -34 191 North Carolina 122 234 237 282 495 403 856 1,625 -18 303 North Dakota 5 9 16 25 32 25 45 80 -22 215 Ohio 253 382 697 861 1,017 520 1,155 2,167 -49 316 Oklahoma 38 73 134 186 315 208 440 666 -34 220 Oregon 56 80 142 168 254 198 456 831 -22 320 Pennsylvania 175 373 547 661 1,006 656 1,105 1,901 -35 190 Rhode Island 18 31 35 42 82 59 79 170 -28 188 South Carolina 121 181 194 240 297 249 566 1,002 -16 302 South Dakota 8 18 26 35 40 37 61 111 -7 202 Tennessee 115 282 280 372 554 415 942 1,604 -25 286 Texas 314 514 701 1,429 2,246 1,215 2,659 4,399 -46 262 Utah 12 22 40 71 90 68 141 263 -24 286 Vermont 9 18 20 22 46 32 45 99 -30 210 Virgin Islands 6 19 23 18 28 21 21 34 -24 61 Virginia 63 158 189 247 450 263 500 923 -42 251 Washington 70 90 140 229 417 241 539 1,047 -42 333 West Virginia 56 87 159 192 253 185 258 408 -27 120 Wisconsin 29 68 148 180 220 129 317 680 -42 428 Wyoming 3 6 15 21 28 19 27 37 -32 99 United States $4,386 $8,721 $10,744 $14,186 $22,764 $14,983 $28,568 $50,360 -34 236 Note: The totals for 1975 and 1980 include amounts for Puerto Rico of $366 and $828 million respectively. Source: U.S. Department of Agriculture, Food and Nutrition Service (2004 to 2009 data published online at www.fns.usda.gov\/pd\/17SNAPfyBEN$.htm) and unpublished data from the Food Stamp National Data Bank. A-32 Table SNAP 5. Average Number of SNAP Recipients by State: Selected Fiscal Years [In thousands] Percent Change 1975 1980 1985 1990 1995 2000 2005 2009 1995-00 2000-09 Alabama 365 583 588 454 525 396 559 679 -22 71 Alaska 15 29 22 25 45 38 56 64 -19 72 Arizona 143 196 206 317 480 259 550 814 -39 214 Arkansas 267 301 253 235 272 247 374 411 -10 67 California 1,455 1,493 1,615 1,937 3,175 1,831 1,992 2,670 -42 46 Colorado 150 163 170 221 252 156 246 319 -36 105 Connecticut 155 170 145 133 226 165 204 258 -26 56 Delaware 26 52 40 33 57 32 62 91 -44 182 Dist. of Columbia 122 103 72 62 94 81 89 103 -13 28 Florida 647 912 630 781 1,395 882 1,382 1,952 -36 121 Georgia 498 627 567 536 816 559 921 1,286 -29 130 Guam 6 22 20 12 16 22 27 32 26 42 Hawaii 75 102 99 77 125 118 94 115 -9 -3 Idaho 39 61 59 59 80 58 93 136 -27 134 Illinois 926 903 1,110 1,013 1,151 817 1,158 1,462 -26 79 Indiana 392 353 406 311 470 300 556 707 -23 135 Iowa 115 141 203 170 184 123 207 295 -30 139 Kansas 58 90 119 142 184 117 178 219 -32 88 Kentucky 472 468 560 458 520 403 570 702 -17 74 Louisiana 510 569 644 727 711 500 808 724 -25 45 Maine 126 139 114 94 132 102 153 201 -22 98 Maryland 261 324 287 255 399 219 289 454 -41 107 Massachusetts 365 453 337 347 410 232 368 628 -38 171 Michigan 619 813 985 917 971 603 1,048 1,450 -36 141 Minnesota 167 171 228 263 308 196 260 345 -33 76 Mississippi 376 496 495 499 480 276 435 506 -40 83 Missouri 300 335 362 431 576 423 766 801 -24 89 Montana 38 43 58 57 71 59 81 92 -16 55 Nebraska 49 66 94 95 105 82 117 134 -19 62 Nevada 32 32 32 50 99 61 122 200 -37 228 New Hampshire 44 50 28 31 58 36 52 79 -31 118 New Jersey 490 605 464 382 551 345 392 500 -36 45 New Mexico 157 185 157 157 239 169 241 291 -28 72 New York 1,291 1,759 1,834 1,548 2,183 1,439 1,755 2,323 -31 61 North Carolina 466 582 474 419 614 488 800 1,137 -23 133 North Dakota 19 25 33 39 41 32 42 53 -20 67 Ohio 854 865 1,133 1,089 1,155 610 1,007 1,357 -42 123 Oklahoma 171 209 263 267 375 253 424 473 -28 87 Oregon 201 197 228 216 289 234 429 581 -19 148 Pennsylvania 848 980 1,032 952 1,173 777 1,043 1,338 -31 72 Rhode Island 86 87 69 64 93 74 76 102 -18 38 South Carolina 410 426 373 299 364 295 521 688 -18 133 South Dakota 33 43 48 50 50 43 56 74 -12 73 Tennessee 397 624 518 527 662 496 850 1,072 -22 116 Texas 1,133 1,167 1,263 1,880 2,558 1,333 2,442 3,003 -44 125 Utah 46 54 75 99 119 82 133 185 -26 126 Vermont 44 46 44 38 59 41 45 72 -28 77 Virgin Islands 16 34 32 18 23 16 14 16 -49 4 Virginia 257 384 360 346 546 336 488 652 -37 94 Washington 253 248 281 340 476 295 508 761 -38 158 West Virginia 242 209 278 262 309 227 262 306 -24 35 Wisconsin 148 215 363 286 320 193 346 548 -32 184 Wyoming 10 14 27 28 34 22 25 27 -32 19 United States 17,192 21,082 19,899 20,049 26,619 17,194 25,718 33,490 -33 95 Note: The totals for 1975 and 1980 include recipients in Puerto Rico of 810 thousand and 1.86 million respectively. Source: U.S. Department of Agriculture, Food and Nutrition Service (2000 to 2009 data published online at www.fns.usda.gov\/pd\/15SNAPpartPP.htm and are subject to revision) and unpublished data from the National Data Bank. http:\/\/www.fns.usda.gov\/pd\/15SNAPpartPP.htm\ufffd A-33 Table SNAP 6. SNAP Recipiency Rates by State: Selected Fiscal Years [In percent] Percent Change 1975 1980 1985 1990 1995 2000 2005 2009 1995-00 2000-09 Alabama 9.9 14.9 14.8 11.2 12.2 8.9 12.3 14.4 -27 62 Alaska 4.0 7.1 4.1 4.5 7.5 6.0 8.3 9.2 -20 54 Arizona 6.3 7.1 6.5 8.6 10.8 5.0 9.2 12.3 -54 146 Arkansas 12.4 13.1 10.9 10.0 10.7 9.2 13.5 14.2 -14 55 California 6.8 6.3 6.1 6.5 10.0 5.4 5.6 7.2 -46 34 Colorado 5.8 5.6 5.3 6.7 6.6 3.6 5.3 6.4 -45 76 Connecticut 5.0 5.5 4.5 4.0 6.8 4.8 5.9 7.3 -29 52 Delaware 4.5 8.7 6.5 5.0 7.8 4.1 7.3 10.3 -48 151 Dist. of Columbia 17.2 16.1 11.4 10.3 16.2 14.1 15.3 17.2 -13 22 Florida 7.6 9.3 5.5 6.0 9.6 5.5 7.8 10.5 -43 92 Georgia 9.8 11.4 9.5 8.2 11.1 6.8 10.1 13.1 -39 92 Hawaii 8.4 10.6 9.5 6.9 10.4 9.7 7.4 8.8 -6 -9 Idaho 4.6 6.4 5.9 5.8 6.8 4.5 6.6 8.8 -34 97 Illinois 8.2 7.9 9.7 8.8 9.6 6.6 9.1 11.3 -32 73 Indiana 7.3 6.4 7.4 5.6 8.0 4.9 8.9 11.0 -39 123 Iowa 4.0 4.8 7.2 6.1 6.4 4.2 7.0 9.8 -34 133 Kansas 2.5 3.8 4.9 5.7 7.1 4.3 6.5 7.8 -39 80 Kentucky 13.6 12.8 15.2 12.4 13.4 10.0 13.6 16.3 -26 63 Louisiana 13.1 13.5 14.6 17.2 16.2 11.2 18.0 16.1 -31 44 Maine 11.8 12.3 9.8 7.6 10.6 8.0 11.7 15.3 -25 92 Maryland 6.3 7.7 6.5 5.3 7.9 4.1 5.2 8.0 -48 93 Massachusetts 6.3 7.9 5.7 5.8 6.7 3.6 5.7 9.5 -45 161 Michigan 6.8 8.8 10.8 9.8 10.0 6.1 10.4 14.5 -40 140 Minnesota 4.2 4.2 5.5 6.0 6.6 4.0 5.1 6.6 -40 65 Mississippi 15.7 19.6 19.1 19.4 17.6 9.7 15.0 17.1 -45 77 Missouri 6.2 6.8 7.2 8.4 10.7 7.6 13.2 13.4 -29 77 Montana 5.1 5.5 7.1 7.1 8.1 6.6 8.7 9.5 -19 44 Nebraska 3.2 4.2 5.9 6.0 6.3 4.8 6.7 7.4 -24 55 Nevada 5.2 4.0 3.4 4.1 6.2 3.0 5.1 7.6 -52 151 New Hampshire 5.3 5.4 2.8 2.7 5.0 2.9 4.0 6.0 -42 104 New Jersey 6.7 8.2 6.1 4.9 6.8 4.1 4.6 5.7 -40 40 New Mexico 13.5 14.1 10.9 10.3 13.9 9.3 12.6 14.5 -33 56 New York 7.2 10.0 10.3 8.6 11.8 7.6 9.1 11.9 -36 57 North Carolina 8.4 9.9 7.6 6.3 8.4 6.0 9.2 12.1 -28 101 North Dakota 2.9 3.9 4.9 6.1 6.4 5.0 6.6 8.2 -22 65 Ohio 7.9 8.0 10.6 10.0 10.3 5.4 8.8 11.8 -48 119 Oklahoma 6.2 6.9 8.0 8.5 11.3 7.3 12.0 12.8 -35 75 Oregon 8.6 7.5 8.5 7.6 9.1 6.8 11.9 15.2 -25 122 Pennsylvania 7.1 8.3 8.8 8.0 9.6 6.3 8.4 10.6 -34 68 Rhode Island 9.2 9.1 7.2 6.4 9.2 7.1 7.1 9.7 -23 37 South Carolina 14.1 13.6 11.3 8.5 9.7 7.3 12.2 15.1 -24 105 South Dakota 4.8 6.2 6.9 7.2 6.8 5.7 7.2 9.1 -17 60 Tennessee 9.3 13.6 11.0 10.8 12.4 8.7 14.2 17.0 -30 96 Texas 9.0 8.1 7.8 11.0 13.5 6.4 10.7 12.1 -53 90 Utah 3.7 3.7 4.6 5.7 5.9 3.6 5.3 6.7 -38 82 Vermont 9.1 8.9 8.2 6.8 10.1 6.7 7.3 11.6 -33 73 Virginia 5.1 7.2 6.3 5.6 8.2 4.7 6.5 8.3 -42 75 Washington 7.0 6.0 6.4 6.9 8.7 5.0 8.1 11.4 -43 129 West Virginia 13.1 10.7 14.6 14.6 16.9 12.6 14.5 16.8 -26 34 Wisconsin 3.2 4.6 7.6 5.8 6.2 3.6 6.2 9.7 -42 170 Wyoming 2.7 3.0 5.4 6.2 6.9 4.5 5.0 4.9 -34 8 United States 7.6 8.5 8.3 8.0 10.0 6.0 8.4 10.7 -39 77 Note: Recipiency rate refers to the average monthly number of SNAP recipients in each state during the particular fiscal year expressed as a percent of the total resident population as of July 1 of that year. The numerators are from Table SNAP 5 and the denominators are from Census population estimates for states both of which are subject to revision. Recipiency rate for the United States are from Table SNAP 1 and are also subject to revision. Source: U.S. Department of Agriculture, Food, Nutrition, and Consumer Services, Office of Food and Nutrition Service, (2000 to 2009 data published online at http:\/\/www.fns.usda.gov\/pd\/15SNAPpartPP.htm and earlier years from unpublished data from the National Data Bank; U.S. Census Bureau (population by state available online at http:\/\/www.census.gov). http:\/\/www.census.gov\/\ufffd A-34 Table SNAP 7. SNAP Child Recipients by State: Selected Fiscal Years 1989 2009 [In thousands] Percent Change 1989 1992 1995 1998 2000 2003 2006 2009 1995-00 2000-09 Alabama 204 271 281 213 201 225 271 335 -28 67 Alaska 14 20 24 21 21 25 26 29 -13 38 Arizona 142 256 284 173 153 251 291 414 -46 171 Arkansas 103 133 133 123 120 156 175 190 -10 58 California 1,130 1,699 2,035 1,633 1,255 1,151 1,277 1,586 -38 26 Colorado 108 150 126 91 75 103 129 164 -40 119 Connecticut 63 110 128 99 82 84 82 98 -36 20 Delaware 16 27 28 23 16 24 33 46 -43 188 Dist. of Columbia 30 48 52 43 44 34 38 39 -15 -11 Florida 319 743 720 488 405 472 528 841 -44 108 Georgia 247 395 421 359 292 378 474 624 -31 114 Hawaii 40 43 61 62 52 40 36 46 -15 -12 Idaho 30 37 41 33 29 39 47 71 -29 145 Illinois 481 536 581 483 379 470 589 676 -35 78 Indiana 139 247 219 156 154 231 270 327 -30 112 Iowa 81 100 93 65 59 71 103 133 -37 125 Kansas 61 90 99 53 53 72 86 100 -46 89 Kentucky 190 251 224 177 177 216 240 298 -21 68 Louisiana 357 444 384 287 268 319 305 342 -30 28 Maine 38 61 53 43 34 45 59 74 -36 118 Maryland 128 188 206 170 104 124 143 204 -50 96 Massachusetts 153 239 232 166 129 150 179 247 -44 91 Michigan 445 506 490 404 314 413 502 575 -36 83 Minnesota 121 159 163 108 103 112 131 161 -37 56 Mississippi 225 256 250 174 143 176 204 238 -43 66 Missouri 192 287 292 209 200 267 398 359 -32 80 Montana 26 31 35 29 28 32 35 40 -20 43 Nebraska 45 55 54 48 38 46 59 66 -30 74 Nevada 19 46 56 38 33 54 56 96 -41 191 New Hampshire 9 26 28 21 18 21 24 32 -36 78 New Jersey 192 263 284 218 160 169 203 230 -44 44 New Mexico 76 119 126 95 90 103 128 151 -29 68 New York 722 915 950 816 627 639 724 895 -34 43 North Carolina 178 300 301 264 233 312 419 547 -23 135 North Dakota 19 22 19 17 14 19 19 23 -26 64 Ohio 492 642 575 336 303 414 487 623 -47 106 Oklahoma 124 168 186 141 128 189 205 219 -31 71 Oregon 91 126 140 101 103 170 180 228 -26 121 Pennsylvania 442 556 536 421 355 362 469 551 -34 55 Rhode Island 29 46 50 42 42 37 35 44 -16 5 South Carolina 138 186 199 176 147 226 244 312 -26 112 South Dakota 25 28 28 25 24 24 29 36 -14 50 Tennessee 230 322 315 261 231 315 384 458 -27 98 Texas 846 1,302 1,406 924 754 1,124 1,418 1,685 -46 123 Utah 52 70 65 53 41 59 69 97 -37 137 Vermont 14 29 29 19 19 16 18 27 -34 42 Virginia 149 231 277 207 149 181 233 288 -46 93 Washington 154 219 249 179 135 171 224 328 -46 143 West Virginia 111 142 123 110 92 100 105 120 -25 30 Wisconsin 176 189 186 110 103 161 186 263 -45 155 Wyoming 15 18 19 13 12 13 11 13 -37 8 United States 9,429 13,349 13,856 10,520 8,741 10,605 12,580 15,589 -37 78 Source: U.S. Department of Agriculture, Food and Nutrition Service Characteristics of Supplemental Nutrition Assistance Program Households, Fiscal Year Supplemental Nutrition Assistance Program Quality Control sample, various year. Data for the 2009 numbers come from Table B-11., www.fns.usda.gov\/ora\/MENU\/Published\/snap\/SNAPPartHH.htm. http:\/\/www.fns.usda.gov\/ora\/MENU\/Published\/snap\/SNAPPartHH.htm\ufffd A-35 Table SNAP 8. SNAP Child Recipiency Rates, by State: Selected Fiscal Years 1989-2009 [In percent] Percent Change 1989 1992 1995 1998 2000 2003 2006 2009 1995-00 2000-09 Alabama 19.0 25.5 25.9 19.8 17.9 20.3 24.3 29.7 -31 66 Alaska 8.0 10.6 12.9 10.9 11.0 13.3 14.1 15.8 -14 43 Arizona 14.6 24.2 24.1 13.4 11.1 17.0 17.9 23.9 -54 115 Arkansas 16.5 21.1 20.3 18.6 17.6 23.0 25.2 26.8 -13 52 California 14.9 20.2 23.2 18.3 13.5 12.2 13.6 16.8 -42 24 Colorado 12.5 16.2 12.9 8.7 6.8 9.0 11.0 13.4 -47 97 Connecticut 8.3 14.2 16.2 12.3 9.7 10.0 9.9 12.1 -40 25 Delaware 9.7 15.8 15.9 12.8 8.2 12.1 16.2 22.2 -48 171 Dist. of Columbia 24.0 41.8 45.8 43.5 38.4 29.5 33.4 34.2 -16 -11 Florida 11.4 23.9 21.5 13.8 11.1 12.4 13.1 20.7 -48 87 Georgia 14.3 21.8 21.9 17.7 13.4 16.3 19.2 24.2 -39 80 Hawaii 14.2 14.8 20.0 21.0 17.7 13.8 12.5 15.8 -12 -10 Idaho 9.7 11.5 11.9 9.4 7.8 10.4 11.8 16.9 -34 116 Illinois 16.2 17.7 18.6 15.2 11.7 14.6 18.4 21.3 -37 82 Indiana 9.6 17.0 14.7 10.3 9.8 14.7 17.1 20.6 -34 110 Iowa 11.3 13.9 12.9 9.0 8.1 9.9 14.5 18.6 -37 132 Kansas 9.2 13.2 14.4 7.6 7.4 10.2 12.4 14.2 -48 91 Kentucky 19.8 26.2 23.1 18.2 17.8 21.7 24.0 29.4 -23 65 Louisiana 28.4 36.2 31.3 23.9 22.0 27.1 28.7 30.4 -30 38 Maine 12.4 19.9 17.5 14.7 11.3 15.3 20.9 27.3 -36 142 Maryland 11.1 15.4 16.2 13.2 7.7 9.0 10.5 15.1 -53 97 Massachusetts 11.3 17.3 16.2 11.4 8.6 10.1 12.4 17.2 -47 101 Michigan 18.1 20.3 19.3 15.9 12.1 16.2 20.3 24.5 -37 102 Minnesota 10.5 13.1 13.2 8.6 8.0 8.8 10.4 12.8 -39 60 Mississippi 29.8 34.4 33.0 23.0 18.5 23.1 26.9 31.0 -44 68 Missouri 14.6 21.3 21.1 14.9 14.0 18.8 28.0 25.1 -34 79 Montana 11.7 13.4 15.0 12.8 12.2 14.4 16.0 18.2 -19 49 Nebraska 10.5 12.6 12.3 10.8 8.4 10.3 13.3 14.6 -31 73 Nevada 6.9 13.7 14.1 8.1 6.4 9.4 8.8 14.1 -55 121 New Hampshire 3.4 9.1 9.6 7.0 5.8 6.8 7.9 11.1 -39 91 New Jersey 10.6 14.0 14.4 10.9 7.7 8.0 9.8 11.2 -47 47 New Mexico 16.8 25.4 25.4 19.0 17.7 20.7 25.7 29.6 -30 67 New York 16.9 20.7 21.0 18.3 13.4 13.8 16.1 20.2 -36 51 North Carolina 11.0 17.9 16.7 13.8 11.8 15.2 19.5 24.0 -29 103 North Dakota 10.6 13.1 11.2 10.4 8.7 12.8 13.2 16.0 -22 83 Ohio 17.5 22.7 20.2 11.8 10.5 14.6 17.6 23.0 -48 119 Oklahoma 14.6 19.5 21.3 16.0 14.4 21.4 23.0 23.8 -32 66 Oregon 12.8 16.4 17.6 12.3 12.2 20.0 21.0 26.1 -31 115 Pennsylvania 15.7 19.5 18.5 14.7 12.2 12.7 16.7 19.9 -34 63 Rhode Island 12.9 20.0 21.1 17.7 16.9 15.0 14.8 19.4 -20 15 South Carolina 14.9 19.9 21.1 18.4 14.5 22.1 23.3 28.9 -31 98 South Dakota 12.7 13.6 13.7 12.5 11.9 12.2 14.8 18.0 -13 52 Tennessee 18.8 25.7 24.1 19.6 16.5 22.2 26.3 30.7 -31 86 Texas 17.6 25.6 26.2 16.3 12.8 18.3 21.9 24.4 -51 91 Utah 8.4 10.8 9.6 7.5 5.7 7.9 8.6 11.2 -41 96 Vermont 10.2 20.1 19.8 13.5 12.9 11.3 13.5 21.4 -35 66 Virginia 9.9 14.7 17.2 12.5 8.6 10.2 12.8 15.6 -50 82 Washington 12.5 16.1 17.6 12.1 8.9 11.3 14.7 20.9 -49 135 West Virginia 24.5 32.8 28.8 26.9 22.9 25.6 27.1 31.1 -20 35 Wisconsin 13.7 14.2 13.8 8.2 7.5 12.0 14.0 20.1 -46 167 Wyoming 10.5 13.1 14.1 10.0 9.3 10.6 8.9 9.8 -34 6 United States 14.9 20.2 20.2 15.0 12.1 14.5 17.1 20.9 -40 73 Source: U.S. Department of Agriculture, Food and Nutrition Service Characteristics of Supplemental Nutrition Assistance Program Households, Fiscal Year Supplemental Nutrition Assistance Program Quality Control sample, various years, www.fns.usda.gov\/ora\/MENU\/Published\/snap\/SNAPPartHH.htm. and U.S. Census Bureau (July 1 resident population by state and age available online at www.census.gov\/popest\/states\/). http:\/\/www.fns.usda.gov\/ora\/MENU\/Published\/snap\/SNAPPartHH.htm\ufffd http:\/\/www.census.gov\/popest\/states\/\ufffd A-36 Supplemental Security Income The Supplemental Security Income (SSI) Program is a means-tested, federally administered income assistance program authorized by title XVI of the Social Security Act. Established in 1972 (Public Law 92-603) and begun in 1974, SSI provides monthly cash payments in accordance with uniform, nationwide eligibility requirements to needy aged, blind and disabled persons. To qualify for SSI payments, a person must satisfy the program criteria for age, blindness, or disability. Children may qualify for SSI if they are under age 18 and meet the applicable SSI disability or blindness, income and resource requirements. Individuals and married couples are eligible for SSI if their countable incomes fall below the federal maximum monthly SSI benefit levels of $674 for an individual and $1,011 for a married couple (if both are eligible) in fiscal year 2009. SSI eligibility is restricted to qualified persons who have countable resources\/assets of not more than $2,000, or $3,000 for a couple. The Social Security Administration (SSA) administers the SSI program. Since its inception, SSI has been viewed as the program of last resort. Therefore, SSA helps recipients obtain any other public assistance that they are eligible to receive before providing SSI benefits. After evaluating all other income, SSI pays what is necessary to bring an individual to the statutorily prescribed income floor. Prior to the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), no individual could receive both SSI payments and Aid to Families with Dependent Children (AFDC) benefits. If eligible for both, the individual had to choose which benefit to receive. Generally, the AFDC agency encouraged individuals to file for SSI and, once the SSI payments had started, the individual was removed from the AFDC filing unit. Since states have the authority to set TANF eligibility standards and benefit levels under PRWORA, there is no federal prohibition against individuals receiving both TANF benefits and SSI. With the exception of California, which converted SNAP benefits to cash payments that are included in the state supplementary payment, SSI recipients may be eligible to receive SNAP benefits. If all household members receive SSI, the household is categorically eligible for SNAP and does not need to meet the SNAP financial eligibility standards. If SSI beneficiaries live in households in which other household members do not receive SSI benefits, the household must meet the net income eligibility standard of the SNAP to be eligible for SNAP benefits. Legislative Changes Public Law 104-121, the Contract with America Advancement Act of 1996, prohibited SSI eligibility to individuals whose drug addiction and\/or alcoholism (DA&A) is a contributing factor material to the finding of disability. This provision applied to individuals who filed for benefits on or after the date of enactment (March 29, 1996) and to individuals whose claims were finally adjudicated on or after the date of enactment. It applied to current beneficiaries on January 1, 1997. PRWORA made several changes designed to maintain the SSI program’s goal of limiting benefits to severely disabled children. First, the act replaced the former comparable severity test with a new definition of disability specifically for children, based on a medically determinable physical or mental impairment that results in marked and severe functional limitations. Second, the Social Security Administration discontinued use of the Individualized Functional Assessment (IFA) for children which it had implemented in 1991 following the Supreme Court’s decision in Sullivan v Zebley, 493 U.S. 521 (1990).8 8 In this case, the Supreme Court ruled that the IFA (or a residual functional capacity assessment) that applied to adults whose condition did not meet or equal a listing of medical impairments to determine eligibility should also be applied to children whose condition did not meet or equal the medical listing of impairments. Third, references to maladaptive behaviors in certain sections of the Listing of Impairments (among medical criteria for evaluation of mental and emotional disorders in the domain of personal\/behavioral function) were eliminated. The latter two A-37 provisions were effective for all new and pending applications upon enactment (August 22, 1996). Beneficiaries who were receiving benefits due to an IFA or under the Listings because of limitations resulting from maladaptive behaviors received notice no later than January 1, 1997, that their benefits might end when their case was redetermined. Additional provisions of PRWORA with impact on enrollment are the requirement that eligibility be redetermined when beneficiaries reach age 18, using the adult disability standard; that \”continuing disability reviews\” be done for children; and that children who were eligible due to low birth weight have their eligibility redetermined at age one. Title IV of Public Law 104-193 (PRWORA) also made significant changes in the eligibility of noncitizens for SSI benefits. Some of the restrictions were subsequently moderated by Public Law 104-208, Public Law 106-169, and most notably by the Balanced Budget Act of 1997 (Public Law 105-33), which grandfathered immigrants who were receiving SSI at the time of enactment of the PRWORA. Those immigrants who entered the U.S. after August 22, 1996, may be eligible to receive SSI after having been lawfully admitted for permanent residence. In addition, Public Law 106-386, the Victims of Trafficking and Violence Protection Act of 2000, provides that noncitizens who are victims of severe forms of trafficking in persons in the United States shall be treated as refugees for purposes of SSI and be eligible for SSI benefits for the first seven years they are in the United States. Several provisions aimed at reducing SSI fraud and improving recovery of overpayments were enacted in 1999 as part of the Foster Care Independence Act of 1999 (Public Law 106-169). Other legislation enacted in 1999 (Public Law 106-170) provides additional work incentives for disabled beneficiaries of SSI (e.g., the Ticket to Work and Self-Sufficiency Program). The Social Security Protection Act of 2004 (Public Law 108-203), enacted March 2, 2004, introduced program and beneficiary protections covering the use of representative payees and required documentation of changes in beneficiary status. It also extended SSI eligibility to blind or disabled children living with a parent assigned to permanent U.S. military duty outside of the U.S. but who were not receiving SSI while in the U.S. Furthermore, Public Law 109-163 provides that individuals who were made ineligible for SSI because of their spouses or parents being called to active military duty would not have to file a new application for SSI benefits if they again could be eligible for benefits before the end of 24 consecutive months of ineligibility. The Deficit Reduction Act of 2005 (Public Law 109-171) included two SSI program reforms, designed to improve the accuracy of disability determinations and benefit awards, among other program goals. SSI Program Data The following tables and figures provide SSI program data: Tables SSI 1 through SSI 5 and Figure SSI 1 present national caseload and expenditure trend data on the SSI program; Table SSI 6 presents demographic characteristics of the SSI caseload; Tables SSI 7 through SSI 9 present state-by-state trend data on the SSI program through fiscal year 2009. SSI Caseload Trends (Tables SSI 1 and SSI 2 and Figure SSI 1). From 1990 to 1995, the number of SSI beneficiaries increased from 4.8 million to 6.5 million, an average growth rate of over 7 percent per year. Between 1995 and 2000, the number of beneficiaries fluctuated between 6.5 and 6.6 million persons. Between 2000 and 2009, the caseload increased from 6.6 to 7.7 million beneficiaries, an average annual growth rate of 1.7 percent. Table SSI 1 presents A-38 information on the total number of persons receiving SSI payments in December of each year from 1974 through 2009, and also presents recipients by eligibility category (aged, blind, and disabled) and by type of recipient (child, adults ages 18-64, and adults ages 65 or older). See also Tables IND 3c and IND 4c in Chapter II for further data on trends in recipiency and participation. The composition of the SSI caseload has been shifting over time, as shown in Table SSI 1. The number of beneficiaries eligible because of age has been declining steadily, from a high of 2.3 million persons in December 1975 to a low of 1.2 million persons in December 2004 and has since remained essentially unchanged. At the same time, there has been growth in the number of blind and disabled beneficiaries, from 1.7 million in December 1974 to 6.5 million in December 2009. Moreover, the number of disabled children has increased, particularly during the 1990s, when the number of disabled children receiving SSI increased from 309,000 in December 1990 to 955,000 in December 1996. The number of disabled children decreased over the next three years, but has been increasing since 2000, reaching just under 1.2 million children in 2009. Several factors have contributed to the growth of the Supplemental Security Income program. Expansions in disability eligibility (particularly for mentally impaired adults and for children), increased outreach, overall growth in immigration, and transfers from state programs were among the key factors identified in a 1995 study by the Government Accountability Office (GAO). GAO concluded that three groups adults with mental impairments, children, and non-citizens accounted for nearly 90 percent of the SSI program’s growth in the early 1990s. The growth in disabled children beneficiaries is generally believed to be due to outreach activities, the Supreme Court decision in the Zebley case, expansion of the medical impairment category, and reduction in reviews of continuing eligibility.9 SSI Expenditures (Tables SSI 3 through SSI 5). The total amount of federally administered SSI benefits has increased over the past four years from $40.9 billion (inflation adjusted) in 2005 to over $46.6 billion in 2009, as shown in Table SSI 3. Average monthly federally administered benefits per person were $499 in 2009, up (3.4 percent) from the 2005 inflation adjusted benefit level of $482. For more details see Table SSI 4. SSI Recipient Characteristics (Table SSI 6). Over the last 20 years, the percentage of aged SSI recipients has dramatically decreased, while the percentage of disabled recipients has increased substantially. As shown in Table SSI 6, the proportion of SSI aged recipients has decreased significantly, from 44 percent in 1980 to under 16 percent in 2009. During the same period, the percentage of disabled recipients increased from 55 percent in 1980 to 84 percent in 2009. 9 The GAO study estimated that 87,000 children were added to the SSI caseload after the IFA for children was initiated. A-39 Figure SSI 1. SSI Recipients by Age: 1974 2009 Source: Social Security Administration, SSI Annual Statistical Report, 2009 (available at www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html). Figure SSI 2. Percent SSI Recipients by Age: 1974 2009 Source: Social Security Administration, SSI Annual Statistical Report, 2009 (available at www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html). 0.1 1.2 1.5 4.5 2.4 2.0 0 1 2 3 4 1974 1977 1980 1983 1986 1989 1992 1995 1998 2001 2005 2009 0.1 1.6 1.2 2.3 10.8 5.1 0 2 4 6 8 10 12 1974 1977 1980 1983 1986 1989 1992 1995 1998 2001 2005 2009 Adults 65 & up Adults 18-64 (In millions) Children under 18 Adults 65 & up Adults 18-64 (Percent) Children under 18 http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html\ufffd http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html\ufffd A-40 Table SSI 1. Number of Persons Receiving Federally Administered SSI Payments: 1974 2009 [In thousands] Eligibility Category Type of Recipient Blind and Disabled Adults Date Total Children Age 65 or Aged Total Blind Disabled 18-64 Older Dec 1974 3,996 2,286 1,710 75 1,636 71 1 1,503 2,422 Dec 1975 4,314 2,307 2,007 74 1,933 107 1,699 2,508 Dec 1976 4,236 2,148 2,088 76 2,012 125 1,714 2,397 Dec 1977 4,238 2,051 2,187 77 2,109 147 1,737 2,353 Dec 1978 4,217 1,968 2,249 77 2,172 166 1,747 2,304 Dec 1979 4,150 1,872 2,278 77 2,201 177 1,727 2,246 Dec 1980 4,142 1,808 2,334 78 2,256 190 1,731 2,221 Dec 1981 4,019 1,678 2,341 79 2,262 195 1,703 2,121 Dec 1982 3,858 1,549 2,309 77 2,231 192 1,655 2,011 Dec 1983 3,901 1,515 2,386 79 2,307 198 1,700 2,003 Dec 1984 4,029 1,530 2,499 81 2,419 212 1,780 2,037 Dec 1985 4,138 1,504 2,634 82 2,551 227 1,879 2,031 Dec 1986 4,269 1,473 2,796 83 2,713 241 2,010 2,018 Dec 1987 4,385 1,455 2,930 83 2,846 251 2,119 2,015 Dec 1988 4,464 1,433 3,030 83 2,948 255 2,203 2,006 Dec 1989 4,593 1,439 3,154 83 3,071 265 2,302 2,026 Dec 1990 4,817 1,454 3,363 84 3,279 309 2,450 2,059 Dec 1991 5,118 1,465 3,654 85 3,569 397 2,642 2,080 Dec 1992 5,566 1,471 4,095 85 4,010 556 2,910 2,100 Dec 1993 5,984 1,475 4,509 85 4,424 723 3,148 2,113 Dec 1994 6,296 1,466 4,830 85 4,745 841 3,335 2,119 Dec 1995 6,514 1,446 5,068 84 4,984 917 3,482 2,115 Dec 1996 6,614 1,413 5,201 82 5,119 955 3,568 2,090 Dec 1997 6,495 1,362 5,133 81 5,052 880 3,562 2,054 Dec 1998 6,566 1,332 5,234 80 5,154 887 3,646 2,033 Dec 1999 6,557 1,308 5,249 79 5,169 847 3,691 2,019 Dec 2000 6,602 1,289 5,312 79 5,234 847 3,744 2,011 Dec 2001 6,688 1,264 5,424 78 5,346 882 3,811 1,995 Dec 2002 6,788 1,252 5,537 78 5,459 915 3,878 1,995 Dec 2003 6,902 1,233 5,670 77 5,593 959 3,953 1,990 Dec 2004 6,988 1,211 5,777 76 5,701 993 4,017 1,978 Dec 2005 7,114 1,214 5,900 75 5,825 1,036 4,083 1,995 Dec 2006 7,236 1,212 6,024 73 5,951 1,079 4,152 2,004 Dec 2007 7,360 1,205 6,155 72 6,083 1,121 4,222 2,017 Dec 2008 7,521 1,203 6,317 70 6,247 1,154 4,333 2,034 Dec 2009 7,677 1,186 6,491 69 6,421 1,200 4,4451 2,026 1 Includes students 18-21 in 1974 only. Source: Social Security Administration, SSI Annual Statistical Report, 2009 (available online at www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html\ufffd A-41 Table SSI 2. SSI Recipiency Rates by Age: 1974 2009 All Recipients Adults 18-64 Child Elderly Recipients (Persons 65 & Older) as a Percent as a Percent Recipients as a Percent of of Total of 18-64 as a Percent All Persons All Elderly Date Population 1 Population 1 of All Children 1 65 & Older 1 Poor 2 Dec 1974 1.9 1.2 0.1 10.8 78.5 Dec 1975 2.0 1.3 0.2 10.9 75.6 Dec 1976 1.9 1.3 0.2 10.2 72.3 Dec 1977 1.9 1.3 0.2 9.7 74.1 Dec 1978 1.9 1.3 0.3 9.3 71.3 Dec 1979 1.8 1.3 0.3 8.8 61.0 Dec 1980 1.8 1.2 0.3 8.6 57.4 Dec 1981 1.7 1.2 0.3 8.0 55.1 Dec 1982 1.7 1.2 0.3 7.4 53.6 Dec 1983 1.7 1.2 0.3 7.3 55.3 Dec 1984 1.7 1.2 0.3 7.2 61.2 Dec 1985 1.7 1.3 0.4 7.1 58.8 Dec 1986 1.8 1.3 0.4 6.9 58.0 Dec 1987 1.8 1.4 0.4 6.7 56.6 Dec 1988 1.8 1.5 0.4 6.6 57.6 Dec 1989 1.9 1.5 0.4 6.5 60.3 Dec 1990 1.9 1.6 0.5 6.5 56.3 Dec 1991 2.0 1.7 0.6 6.5 55.0 Dec 1992 2.2 1.8 0.8 6.4 53.5 Dec 1993 2.3 2.0 1.1 6.4 56.3 Dec 1994 2.4 2.1 1.2 6.3 57.9 Dec 1995 2.4 2.1 1.3 6.2 63.7 Dec 1996 2.4 2.1 1.4 6.1 61.0 Dec 1997 2.4 2.1 1.2 6.0 60.8 Dec 1998 2.4 2.1 1.2 5.9 60.0 Dec 1999 2.3 2.1 1.2 5.8 62.7 Dec 2000 2.3 2.1 1.2 5.7 60.5 Dec 2001 2.3 2.2 1.2 5.6 58.4 Dec 2002 2.3 2.2 1.3 5.6 55.8 Dec 2003 2.4 2.2 1.3 5.5 56.0 Dec 2004 2.4 2.2 1.3 5.4 57.3 Dec 2005 2.4 2.2 1.4 5.4 55.4 Dec 2006 2.4 2.2 1.5 5.3 59.1 Dec 2007 2.4 2.2 1.5 5.3 56.7 Dec 2008 2.5 2.3 1.5 5.2 55.6 Dec 2009 2.5 2.3 1.6 5.1 59.0 1 Population numbers used for the denominators are Census Bureau resident population estimates adjusted to the December date by averaging the July 1 population of the current year with the July 1 population of the following year (resident population estimates by age are available online at www.census.gov). 2 For the number of persons (65 years of age and older living in poverty) used as the denominator, see Current Population Reports, Series P60-238. Note: Numerators for these ratios are from Table SSI 1. Rates computed by DHHS. Source: U.S. Census Bureau, Income, Poverty, and Health Insurance Coverage in the United States: 2009,\” Current Population Reports, Series P60-238 (available online at www.census.gov\/hhes\/www\/poverty.html). http:\/\/www.census.gov\/\ufffd http:\/\/www.census.gov\/hhes\/www\/poverty.html\ufffd A-42 Table SSI 3. Federally Administered SSI Benefits and Administration: 1974 2009 1 [In millions of dollars] Total Benefits Federal State Administrative Calendar Year 2009 Dollars 2 Current Dollars Payments Supplementation Costs (fiscal year) 1974 $19,555 $5,097 $3,833 $1,264 $285 1975 20,254 5,716 4,314 1,403 399 1976 19,771 5,900 4,512 1,388 500 1977 19,322 6,134 4,703 1,431 527 1978 19,226 6,372 4,881 1,491 539 1979 18,914 6,869 5,279 1,590 611 1980 19,120 7,715 5,866 1,848 668 1981 18,911 8,357 6,518 1,839 717 1982 18,578 8,705 6,907 1,798 780 1983 18,695 9,134 7,423 1,711 846 1984 19,807 10,073 8,281 1,792 864 1985 20,436 10,750 8,777 1,973 956 1986 21,924 11,741 9,498 2,243 1,023 1987 22,743 12,592 10,029 2,563 977 1988 23,355 13,405 10,734 2,671 976 1989 24,319 14,561 11,606 2,955 1,052 1990 25,666 16,133 12,894 3,239 1,075 1991 27,638 17,996 14,765 3,231 1,230 19923 32,477 21,682 18,247 3,435 1,426 1993 35,068 23,991 20,722 3,270 1,468 1994 36,196 25,291 22,175 3,116 1,780 1995 37,785 27,037 23,919 3,118 1,978 1996 38,460 28,252 25,265 2,988 1,953 1997 37,803 28,371 25,457 2,913 2,055 1998 38,647 29,408 26,405 3,003 2,304 1999 38,755 30,106 26,805 3,301 2,493 2000 38,203 30,672 27,290 3,381 2,321 2001 38,970 32,166 28,706 3,460 2,397 2002 40,202 33,719 29,899 3,820 2,522 2003 40,461 34,693 30,688 4,005 2,656 2004 40,954 36,065 31,887 4,179 2,806 2005 40,911 37,236 33,058 4,178 2,795 2006 41,371 38,889 34,736 4,153 2,916 2007 42,625 41,205 36,884 4,321 2,857 2008 42,877 43,040 38,656 4,385 2,820 2009 46,592 46,592 42,629 3,964 3,326 1 Payments and adjustments during the respective year but not necessarily accrued for that year. 2 Data adjusted for inflation by ASPE using the CPI-U-RS for calendar years. 3 The jump in benefits in 1992 is due to retroactive payments resulting from the Sullivan v. Zebley decision. Note: This table differs from earlier versions; because of variations across states in reported numbers of recipients and payment amounts of SSI state-administered state supplements, information on state-administered state supplements is no longer published by SSA. Source: Social Security Administration, SSI Annual Statistical Report, 2009 (available online at www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html); SAA Performance and Accountability Report FY 2008 (available online at http:\/\/mwww.ba.ssa.gov\/finance\/fy09_accountability.html). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html\ufffd http:\/\/mwww.ba.ssa.gov\/finance\/fy09_accountability.html\ufffd A-43 Table SSI 4. Average Monthly Federally Administered SSI Benefits: December 1975 2009 1 Total Benefits Federal State Calendar Year 2009 Dollars 2 Current Dollars Payments Supplementation 1975 $377 $106 $91 $62 1976 375 112 96 67 1977 368 117 101 67 1978 369 122 107 111 1979 411 149 119 95 1980 401 162 138 95 1981 399 176 155 92 1982 403 189 168 91 1983 418 204 182 94 1984 415 211 189 99 1985 415 218 194 99 1986 435 233 205 116 1987 431 238 208 114 1988 427 245 215 121 1989 429 257 224 128 1990 440 276 242 128 1991 448 292 260 120 1992 452 302 275 105 1993 461 315 290 100 1994 465 325 302 94 1995 469 335 313 99 1996 468 344 322 99 1997 467 351 328 102 1998 472 359 336 102 1999 474 369 342 111 2000 472 379 351 113 2001 477 394 366 114 2002 486 407 377 128 2003 487 417 384 138 2004 486 428 395 138 2005 482 439 407 156 2006 484 455 423 156 2007 485 468 437 157 2008 476 478 447 156 2009 499 499 476 125 1 Payments and adjustments during the respective year but not necessarily accrued for that year. 2 Data adjusted for inflation by ASPE using the CPI-U-RS for calendar years. Note: This table differs from earlier versions because of variations across states in reported numbers of recipients and payment amounts of SSI state-administered state supplements; information on state-administered state supplements is no longer published by SSA. Source: Social Security Administration, SSI Annual Statistical Report, 2009 (available online at www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html; SAA Performance and Accountability Report FY 2008 (available online at http:\/\/mwww.ba.ssa.gov\/finance\/fy09_accountability.html). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_asr\/2009\/index.html\ufffd http:\/\/mwww.ba.ssa.gov\/finance\/fy09_accountability.html\ufffd A-44 Table SSI 5. Number of Persons Receiving Federally Administered SSI Payments by Eligibility Category [In thousands] Month and year Total 1 Federal SSI Federally Administered State Supplementation State Supplementation Only Jan 1974……………………………… 3,216 2,956 1,480 260 Dec 1975……………………………… 4,314 3,893 1,684 421 Dec 1976……………………………… 4,236 3,799 1,638 437 Dec 1977……………………………… 4,238 3,778 1,658 460 Dec 1978……………………………… 4,217 3,755 1,681 462 Dec 1979……………………………… 4,150 3,687 1,684 462 Dec 1980……………………………… 4,142 3,682 1,685 460 Dec 1981……………………………… 4,019 3,590 1,625 429 Dec 1982……………………………… 3,858 3,473 1,550 384 Dec 1983……………………………… 3,901 3,590 1,558 312 Dec 1984……………………………… 4,029 3,699 1,607 331 Dec 1985……………………………… 4,138 3,799 1,661 339 Dec 1986……………………………… 4,269 3,922 1,723 348 Dec 1987……………………………… 4,385 4,019 1,807 366 Dec 1988……………………………… 4,464 4,089 1,885 375 Dec 1989……………………………… 4,593 4,206 1,950 387 Dec 1990……………………………… 4,817 4,412 2,058 405 Dec 1991……………………………… 5,118 4,730 2,204 389 Dec 1992……………………………… 5,566 5,202 2,372 364 Dec 1993……………………………… 5,984 5,636 2,536 348 Dec 1994……………………………… 6,296 5,965 2,628 331 Dec 1995……………………………… 6,514 6,194 2,518 320 Dec 1996……………………………… 6,614 6,326 2,421 288 Dec 1997……………………………… 6,495 6,212 2,372 283 Dec 1998……………………………… 6,566 6,289 2,412 277 Dec 1999……………………………… 6,557 6,275 2,441 282 Dec 2000……………………………… 6,602 6,320 2,481 282 Dec 2001……………………………… 6,688 6,410 2,520 278 Dec 2002……………………………… 6,788 6,505 2,462 283 Dec 2003……………………………… 6,902 6,614 2,467 288 Dec 2004……………………………… 6,988 6,695 2,498 293 Dec 2005……………………………… 7,114 6,819 2,242 295 Dec 2006……………………………… 7,236 6,939 2,269 297 Dec 2007……………………………… 7,360 7,061 2,302 298 Dec 2008……………………………… 7,521 7,219 2,344 301 Dec 2009……………………………… 7,677 7,423 2,339 254 1 Total equals the sum of \”Federal SSI\” and \”State supplementation only.\” Source: Number of persons receiving payments obtained from Social Security Administration, Office of Research, Evaluation, and Statistics, Social Security Bulletin, Annual Statistical Supplement, 2010 (available online at www.ssa.gov\/policy\/docs\/statcomps\/supplement\/2010\/index.html). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/supplement\/2010\/index.html\ufffd A-45 Table SSI 6. Characteristics of SSI Recipients by Selected Characteristics: Selected Years 1980-2009 1980 1985 1990 1994 1998 2000 2004 2009 Total Ages 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 under 18 5.5 5.5 6.4 13.4 13.5 12.8 14.2 15.6 18-64 40.9 45.4 50.9 53.0 55.5 56.7 57.6 58.0 65 or older 53.6 49.1 42.7 33.7 31.0 30.5 28.2 26.4 Sex Male 34.4 35.2 37.2 41.3 41.3 41.5 42.7 44.8 Female 65.5 64.8 62.8 58.7 58.7 58.5 57.3 55.2 Selected Sources of Income Earnings 3.2 3.8 4.7 4.2 4.5 4.4 3.4 3.4 Social Security 51.0 49.4 45.9 39.1 36.5 36.1 34.9 34.2 No other income 34.8 34.5 36.4 43.6 47.3 54.4 55.5 56.5 Noncitizens NA 5.1 9.0 11.7 10.2 10.5 9.7 8.4 Eligibility Category Aged 43.6 36.4 30.2 23.3 20.3 19.5 17.3 15.4 Blind 1.9 2.0 1.7 1.4 1.2 1.2 1.1 0.9 Disabled 54.5 61.7 68.1 75.4 78.5 79.3 81.6 83.6 Aged Ages 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 65-69 14.0 14.9 19.4 20.5 17.6 15.6 15.0 15.1 70-79 51.5 45.6 41.3 44.3 48.4 50.0 47.3 44.2 80 or older 34.5 39.5 39.2 35.1 34.0 34.5 37.6 40.8 Sex Male 27.3 25.5 25.1 26.8 27.8 29.0 30.7 33.0 Female 72.6 74.5 74.9 73.2 72.2 71.0 69.3 67.0 Noncitizens NA 9.7 19.4 30.0 27.0 28.5 28.3 26.7 Blind and Disabled Ages 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 18-64 80.2 77.7 80.0 83.4 83.6 83.8 83.9 84.0 65 or older 19.8 22.3 20.0 16.6 16.4 16.2 16.0 15.8 Sex1 Male 39.8 40.8 42.4 41.8 41.1 44.5 41.1 42.6 Female 60.2 59.2 57.6 58.2 58.9 55.5 58.9 57.4 Noncitizens NA 2.4 4.6 6.2 5.5 6.2 5.8 5.1 Children Ages 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 Under 5 11.7 NA NA 15.8 15.8 15.5 15.9 16.1 5-9 20.9 NA NA 28.5 30.2 28.5 26.8 29.1 10-14 28.8 NA NA 32.7 34.6 36.2 36.2 33.6 15-17 21.7 NA NA 17.3 19.4 19.8 21.1 21.3 18-212 16.8 14.3 9.3 5.7 \u2014 \u2014 \u2014 \u2014 Sex Male NA NA NA 63.0 62.9 63.8 65.0 66.0 Female NA NA NA 37.0 37.1 36.2 35.0 34.0 Note: Data are for December of the year. 1 For 1980-1992 male-female classification reflects all blind and disabled, both children and adults; thereafter, it is based on adults only. 2 In this table, students 18-21 are classified as children prior to 1998. Source: Social Security Administration, Social Security Bulletin, Annual Statistical Supplement, 2010 and prior years (available online at www.ssa.gov\/policy\/docs\/statcomps\/supplement\/2010\/). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/supplement\/2010\/\ufffd A-46 Table SSI 7. Total Federally Administered SSI Payments by State: Calendar Year 2009 [In thousands] Federally administered State Total Federal Federal SSI state supplementation Total $46,592,308 $42,628,706 $3,963,602 Alabama 960,005 960,005 – Alaska 67,440 67,440 – Arizona 612,170 612,170 – Arkansas 572,704 572,704 – California 9,082,274 6,125,159 2,957,115 Colorado 349,825 349,825 – Connecticut 325,218 325,218 – Delaware 86,510 85,517 993 District of Columbia 143,189 139,028 4,161 Florida 2,595,668 2,595,668 – Georgia 1,264,015 1,264,015 – Hawaii 151,379 135,414 15,965 Idaho 145,631 145,631 – Illinois 1,621,736 1,621,736 – Indiana 673,252 673,252 – Iowa 256,272 251,102 5,170 Kansas 260,049 260,049 – Kentucky 1,076,749 1,076,749 – Louisiana 947,234 947,234 – Maine 188,521 188,521 – Maryland 622,891 622,891 – Massachusetts 1,152,092 972,683 179,409 Michigan 1,479,092 1,457,653 21,439 Minnesota 488,129 488,129 – Mississippi 681,440 681,440 – Missouri 738,140 738,140 – Montana 91,829 90,841 988 Nebraska 136,140 136,140 – Nevada 218,295 212,271 6,024 New Hampshire 93,240 93,240 – New Jersey 957,427 867,099 90,328 New Mexico 326,987 326,987 – New York 4,335,563 3,722,605 612,958 North Carolina 1,187,361 1,187,361 – North Dakota 40,902 40,902 – Ohio 1,694,864 1,694,864 – Oklahoma 515,321 515,321 – Oregon 405,574 405,574 – Pennsylvania 2,142,123 2,100,476 41,647 Rhode Island 188,980 171,296 17,684 South Carolina 617,298 617,298 – South Dakota 70,565 70,565 – Tennessee 967,111 967,111 – Texas 3,126,279 3,126,279 – Utah 150,696 150,616 80 Vermont 82,239 72,598 9,641 Virginia 789,610 789,610 – Washington 817,634 817,634 – West Virginia 461,631 461,631 – Wisconsin 594,237 594,237 – Wyoming 33,051 33,051 – Other: N. Mariana Islands 5,726 5,726 – 1 Columns may not add to totals since the totals may include a small amount of payments not distributed by jurisdiction. Source: Social Security Administration, Office of Research, Evaluation, and Statistics, Social Security Bulletin, Annual Statistical Supplement, 2010 (available online at www.ssa.gov\/policy\/docs\/statcomps\/). http:\/\/www.ssa.gov\/policy\/docs\/statcomps\/\ufffd A-47 Table SSI 8. State Recipiency Rates for Federally Administered SSI Payments by Age: 1996 & 2009 [In percent] Rate for Children 0-17 Rate for Adults 18-64 Rate for Adults 65 & Over Percent Percent Percent Change Change Change State 1996 2009 1996-09 1996 2009 1996-09 1996 2009 1996-09 Alabama 0.4 2.7 534 3.1 3.7 18 9.7 4.7 -52 Alaska 0.1 0.7 465 1.2 1.7 42 5.5 5.8 5 Arizona 0.1 1.2 1297 1.6 1.5 -3 3.5 2.9 -17 Arkansas 0.4 3.5 714 3.0 3.5 15 8.5 4.0 -53 California 0.2 1.2 371 2.6 2.6 -1 13.0 13.0 -0 Colorado 0.2 0.7 301 1.4 1.2 -13 3.6 2.8 -23 Connecticut 0.2 0.9 404 1.4 1.6 13 2.5 2.7 7 Delaware 0.3 1.7 504 1.4 1.7 23 2.8 2.0 -29 District of Columbia 0.1 3.9 2673 3.2 3.6 12 7.6 6.0 -21 Florida 0.2 2.2 1314 1.9 2.0 5 5.1 4.8 -5 Georgia 0.2 1.5 519 2.2 2.1 -5 9.2 4.9 -47 Hawaii 0.1 0.6 521 1.3 1.7 37 6.1 4.5 -26 Idaho 0.2 1.2 672 1.5 1.8 24 2.3 1.9 -16 Illinois 0.1 1.4 896 2.2 2.0 -9 3.9 3.7 -5 Indiana 0.1 1.6 1143 1.5 1.9 23 2.0 1.5 -24 Iowa 0.2 1.1 364 1.5 1.7 14 2.1 1.6 -24 Kansas 0.2 1.2 383 1.4 1.7 15 2.1 1.8 -13 Kentucky 0.3 3.0 873 4.3 4.6 7 8.3 5.7 -32 Louisiana 0.7 3.0 326 3.5 3.6 4 10.2 5.9 -42 Maine 0.3 1.4 467 2.3 3.0 29 4.0 2.5 -36 Maryland 0.2 1.2 441 1.4 1.7 19 4.4 3.6 -19 Massachusetts 0.4 1.5 281 2.6 2.7 5 5.9 5.6 -5 Michigan 0.2 1.7 936 2.3 2.6 16 3.3 2.8 -14 Minnesota 0.2 1.0 467 1.3 1.6 20 2.6 2.7 4 Mississippi 0.5 3.1 482 4.2 4.1 -3 14.2 7.0 -51 Missouri 0.3 1.5 423 2.1 2.3 12 3.7 2.3 -37 Montana 0.2 1.1 453 1.7 1.9 12 2.4 1.8 -24 Nebraska 0.2 0.9 283 1.3 1.5 17 2.1 1.6 -21 Nevada 0.1 1.1 1371 1.2 1.3 8 3.6 3.3 -7 New Hampshire 0.1 0.8 558 1.0 1.5 51 1.5 1.1 -29 New Jersey 0.3 1.2 328 1.5 1.6 6 4.6 4.5 -1 New Mexico 0.2 1.7 609 2.3 2.8 20 8.1 6.1 -24 New York 0.5 1.8 235 2.7 2.8 5 8.9 8.9 0 North Carolina 0.2 1.8 795 2.1 2.1 3 7.3 3.8 -48 North Dakota 0.1 0.8 453 1.3 1.3 4 2.9 1.7 -40 Ohio 0.2 1.7 658 2.3 2.6 12 2.7 2.4 -10 Oklahoma 0.3 1.9 531 2.0 2.6 28 5.2 3.0 -43 Oregon 0.2 1.1 400 1.5 1.9 23 2.6 2.8 9 Pennsylvania 0.3 2.4 615 2.2 2.8 28 3.6 3.1 -12 Rhode Island 0.3 1.9 488 2.4 3.0 22 4.9 4.7 -4 South Carolina 0.3 1.9 628 2.5 2.3 -5 8.2 3.6 -55 South Dakota 0.3 1.2 366 1.7 1.7 -4 3.5 2.6 -26 Tennessee 0.3 1.7 432 3.1 2.8 -8 7.8 3.9 -50 Texas 0.3 1.7 472 1.6 2.0 25 8.6 6.5 -24 Utah 0.1 0.6 464 1.1 1.0 -7 2.0 1.7 -13 Vermont 0.3 1.4 462 2.2 2.6 18 4.8 2.8 -42 Virginia 0.2 1.3 440 1.6 1.7 8 5.6 3.6 -36 Washington 0.2 1.1 475 1.7 2.0 13 3.4 3.7 9 West Virginia 0.3 2.4 859 4.1 5.1 26 5.3 4.1 -23 Wisconsin 0.3 1.5 346 1.7 1.9 10 2.7 2.1 -24 Wyoming 0.1 0.7 826 1.2 1.3 4 1.9 1.2 -37 Total 0.3 1.6 481 2.2 2.3 7 6.2 5.1 -17 Note: Recipiency rates for 2009 are the ratios of the number of SSI recipients (in the respective age groups) as of the month of December to the estimated population in the respective age group as of the month of July; calculations by DHHS. Source: Social Security Administration, Supplemental Security Income, Annual Statistical Report, 2009 and U.S. Census Bureau (resident population by state available online at www.census.gov\/population\/estimates\/state\/). http:\/\/www.census.gov\/population\/estimates\/state\/\ufffd A-48 Table SSI 9. SSI Recipiency Rates as Percent of Population by State: Selected Years 1980 2009 [In Percent] State 1980 1985 1990 1996 2 1998 2 2000 2 2002 2 2004 2 2006 2 2008 2 2009 2 Alabama 3.4 3.3 3.3 3.9 3.8 3.6 3.6 3.6 3.6 3.6 3.6 Alaska 0.8 0.7 0.8 1.2 1.3 1.4 1.5 1.6 1.7 1.7 1.7 Arizona 1.1 1.0 1.2 1.7 1.7 1.6 1.6 1.6 1.6 1.6 1.6 Arkansas 3.4 3.1 3.2 3.8 3.5 3.2 3.1 3.2 3.3 3.5 3.6 California 3.0 2.6 2.9 3.3 3.2 3.2 3.2 3.3 3.4 3.5 3.4 Colorado 1.0 0.9 1.1 1.5 1.4 1.2 1.2 1.2 1.2 1.2 1.2 Connecticut 0.8 0.8 1.0 1.4 1.4 1.4 1.5 1.5 1.5 1.6 1.6 Delaware 1.2 1.2 1.2 1.6 1.6 1.5 1.6 1.6 1.6 1.7 1.7 District of Columbia 2.4 2.5 2.7 3.7 3.8 3.5 3.5 3.8 3.7 3.9 3.9 Florida 1.8 1.6 1.7 2.4 2.4 2.4 2.4 2.4 2.4 2.4 2.5 Georgia 2.8 2.6 2.5 2.7 2.6 2.4 2.3 2.3 2.2 2.2 2.2 Hawaii 1.1 1.1 1.3 1.6 1.6 1.7 1.7 1.8 1.8 1.8 1.9 Idaho 0.8 0.8 1.0 1.5 1.4 1.4 1.4 1.5 1.6 1.6 1.7 Illinois 1.1 1.2 1.6 2.3 2.1 2.0 2.0 2.0 2.0 2.1 2.1 Indiana 0.8 0.9 1.1 1.6 1.5 1.4 1.5 1.5 1.6 1.7 1.8 Iowa 0.9 1.0 1.2 1.5 1.4 1.4 1.4 1.4 1.5 1.5 1.5 Kansas 0.9 0.9 1.0 1.5 1.4 1.3 1.4 1.4 1.4 1.5 1.6 Kentucky 2.6 2.7 3.1 4.4 4.4 4.3 4.3 4.3 4.3 4.4 4.4 Louisiana 3.2 2.9 3.2 4.2 4.0 3.7 3.7 3.8 3.7 3.8 3.8 Maine 1.9 1.9 1.9 2.2 2.3 2.3 2.4 2.4 2.5 2.6 2.6 Maryland 1.1 1.2 1.3 1.7 1.7 1.7 1.6 1.7 1.7 1.8 1.8 Massachusetts 2.2 1.9 2.0 2.7 2.7 2.6 2.6 2.6 2.7 2.8 2.8 Michigan 1.2 1.4 1.5 2.2 2.2 2.1 2.1 2.2 2.2 2.3 2.4 Minnesota 0.8 0.8 0.9 1.4 1.3 1.3 1.3 1.4 1.5 1.5 1.6 Mississippi 4.4 4.3 4.4 5.2 4.9 4.5 4.4 4.3 4.2 4.2 4.2 Missouri 1.7 1.6 1.7 2.2 2.1 2.0 2.0 2.0 2.1 2.1 2.1 Montana 0.9 0.9 1.3 1.6 1.6 1.5 1.6 1.6 1.6 1.7 1.7 Nebraska 0.9 0.9 1.0 1.3 1.3 1.2 1.3 1.3 1.3 1.3 1.4 Nevada 0.8 0.9 1.0 1.4 1.3 1.3 1.3 1.4 1.4 1.4 1.5 New Hampshire 0.6 0.6 0.6 0.9 1.0 0.9 1.0 1.0 1.1 1.2 1.3 New Jersey 1.2 1.2 1.4 1.8 1.8 1.7 1.7 1.7 1.8 1.8 1.9 New Mexico 1.9 1.8 2.1 2.7 2.6 2.6 2.6 2.7 2.8 2.9 2.9 New York 2.1 2.0 2.3 3.3 3.3 3.3 3.3 3.3 3.3 3.4 3.4 North Carolina 2.4 2.2 2.2 2.7 2.6 2.4 2.3 2.3 2.3 2.3 2.3 North Dakota 1.0 1.0 1.2 1.4 1.3 1.3 1.3 1.3 1.3 1.3 1.3 Ohio 1.1 1.2 1.4 2.3 2.2 2.1 2.1 2.1 2.2 2.3 2.4 Oklahoma 2.2 1.8 1.9 2.3 2.2 2.1 2.1 2.2 2.3 2.4 2.5 Oregon 0.8 1.0 1.1 1.5 1.5 1.5 1.6 1.6 1.7 1.8 1.8 Pennsylvania 1.4 1.4 1.6 2.2 2.3 2.3 2.4 2.6 2.6 2.7 2.8 Rhode Island 1.6 1.6 1.7 2.6 2.6 2.6 2.7 2.7 2.9 3.0 3.0 South Carolina 2.7 2.6 2.6 3.0 2.9 2.7 2.6 2.5 2.4 2.4 2.4 South Dakota 1.2 1.2 1.5 1.9 1.8 1.7 1.7 1.6 1.6 1.6 1.7 Tennessee 2.8 2.7 2.9 3.4 3.1 2.9 2.8 2.7 2.7 2.7 2.7 Texas 1.8 1.6 1.7 2.2 2.1 2.0 2.0 2.1 2.2 2.3 2.4 Utah 0.5 0.5 0.7 1.1 1.0 0.9 0.9 0.9 0.9 0.9 1.0 Vermont 1.7 1.8 1.8 2.2 2.1 2.1 2.1 2.1 2.1 2.3 2.4 Virginia 1.5 1.5 1.5 2.0 2.0 1.9 1.8 1.8 1.8 1.8 1.8 Washington 1.1 1.1 1.3 1.7 1.7 1.7 1.7 1.8 1.9 1.9 2.0 West Virginia 2.1 2.2 2.6 3.8 3.9 3.9 4.1 4.2 4.3 4.4 4.4 Wisconsin 1.4 1.5 1.8 1.8 1.7 1.6 1.6 1.6 1.7 1.8 1.8 Wyoming 0.4 0.5 0.8 1.2 1.2 1.2 1.1 1.1 1.1 1.1 1.1 Total 1 1.8 1.7 1.9 2.5 2.4 2.3 2.4 2.4 2.4 2.5 2.5 1 The number of SSI recipients used to calculate the total recipiency rate includes a certain number of recipients whose State is unknown. For 1985, the numbers of unknown (in thousands) were 14. 2 For 1975-92 the percentages are calculated as the average number of monthly SSI recipients over the total population of each State in July of that year. For 1994-2009 the number of recipients is from the month of December; calculations by DHHS. Source: Social Security Administration, Supplemental Security Income, Annual Statistical Report, 2010, and U.S. Census Bureau (resident population by state available online at www.census.gov\/population\/estimates\/state\/). http:\/\/www.census.gov\/population\/estimates\/state\/\ufffd Appendix B Alternative Definition of Dependence Based on Income from TANF and SNAP Appendix B. Alternative Definition of Dependence Based on Income from TANF and SNAP As directed by the Welfare Indicators Act of 1994 (Public Law 103-432), this report on Indicators of Welfare Dependence focuses on dependence on three programs: the Temporary Assistance for Needy Families (TANF) program, formerly the Aid to Families with Dependent Children (AFDC) program; the Supplemental Nutrition Assistance Program (SNAP) (formerly the Food Stamp Program); and the Supplemental Security Income (SSI) program. We adopt the following definition of welfare dependence for this report: Welfare dependence is the proportion of all individuals in families that receive more than half of their total family income in one year from TANF, SNAP and\/or SSI. This appendix examines an alternative definition of dependence that considers TANF and SNAP alone, excluding SSI. As shown in Table B-1, the rate of dependency would have been much lower only 2.7 percent in 2009 if based on income from TANF and SNAP, as opposed to 4.6 percent when counting income from all three programs (TANF, SNAP, and SSI). There also is significant variation across age groups in the programs upon which individuals are dependent. The elderly depend more on SSI than on TANF and SNAP; whereas 2.2 percent of elderly persons are dependent when counting the three major types of means-tested assistance, very few, 0.3 percent, are dependent when the definition is limited to TANF and SNAP. In contrast, children are primarily dependent on TANF and SNAP. Dependency on AFDC\/TANF and SNAP receipt has generally declined since 1995 but there is a noteworthy uptick in 2009 related to the 2007-2009 recession. Dependency on SSI receipt alone has remained relatively stable overall as shown in Table B-2. As a result, the difference between the standard definition (based on all three programs) and the alternative definition (based on TANF and SNAP only) has grown somewhat. In 1995, over two-thirds (68 percent) of individuals who were dependent under the standard definition also were dependent under the alternative definition shown in this appendix. By 2009, the proportion had dropped to 59 percent. If this report had focused on the alternative definition of dependence, it would have shown an even larger decline in dependence than usually reported. For example, between 1995 and 2009, dependency declined by 25 percent (3.6 percent to 2.7 percent) under the alternative definition, compared to a decline of 13 percent (5.3 percent to 4.6 percent) under the standard definition. B-1 Table B-1. Percentage of the Total Population with More than 50 Percent of Income from Various Means-Tested Assistance Programs by Selected Characteristics: 2005 TANF, SSI & SNAP TANF & SNAP SSI Only All Persons 3.8 2.1 1.4 Racial\/Ethnic Categories Non-Hispanic White 2.2 1.1 .9 Non-Hispanic Black 10.2 5.7 3.2 Hispanic 5.6 3.5 1.7 Age Categories Children ages 0-5 7.4 5.1 1.4 Children ages 6-10 6.1 4.4 1.1 Children ages 11-15 5.5 3.5 1.3 Women ages 16-64 4.0 2.2 1.5 Men ages 16-64 2.4 1.1 1.1 Adults ages 65 and over 2.2 0.2 1.7 Family Categories Persons in married families 1.1 0.5 0.4 Persons in female-headed families 14.0 8.7 3.6 Persons in male-headed (no spouse) families 4.3 2.3 1.6 Unrelated persons 4.7 1.8 2.8 Note: Income is measured as total family income. Persons of Hispanic ethnicity may be of any race. Beginning in 2002, estimates for Whites and Blacks are for persons reporting a single race only. Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the total for all persons but are not shown separately. Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 2006, analyzed using the TRIM3 microsimulation model. Table B-2. Percentage of the Total Population with More than 50 Percent of Income from Various Means-Tested Assistance Programs: 1995-2005 TANF, SSI & SNAP TANF & SNAP SSI Only 1995 5.3 3.6 1.1 1998 3.8 2.1 1.3 1999 3.3 1.7 1.2 2000 3.0 1.5 1.2 2001 3.1 1.4 1.3 2002 3.2 1.5 1.3 2003 3.6 1.9 1.3 2004 3.7 2.0 1.3 2005 3.8 2.1 1.4 Source: Unpublished tabulations from the Current Population Survey, Annual Social and Economic Supplement, 1996-2006, analyzed using the TRIM3 microsimulation model. B-2 Appendix C Additional Nonmarital Birth Data Appendix C. Additional Nonmarital Birth Data Table C-1. Percentage of Births to Unmarried Women within Age Groups by Race and Ethnicity: Selected Years 1940-2009 White Black1 Hispanic2 Total Age Age Total Total Age Age Total Total Age Age Total Teens 3 15 – 17 18 – 19 Women Teens 15 – 17 18 – 19 Women Teens 15 – 17 18 – 19 Women 1940 7 2 36 17 1945 10 2 41 18 1950 6 10 5 2 37 48 28 18 1955 7 10 5 2 42 52 33 20 1960 7 12 5 2 43 54 34 22 1965 12 17 9 4 51 63 39 26 1970 17 25 14 6 64 76 52 38 1975 23 33 17 7 78 87 68 49 1980 34 45 27 11 86 93 80 56 42 51 36 24 1985 45 58 38 15 91 96 86 61 61 46 30 1990 57 68 51 20 92 96 89 67 62 68 54 37 1991 59 70 53 22 93 96 90 68 64 69 56 38 1992 61 71 55 23 93 96 90 68 65 69 57 39 1993 63 72 57 24 93 96 91 69 66 69 58 40 1994 68 78 62 25 95 98 93 70 73 77 65 43 1995 68 77 62 25 95 98 93 70 71 75 62 41 1996 69 79 63 26 96 98 94 70 71 75 63 41 1997 71 82 65 26 96 98 94 69 76 80 66 41 1998 72 83 67 26 96 98 94 69 77 82 67 42 1999 73 83 67 27 96 98 94 69 76 82 67 42 2000 73 83 68 27 96 98 94 69 76 82 67 43 2001 73 83 68 28 96 99 94 68 75 81 67 42 2002 75 85 70 28 96 99 94 68 77 83 69 44 2003 77 86 72 29 96 99 95 68 80 85 71 45 2004 78 87 74 31 96 99 95 69 81 86 73 46 2005 79 88 75 32 96 99 95 69 83 87 75 48 2006 80 89 76 33 97 99 95 70 84 89 76 50 2007 82 90 78 35 97 99 96 71 86 90 78 51 2008 83 92 79 36 97 99 96 72 88 92 80 53 2009 84 92 80 36 97 99 96 72 89 94 81 53 Note: Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non- marital births when marital status is not reported. In particular, the increases from 1993 to 1994 to a great extent reflect improvements in the completeness of reporting of nonmarital births in two states, Michigan and Texas. 1 From 1940 to 1965, the percentage of births to unmarried Black women (shown in italics) includes all unmarried Non-white. 2 Persons of Hispanic origin may be of any race. Data for Hispanics have been available only since 1980, with 22 states reporting in 1980, representing 90 percent of the Hispanic population. Hispanic birth data were reported by 23 states and the District of Columbia in 1985; 48 states and the District of Columbia in 1990; 49 states and the District of Columbia in 1991 and 1992; and all 50 states and the District of Columbia since 1993. 3 Teens under 15 included in Total Teen but not shown separately. Source: National Center for Health Statistics, Births of Hispanic Parentage, 1980, Monthly Vital Statistics Report, Vol. 32, No. 6 Supplement; Births of Hispanic Parentage, 1985, Monthly Vital Statistics Report, Vol. 36, No. 11 Supplement; Nonmarital Childbearing in the United States, 1940 – 1999, National Vital Health Statistics Reports, Vol. 48 (16); Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), and earlier reports. Additional calculations by ASPE staff. C-1 Table C-2. Percentage of Births that are to Unmarried Women by State: Selected Years 1960-2009 1960 1970 1980 1990 1995 2000 2005 2009 Alabama 11 14 22 30 34 34 36 40 Alaska 5 9 16 26 30 33 36 38 Arizona NA 9 19 33 38 39 43 45 Arkansas NA 13 20 29 33 36 40 45 California NA NA 21 32 32 33 36 40 Colorado NA 9 13 21 25 25 27 25 Connecticut NA NA 18 27 31 29 32 36 Delaware 9 15 24 29 35 38 44 48 Dist of Columbia 20 38 56 65 66 60 56 58 Florida 9 14 23 32 36 38 43 47 Georgia NA NA 23 33 35 37 41 45 Hawaii 5 10 18 25 29 32 36 38 Idaho NA NA 8 17 20 22 23 25 Illinois 6 13 23 32 34 35 37 41 Indiana 4 8 16 26 32 35 40 43 Iowa 2 7 10 21 25 28 32 35 Kansas 3 7 12 22 26 29 34 38 Kentucky 5 8 15 24 29 31 36 41 Louisiana 9 15 23 37 42 46 48 53 Maine 3 7 14 23 28 31 35 40 Maryland NA NA 25 30 33 35 37 42 Massachusetts NA NA 16 25 26 27 30 34 Michigan 4 11 16 26 34 33 37 40 Minnesota 3 8 11 21 24 26 30 33 Mississippi 14 17 28 40 45 46 49 54 Missouri 6 11 18 29 32 35 38 41 Montana NA NA 13 24 26 31 35 37 Nebraska NA 8 12 21 24 27 31 34 Nevada 4 11 13 25 42 36 41 43 New Hampshire NA 6 11 17 22 25 27 33 New Jersey 4 10 21 24 28 29 31 35 New Mexico NA NA 16 35 43 46 51 53 New York NA NA 24 33 38 37 39 41 North Carolina 9 12 19 29 31 33 38 42 North Dakota 3 7 9 18 24 28 32 34 Ohio 4 NA 18 29 33 35 39 43 Oklahoma NA 8 14 25 30 34 39 42 Oregon 3 7 15 26 29 30 33 36 Pennsylvania 4 10 18 29 32 33 37 41 Rhode Island 3 7 16 26 31 35 39 44 South Carolina 12 15 23 33 37 40 43 48 South Dakota 3 7 13 23 28 33 36 38 Tennessee 9 12 20 30 33 35 40 44 Texas 5 9 13 18 30 31 38 42 Utah 2 4 6 14 16 17 18 20 Vermont NA NA 14 20 25 28 32 39 Virginia 8 11 19 26 29 30 32 36 Washington 3 9 14 24 27 28 31 34 West Virginia 6 6 13 25 31 32 37 42 Wisconsin 3 8 14 24 27 29 32 36 Wyoming 2 7 8 20 26 29 33 35 United States 5 11 18 28 32 33 37 41 Source: National Center for Health Statistics, Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011 and earlier reports. C-2 Table C-3. Percentage of Births that are to Unmarried Women by Race and Ethnicity and State: 1994 and 2009 Non-Hispanic All races White Black Hispanic\u2020 State 1994 2009 1994 2009 1994 2009 1994 2009 Alabama 35 41 16 27 71 74 19 26 Alaska 29 38 21 24 41 48 29 37 Arizona 38 45 25 30 65 62 51 57 Arkansas 33 45 20 35 74 82 31 50 California 36 41 23 24 63 69 46 53 Colorado 25 25 18 18 57 49 44 36 Connecticut 31 38 18 23 70 68 65 66 Delaware 35 48 22 34 74 72 50 65 Dist. of Columbia 69 56 10 6 81 79 59 67 Florida 36 48 24 36 69 71 34 51 Georgia 36 45 18 27 68 71 23 52 Hawaii 28 38 15 25 19 26 44 50 Idaho 19 26 17 22 42 31 25 44 Illinois 34 41 18 26 79 81 38 52 Indiana 32 44 26 37 78 81 42 58 Iowa 25 35 23 32 75 74 37 52 Kansas 26 38 21 31 67 74 39 54 Kentucky 28 41 23 37 73 77 25 54 Louisiana 43 54 21 35 73 80 30 58 Maine 28 41 28 41 45 34 23 48 Maryland 34 43 18 27 64 65 39 57 Massachusetts 27 35 19 26 63 59 62 68 Michigan 35 41 23 31 79 80 42 51 Minnesota 24 34 20 26 75 62 46 58 Mississippi 45 55 18 32 75 82 21 57 Missouri 33 41 24 33 79 80 34 53 Montana 26 36 20 30 29 48 30 50 Nebraska 25 34 20 28 74 71 39 51 Nevada 35 43 27 31 70 72 44 53 New Hampshire 22 33 21 34 33 45 37 49 New Jersey 28 35 13 18 68 69 48 59 New Mexico 42 53 23 32 60 60 49 60 New York 38 42 19 25 70 70 61 66 North Carolina 32 42 17 27 68 73 29 54 North Dakota 23 33 19 26 24 33 26 44 Ohio 33 44 25 36 78 80 50 63 Oklahoma 30 42 23 35 70 76 31 46 Oregon 29 35 27 32 72 65 35 48 Pennsylvania 33 41 23 31 80 78 63 66 Rhode Island 32 45 24 35 70 67 58 65 South Carolina 37 48 19 31 67 78 28 47 South Dakota 28 38 20 28 21 54 33 58 Tennessee 33 45 21 34 75 79 26 54 Texas 29 42 18 27 63 67 31 50 Utah 16 19 13 13 52 47 37 45 Vermont 25 40 25 40 32 42 34 52 Virginia 29 36 18 24 64 67 38 52 Washington 26 34 23 28 56 53 35 51 West Virginia 30 44 29 42 76 78 22 46 Wisconsin 27 37 20 28 82 85 46 56 Wyoming 28 34 25 30 42 48 45 52 United States 33 41 21 29 71 73 43 53 \u2020 Women of Hispanic origin may be of any race. Source: National Center for Health Statistics, Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011 and earlier reports. C-3 Table C-4. Birth Rates of Teens 15-19 Years by State: Selected Years 1960-2009 [Births per 1,000 women in specified group] State 1960 1970 1980 1985 1990 1995 2000 2005 2009 Alabama 104 90 68 64 71 69 61 50 51 Alaska 128 103 64 56 65 55 49 37 45 Arizona 112 79 65 67 76 74 68 58 51 Arkansas 116 93 75 73 80 72 66 59 59 California 103 69 53 53 71 67 47 39 37 Colorado 97 67 50 48 55 52 51 43 39 Connecticut 54 44 31 31 39 39 31 23 21 Delaware 100 73 51 51 55 55 48 44 35 Dist. of Columbia 132 116 62 72 93 85 53 63 48 Florida 117 86 59 58 69 60 51 42 39 Georgia 117 101 72 68 76 70 63 53 48 Hawaii 77 66 51 48 61 49 46 36 41 Idaho 102 66 59 47 51 49 43 38 36 Illinois 63 63 56 51 63 58 48 39 36 Indiana 100 75 57 52 59 57 49 43 43 Iowa 73 53 43 35 41 38 34 33 32 Kansas 94 65 57 52 56 52 46 41 44 Kentucky 108 86 72 63 68 62 55 49 51 Louisiana 113 84 76 72 74 70 62 49 53 Maine 93 65 47 42 43 34 29 24 24 Maryland 100 69 43 46 53 47 41 32 31 Massachusetts 51 40 28 29 35 33 26 22 20 Michigan 80 69 45 43 59 49 40 32 33 Minnesota 64 44 35 31 36 33 30 26 24 Mississippi 121 103 84 76 81 79 70 61 64 Missouri 99 72 58 54 63 55 49 42 42 Montana 97 62 48 44 48 42 37 35 39 Nebraska 82 54 45 40 42 38 38 34 35 Nevada 118 94 59 55 73 73 63 50 47 New Hampshire 76 55 34 32 33 30 23 18 16 New Jersey 58 50 35 34 41 38 32 23 23 New Mexico 127 79 72 73 78 74 66 62 64 New York 57 51 35 36 44 42 33 27 24 North Carolina 104 88 58 57 68 63 59 48 45 North Dakota 68 44 42 36 35 33 27 30 28 Ohio 84 65 52 50 58 53 46 39 39 Oklahoma 112 83 75 69 67 64 60 54 60 Oregon 88 58 51 43 55 50 43 33 33 Pennsylvania 67 53 41 40 45 41 34 30 29 Rhode Island 56 43 33 36 44 40 34 31 27 South Carolina 109 89 65 63 71 63 58 51 49 South Dakota 83 49 53 46 47 41 38 38 38 Tennessee 103 88 64 61 72 67 60 55 51 Texas 115 85 74 72 75 76 69 62 61 Utah 86 56 65 50 49 41 38 33 31 Vermont 74 54 39 36 34 28 23 19 17 Virginia 103 76 48 46 53 48 41 34 31 Washington 88 60 47 45 53 48 39 31 32 West Virginia 87 72 68 54 57 53 47 43 50 Wisconsin 64 46 40 39 43 38 35 30 29 Wyoming 112 71 79 59 56 48 42 43 45 United States 89 68 53 51 60 56 48 40 39 Source: National Center for Health Statistics, Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1),November 2011 and earlier reports available online at (http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm). C-4 http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm\ufffd Table C-5. Birth Rates of Teens 15-19 Years by Race and Ethnicity and State: Selected Years [Births per 1,000 women in specified group] All races Non-Hispanic White Non-Hispanic Black Hispanic\u2020 State 1990 2000 2009 1990 2000 2009 1990 2000 2009 1990 2000 2009 Alabama 71 61 51 55 49 42 106 82 62 34 107 114 Alaska 65 49 45 53 32 26 \u2021 \u2021 38 \u2021 74 53 Arizona 76 68 51 51 39 27 124 79 49 123 115 79 Arkansas 80 66 59 66 56 52 132 98 80 \u2021 103 78 California 71 47 37 43 23 14 109 58 42 112 79 60 Colorado 55 51 39 39 31 21 112 84 44 111 114 88 Connecticut 39 31 21 20 15 8 108 65 39 122 90 70 Delaware 55 48 35 35 31 20 121 87 59 \u2021 103 82 Dist. of Columbia 93 53 48 11 \u2021 \u2021 123 77 64 89 80 82 Florida 69 51 39 51 37 27 138 85 62 60 59 47 Georgia 76 63 48 56 47 32 117 82 57 73 132 106 Hawaii 61 46 41 38 21 30 \u2021 \u2021 17 133 99 163 Idaho 51 43 36 46 36 29 \u2021 \u2021 \u2021 119 105 79 Illinois 63 48 36 37 26 20 146 96 68 95 90 65 Indiana 59 49 43 52 42 36 124 92 70 65 95 81 Iowa 41 34 32 38 30 27 119 89 80 80 97 89 Kansas 56 46 44 49 37 33 135 89 74 86 100 103 Kentucky 68 55 51 64 52 48 116 84 65 \u2021 92 101 Louisiana 74 62 53 53 43 40 113 92 69 21 40 70 Maine 43 29 24 43 29 24 \u2021 \u2021 \u2021 \u2021 \u2021 \u2021 Maryland 53 41 31 36 27 17 97 68 48 46 63 75 Massachusetts 35 26 20 24 16 12 94 53 34 121 87 65 Michigan 59 40 33 41 30 23 132 81 65 94 81 63 Minnesota 36 30 24 30 21 15 156 93 65 79 105 84 Mississippi 81 70 64 56 51 50 113 93 79 \u2021 52 69 Missouri 63 49 42 50 41 35 145 92 71 46 80 71 Montana 48 37 39 39 30 29 \u2021 \u2021 \u2021 \u2021 \u2021 62 Nebraska 42 38 35 35 30 24 137 87 69 82 105 101 Nevada 73 63 47 61 42 27 133 83 64 108 110 76 New Hampshire 33 23 16 na 23 15 na \u2021 22 na \u2021 40 New Jersey 41 32 23 19 13 8 105 69 47 80 70 57 New Mexico 78 66 64 51 39 32 100 68 36 97 85 84 New York 44 33 24 25 19 13 86 55 36 82 64 52 North Carolina 68 59 45 51 43 31 107 80 59 106 146 108 North Dakota 35 27 28 29 21 20 \u2021 \u2021 \u2021 \u2021 \u2021 61 Ohio 58 46 39 47 38 31 130 94 72 74 80 77 Oklahoma 67 60 60 na 51 50 na 85 71 na 97 109 Oregon 55 43 33 51 35 25 112 74 39 114 103 81 Pennsylvania 45 34 29 32 24 19 128 84 61 126 91 90 Rhode Island 44 34 27 32 22 15 137 66 37 130 92 71 South Carolina 71 58 49 54 44 37 101 79 63 67 96 97 South Dakota 47 38 38 35 27 26 \u2021 \u2021 69 \u2021 \u2021 95 Tennessee 72 60 51 61 50 42 122 91 70 41 120 107 Texas 75 69 61 49 41 32 117 78 61 104 104 93 Utah 49 38 31 44 31 21 \u2021 51 27 115 106 95 Vermont 34 23 17 35 24 17 \u2021 \u2021 \u2021 \u2021 \u2021 \u2021 Virginia 53 41 31 40 30 22 100 70 48 56 71 63 Washington 53 39 32 47 31 22 98 58 34 113 101 89 West Virginia 57 47 50 57 46 51 74 68 44 \u2021 \u2021 \u2021 Wisconsin 43 35 29 30 24 18 177 113 87 90 98 84 Wyoming 56 42 45 51 36 39 \u2021 \u2021 33 94 81 78 United States 60 48 39 43 33 26 116 79 59 100 87 70 \u2020 Women of Hispanic origin may be of any race. \u2021 Rates not deemed to be reliable due to small number of births or number of women in the group. Source: National Center for Health Statistics, Trends in Characteristics of Births by State: United States, 1990, 1995, 2000-2002, National Vital Statistics Reports, Vol. 52 (19), May 2004; 2009 rates calculated by ASPE based number of births (NCHS Natality Data Set) and Census Bureau population estimates. C-5 Figure C-1. Percentage of Nonmarital Births by Age, Race, and Hispanic Origin: 1980-2009 Note: Trends in non-marital births may be affected by changes in the reporting of marital status on birth certificates and in procedures for inferring non-marital births when marital status is not reported. Prior to 1980, racial classification was reported on the basis of the race attributed to the child; thereafter it was based on the race of the mother. For Hispanics the graph lines are partially in bold to distinguish between the interpolated data in the two intervals 1980-1985 and 1985-1990 from the annual data from 1990 onward. Source: National Center for Health Statistics, Nonmarital Childbearing in the United States, 1940-1999, National Vital Statistics Reports, Vol. 48 (16), 2000; Births: Final Data for 2009, National Vital Statistics Reports, Vol. 60 (1), November 2011, http:\/\/www.cdc.gov\/nchs\/products\/pubs\/pubd\/nvsr\/nvsr.htm. 45.4 92.3 27.1 80.0 11.2 36.0 0 25 50 75 100 1980 1985 1990 1995 2000 2005 2009 (In percent) Ages 15-17 Ages 18-19 All ages 93.1 99.2 79.9 96.1 56.1 72.3 0 25 50 75 100 1980 1985 1990 1995 2000 2005 2009 51.0 94.4 36.0 81.2 24.0 53.2 0 25 50 75 100 1980 1985 1990 1995 2000 2005 2009 Hispanic Ages 15-17 Ages 18-19 All ages Ages 15-17 Ages 18-19 All ages White Black C-6 Appendix D Technical Notes Appendix D. Technical Notes Age Categories Most of the indicators are shown by age categories, generally children ages 0 to 15, adults ages 16 to 64, and adults 65 and older. Youth 17 and 18 years of age are often classified with adults because they are considered potential members of the labor force in many labor force statistics. Many of the risk factors, however, use published data that define children to include all individuals less than 18 years of age. Annual and Monthly Measures There are differences between monthly and annual observation of benefit receipt. The measures of annual recipiency (that is, any receipt over the course of a year) shown in Figure and Table SUM 1 are higher than the more traditional measures of recipiency in an average month, as shown in several other indicators. Note that annual measures are for calendar years except where explicitly noted as fiscal years. Race and Ethnicity Most of the data sources allow analysis of the indicators and predictors of welfare dependence across several age and racial\/ethnic categories. Where the data are available, statistics are shown for three racial\/ethnic groups Non-Hispanic White, Non-Hispanic Black and Hispanic. Due to small sample size, American Indians\/Alaska Natives, Asians and Native Hawaiians\/Other Pacific Islanders are included in the totals for all persons but are not shown under separate race categories. In some instances, however, data are shown for Whites and Blacks, rather than for Non-Hispanic Whites and Non-Hispanic Blacks; in such cases these racial categories include individuals of Hispanic Origin. Footnotes to the tables provide further documentation of issues related to race and ethnicity. Estimates based on 2002 (and more recent) Current Population Survey (CPS) data are affected by a change in the CPS questionnaire that allows individuals to report one or more races. This change was implemented to comply with the 1997 Standards for Federal Data on Race and Ethnicity. In 2000, the Office of Management and Budget (OMB) published guidelines for implementing these new standards. To accommodate the race categories under the new standards, CPS estimates for racial\/ethnic categories beginning in 2002 are for persons who are Non-Hispanic White (and no other race), Non- Hispanic Black (and no other race) and Hispanic (of any race). Persons who reported more than one race are included in the total for all persons but are not shown under any race category. Family Structure Categories For the primary measure of dependency, as well as selected indicators and measures, estimates are provided for individual persons by family structure (see SUM 1, IND 1, IND 2, IND 5, and ECON 7). For these measures, the entire population is subdivided into the following four groups: Persons in Married-Couple Families Persons in Female-Headed Families Persons in Male-Headed Families Unrelated Persons. Two additional measures use a subset of the above categories (see IND 4, and ECON 1). D-1 Spells Spells of program recipiency (IND 7), spells of welfare receipt with no attachment to the labor market (IND 8) and spells of poverty (ECON 5) are limited to those spells that begin during the SIPP panel of observation. Spells separated by only 1 month are not considered separate spells. If an individual has 2 or more spells of dependency or receipt, each is counted separately in the analysis. Unit of Analysis The individual, rather than the family or household, is the unit of analysis for most of the statistics in this report. The individual’s dependency status, however, is generally based on total family income, taking into account means-tested assistance, earnings and other sources of income for all individuals in the family.1 1 Family is generally defined as following the broad U.S. Census Bureau definition of family all persons residing together that are related by birth, marriage, or adoption. The introductory chapter of this report, for example, shows the percentage of individuals that are dependent (in SUM 1) or poor (in SUM 2) according to annual total family income. Recipiency status is also based on total annual family income in some instances; in SUM 1, for example, recipients are individuals in families receiving assistance at some point in the year. In most other indicators, however, recipiency is measured as the direct receipt of a benefit by an individual in a month. The difference between an individual and a family measure of recipiency is largest in the SSI program, which provides benefits to individuals and couples, not to families. D-2 Indicators of Welfare Dependence U.S. Department of Health and Human Services I-1 II. Indicators of Dependence II-1 Economic Security Risk Factors III-1 Nonmarital Birth Risk Factors TANF and SNAP A-1 B-1 C-1 D-1 List of Figures List of Tables Appendix B Executive Summary 2012 Indicators ~ 3-26-13x.pdf Indicators of Welfare Dependence U.S. Department of Health and Human Services I-1 II. Indicators of Dependence II-1 Economic Security Risk Factors III-1 Nonmarital Birth Risk Factors TANF and SNAP A-1 B-1 C-1 D-1 List of Figures List of Tables Appendix B Executive Summary Chapter 1 & Chap 2 3-26-13.pdf Figure IND 4. Participation Rates in the AFDC\/TANF1, SNAP and SSI Programs: Selected Years Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; TANF and SNAP receipt are based on the full recipient unit. Recipients are defined as those individuals who receive SSI or live in a family that receives either TANF or SNAP benefits. In practice, individuals typically do not receive both TANF and SSI; hence, no individual receives benefits from all three programs. Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; AFDC\/TANF and Food Stamps\/SNAP receipt are based on the full recipient unit. In practice, individuals do not tend to receive both AFDC\/TANF and SSI; hence, no individual receives benefits from all three programs. The percentage of individuals receiving assistance from any one program in an average month (shown here) is lower than the percentage residing in families receiving assistance at some point over the course of a year (shown in Table SUM 1 in Chapter I and Table IND 1a in Chapter II). Spouses are not present in the female-headed and male-headed family categories. Note: Categories are mutually exclusive. SSI receipt is based on individual receipt; AFDC\/TANF and Food Stamps\/SNAP receipt are based on the full recipient unit. In practice, individuals do not tend to receive both AFDC\/TANF and SSI; hence, no individual receives benefits from all three programs. The percentage of individuals receiving assistance from any one program in an average month (shown here) is lower than the percentage residing in families receiving assistance at some point over the course of a year (shown in Table SUM 1 in Chapter I and Table IND 1a in Chapter II). Chapter 3 Text w ECON WORK BIRTH 3-26-13 gc.pdf Below 50 Percent Below 75 Percent Table ECON 3a. Percentage of Persons in Poverty Using Various Experimental Poverty Age Categories Racial\/Ethnic Categories Family Categories Figure ECON 8. Percentage of Persons without Health Insurance by Poverty Status: 2009 Figure WORK 1. Percentage of Persons in Families with Labor Force Participants by Race and Ethnicity: 2009 Racial\/Ethnic Categories Age Categories Figure WORK 7. Percentage of the Non-Elderly Population Reporting an Activity Limitationby Selected Characteristics: 2009 Year Ages 15 to 17 Ages 18 and 19 Appendix A TANF SNAP SSI 3-26-13.pdf Temporary Assistance for Needy Families (TANF) and Aid to Families with Dependent Children (AFDC) Legislative Changes Data Issues Relating to the TANF Program and the AFDC-TANF Transition Figure TANF 1. Average Monthly AFDC\/TANF Families Receiving Assistance \/ Note: Basic Families are single-parent families and UP Families are two-parent cases receiving benefits under AFDC Unemployed Parent programs that operated in certain states before FY 1991 and in all states after October 1, 1990. The AFDC Basic a… Figure TANF 2. Average Monthly AFDC\/TANF Benefit per Recipient in Constant 2009 Dollars Note: Benefits do not include emergency assistance payments and have not been reduced by child support collections. Foster care payments are included from 1971 to 1980. State funds for benefits include benefits under Separate State Programs. Begin… 1 Constant dollar adjustments to 2009 level were made using a CPI-U-RS fiscal year price index. 2 Includes expenditures for services . 3 Administrative expenditures only. 4 The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 repealed the AFDC program as of July 1, 1997 and replaced it with the Temporary Assistance for Needy Families (TANF) program. Under PRWORA, spending categories are not enti… Source: U.S. Department of Health and Human Services, Administration for Children and Families, Office of Administration. SNAP Families with No Adult in Asst. Unit Median Months on AFDC\/TANF Presence of Assistance Presence of Income United States SNAP Data SNAP Household Characteristics. As shown in Table SNAP 3, the proportion of SNAP households with earnings has increased, from about 20 percent for most of the 1980s and early 1990s, to 29 percent in 2009. At the same time, the proportion of househol… \/ Figure SNAP 1. Persons Receiving SNAP: 1962 2009 Note: Total persons includes participants receiving assistance in Guam and the Virgin Islands. Shaded areas are periods of recession as determined by the National Bureau of Economic Research. NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Iowa Adults Total NA NA Table SNAP 3. Characteristics of SNAP Households: Selected Years 1980 2009 Supplemental Security Income Legislative Changes SSI Program Data SSI Caseload Trends (Tables SSI 1 and SSI 2 and Figure SSI 1). From 1990 to 1995, the number of SSI beneficiaries increased from 4.8 million to 6.5 million, an average growth rate of over 7 percent per year. Between 1995 and 2000, the number of bene… \/Figure SSI 1. SSI Recipients by Age: 1974 2009 Figure SSI 2. Percent SSI Recipients by Age: 1974 2009 \/ Table SSI 6. Characteristics of SSI Recipients by Selected Characteristics: Selected Years 1980-2009 Appendices B C D 3-1-13 gc.pdf State United States Alabama Connecticut Hawaii Kansas Massachusetts Oklahoma Virginia United States State Alabama Alaska Connecticut Hawaii Kansas Massachusetts Missouri Oklahoma Virginia United States Appendix D. Technical Notes ”

” Last Updated 7\/2013 County Expense Claim Guidelines and Procedures Manual http:\/\/www.cwda.org\/downloads\/tools\/fiscal CWDA | County Tools – Fiscal Written by representatives from CDSS and participating counties: Kern, Placer, Riverside, San Francisco, San Luis Obispo, Santa Clara, and Tulare. http:\/\/www.cwda.org\/tools\/fiscal.php Last Updated 7\/2013 DEDICATION PAGE The County Expense Claim Guidelines and Procedures Manual is dedicated to all those who shared their time and talent to make this manual possible. CDSS STAFF Current Participants Kirk Haley, Manager Gena Nguyen, CEC Administrator Former Participants Virginia Becker Sharon Blakeman Lena Cole Patricia Cox Eric Ericson Sharon Ferguson Jane Hereth Cindy Ma Jennifer Niklas Didi Okamoto Cheley Swart Jesse Ward Mary Ann Warren COUNTY STAFF Current Participants Patricia LaRose, Chairperson San Luis Obispo County Michele Boyer Tulare County Patti Cornelius Tulare County Beth Cox Riverside County Ann Sullivan Tulare County Don Wood Humboldt County Former Participants Miriam Acha Riverside County Ranjan Bagla Santa Clara County Monica Bentley Riverside County Dan Crick Santa Clara County Steve Dashiell Placer County Margaret Dolan Kern County Karen Ferguson Tulare County Debbie Hill Riverside County Linda McCauley Tulare County Grace Moreno Tulare County Darrell Spencer San Francisco County Christine Stevens San Luis Obispo County Terri Wiech Placer County Last Updated 7\/2013 DISCLAIMER All information used to develop examples within this manual are obtained from County Fiscal Letters (CFL) for the 05\/06 Fiscal Year. Counties should always refer to the most recent CFL to obtain current information on programs, ledgers, allocations, etc. Additionally, this manual was developed to provide Counties with a useful training tool on the CEC template and to provide additional information on available reports and how they work. In determining whether certain costs are claimable, it is the responsibility of each County to review the OMB Circular A-87 (Cost Principles for State, Local, and Indian Tribal Governments). All claiming questions should be addressed to California Department of Social Services (CDSS) at [email protected]. Last Updated 7\/2013 i Table of Contents Overview of CEC Manual …………………………………………………………………………. iii What’s New in the Manual? ……………………………………………………………………… iv Introduction to the County Expense Claim …………………………………………………… 1 Section I – Input Pages ……………………………………………………………………………… 6 Setting Up the Quarterly CEC System …………………………………………………….. 7 DFA 325.5 Expenditure Certification for the County Welfare Department Expense Claim (CEC) …………………………………………………………………………. 13 Additional Information Main Menu …………………………………………………………. 14 Claim Cover Letter ……………………………………………………………………………… 15 DFA 325.1 Expenditure Schedule …………………………………………………………. 18 Extraneous Costs ……………………………………………………………………………….. 31 DFA 325.1A Electronic Data Processing (EDP) ………………………………………. 33 DFA 325.1B Direct Cost ………………………………………………………………………. 47 DFA 325.1C Staff Development ……………………………………………………………. 53 DFA 7A Support Staff ………………………………………………………………………….. 59 DFA 7B Reconciliation of General Administration, Program Administration, & Clerical Support Staff Salaries and FTE’s ………………………………………………. 66 DFA 7B2 Support Staff Salary Distribution to Program …………………………….. 67 DFA 7B3 Distribution of Generic Support Staff Cost to General Administration; Program Administration; & Clerical Support Staff …………………………………….. 68 DFA 325.1E Direct-to-Program Support Staff Salary Input ……………………….. 70 DFA 55 Casework Time Studies …………………………………………………………… 72 DFA 403 Full Time Equivalents …………………………………………………………….. 80 DFA 419 Claim Summary Sheet …………………………………………………………… 82 DFA 329 Incentive Funds Expenditure …………………………………………………… 84 DFA 335 TANF Incentive Funds Expenditure …………………………………………. 87 Addendums ……………………………………………………………………………………….. 89 Section II Output Pages ……………………………………………………………………….. 90 DFA 327.1 – Distribution of Salary Cost and Allocable Support Staff and Operating Costs …………………………………………………………………………………. 91 DFA 327.2 EDP Cost Schedule…………………………………………………………….. 94 DFA 327.3’s Program Cost Summary ……………………………………………………. 98 DFA 327.4A-E CEC Staff Development Cost Summary and Funding ……….. 103 DFA 327.5’s P1 Welfare Program Adjustments and Fiscal Incentives ………. 105 DFA 327.5’s Welfare Program Funding ………………………………………………… 107 DFA 327.6’s CEC Staff Development Cost Summary and Funding Scheduled Differences ………………………………………………………………………………………. 109 DFA 327.7’s Welfare Program Funding Scheduled Differences ……………….. 110 DFA 327.8 Close Out Payment Report ………………………………………………… 112 County Expense Claim Reconciliation ………………………………………………….. 113 Submitting the CEC …………………………………………………………………………… 117 Ledgers Tracking System …………………………………………………………………… 119 CEC Ledger Tracking System Shift Report …………………………………………… 126 Last Updated 7\/2013 ii CEC Ledger Tracking System Status Report ………………………………………… 127 Single Shift Ledgers ………………………………………………………………………….. 128 In Home Supportive Services Ledger …………………………………………………… 133 Child Welfare Services Ledgers ………………………………………………………….. 134 Community Care Licensing Foster Family Homes Ledger ……………………. 142 Community Care Licensing Family Child Care Home Ledger ……………….. 144 CalFresh Ledger ……………………………………………………………………………….. 145 CalFresh Employment and Training (CFET) Ledger ………………………………. 147 Independent Living Program Ledgers ………………………………………………….. 149 CalWORKs Single Allocation Ledger …………………………………………………… 151 APS \/ CSBG Ledger ………………………………………………………………………….. 159 Community Care Licensing Family Day Care Ledger …………………………… 161 Community Care Licensing Title XX Ledger ……………………………………….. 162 PSSF Monthly Casework Visits Grant (CVG) Ledger …………………………… 164 Ledger Flowcharts …………………………………………………………………………….. 165 County Reports ………………………………………………………………………………… 170 Program Code List ProCodes …………………………………………………………… 174 Section III – Additional Reference Information …………………………………………… 175 Quick Reference Guide Summary of CEC Reports ……………………………… 176 CEC Definitions ………………………………………………………………………………… 187 Acronym List…………………………………………………………………………………….. 196 CEC Frequently Asked Questions (FAQs) ……………………………………………. 201 Section IV – Revenue ……………………………………………………………………………. 210 Revenue ………………………………………………………………………………………….. 211 CEC Payments …………………………………………………………………………………. 212 Extraneous\/Addendums …………………………………………………………………….. 214 Revenue Pass Thru …………………………………………………………………………… 215 Single Funding Page Crosswalk ………………………………………………………….. 219 CEC Payment and Audit Frequently Asked Questions (FAQs) ………………… 223 Address Changes ………………………………………………………………………….. 223 Advance ……………………………………………………………………………………….. 223 Claim Letter ………………………………………………………………………………….. 223 Copies …………………………………………………………………………………………. 223 General Fiscal Policy Questions ………………………………………………………. 224 Offsets …………………………………………………………………………………………. 224 Outstanding Payments …………………………………………………………………… 224 Payments \/ Reimbursements …………………………………………………………… 224 Performance Incentives ………………………………………………………………….. 226 Reconciliations ………………………………………………………………………………. 226 Status Report\/Shift Report from the Audited CEC ………………………………. 226 Warrant Release Date (WRD) …………………………………………………………. 226 What are CEC Revenues? …………………………………………………………………. 227 What is a Zero Balance AA190? …………………………………………………………. 232 Section V Realignment 2011 ………………………………………………………………. 236 AB 118 (Realignment 2011) ……………………………………………………………….. 237 Last Updated 7\/2013 iii Overview of CEC Manual The purpose of this manual is to provide you with a reference tool for understanding the structure of the County Expense Claim (CEC) and the principles behind how it works. By reviewing the material in the manual, you will develop a good understanding about the importance of correct time study data, correct case count information, and accurate and complete data from your County’s Financial Management System. The importance of the CEC process to the County and State agency operations cannot be overstated. The CEC is the financial life blood to the department. It is the vehicle for obtaining the administrative revenues anticipated in the department’s county budget. The Introduction to the County Expense Claim section provides an overview of the CEC, a brief discussion of the internal DSS process in completing the CEC, including use of the Fox Pro CEC template, and a summary of the contents of this manual. The Quick Reference Guide Summary of CEC Reports section is intended to be used as a reference guide to the CEC page numbers and titles. The County Expense Claim Page, Column and Line Descriptions section provides a more detailed review of the purpose and content of the page-series within the CEC. The columns and lines on each page are described, including where the information comes from and how costs are derived and allocated. This should facilitate your understanding of the structure of the CEC and how different costs are distributed to programs. The County Expense Claim Definition of Terms and Acronyms section serves as a reference guide to definitions and acronyms when you’re reviewing this manual or any CEC. These brief descriptions should help in better understanding the data you see. The Question and Answer section will answer some of the most frequently asked questions. The Revenue Section provides an overview of how the Counties receive advances and reimbursements from CDSS. This overview includes detailed descriptions of the AA190’s and the Cross Walk. Also included are answers to the most frequently asked questions. Last Updated 7\/2013 iv NEW What’s New in the Manual? The manual has been updated to include hyperlinks. On the table of contents page, press the control key and select the page number you wish to navigate to. Updated the information in the manual on case counts due to the issuance of CFL 12\/13-24; including updating the screen shots due to changes in program names (pages 20 27). Updated the instructions on submitting the CEC Claim, step 23 (page 117 118). Updated Ledger Tracking System screen shots (pages 119 122) The Single Shift Ledger section (pages 128 132) was updated to include references for the programs impacted by Realignment 2011. Additionally, the following four ledgers were added: \uf0b7 Ledger 156 Non-Medical Out of Home Care (NMOHC) CFL 11\/12-28 \uf0b7 Ledger 157 County Welfare Dept. (CWD) \/ Local Health Dept. (LHD) Expansion for Community Nutrition (CFL 11\/12-30) \uf0b7 Ledger 158 IHSS Adult Day Health Care (ADHC) CFL 11\/12-48 \uf0b7 Ledger 159 CalFresh Innovative Ideas Project – CFL 11\/12-42 Due to the implementation of the IHSS MOE, a new ledger section was developed for IHSS that provides information on the IHSS MOE (page 133). Changes were made to the ledger information included in the manual for the following programs due to the implementation of Assembly Bill (AB) 118, which is also referred to as Realignment 2011 (CFL 11\/12-18): \uf0b7 CWS (pages 134 141) \uf0b7 ILP (pages 149 150) \uf0b7 APS\/CSBG (pages 159 160) A new section was created that provides information on Realignment 2011 (pages 236 238). Additional Information \/ New Claiming Items Effective December 2011 quarter a new Type of Expense (TOE) code of 72 has been established to capture CalFresh outreach activities (CFL 11\/12-30). Effective September 2011 the description for all CalFresh program codes has been updated to reflect the program’s name change from Food Stamps to CalFresh. All necessary references have been updated in the manual as well. Updated the DFA 55, DFA 325.1B, and CEC FAQ sections with Information on how to claim PQCR hours and\/or costs. Last Updated 12\/2008 1 Intro Introduction to the County Expense Claim The State-County Relationship In California, welfare programs are state-supervised, but county administered. Used in this context, welfare refers to all the programs the County Agency typically administers. Under this state-supervised arrangement, the California Department of Social Services (CDSS) issues applicable regulations to the County Agency on how these programs are to be administered. As part of this regulatory process, CDSS sets county standards for obtaining state and federal reimbursement for costs incurred in administering these mandated programs. The County Expense Claim (CEC) is the vehicle used by counties to obtain such reimbursement. Counties now have the option to direct charge support operation to programs. The County Agency is obligated to process the CEC in accordance with State instructions. CEC Overview The CEC is a document that identifies numerous programs. These programs are largely sub-components of much larger programs like Child Welfare Services, CalWORKs, CalFresh (formerly NAFS), etc. It is necessary to capture costs to the program sub-component level because of a legislative or regulatory mandate, or the need to segregate costs for proper reimbursement from appropriate funding sources. The following briefly discusses program functions, time studies, and cost pools. Program Functions The programs are grouped into the following six functions: \uf071 Social Services(SS) \uf071 CalWORKs(CW) \uf071 Other Public Welfare(OPW) \uf071 Child Care(CC) \uf071 NonWelfare(NW) \uf071 Generic Programs of similar type are assigned to the same function. The NonWelfare function is available for County Agencies that administer County specific programs. The Generic function allows casework staff to time study to generic, or administrative, non- casework activities. This allows the County Agencies the organizational flexibility to utilize casework staff to provide such generic administrative support services, without having to reassign them to an administrative arm of the department. The CEC allows for expanded use of generic as an interim function for the charging of support operation costs, such as space, travel, etc. Please note that general administrative costs, including staff costs that time study to generic activities, do appear as generic Last Updated 12\/2008 2 Intro costs on the CEC. These costs should not be confused with the generic (casework) activities. Throughout the CEC page-series, the functions are displayed in the above sequence. Within the functions, each program is assigned a three-digit program code (PC) unique to that program sub-component. Factors that Allocate Costs Time Studies and Caseloads are the key factors that allocate costs through the CEC to programs. Time Studies for Allocating Costs The time study process is the most common method for allocating most of the costs within the CEC. Other costs would come from direct-to-program expenditures, Electronic Data Processing (EDP) costs, etc. Federal and state guidelines require equitable distribution of costs among programs. This means that all programs must pay their fair share of applicable administrative costs. Thus, if a program benefits from a cost factor (e.g. caseworker, space, supplies, telephones, computer systems, etc.), that program is allocated a proportionate share of those costs via the ratios created in the CEC from the caseworker time study hours. Although recent trends in California have been toward increased direct charging of costs, the vast majority of the costs continue to be allocated through the caseworker time study ratios created in the CEC. Recent revisions in the County Welfare Department Cost Allocation Plan expands county flexibility in direct charging of support operating costs to program. This flexibility has allowed counties to meet local programmatic or community needs. Caseworker time study ratios are the single most important element in the entire CEC process for allocating costs to program. Cost Pools Cost pools are simply the grouping of like costs. The CEC requires many cost pools to properly distribute costs within the claim. Such groupings can be either salary or non- salary pools, i.e. caseworker salaries, support staff salaries, support operating, EDP staff, Staff Development, and direct cost pools. Last Updated 12\/2008 3 Intro \uf071 Caseworker Salary Pools The salaries and benefits of caseworkers and their first line supervisors with similar classifications are pooled and then allocated to programs through time study ratios. The CEC allows for the use of four different caseworker salary pools, i.e. social workers, employment services workers, eligibility determination workers, and fraud investigators. \uf071 Support Staff Salary Pools Support staff is non-casework personnel. Support staff consist of general administration staff, program administration staff, and clerical staff. Support staff are designated into these cost pools by the duties that they perform on behalf of the department, not by their classification. \uf071 Support Operating Costs Pools Support operating costs include expenditures for travel, space, telephones, supplies, etc. These costs are pooled, then allocated based upon a ratio of caseworker allocable time study hours\/observations, or direct charged to a function and\/or program. \uf071 EDP Cost Pool The EDP pool captures information technology costs of the County Agency. Costs include salaries and benefits of EDP personnel, purchase of services, and CWD operating costs. Two major categories are utilized within the EDP section: \uf0d8 Maintenance and Operations (M & O) \uf0d8 Developmental Costs are identified to one of the six functions, (Social Services, CalWORKs, Other Public Welfare, Child Care, NonWelfare, or Generic), or direct-to- program. Generic costs are allocated to the function using quarterly case count ratios. Function costs are allocated to program based on caseworker time study ratios. EDP personal service costs can also be direct charged to a program. M & O costs and Developmental costs (direct costs and single\/multi-function) are allocated to programs benefiting from the project\/service. Last Updated 12\/2008 4 Intro \uf071 Staff Development Cost Pool The Staff Development pool captures the costs associated with the operation of the staff development division. This division provides for the training of County Welfare staff. \uf071 Direct Costs Direct costs are expenditures made on behalf of the County Agency’s clients, or costs that can accurately be determined to benefit only one program. Direct costs are not included in the allocation process. Such costs may include the County Agency’s support operation costs that directly benefit a program, program start-up, and one-time only costs that cannot equitably be distributed via the normal allocation process. \uf071 Extraneous Costs Extraneous costs are costs that cannot be allocated through the CEC. These costs do not receive state or federal financial participation through the CEC. Last Updated 12\/2008 5 Intro County Expense Claim Page, Column, and Line Descriptions Section I – Input Pages Last Updated 12\/2008 7 Getting Stated Setting Up the Quarterly CEC System Each quarter an e-mail is sent to the Counties from CDSS informing them when the quarterly Original, Revised, or Audited CEC Files are available. This e-mail will also provide step by step instructions for setting up the quarterly CEC System. These steps are detailed below: 1. In your internet browser type in the following link and press enter: https:\/\/secure.dss.cahwnet.gov\/admin\/finance\/cec\/ 2. In the drop-down menu that displays \”ALAMEDA\”, find your county’s name and click on it so that the name stays visible. 3. In the input field directly above the drop-down field, type your county name (this field is case sensitive and must be typed exactly as displayed in the field below). 4. Click the Submit Query button. https:\/\/secure.dss.cahwnet.gov\/admin\/finance\/cec\/ Last Updated 12\/2008 8 Getting Stated 5. On the left of the screen, click on the appropriate claim type (Original or Adjustment) being processed. 6. In the drop down menu that appears on the screen, select the appropriate fiscal year and then click the Select button. 7. Another drop-down menu will appear below, select the appropriate quarter and then click the Select button. Three or five files will then appear below the drop-down menu (the number of files that appear depends on the type of claim you are processing). 8. Click on the file named \”1cec.YY-YY.mo.exe\”. 9. A dialog box will display prompting the file to be run or \”saved\”. Save the file to a location of your choice (such as your c:\\ drive or desktop). 10. Repeat steps 8 and 9 for each of the files listed (files 2 thru 5). 11. Exit and close out of the Extranet. Last Updated 12\/2008 9 Getting Stated 12. Using Windows Explore, find the files that were just saved. 13. Double-click on the first file (named \”1cec.YY-YY.mo.exe\”). The file is in a self-extracting format, and the correct path (for example c:\\Cec_032007) is defaulted in the WinZip window. 14. Click on \”unzip\” and the files will automatically unzip to the proper location. 15. Repeat steps 13 and 14 for each of the files saved (files 2 thru 5). 16. Using Windows Explore, open the folder that was just created (for example c:\\Cec_032007) and locate the exe file. * NOTE: An alternative to steps 8 and 9, is to select run instead of \”save\”, and then just unzip each file to the defaulted locations directly from the website. * NOTE: The appropriate location for each of the unzipped files are as follows: 1cec.YY-YY.mo.exe (c:\\Cec_QQYYYY) 2procodeb.YY-YY.mo.exe (c:\\ProCodes) 3ledg.YY-YY.mo.exe (c:\\Ledgers) 4cectbl.YY-YY.mo.exe (c:\\Cec_QQYYYY) 5procodea.YY-YY.mo.exe (c:\\ProCodes) Last Updated 12\/2008 10 DFA 325.5 Welcome Screen Allows the County’s Claim Processor to determine which claim to use in the working directory Month and year relative to the working claim quarter For help, please contact the State Systems Unit Default to working subdirectory Last Updated 12\/2008 11 DFA 325.5 Tell Us Who You Are Input Screen This screen must be completed first. Always verify your County Number Last Updated 12\/2008 12 DFA 325.5 CEC Main Menu Verify proper quarter before proceeding Last Updated 12\/2008 13 DFA 325.5 DFA 325.5 Expenditure Certification for the County Welfare Department Expense Claim (CEC) The DFA 325.5 summarizes the quarterly County Agency expenditures, classified as Allowable and Extraneous. Allowable costs are allocated and direct charged through the CEC, as described in this manual. Extraneous costs are not allocated through the CEC and are not claimable as a welfare administration cost. Extraneous costs have other funding mechanisms outside the CEC; however, the costs must be reported for reconciliation purposes. The DFA 325.5: \uf071 Identifies the county and claiming quarter. \uf071 Displays the Total Allowable Welfare Costs as reported on the DFA 325.1. \uf071 Displays the Total Extraneous Costs as reported on the DFA 325.1. \uf071 Provides for the approved signatures of the County Welfare Director and County Auditor (or designees), certifying that the claimed costs have been expended and are allowable in accordance with rules and regulations. \uf071 Identifies the county contact person and their telephone number. \uf071 Displays the total costs by funding sources, including federal, state, health, and county. These costs are transferred from the Grand Total lines of the CEC DFA 327.5’s Welfare Program Funding pages and the CEC Staff Development Cost Summary and Funding pages (DFA 327.4 A-E). Last Updated 12\/2008 14 Letter Additional Information Main Menu *Hint: See program code list ProCodes in this document for further information regarding ProCodes. Also available using ProCodes County Use Only Checklist of County Operated Programs Last Updated 12\/2008 15 Letter Claim Cover Letter Input Screen Last Updated 12\/2008 16 Letter Claim Cover Letter A Claim cover letter is only required for the September (1st Quarter) claim and for all adjustment claims. The Claim cover letter is enclosed with each CEC and should include the following: \uf071 Total Allowable Welfare Costs: The amount reported on the DFA 325.5 (Certification page). \uf071 Total Extraneous Costs: The amount reported on the DFA 325.5 (Certification page). \uf071 Total Fiscal Incentives claimed. \uf071 Date claim files were sent to County Systems Unit. \uf071 Date a faxed copy of the signed claim letter and Certification page (DFA 325.5) were sent to CDSS. \uf071 County contact person and phone number. \uf071 For the September (1st Quarter) claim only – Include the budget units identified in the County Cost Allocation Plan (CCAP) and approved by the State Controller’s Office (SCO). For more information see CFL 97\/98-26, dated October 15, 1997. \uf071 For Adjustment Claims – Provide an explanation for any significant fluctuations on the DFA 325.1 (Expenditure Schedule) between the adjustment and the original claims. A 15 percent change (either positive or negative) within any of the claiming categories is considered a significant fluctuation. Last Updated 12\/2008 17 Letter Claim Letter Example December 19, 20xx Attention: Enclosed is (Name of County) County’s Adjusted Expense Claim for the quarter ending March 31,20xx. The adjusted Claim \”Total Allowable Welfare Costs\” reported were $60,000,000, an increase of $500,000. The total \”Extraneous Costs\” reported is $5,000,000. The March 20xx adjustment included the corrected payroll distribution of salaries. Total Support Staff costs decreased $65,000, EDP Developmental costs increased $70,000 and M&O costs decreased $100,000 with the correct redistribution of salary and programming costs. Direct costs increased $50,000 when it was discovered that a number of items previously charged as other operating costs were clearly identified as direct costs. Claim files were uploaded to Systems on December 19, 20xx. A fax copy of this signed Claim letter and signed Certification page (DFA 325.5) was sent December 19, 20xx to County Admin Claims Unit. If you have any questions, please contact Joe Smith, Supervising Accountant, Department of Public Social Services; Fiscal Office at (555) 555-5555. Sincerely, Jane Doe DPSS Deputy Director JS:JD Enclosures Last Updated 7\/2013 18 DFA 325.1 DFA 325.1 Expenditure Schedule Main Menu Last Updated 7\/2013 19 DFA 325.1 Support Operating Costs Purchase of Services Input Screen Source Documents: County financial records of overhead expenditures Must be authorized by State Controller’s Office (See A- 87 Guidelines) Last Updated 7\/2013 20 DFA 325.1 Federal\/Non-Federal Persons Count Input Screen *Note: Although the column names within this input screen refer to case counts , person counts are used for the federal\/nonfederal and CFAP counts. Counties should refer to CFL 12\/13-24 when compiling case count data. This CFL is the single source authority on the Federal\/Non-Federal Persons Count within the CEC. ADOPTION ASSISTANCE COUNTS The Adoption Assistance Person Counts are obtained by using information from the CA 800A Fed (Monthly Summary Report of Assistance Expenditures) and the CA800A NonFed (Monthly Summary Report of Assistance Expenditures). Line AD. Federal Count 2\/ Person count is obtained from the CA 800A FED under Aid Code 03. Enter person count from CA 800A NONFED Enter person count from Part B of completed AFDC FC Fed & Non-Fed Person Count Form. Enter person count from Part A of completed AFDC FC Fed & Non-Fed Person Count Form. Enter person count from DFA 296 Enter person count from CA 800A FED Last Updated 7\/2013 21 DFA 325.1 Line AE. Non Federal Count\/CFAP-Families Count Person count is obtained from the CA 800A NONFED under Aid Code 04. AFDC FOSTER CARE COUNTS The Foster Care Person Counts are obtained by using information from the AFDC Foster Care Federal and Non-Federal Persons Count Form (attachment in CFL 12\/13-24). A sample of this form can be found on page 23. Line AD. Federal Count 2\/ Person count is obtained from the CA 800 FC FED under Aid Code 42. Only Emergency Assistance cases that are pending approval of a placement for no more than four months can be included in the federal count. Line AE. Non Federal Count\/CFAP-Families Count Person count is obtained from the CA 800 FC NONFED under Aid Code 40. Non-related legal guardian cases must be excluded when calculating this ratio; as activities performed related to these cases are time studied to a specific TSC. Person count is obtained from the CA 800A Fed under aid code type 5K. All 5K cases, with the exception of cases pending approval of a placement for no more than four months, should be counted as non-federal. For further information on what type of cases can\/cannot be included please check pertinent CFL’s. CALFRESH DATA The CalFresh Persons Count is obtained by using information from the CalFresh Program Monthly Caseload Movement Statistical Report (DFA 296). Line AD. Fed Count 2\/ Person count is obtained from cell 45. Line AE. Nonfederal Count\/CFAP-Families Count Person count is obtained by adding cells 47 & 51. Line AF. CFAP Single Count\/4 Person count is obtained by adding cells 46 & 50. *Hint: When entering person counts add all 3 months together to determine the quarter total. Last Updated 7\/2013 22 DFA 325.1 Source Documents: CFL 12\/13-24 AFDC Foster Care Federal and Non-Federal Persons Count Form CA 800A FED Summary Report of Assistance Expenditures Adoption Assistance, Emergency Assistance- General Assistance, Emergency Assistance- Foster Care, & Refugee Cash Assistance \/ Federal CA 800A NONFED Summary Report of Assistance Expenditures Adoption Assistance Program \/ NonFederal CA 800 FC NONFED NonFed Foster Care and Seriously Emotionally Disturbed Children (SED) CA800 FC FED Summary Report of Assistance Expenditures \/ Foster Care and Foster Care-SB 163 \/ Federal CA 800 FC (ECF Temp) FED Summary Report of Assistance Expenditures Foster Care Extended Foster Care (EFC) Federal CA 800 FC (EFC Temp) NONFED Summary Report of Assistance Expenditures Foster Care Extended Foster Care (EFC) NonFederal DFA 296 CalFresh Program Monthly Caseload Movement Statistical Report Last Updated 7\/2013 23 DFA 325.1 Last Updated 7\/2013 24 DFA 325.1 CWS Caseload Input Screen Note: This input screen is no longer used by counties. Per CFL 09\/10-66, counties will no longer report EA cases on the CEC effective July 1, 2010. Last Updated 7\/2013 25 DFA 325.1 Two-Parent Family Caseload Input Screen Counties should refer to CFL 02\/03-68 when compiling case count data. This CFL is the single source authority on the Two Parent Family Caseload within the CEC. The Two-Parent Family Caseload is obtained by using information from the CalWORKs Caseload Movement Report (CA 237 CW). All of the information comes from the section that identifies total cases open during the month (must add both cases received and other cases). Line AN. CalWORKs Caseload Caseload is obtained by adding all the cells on Line 8 (total cases open during the month). Line AO. Two-Parent Family Caseload Count is obtained from the Two Parent Families cell on Line 8. The reasoning being that all the cases in these cells are CalWORKs Cases and Cell 54 is only Two-Parent Families. Enter case counts Last Updated 7\/2013 26 DFA 325.1 Line AP. Two-Parent Family Ratios No input is required as the ratios are automatically calculated within the CEC template and can be found on the DFA 325.1 Report (page 2). *Hint: When entering case counts add all 3 months together to determine the quarter total. Source documents: CA 237CW CalWORKs Caseload Movement Report Last Updated 7\/2013 27 DFA 325.1 Public Assistance CalFresh (PACF) Household (Cases) Input Screen The Public Assistance CalFresh (PACF) caseload is obtained by using information from the CalFresh Program Participation and Benefit Issuance Report (DFA 256). All of the information comes from Line 1 (number of households) Public Assistance. Line AQ. Public Assistance CalFresh (PACF) Caseload Pubic Assistance caseload is obtained by adding total number of households for Fed, Fed\/State, and State. Line AR. Public Assistance CalFresh (PACF) Ratio No input is required as the ratios are automatically calculated within the CEC template and can be found on the DFA 325.1 Report (page 2). *Hint: When entering case counts add all 3 months together to determine the quarter total. Source documents: DFA 256 CalFresh Program Participation & Benefit Issuance Report Enter PACF Case Counts Last Updated 7\/2013 28 DFA 325.1 DFA 325.1 County Expense Claim Expenditure Schedule The DFA 325.1 summarizes the agency’s expenditures for the quarterly claiming period. First, expenditures are summarized at the function level (Social Services, CalWORKs, Other Public Welfare, Child Care, NonWelfare and Generic). Then, the expenditures are summarized at the cost pool level (Casework Costs, Support Staff Costs, Support Operating Costs\/Purchase of Service, EDP Costs, Staff Development Costs, and Direct Costs). The DFA 325.1 Expenditure Schedule and the DFA 55 Casework Time Study and Salary Distribution are the key reports that allocate costs in the CEC. Page 1 of the DFA 325.1 \uf071 Casework Costs: Represents the salary and benefits of the caseworker as they perform activities for their clients. Casework costs are displayed by cost pool. The casework costs are originally entered on the DFA 55 and costs are summarized to the functional level on the DFA 325.1. \uf071 Support Staff Costs: Represents the salary and benefits of the support staff and are summarized into three components: General Administration, Program Administration, and Clerical. Within each of the three components, costs may be allocated to the function, or direct-to-program level, as specified in the County’s Support Staff Time Reporting Plan (SSTRP). The SSTRP is optional for the 18 small counties. Support Staff Costs reported to the function level are distributed to the program level based on the casework time study ratios from the DFA 325.1 to allocate costs. The Support Staff Costs are originally entered on the DFA 7A and DFA 7B and are summarized by function on the DFA 325.1. \uf071 Support Operating Costs\/Purchase of Service: Represents the expenditures associated with operating the county agency. Expenditures in this cost pool are displayed as travel, space, other operating costs, purchase of service, including Countywide Cost Allocation Plan (CCAP) and non-CCAP costs. Typically, support operating costs are entered on this page, however some counties have chosen to direct charge these costs to specified programs. In order to direct charge support operating costs, counties must submit a letter of intent to CDSS Fiscal Policy Bureau. For more information on this policy, please reference County Fiscal Letter (CFL) 00\/01-78, dated May 21, 2001. \uf071 EDP Costs: Represents the salary and benefits of all EDP staff and the cost of operating the EDP unit\/office. EDP costs consist of two categories: Developmental Projects and Maintenance & Operation costs. Costs are Last Updated 7\/2013 29 DFA 325.1 summarized on the DFA 325.1 by function. EDP costs are entered on numerous pages (DFA 325.1A series) of the CEC, dependent upon what type of cost it is. \uf071 Staff Development: Represents the salary and benefits of all staff development staff and the cost of operating the staff development office. Expenditures in this cost pool are displayed in two categories: Personal services\/Operating costs and Purchase of Service\/Direct Cost of Trainees. Staff development costs are originally entered on the DFA 325.1C, funded on the DFA 327.4A-E and summarized on the DFA 325.1. \uf071 Direct Costs: Expenditures in this cost pool are directly identified to a program via a six digit Program Identifier Number (PIN) code. However, once the costs reach the DFA 325.1, the costs are displayed at the function level. The detailed expenditures are on the DFA 325.1B Direct Cost Input Schedule. \uf071 Sub-Total Allowable Welfare Cost: Total of all the cost pools by function. \uf071 Performance Incentives: Performance Incentives are funds that are earned by individual counties based upon certain program performance criteria. Counties elect when to use incentive funds for program reimbursement. \uf071 Total Allowable Welfare Costs: The total displays all welfare costs, net of performance incentives. \uf071 Extraneous Costs (Summarized): Extraneous costs are County Agency expenditures not reimbursable via the CEC. As such, they are not allocated through the claim. Some extraneous costs may have reimbursement available under other claiming processes (grants, etc.) while others have no funding mechanism at all, except through the county budget. A detailed listing of extraneous costs appears on the DFA 325.1 as an addendum. Page 2 of the DFA 325.1 \uf071 Casework (Total Paid Casework) Hours\/Observations: Data on this line summarizes time study hours by function from the DFA 55. Total function hours are used to calculate total function casework ratios. \uf071 Casework Ratios: The casework ratios are used to allocate the generic, caseworker, support staff, and other operating costs back to the function level. Casework time study ratios are derived by dividing the total of each function’s casework time study hours (DFA 325.1 page 2, Line AB) by the total of all the functions casework hours. Last Updated 7\/2013 30 DFA 325.1 Caseworkers’ salary, Support Staff salary and Other Operating Costs are allocated to the functions based on Casework ratios. Casework ratios are comprised of the allocable hours by programs in each function and further allocation at the program level is done by the ratio of each program. \uf071 Federal\/Non-federal Persons Counts: Refer to the federal and nonfederal data and resultant ratios. These lines are used to determine the proper amount of federal reimbursement for the Adoptions Assistance, AFDC-FC, and CalFresh programs. The Federal government will not reimburse states\/counties for costs incurred for non-federally eligible persons served in these programs, nor for state run programs such as the California Food Assistance Program (CFAP). The ratios are applied to specified program codes in the CEC and that portion of the total is taken out and shifted to another program code. Case counts and corresponding ratios are also determined for the following categories: \uf0d8 CalWORKs Case Two-Parent Family \uf0d8 CalFresh Cases receiving public assistance. \uf071 Total Salaries and Benefits: The total salary and benefits of each Casework cost pool. *Hint: Per CFL 07\/08-31, the CA 800 Assistance Claim must be the single data source for obtaining all caseload data. Last Updated 12\/2008 31 EXT Extraneous Costs Input Screen Source Documents: County financial records of extraneous costs Always verify cursor is at the top before entering data Last Updated 12\/2008 32 EXT Extraneous This section of the CEC is used to report expenditures of the County Agency that cannot be allocated through the CEC, are unallowable for state and federal financial participation, or reimbursed from another funding source. These costs may include: \uf071 Financing\/Interest Costs: a) Interest on borrowed capital or the use of a governmental unit’s own funds. b) Financing costs (including interest) on otherwise allowable costs of equipment incurred and paid prior to September 1995. c) Financing\/interest costs are subject to the condition outlined in OMB (Office of Management & Budget) Circular A-87, Attachment B, Item 26, subsection b. \uf071 The portion of a lease payment for a capitalized asset, such as buildings or equipment, which is in excess of depreciation or use allowance; \uf071 Costs unallowable for reimbursement under federal cost principles, including local government expenses, legislative expenses, fines, penalties, and entertainment expenses; \uf071 Interest or reserve account contributions included in billings from county internal service funds; \uf071 Costs of supportive services which are not issued to clients in the quarter, e.g. bus passes; \uf071 Costs claimed via a monthly claim\/invoice process, e.g. Interim Statewide Automated Welfare System (ISAWS), California Welfare Integrated Network (CalWIN). \uf071 Grants or contracted services paid by a different source. CFL 01\/02-36 California County Welfare Department (CWD) Cost Allocation Plan (CAP) 2001\/2002 Fiscal Year (FY) Last Updated 12\/2008 33 DFA 325.1A DFA 325.1A Electronic Data Processing (EDP) Main Menu Last Updated 12\/2008 34 DFA 325.1A EDP M & O Function Input Screen EDP CASE COUNTS The Electronic Data Processing (EDP) case counts are the quarterly total of cases processed on an EDP system by benefiting function. The case counts are for the following functions: Social Services, CalWORKs, Other Public Welfare, Child Care, and Non Welfare. Total active cases for each function are entered on the M & O by Function Screen. Case counts are from county records; below is a sample of the types of cases to include. Case counts for Social Services may include the following: Families and Children referred to CWD Children in Out-of-Home Placement Emergency Response Children referred to Investigation IHSS Cases Enter Case Counts Enter Hours Enter EDP Operating Costs by Function Last Updated 12\/2008 35 DFA 325.1A Case counts for CalWORKs may include the following: CalWORKs Cases (CW 237) Welfare to Work Cases (WtW 25) Fraud Cases Case counts for Other Public Welfare may include the following: Refugees Seriously Disturbed Children Adoption Assistance Foster Children Medi-Cal Cases GA Cases CalFresh NonAssisted (CalFresh) Cases Fraud (other than CalWORKs) Case counts for Child Care may include the following: Stage One Child Care Cases Case counts for Non Welfare may include the following: Non Welfare Cases *Hint: When entering case counts, you may use either method of; 1) adding all 3 months to determine total, or 2) enter mid-month totals. Whichever method you use, you must be consistent. *Hint: When entering hours for any EDP staff, you must enter the total hours for all three months in the quarter, as specified in the Quarterly Time Study Instructions. Source documents: County caseload counts of active cases DFA 10 EDP Time Study County financial records of EDP costs Last Updated 12\/2008 36 DFA 325.1A M & O Function Allocation Input Screen *Hint: If it benefits all programs within the function, check (\uf034) the box and save. If it does not benefit all programs, you must enter the appropriate benefiting codes and save. **Hint: If there are no caseworker hours to a program code, the program will not draw any costs. Check here if benefiting all programs in the function Last Updated 12\/2008 37 DFA 325.1A EDP M & O Direct to Program Input Screen *Hint: Hours are for informational purposes only. Direct Personal Service costs must be determined outside the claim prior to input. Source documents: County financial records of EDP costs Enter EDP Overhead Program costs Enter Salary\/Benefits Costs by Program Enter Hours Last Updated 12\/2008 38 DFA 325.1A EDP Single & Multi-Function Developmental Projects Input Screen *Hint: Replacement costs are entered as M & O costs, not developmental costs. **Hint: Use the arrows to verify input. Source documents: County financial records of EDP costs HHSDC Advanced Planning Document (APD) Enter Costs Enter Hours Must either check a box or enter a program code Enter Project Name Always verify it’s the first record prior to start. Delete any blank records Enter APD # Must start here to and enter program codes from left to right. Last Updated 12\/2008 39 DFA 325.1A EDP Multiple Developmental Projects Charged to a Single Program Code Input Screen *Hint: Hours are for informational purposes only. Direct Personal Service costs must be determined outside the claim prior to input. Source documents: County financial records of EDP costs County payroll records regarding salaries and benefits HHSDC Advanced Planning Document (APD) Enter Progra m Code Enter APD # Enter Project Salary\/Benefits costs Enter Project Operating\/PO S costs Enter Hour s Enter Project Name Last Updated 12\/2008 40 DFA 325.1A EDP Developmental Direct to Program Input Screen *Hint: Hours are for informational purposes only. Direct Personal Service costs must be determined outside the claim prior to input. Source documents: County financial records of EDP costs County payroll records regarding salaries and benefits HHSDC Advanced Planning Document (APD) Enter APD # Enter Project Operating\/ POS costs Enter Project Salary\/ Benefits Costs Enter Hours Please Note Enter Project Name Last Updated 12\/2008 41 DFA 325.1A EDP Personal Services Direct Billed and Allocated Input Screen Source documents: County payroll records regarding salaries and benefits Enter Salary\/ Benefits for EDP staff to be allocated Must be authorized by State Controller’s Office (See A-87 Guidelines) Last Updated 12\/2008 42 DFA 325.1A DFA 325.1A EDP Cost Detail Schedule The DFA 325.1A is a report of EDP expenditures displayed in two major groupings: Maintenance and Operations (M & O) and Developmental Projects. Within those two groups, provisions are made for M & O and Developmental Project direct costs. Provisions are also made for single and multifunction developmental project costs. Each of the above groupings and sub-groupings will be discussed below. 1. Maintenance and Operations (M & O) This group is shown in the first section of the DFA 325.1A. Although a significant portion of costs under M and O are allocated to program or function via case count ratios (discussed below), certain costs that can be identified to a function are claimed accordingly. For example, personal service costs are allocated to function based on EDP staff time study ratios to that function. Also, operating costs that can be identified to a benefiting function are also claimed accordingly. Those costs that cannot reasonably be identified to a benefiting function are claimed as generic and allocated to function via case count ratios. Such costs are subsequently allocated to program based on caseworker time study ratios. M and O costs are displayed in two groupings on the DFA 325.1A. The first group includes personal services and operating costs that are either generic or identified to specific program(s)\/function(s). The generic costs are allocated to program(s)\/function(s) based on the quarterly case counts reported in columns labeled Case Counts and Case Counts Ratio. Personal service costs are either identified as generic, or to specific program(s)\/function, based on EDP staff time study hours\/ratios. Those personal service costs identified directly to program(s)\/function are claimed accordingly. Generic personal services costs are allocated to functions, along with the operating costs, via the case count ratios. Caseworker time study ratios allocate these costs to programs. The second group of M and O costs are those that are claimed to a specific three-digit program code. Such costs are direct charged to a program. They are not allocated to a program through the use of the time study ratios. These costs are subsequently reported on the DFA 327.2 series to the program codes listed on the DFA 325.1A. \uf071 Function Lines: These lines are used to display the six function levels (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, NonWelfare, and Generic), plus Central Data Base-SAWS (CDB-SAWS) and SAWS. Last Updated 12\/2008 43 DFA 325.1A \uf071 Quarterly Cases: Case counts for these groupings are displayed in the column labeled Case Counts, with the case count ratios established in the column labeled Case Counts Ratio. The case count ratios are used for allocating generic personal services and operating costs among these groupings. \uf071 Quarterly Time Study Hours: Quarterly time study hours for EDP staff (personal services costs) are reported in the column labeled Quarterly Time Study Hours, with the respective time study ratios displayed in the column labeled Quarterly Time Study Hours Ratio. \uf071 CWD Personal Services\/Allocation: CWD personal service staff costs (EDP staff) are reported in this column. \uf071 CWD Operating Costs\/Purchase of Service (POS) Non-CCAP: Operating costs (Non-CCAP) are displayed in this column. \uf071 CDB-SAWS and SAWS Redistribution: Redistributes CDB-SAWS and SAWS costs the CalWORKs and Other Public Welfare functions. \uf071 Public Agencies\/POS CCAP: This column displays CCAP costs. \uf071 Reallocation of Generic EDP Costs: This column is used to reallocate generic costs (both personal services and operating costs) to the seven groupings (the five functions plus Central Data Base-SAWS and SAWS) based on the case count ratios established in the column Case Counts Ratio. \uf071 Total EDP Costs: This column sums the costs reported in CWD Personal Services Allocation, CWD Operating Costs, Purchase of Service-Non-CCAP, CDB-SAWS & SAWS Redistribution, Public Agencies Purchase of Service- CCAP, and Reallocation of Generic EDP Cost. M & O Direct Cost The five program functions are displayed on this portion of the report (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare). Please note that Generic is not listed here, as these are projects in which the costs go direct to the program(s) that benefit from the system. Generic EDP is distributed to function based on the function case count ratios and then to program based on caseworker time study ratios. \uf071 Program Code: This column is used to report the claiming program code for M & O Direct Costs. \uf071 Time Study Hours: Time study hours are reported here for information only. These hours are not used for allocating costs to programs here because the costs are claimed directly to program, via the three-digit program code. Last Updated 12\/2008 44 DFA 325.1A \uf071 CWD Personal Services\/Direct: EDP staff costs are direct charged here. The EDP personal service cost to be claimed to each program is calculated prior to claim input. \uf071 CWD Operating Costs\/Purchase of Service\/Non-CCAP: Direct charged operating costs\/purchase of service is reported in this column. \uf071 Total EDP Costs: The direct costs for all projects in this category from columns CWD Personal Services Direct Cost and CWD Operating Costs\/Purchase of Service-Non-CCAP are summed here. 2. Developmental Projects The second section of the DFA 325.1A is dedicated to developmental projects. Developmental projects are separated into direct-to-program, multifunction (e.g. projects that benefit more than one function) and single function projects. Direct to program projects are listed separately from single and multifunction projects. Developmental Projects\/Direct Cost The Developmental Project\/Direct Cost section groups projects by benefiting functions (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare). Each project is listed with a benefiting program code, project number, and associated costs. \uf071 Program\/Project Name: The names of approved projects are listed here. \uf071 Program Code: The three-digit program code (provided by CDSS) is displayed here. \uf071 Project Number: Project numbers (Advanced Purchase Document (APD) numbers assigned by Health & Human Services Data Center (HHSDC) for approval and claiming purposes) are reported here. \uf071 Qtrly Time Study Hours Info Only: EDP staff project hours are posted here. Please note, the hours reported here are for information only. \uf071 CWD Personal Services Allocation: EDP Staff costs are direct charged here. The EDP personal service cost to be claimed to each program is calculated prior to claim input. \uf071 CWD Operating Costs\/Purchase of Service\/Non-CCAP: Direct charged operating costs\/purchase of service is reported in this column. Last Updated 12\/2008 45 DFA 325.1A \uf071 Total EDP Costs: The direct costs for all projects in this category from columns CWD Personal Services Allocation and CWD Operating Costs\/ Purchase of Service-Non-CCAP are summed here. Developmental Projects Single Function and Multifunction The single and multifunction section of Developmental Projects lists projects and indicates the benefiting function(s) (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare). \uf071 Project name: Approved project titles are listed here. \uf071 Project Number: Project numbers (APD numbers assigned by HHSDC for approval and claiming purposes) are reported here. \uf071 Function: Functions are listed in this column (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare.) Entries in this column identify the benefiting functions. \uf071 Time Study Hours\/Ratios: For projects listed, these columns are used for reporting time study hours and ratios. \uf071 CWD Personal Services Allocation: Costs are calculated by using the EDP time study hours. Ratios are calculated by EDP staff time study hours and multiplied to the EDP personal services salary pool to derive at the personal services allocated cost by project. \uf071 CWD Operating Costs Purchase of Service\/Non-CCAP: Costs in this column have been specifically identified, prior to claim input, to the appropriate project. \uf071 Total EDP Costs: The totals for columns CWD Personal Services Allocation and CWD Operating Costs Purchase of Service-Non-CCAP are summed here. Last Updated 12\/2008 46 DFA 325.1A Last Updated 7\/2013 47 DFA 325.1B DFA 325.1B Direct Cost Main Menu Input Enter direct costs by function, or use the All to display all functions. Enter All functions Enter by function Last Updated 7\/2013 48 DFA 325.1B Direct Cost Input Screen An annual Letter of Intent to Direct Charge expenditures to a Type of Expense (TOE) code of 88-91, must be submitted by the 15th of the month prior to the start of the fiscal year or quarter of implementation. An example can be found on the following page. **Hint: Move columns around to make input easier by using the drag and drop feature. Note: If on an Adjustment Claim costs are moved from one 6-digit PIN to another, make sure to leave at least $1 to the 6-digit PIN previously claimed to on the Original CEC. Do not leave the cost space blank or zero. If $1 is not left in, it will throw costs off during the calculation of the claim. REQUIRED MANUAL ADJUSTMENTS for PQCR Pursuant to CFL 12\/13-17; any county claiming direct costs to PQCR (PC 088) should take the following steps in allocating and claiming the costs: Enter Direct Costs Optional: To be used at the County’s discretion Last Updated 7\/2013 49 DFA 325.1B Prior to inputting the costs into the CEC Template; the total costs should be divided between PC 088 and 828 according to the percentages in the PQCR methodology. The costs should then be entered to appropriate pin code accordingly. While the percentages to be used for this methodology are fiscal year specific; below is an example based on the FY 12\/13 percentages. Code Program Name Ratio Program 088 Peer Quality Case Review 0.6616 Title IV-E 828 Non IV-E PQCR 0.3384 State General Fund *Ratios identified above are specific to FY 12\/13 Total costs to be claimed for PQCR = $2,500.00 Divide the costs between PC 088 and PC 828 as follows: (PC 088) $2,500.00 * 0.6616 = $1,654.00 (PC 828) $2,500.00 * 0.3384 = $846.00 Enter the costs into the DFA 325.1B as follows using the appropriate TOE code: PC 088 = $1,654.00 PC 828 = $846.00 Source Documents: County financial records of direct expenditures Last Updated 7\/2013 50 DFA 325.1B Example of a Letter of Intent to Direct Charge [Insert Date] Fiscal Policy Bureau Department of Social Services 744 P Street, MS 20-03 Sacramento, CA 95814 Attention Fiscal Policy Bureau: SUBJECT: DIRECT CHARGE METHODOLOGY This is to inform the California Department of Social Services, Fiscal Policy Bureau, of Riverside County’s intent to continue our Direct Charge Methodology for identifying Support Operating Costs. Any changes in our methodology for direct charging a specific operating cost to a function or program will be implemented beginning with the [Insert Fiscal Year and Quarter of Implementation]. We understand that a request to implement a new methodology is due prior to the quarter of implementation and that the chosen methodology must remain in effect until the end of the fiscal year. If we choose to discontinue the methodology, it must be done at the beginning of a new fiscal year by submitting a written document signed by our County Fiscal Officer, Director, or Representative with a designated signature on file with the CDSS. Riverside County also acknowledges that all State and Federal laws\/regulations\/guidelines with respect to claiming direct costs still apply. If additional information is required, please contact [Insert Contact Name & Number]. Sincerely __________________________ [Insert Authoring Signature] [Insert Title] [Insert County] Last Updated 7\/2013 51 DFA 325.1B DFA 325.1B Direct Cost Input Schedule The DFA 325.1B is a report used to display costs directly claimed to specific programs. The number of lines\/pages is dependent upon the number of direct costs entered (one per line). This page is used by the County Expense Claim (CEC) to populate the aggregate Direct Cost information displayed on the DFA 327.3 to the three-digit program code level. The costs are summarized by function on the DFA 325.1 Expenditure Schedule. \uf071 Function #: This identifies the function classification: 1= Social Services (SS) 2= CalWORKs (CW) 3= Other Public Welfare (OPW) 4= Child Care (CC) 5= NonWelfare (NW) \uf071 Program ID#: A six-digit number that determines the program to which the cost is directly identified. This is referred to as the Program Identifier Number (PIN) code. The first three digits are the program code to which the costs will be claimed. The fourth digit refers to the component ID. The last two digits represent the Type of Expense (TOE) code. For example: \uf0bd147\uf0bd2\uf0bd03\uf0bd CWS Court Related Activities – Family Maintenance – Transportation (Program) (Component ID) (Expense Type) Direct Costs are costs not included in the allocation process. Direct Costs are costs made on behalf of the County Agency clients, or direct charged Support and Other Operating costs. Direct Cost entries on the DFA 325.1B are entered by PIN code by function. \uf071 Program Title: Identifies the program title. \uf071 Type of Expense: TOE classification denoted by the last two digits of the PIN code. \uf071 Direct Cost: The cost of the service to be claimed. \uf071 Program Subtotal: The sum of the program costs. *Hint: Program subtotals will not print out when All Reports is selected during the printing process. \uf071 Contract Number\/Fiscal Year: The contract number and\/or fiscal year are entered here, if applicable. Last Updated 7\/2013 52 DFA 325.1B Last Updated 12\/2008 53 DFA 325.1C DFA 325.1C Staff Development Main Menu Input Last Updated 12\/2008 54 DFA 325.1C Staff Development Costs to Function Input Screen *Hint: When entering hours for Staff Development Trainers, you must enter the total hours for all three months in the quarter as specified in the Quarterly Time Study Instructions. Source documents: County financial records of Staff Development costs County payroll records regarding salaries and benefits County Training Plan DFA 10 Staff Development Time Study Enter Hours for Staff Development Trainers Only (Not Trainees) Enter Staff Development Training\/POS Costs for each Function Last Updated 12\/2008 55 DFA 325.1C Staff Development Direct to Program Input Screen Source documents: County financial records of Staff Development costs County payroll records regarding salaries and benefits County Training Plan DFA 10 Staff Development Time Study Enter Hours for Staff Development Trainers Only (Not Trainees) Enter Staff Development Training\/POS Costs for each Program Last Updated 12\/2008 56 DFA 325.1C Staff Development Personal Services Input Screen Source documents: County financial records of Staff Development costs County payroll records regarding salaries and benefits County Training Plan Enter Staff Development costs to be allocated Last Updated 12\/2008 57 DFA 325.1C DFA 325.1C Staff Development Detail Schedule The Staff Development expenditures are displayed on the DFA 325.1C for personal services, operating costs, and the direct cost of trainees\/purchase of services. The top of the DFA 325.1C display costs claimed at the function level (including Generic), while the bottom of the report displays those costs claimed direct-to-program. This information is used to populate the data on the DFA 327.4A-E pages and is summarized on the DFA 325.1 Expenditure Schedule. \uf071 Program Code: The three-digit program code is displayed in the direct-to- program section of the page. \uf071 Program Description\/Cost Distribution Level: The top section is used for displaying costs at the function level. The bottom section identifies those programs where training costs have been claimed direct-to-program. \uf071 Time Study Hours\/Observations\/Ratios: Displays the time study hours and corresponding ratios for trainers. \uf071 Personal Services and Operating Costs: This column displays the personal services and operating costs at the function and direct-to-program level for staff assigned to the Staff Development office. \uf071 Direct Cost of Trainees\/Purchase of Services: The salaries of trainees and purchase of service costs are displayed at the function and direct-to-program level. \uf071 Reallocation of Generic Staff Development: All Generic personal services and trainees cost\/purchase of service is reallocated to the function level based on the casework time study hours ratio found on the DFA 325.1 Expenditure Schedule. \uf071 Total Staff Development: This column sums the total Staff Development costs to the function and\/or direct-to-program level. Last Updated 12\/2008 58 DFA 325.1C Last Updated 12\/2008 59 DFA 7A DFA 7A Support Staff Main Menu Input For SSTRP Counties For Non- SSTRP Counties Last Updated 12\/2008 60 DFA 7A SSTRP Counties Support Staff Time Studies Input Screen Source Documents: DFA 7 Support Staff Time Report Enter Hours Last Updated 12\/2008 61 DFA 7A Non-SSTRP Counties Support Staff Time Studies Input Screen Source Documents: DFA 7 Support Staff Time Report County payroll records regarding salaries and benefits Enter Salary Costs Last Updated 12\/2008 62 DFA 7A Direct Charge Support Staff Costs Input Screen for Cluster Codes Can be used by either SSTRP or Non-SSTRP Counties. Hint: When using this input screen, do not put corresponding hours or dollars into the other SSTRP or Non-SSTRP screens. Source Documents: DFA 7 Support Staff Time Report County payroll records regarding salaries and benefits Enter Salary\/Benefits Costs Directly to Benefiting Program Last Updated 12\/2008 63 DFA 7A Total Support Staff Salaries Input Screen For use by SSTRP Counties only Source Documents: County payroll records regarding salaries and benefits Enter Salary\/ Benefits costs Last Updated 12\/2008 64 DFA 7A DFA 7A Support Staff Summary The DFA 7A is a report detailing all support staff time study hours, time study ratios, and salary distribution displayed for the General Administration, Program Administration, and Clerical Support. The DFA 7A displays function, multi- function, and direct-to-program support staff time study hours, ratios, and costs. All possible combinations are displayed in this report. Support Staff Summary DFA 7A pg1 Section I These pages display support staff time study hours, time study ratios and salaries. The top of the page displays total salary costs for General Administration, Program Administration, and Clerical Support. The total information is also displayed at the bottom of the last page of this section. \uf071 Benefiting Level \/ Program Code: This area is used to identify the benefiting levels. These pages display the function data, multi-function data, and direct-to-program data. \uf071 Hours Reported: The time study hours reported for General Administration, Program Administration, and Clerical Support are displayed in this column by benefiting level. \uf071 Ratio to Grand Total: Time study ratios are derived within the General Administration, Program Administration, and Clerical Support personnel groupings. \uf071 Distribution of Salary: Salary costs are displayed on each applicable line for General Administration, Program Administration, and Clerical support at the function, multi-function, and direct-to-program level, according to the ratios developed. Distribution of Multi-Function Salaries DFA 7A pg1 Section II \uf071 Multi-Function Pool: This section allocates multi-function salary costs to the function level. There is a separate page for each salary cost pool (General Administration, Program Administration, or Clerical support). The salaries displayed here reflect the salaries spread for the multi-function pool. Last Updated 12\/2008 65 DFA 7A Last Updated 12\/2008 66 DFA 7B DFA 7B Reconciliation of General Administration, Program Administration, & Clerical Support Staff Salaries and FTE’s This is a reconciliation page for distribution of support salary costs \/ FTE’s for General Administration, Program Administration, and Clerical Support staff. \uf071 Benefiting Level: This area displays the benefiting level by program function. \uf071 Salaries: Salary costs are summarized to the function or program level (including Generic) for General Administration, Program Administration, and Clerical Support staff. The detail of this summary is displayed on the DFA 7A by cost pool, function (including the multi-function distribution of salaries), and direct-to-program. \uf071 Ratio: Ratios are developed for the support salaries by benefiting level to total salaries in the pool. \uf071 FTE’s: The total FTE’s from the DFA 403 are distributed according to the ratio developed by total salaries to each salary cost pool (General Administration, Program Administration, and Clerical Support). The FTE’s at the function level or direct-to-program level are derived from the applicable support staff time study ratios. Last Updated 12\/2008 67 DFA 7B2 DFA 7B2 Support Staff Salary Distribution to Program The DFA 7B2 is a summary of direct-to-program salary costs. The programs are displayed in program function order (e.g. Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare). \uf071 Code: An alphanumeric code is used to identify the program component to which the direct-to-program salary costs are to be distributed. This alphanumeric code is linked to the base program code. \uf071 Program Title: The program description\/title is displayed here. \uf071 General Salaries\/Program Salaries\/Clerical Salaries from DFA 7: The Support staff salaries are displayed here. \uf071 DFA 55 Casework Hours: Applicable casework hours from the DFA 55 are displayed here. \uf071 Intermediate Ratio of Casework Hours: Intermediate casework time study ratios are derived within the program component groupings. This ratio is used to distribute direct-to-program support staff salaries by program. \uf071 Distribution of General\/Program\/Clerical Salaries: Applicable salary costs are displayed in the respective columns by program using the Intermediate Ratio of Casework Hours ratio. \uf071 Total Salaries to Program: The sum of General, Program, and Clerical Salaries are displayed here by program. \uf071 Program Code: The three digit program codes are displayed here. Last Updated 12\/2008 68 DFA 7B3 DFA 7B3 Distribution of Generic Support Staff Cost to General Administration; Program Administration; & Clerical Support Staff \uf071 Benefiting Level: This column displays the benefiting level by function. \uf071 General Administration Support Staff: This column displays the salaries of the General Administrative Support Staff to the benefiting level. \uf071 Program Administration Support Staff: This column displays the salaries of the Program Administrative Staff to the benefiting level. \uf071 Clerical Support Staff: This column displays the salaries of the Clerical Staff to the benefiting level. \uf071 Total Support Staff: This column sums the General Administration, Program Administration, and Clerical Support columns to the benefiting level. \uf071 Casework Ratio: The ratios from the DFA 325.1 – Total Paid Casework Hrs. and Casework Ratios, are displayed here. \uf071 Generic Cost Distribution: This column distributes the Grand Total of the Generic Salary costs from the General Administration, Program Administration, and Clerical Support Staff columns to the benefiting function levels by the casework ratios. \uf071 Total Cost: A recalculation takes place here with a new total by benefiting level, including the allocated Generic costs. Last Updated 12\/2008 69 DFA 7B3 Last Updated 12\/2008 70 DFA 325.1E DFA 325.1E Direct-to-Program Support Staff Salary Input The DFA 325.1E displays the salary costs from the DFA 7B (Support Staff Salary Distribution to General Salaries, Program Salaries, and Clerical Salaries) for General Administration, Program Administration, and Clerical Support at the direct-to-program level. The information provided on this report is based upon what the county has specified in their Support Staff Time Reporting Plan (SSTRP). This does not apply to non-SSTRP counties. The data on this page is populated from information input on the DFA 7A and is summarized by function on the DFA 325.1 Expenditure Schedule. \uf071 Program Code\/Title: The three-digit program code and corresponding title is displayed. \uf071 General Salaries: Salaries and benefits of staff (i.e. Directors, Deputy Directors, personnel staff) typically having department-wide benefit; however, they can be assigned to a program during a particular time study period. \uf071 Program Salaries: Salaries and benefits of staff (i.e., professionals, supervisors, managers, or other similar staff) who oversee or are otherwise responsible to support line staff for specified program(s). \uf071 Clerical Salaries: Salaries and benefits of clerical staff that perform clerical activities in direct support of caseworker staff assigned to specific programs. Staff time study to the appropriate program. \uf071 Total Salaries to Program: The sum of the direct-to-program support staff salaries. Last Updated 12\/2008 71 DFA 325.1E Last Updated 7\/2013 72 DFA 55 DFA 55 Casework Time Studies Main Menu Enter Casework Time Study Hours individually by function, or use the ‘All’ to display all functions. Displays all Time Study Codes Displays Time Study Codes for each Function Enter Casework Salary \/ Benefits Last Updated 7\/2013 73 DFA 55 Casework Time Studies Input Screen *Hint: Move columns around to make input easier by using the drag and drop feature. Source Documents: DFA 10 Casework Time Study Enter Fraud Worker Hours Enter Eligibility Determination Worker Hours Enter Employment Services Worker Hours Enter Social Worker Hours Last Updated 7\/2013 74 DFA 55 Casework Salary \/ Benefits Input Screen Source Documents: County payroll records regarding salaries and benefits Enter Salary\/ Benefit costs Last Updated 7\/2013 75 DFA 55 DFA 55 Casework Time Study and Salary Distribution Summary Time Study Hours\/Observation by Salary Pool\/Program The DFA 55 report summarizes caseworker time study hours and salary distribution to Social Services, CalWORKs, Other Public Welfare, Child Care and NonWelfare. Within each function, programs are listed in time study code order (four-digit). SPECIAL NOTE: Caseworker time study hours\/ratios are the most significant element for allocating costs to programs within the CEC. Section I Casework Time Study and Salary Distribution Summary Time Study Hours\/Observation by Salary Pool\/Program \uf071 Program Code & Description: The time study code (four digit) and program descriptions are listed here in numerical order. \uf071 Time Study Hours\/Observation by Salary Pool\/Program: Social Workers, Employment Service Workers, Eligibility Determination Workers, and Fraud Investigator Hrs\/Observations are displayed by program throughout these pages. \uf071 Program Ratio: Program ratios are established from the corresponding time study hours for each time study code. Program ratios are derived within each caseworker salary pool. Function ratios are derived from all caseworker hours to programs within a function. Section II Casework Time Study and Salary Distribution Summary by Pool\/Program \uf071 Program Code & Description: This displays the program numbers and descriptions by function. \uf071 Distribution of Salary Costs by Pool\/Program: Salary costs are displayed by program within the caseworker salary pools (e.g. Social Workers, Employment Service Workers, Eligibility Determination Workers, and Fraud Investigators), calculated by ratio to Grand Total All Functions salary pool. \uf071 Grand Total Salary Cost: Salary costs displayed are summarized in this column. Total Hours\/Observations\/Ratios \uf071 Total Program Hrs\/Obs: Total program hours reported on the previous DFA 55 are summed in this column. Last Updated 7\/2013 76 DFA 55 \uf071 Component to Program Ratio: These ratios are derived from the total time study hours reported in the previous column within the same time study program. For example, ratios are established for time study codes 1031, 1032, 1033, and 1034 for the base PC 103. The ratios within these components sum to 100% for PC 103. \uf071 Program to Function Ratio: Function ratios are derived in this column. Program to Function ratio differs from Program ratio if caseworkers time study to more than one salary pool within the function. \uf071 Generic Distribution\/Generic Salary Cost by Function\/Program: Generic casework salary costs are distributed to program in this column. Total Generic caseworker salary and benefit costs are first allocated to the function level using the caseworker function ratios on the DFA 325.1. Function totals are then allocated to program(s) using program ratios found in the Program to Function Ratio column. PROGRAM CODES: EXAMPLE: 148103 CWS ER CASE MANAGEMENT TRANSPORTATION The first three digits 148 of the six digit codes used on the CEC is the program code. It is referenced throughout the CEC. The fourth digit 1 is the Component ID and is the Time Study code used on Time Studies for caseworkers (e.g., 1481). The last two digits 03 is the Type of Expense (TOE) or the Program Identifier Number (PIN #) used for Direct Charges for specific services (e.g., contracts, direct service delivery, start up costs, transportation assistance, etc). This code is used on the Direct Cost Input Schedule, DFA 325.1b. REQUIRED MANUAL ADJUSTMENTS for PQCR Pursuant to CFL 12\/13-17; any county claiming time study hours to PQCR (PC 088) should take the following steps in allocating and claiming the hours: Activities should be time studied to TSC 0881 by county case workers. Prior to inputting the hours into the CEC Template; the total hours should be divided between TSC 0881 and 8281 according to the percentages in the PQCR methodology. The hours should then be entered to TSC 0881 and 8281 accordingly. While the percentages to be used for this methodology are fiscal year specific; below is an example based on the FY 12\/13 percentages. Last Updated 7\/2013 77 DFA 55 Code Program Name Ratio Program 088 Peer Quality Case Review 0.6616 Title IV-E 828 Non IV-E PQCR 0.3384 State General Fund *Ratios identified above are specific to FY 12\/13 Total hours reported to TSC 0881 = 120.0 Divide the hours between TSC 0881 and TSC 8281 as follows: (TSC 0881) 120.0 * 0.6616 = 79.39 (TSC 8281) 120.0 * 0.3384 = 40.61 Enter the hours into the DFA 55 as follows: TSC 0881 = 79.39 TSC 8281 = 40.61 Last Updated 7\/2013 78 DFA 55 Last Updated 7\/2013 79 DFA 55 Last Updated 7\/2011 80 DFA 403 DFA 403 Full Time Equivalents (FTE’S) Input Screen FTE information produced by this input screen is used by County Financial Analysis Bureau (CFAB). Any questions regarding FTE’s should be directed to CFAB through the fiscal.systems e-mail address. Enter Part Time Staff Enter Full Time Staff Last Updated 7\/2011 81 DFA 403 DFA 403 Full Time Equivalent The DFA 403 displays the number of full time and part time staff that are assigned to a particular CEC Salary Cost Pool. There are eight salary cost pools on this form. Four of the pools account for caseworker staff, three of the pools account for support staff, and one pool accounts for EDP staff. Caseworker pools consist of: \uf071 Allocable Social Services Casework Costs Pool \uf071 Allocable Employment Services Casework Costs Pool \uf071 Allocable Eligibility Determination Casework Costs Pool \uf071 Allocable Welfare Fraud Casework Costs Pool Support Staff pools consist of: \uf071 General Support \uf071 Program Administration Support \uf071 Clerical Support EDP has one cost pool. Each cost pool captures the following information: \uf071 Number of full time staff \uf071 Number of part time staff \uf071 Total staff in salary pool Last Updated 12\/2008 82 DFA 419 DFA 419 Claim Summary Sheet Input Screen *Hint: If the comments entered in the additional information box become repetitive, use Control C to copy and Control V to paste Source documents: DFA 419 Variance Report Prior and Current Quarter CEC Claims Check the appropriate box for variances Last Updated 12\/2008 83 DFA 419 DFA 419 Claim Summary Sheet The DFA 419 is a summary of factors reflecting variances of 15% over or under the previous quarter. The line numbers on the DFA 419 correspond to the line numbers on the DFA 325.1. Data on this page provides CDSS with the reasons for significant cost changes for various cost categories quarter to quarter. CDSS requires that each county validate the variances of 15% over or under by using a (\uf0fc) under one of the eight headings at the top of the page or adding further description under additional information. The reasons for the variations in the above cost\/information categories are entered in one or more cells under the following headings: extra pay period, fluctuation in staff, increase in salary and\/or benefits, prior quarter (adjustments only), cash flow, current time period claimed (number of months), new contracts or leases, or terminated contracts or leases. If none of these reasons apply to your cost difference then you must validate the cost under additional information. Casework ratios help Counties identify variances at the function level and may be used to explain any 15% variances on DFA 419. Reference note: DFA 419 Variance Claim Summary Sheet The DFA 419 Variance Claim summary Sheet (found under County Reports) addresses variances line by line according to the 325.1 page of the current quarter and the previous quarter. It describes the current quarter costs, prior quarter costs, differences and the percentage of the variance. The CDSS requests each county to validate any variances of 15% over or under the current quarter to the previous quarter. The information contained in this report will assist you in determining what to validate on the DFA 419. Last Updated 12\/2008 84 DFA 329 DFA 329 Incentive Funds Expenditure Main Menu When entering Incentives, you must enter both IPC and IEC and they must balance Last Updated 12\/2008 85 DFA 329 Fiscal Incentives Input Screen *Hint: When using PC’s 090 097, your total program costs must be zero on the DFA 327.5 Welfare Funding page. Enter TANF Incentive costs Enter Fraud Incentive Costs Must equal the total on TANF Incentive Funds Expenditure Input screen Last Updated 12\/2008 86 DFA 329 DFA 329 Performance \/ Fraud Incentive \uf071 Program Code\/Title: The DFA 329 displays all of the transactions entered on the input screen for Incentive Expenditure by Program Category (IPC) by three digit program code. \uf071 TANF\/Expanded Needy Families: Displays the amount of performance incentives to be abated against the applicable program codes. \uf071 Fraud TANF: Displays the amount of fraud incentives to be abated against the applicable program codes. The transactions listed on the DFA 329 should match the transactions recorded on the DFA 327.5’s P1 on the TANF Incentive and Fraud Incentive columns. Performance Incentives are abated against total program costs. The County Expense Claim will not process negative expenditures when applying performance or fraud incentives. Last Updated 12\/2008 87 DFA 335 DFA 335 TANF Incentive Funds Expenditure Input Screen Must equal the total on Fiscal Incentive Input screen Do not enter any costs into the heading lines Last Updated 12\/2008 88 DFA 335 DFA 335 Temporary Assistance for Needy Families (TANF) Incentive Funds Expenditures The DFA 335 summarizes all the transactions entered on the input screen for Incentive Expenditures by Category(IEC) by Assistance and Non-Assistance Categories. Expenditures Category Assistance includes the following 4 choices in the input area: 1. Cash Based Assistance 2. Child Care 3. Other Supportive Services 4. Assistance Authorized Solely Under Prior Law Expenditure Category Non-Assistance includes the following 11 choices in the input area: 1. Work Subsidies 2. Education 3. Work Activities\/Expenses 4. Child Care 5. Transportation 6. Job Access 7. Diversion Payment 8. Prevention of Out-of-Wedlock Pregnancies 9. 2-Parent Family Formation and Maintenance 10. Administration 11. Information Systems and Technology \uf071 Total Expenditures: Displays the total expenditures by expenditure category. \uf071 TANF: Displays TANF expenditures by expenditure category. \uf071 Expanded Needy Families: Displays Expanded Needy Families expenditures by expenditure category. \uf071 Fraud Incentives: Displays Fraud expenditures by expenditure category. The total of these transactions must match with the total of Incentives entered on the DFA 329 by program and the DFA 327.5’s P1 Total Performance Expenditures entered. The County Expense Claim will not process negative expenditures when applying performance or fraud incentives. Last Updated 12\/2008 89 ADD Addendums Main Menu For use by Los Angeles and Merced Counties only. County Expense Claim Page, Column, and Line Descriptions Section II Output Pages Last Updated 12\/2008 91 DFA 327.1 DFA 327.1 – Distribution of Salary Cost and Allocable Support Staff and Operating Costs The DFA 327.1 distributes the caseworker salary costs based on the time study hours ratios for each function. Allocable support staff costs, direct-to-program support staff costs, and allocable support operating costs are distributed to the following functions: \uf071 Social Services \uf071 CalWORKs \uf071 Other Public Welfare \uf071 Child Care \uf071 Non-Welfare DFA 327.1 pages do not require any input. These numbers are calculated by formulas in the database system. \uf071 Distribution of Salary Costs: The salary cost distribution by four-digit time study code is computed on the DFA 55 pages based on caseworker time study hours. The DFA 327.1 transfers the summarized Grand Total Salary Cost from the DFA 55 based on the program codes. For example PC 103 on DFA 327.1 summarizes the total of time study codes 1031, 1032, 1033, and 1034 from the DFA 55 Grand Total Salary Cost. The total Distribution of Salary Costs for each function on the DFA 327.1 should match with the corresponding function on the DFA 325.1 Total Casework Costs by function salary cost pool. \uf071 Time Study Hours\/Observations: The Time Study Hours\/Observations summarizes the Total Program Hrs\/Observations from the DFA 55 based on the program codes. For example, PC 103 on the DFA 327.1 summarizes the total of PC’s 1031, 1032, 1033, and 1034 from the DFA 55 Total Program Hrs\/Observations. The total Time Study Hrs\/Observations for each function on the 327.1 should match with page 2 of the DFA 325.1 Casework (or Total Paid Casework) Hrs\/ Observations. \uf071 Ratio: This column displays the ratio for each program based on each program’s time study hours within a function. \uf071 Generic Salary Cost: The Generic Salary Cost by Function\/Program reported on the DFA 55 are transferred to the Generic Salary Cost on the DFA 327.1. \uf071 Allocable Support Staff Costs: The Total Cost by function reported on the DFA 7B3 is distributed to the program based on the program ratio. Last Updated 12\/2008 92 DFA 327.1 \uf071 Direct-To-Program Support Staff Cost: Displays the Direct-To-Program Support Staff Costs from the DFA 7A and the DFA 7B. \uf071 Allocable Support Operating Cost: The Total Support Operating Costs pool from DFA 325.1 first gets allocated to each function based on the Casework Ratios found on page 2 of the DFA 325.1, and then distributed to the program based on the program ratios found on the DFA 327.1. \uf071 Adjustments: The Allocable Support Staff Costs, Direct-to-Program Support Staff Costs, and the Allocable Support Operating Costs for some programs are redistributed to other programs. For example, The Allocable Support Staff Costs, Direct-to-Program Support Staff Costs, and the Allocable Support Operating Costs for PC 145 are redistributed to PC 575. \uf071 Total Casework and Allocable Support Costs By Program: The Total Casework and Allocable Support Costs By Program column summarizes the Distribution of Salary Costs, Generic Salary Costs, Allocable Support Staff Costs, Direct-to-Program Support Staff Costs, Allocable Support Operating Costs, and the Adjustments on the DFA 327.1. Total Casework and Allocable Support Costs By Program from DFA 327.1 are displayed on the DFA 327.3. Last Updated 12\/2008 93 DFA 327.1 Last Updated 12\/2008 94 DFA 327.2 DFA 327.2 EDP Cost Schedule The DFA 327.2 displays the program costs in function groups as follows: Social Services, CalWORKs, Other Public Welfare, Child Care, and NonWelfare. These pages allocate EDP costs to the program in a similar manner to the other DFA 327 pages. As will be discussed below, the DFA 327.2 is closely linked to information contained on the DFA 325.1A. 1. EDP Cost Schedule Total EDP Costs Costs shown in this section are total EDP costs accumulated by program to be later displayed on the DFA 327.3’s Total EDP Cost column. \uf071 M & O Allocable Cost: The costs in this column are calculated on the DFA 327.2 section Allocation of M & O EDP Costs and M & O Direct Cost, under the Allocated Costs column. These costs are displayed by program. \uf071 M and O Direct Cost: The costs in this column are calculated on the DFA 327.2 section Allocation of M & O EDP Costs and M & O Direct Cost, under the Direct Costs column. These costs are displayed by program. \uf071 Development Direct Costs: Costs in this column are reported on the DFA 325.1A under Developmental Projects\/Direct Costs, under the Total EDP Cost column. \uf071 Developmental Multifunction Cost: Costs in this column are reported on DFA 327.2 EDP Multifunction Developments Projects (explained below). Currently there is provision for up to 24 separate EDP Developmental Projects. \uf071 EDP Adjustments Allocable Cost: This column is used to shift costs to other program codes for state defined reasons. \uf071 Total EDP Costs: This column sums the costs reported in columns M & O Allocable Cost, M & O Direct Costs, Development Direct Costs, Developmental Multifunction Cost, and EDP Adjustments Allocable Cost. 2. Allocation of M & O EDP Costs and M & O Direct Cost This section of the DFA 327.2 calculates the allocated EDP costs for M & O and accumulates direct costs by program. \uf071 Allocated Costs: The costs shown here are reported on the DFA 325.1A with the respective program function amount reported on the subtotal page of the corresponding function on the DFA 327.2. The M and O amount is calculated by multiplying the total generic EDP costs, by the case count function ratios displayed on the DFA 325.1A. Ratios are developed from the Last Updated 12\/2008 95 DFA 327.2 case counts reported on the DFA 325.1A. The amount reported here includes CWD personal services and operating costs and is allocated to programs based on caseworker time study ratios (DFA 327.1, in column labeled ratios, and the DFA 55, Program to Function Ratio). \uf071 Direct Costs: These costs are reported on the DFA 325.1A, Quarterly Time Study Hours Ratio and CWD Personal Services Allocation, and distributed to program on the DFA 327.2. Direct costs are reported on the DFA 325.1A, using the three-digit program code. This same program code is utilized on the DFA 327.2. \uf071 Program Code Adjustments: This column is used to shift costs to other program codes for state defined reasons. \uf071 M & O Total Costs: This column sums the amounts reported in columns Allocated Costs, Direct Costs, and Program Code Adjustments. 3. EDP Multi-Function Development Projects (1-24) Costs reported in this section are being allocated to the benefiting programs in the identified functions on the DFA 325.1A, section EDP-Cost Detail Schedule Developmental Projects\/Single and Multi-Functions. \uf071 Program Code\/Title: The three-digit program code and the corresponding program title is displayed here. \uf071 Observed Hours: The hours displayed in this column are the caseworker hours accumulated by program from the DFA 55. \uf071 Projects: In these columns, project numbers are listed from the DFA 325.1A, section EDP-Cost Detail Schedule Developmental Projects\/ Single and Multi- Functions. Each project is listed in a separate column. The costs reported on the DFA 325.1A for that project are first allocated to the benefiting function using the EDP case count function ratios. Costs are then allocated to the programs on the DFA 327.2 using caseworker time study ratios found on the DFA 55. Last Updated 12\/2008 96 DFA 327.2 Last Updated 12\/2008 97 DFA 327.2 Last Updated 7\/2011 98 DFA 327.3 DFA 327.3’s Program Cost Summary The DFA 327.3 consolidates information contained on other claim pages, providing for total costs, by program (exclusive of staff development costs). The purpose of the DFA 327.3 is to provide information in one place for all costs to programs and is used for distributing costs to the funding sources on the DFA 327.5. The DFA 327.3 displays function costs as follows: Social Services, CalWORKs, Other Public Welfare, Child Care, and Nonwelfare. Columns display groups of costs and cost shifts. Not all functions utilize the cost shift columns as will be explained below. \uf071 Program Code\/Title: The three-digit program code and corresponding program title is displayed here. \uf071 Casework & Allocable Support Costs: The costs in this column can be found on the DFA 327.1, Total Casework and Allocable Support Costs By Program. \uf071 Total EDP Cost: The costs in this column are found on the DFA 327.2, Total EDP Costs. \uf071 EA Cost Eligible: This column is no longer used; effective July 1, 2010 counties were instructed to stop reporting EA cases on the CEC (CFL 09\/10- 66). \uf071 Direct Costs: These costs can be found on the DFA 325.1B. Note that the DFA 325.1B uses a six-digit Program Identifier Number (PIN). The first three digits of the PIN are the same as the program code. The fourth digit is the program sub-component number, and the fifth and sixth digits are Type of Expense identifiers (TOE) (e.g. transportation, direct cost, contracted service, etc.). \uf071 AFDC\/TANF Adj: This column allocates program costs between TANF and FS funding. For this shift, costs reported to PC 315 (Federal CalWORKs and CF Fraud) are split equally between PC 301 (CalWORKs Fraud) and PC 312 (Fraud PA CalFresh). For PC 342 (EFD\/P Cal WORKs and CF) costs are split equally between PC 340 (EFD\/P Federal CalWORKs) and PC 341 (EFD\/P NACF WFI). For PC 320 (Nonfederal CalWORKS and CF Fraud) costs are split equally between PC 305 (NF Cal WORKs Fraud) and PC 310 (NACF Fraud). The purpose of these shifts is to claim costs to benefiting programs. It has no financial impact on the state or counties. \uf071 Non Fed Costs: Costs in this column are calculated shifts using ratios from the federal\/non-federal case counts on the DFA 325.1. The shifts are made to properly claim reimbursement for non-federally eligible cases. Examples of some cost shifts are listed below. Not all shifts are listed. Last Updated 7\/2011 99 DFA 327.3 From Programs To Programs 014 Family Conferencing 019 NF Family Conferencing 117 Adoptions Case Mgmt 118 Adoptions Ind\/NF 155 Foster Family Licensing 156 Foster Family Licensing NF 175 FPP Services\/Non-federal 177 FPP CM:PS 359 CWS 358 SUO CWS Livescan 504 AB 2129 Foster Parent Trng 505 AB 2129 Foster Parent 506 AB 2129 Foster Parent 507 AB 2129 Foster Parent 577 Mo Visits\/Group Homes\/CWD 586 NF Group Homes 730 P.L.110-351 IV-E Trng-FC 731 NF P.L. 110-351 IV-E Trng-FC 748 P.L.110-351 IV-E Trng-Adopt 749 NF P.L. 110-351 IV-E Trng-Adopt 145 CWS Training 147 CWS Court Related Act 146 CWS Services\/Non-federal 148 CWS Case Mgmt 170 CWS – Emergency \uf071 PACF Shift: This column is used to shift Casework and Allocable Support Costs and Total EDP Costs from the CalWORKs function to the Other Public Welfare function to claim costs to the proper federal funding sources. The shift occurs based on a ratio computed on PACF Households to the CalWORKs caseload. The ratio is applied to costs reported to PC 614 CalWORKs Eligibility and PC 663 CalWORKs Case Management. The resultant answer is shared equally between PC 614 CalWORKs Eligibility, PC 663 CalWORKs Case Management, and PC 343 NACF Eligibility. The same ratio is applied to PC 618 CalWORKs Program Integrity and is shared equally with PC 344 NACF Program Integrity. For a numeric example, please refer to the section of the Manual that discusses Ledger # 076. Example of CalWORKs Eligibility shift: PACF Caseload [households] divided by CalWORKs caseload (including Two Parent Families Caseload) = PACF ratio. PACF ratio X expenditures of PC 614 and PC 663 = total expenditures to be shared equally between the CalFresh and CalWORKs programs. \uf071 CFAP\/ 2 Parent Families: In this column, two separate shifts take place California Food Assistance Program (CFAP) Families and 2 Parent Families. In lieu of capturing time study data to either program to allocate costs, administrative costs for these programs are determined based on the non- federal person counts\/ratios reported on the DFA 325.1. Last Updated 7\/2011 100 DFA 327.3 As a result of federal welfare reform legislation that would otherwise have terminated CalFresh eligibility for certain legal immigrants, CFAP, a state funded food assistance program, was initiated. There is no federal participation in the cost of this program. In order to properly claim CFAP administrative costs, ratios of CFAP persons are used to reduce federal participation claimed to CalFresh program codes. The programs that are reduced by the CFAP ratio are listed below: 211 CalFresh Issuance 218 NACF IEVS 268 SAVE Program NACF 275 EFD\/P – NACF 310 NACF Fraud 312 Fraud PA CalFresh 341 EFD\/P NACF (WFI) 343 NACF Eligibility 344 NACF Program Integrity 347 NACF Quality Control The sum of the amounts are reduced from these program codes are transferred to CFAP PC 606 CFAP Families. The Two Parent Family shift is similar to the CFAP shift. In order to properly claim Two Parent Family administrative costs to federal, the Two Parent Family ratio found on the DFA 325.1 is used to reduce federal participation claimed to CalWORKs program codes. Costs are shifted in the programs listed below: From Programs To Programs 614 CalWORKs Eligibility 065 Two Pr Fam CW-Elig Adm 663 CalWORKs Case 066 Two Pr Fam CW\/CM-NonAdm \uf071 CFAP Singles: In this column the CFAP shift for Singles, adults without children eligible for the CFAP program, takes place. The principle behind this shift is the same as for the CFAP Families shift described above. That ratio is calculated using the CFAP Singles case count listed on DFA 325.1. This ratio is applied to the following programs: 211 CalFresh Issuance 218 NACF IEVS 268 SAVE Program NACF 275 EFD\/P – NACF 310 NACF Fraud 312 Fraud PA CalFresh 341 EFD\/P NACF (WFI) Last Updated 7\/2011 101 DFA 327.3 343 NACF Eligibility 344 NACF Program Integrity 347 NACF Quality Control The sum of the amounts that are reduced from these program codes are transferred to CFAP PC 609 – CFAP Singles. \uf071 Total Program Cost: This column shows the total costs by program after all shifts listed on this page have been applied. The totals are displayed on the DFA 327.5’s where funding ratios for each program are applied. Last Updated 7\/2011 102 DFA 327.3 Last Updated 12\/2008 103 DFA 327.4 DFA 327.4A-E CEC Staff Development Cost Summary and Funding The DFA 327.4 A-E reports and distributes Staff Development costs to the programs. The program funding sources are also identified. Staff Development costs are kept separate from the welfare costs on the CEC due to the enhanced funding available with some programs for staff development activities. The costs reported on the DFA 327.3 (Program Cost Summary) and the DFA 327.5’s (Welfare Program Funding) do not include staff development expenditures. The information on the DFA 327.4A-E is similar to the information reported on both the DFA 327.3 and DFA 327.5’s for all other (non-staff development) program costs. \uf071 Allocable General Staff Development: The function costs reported on the Total Staff Development column of the 325.1C (Staff Development Detail Schedule) are allocated to program based on casework time study ratios, as reported on the DFA 55 and the DFA 327.1. \uf071 Direct to Program Staff Development: The direct-to-program costs reported on the Total Staff Development column of the 325.1C (Staff Development Detail Schedule) are allocated directly to the program. \uf071 Non Federal\/Other Adjustments: Cost shifts occur here to accommodate proper claiming of State General Funds (SGF) for services provided to non- federal persons. For example, the non-federal portion of the costs for CWS PC’s 145, 147, 148, and 170 are shifted to SUO code 164 based on the non- federal AFDC FC ratio found on the DFA 325.1. \uf071 Total Staff Development: This column sums the costs reported on the Allocable General Staff Development column, the Direct to Program Staff Development column, and the Non-Federal\/Other Adjustments column by program. \uf071 Federal Welfare Funds, State Welfare Funds, Health Funds and County Funds, Staff Development Funding Ratios: Total staff development costs are distributed to the funding sources in accordance with established sharing ratios. Last Updated 12\/2008 104 DFA 327.4 Last Updated 12\/2008 105 DFA 327.5 P1 DFA 327.5’s P1 Welfare Program Adjustments and Fiscal Incentives The Total Program Costs from the DFA 327.3’s are displayed on the DFA 327.5’s P1 by function. The DFA 327.5’s P1’s have Misc Adj +\/- adjustments. Examples: The costs from PC 146 CWS Services\/Non-federal on the DFA 327.3’s are shifted to PC 164 SUO CWS IV.B-146-75\/17.5\/7.5 on the DFA 327.5’s P1. The costs from PC 615 – Initial Elig Det CalWORKs\/CF\/MediCal are shifted equally to PC 215 – MediCal, PC 343 – NACF Eligibility, and PC 615 – Initial Elig Det CalWORKs\/CF\/MediCal. All expenditures of Performance Incentive Funds are abated in one of the three columns on DFA 327.5’s P1. The State General Fund Incentive column is not used at this time. The Total Program Cost column will reflect the final amount after the Incentive Funds are deducted. The totals are displayed on the DFA 327.5’s – Welfare Program Funding pages. Last Updated 12\/2008 106 DFA 327.5 P1 Last Updated 12\/2008 107 DFA 327.5 DFA 327.5’s Welfare Program Funding \uf071 Total Program Cost to Fund: The Total Program Cost from the DFA 327.5’s P1 are displayed on the DFA 327.5’s – Welfare Program Funding pages by all functions and programs. \uf071 Federal Share\/Ratio: Displays the federal reimbursement amount and ratio of the reimbursement for each program. \uf071 Share\/Ratio: Displays the state reimbursement amount and ratio of the reimbursement for each program. \uf071 Reimbursement\/Health Share\/Ratio: Displays the Health reimbursement amount and ratio of the reimbursement for each program. \uf071 County Share\/Ratio: Displays the county share and ratio for each program. Last Updated 12\/2008 108 DFA 327.5 Last Updated 12\/2008 109 DFA 327.6 DFA 327.6’s CEC Staff Development Cost Summary and Funding Scheduled Differences The DFA 327.6’s are created during the adjustment claim process and work in the same manner as the DFA 327.4s on the Original Quarter Claim. The purpose of this report is to displays the differences between the audited original claim and what was claimed on the adjustment claim. Therefore, the report is comparing the DFA 327.4’s on the audited original claim with the DFA 327.4’s on the adjustment claim and reporting the differences on the DFA 327.6’s. \uf071 Total Staff Development: Displays the program total difference between the audited original and the adjustment DFA 327.4’s for staff development. \uf071 Federal Welfare Funds: Displays the federal reimbursement ratio and amount for each program. \uf071 State Welfare Funds: Displays the state reimbursement ratio and amount for each program. \uf071 Health Funds: Displays the health reimbursement ratio and amount for each program. \uf071 County Funds: Displays the county share ratio and amount for each program. Last Updated 12\/2008 110 DFA 327.7 DFA 327.7’s Welfare Program Funding Scheduled Differences The DFA 327.7’s are created during the adjustment claim process and work in the same manner as the DFA 327.5’s on the Original Quarter Claim. The purpose of this report is to display the differences between the audited original claim and what was claimed on the adjustment claim. Therefore, the report is comparing the DFA 327.5’s on the audited original claim with the DFA 327.5’s on the adjustment claim and reporting the differences on the DFA 327.7’s. \uf071 Total Program Cost: Displays the program total difference between the audited original and the adjustment DFA 327.5’s. \uf071 Federal Welfare Funds: Displays the federal reimbursement ratio and amount for each program. \uf071 State Welfare Funds: Displays the state reimbursement ratio and amount for each program. \uf071 Health Funds: Displays the health reimbursement ratio and amount for each program. \uf071 County Funds: Displays the county share ratio and amount for each program. Last Updated 12\/2008 111 DFA 327.7 Last Updated 12\/2008 112 DFA 327.8 DFA 327.8 Close Out Payment Report Close Out represents the redistribution and final funding of federal and state dollars allocated to the counties for each federal and\/or state fiscal year. This report is created by CDSS during the close out process. The counties receive this report from CDSS when the close out process is complete. The upper left-hand corner will display the time period and the Round completed. There may be multiple close outs for any federal and\/or state fiscal year. Each version is identified by a Round. As with any other funding page, only those programs affected will be displayed. \uf071 Program Code\/Title: Displays the program title. \uf071 Total Prg. Cost to Fund: Displays the total program cost to be funded. \uf071 Federal Share\/Ratio: Displays the federal reimbursement amount and ratio for each program. \uf071 State Share\/Ratio: Displays the state reimbursement amount and ratio for each program. \uf071 Health Share\/Ratio: Displays the health reimbursement amount and ratio for each program. \uf071 County Share\/Ratio: Displays the county share amount and ratio for each program. Note: This is a CDSS generated report and can not be printed from the CEC Template. Once available, this report will be sent to each County through U.S. Mail. Last Updated 12\/2008 113 REC County Expense Claim Reconciliation Export \/ Copy Menu Screen *Hint: Do this process twice. Last Updated 12\/2008 114 REC Original CEC Reports Menu *Hint: If screen flashes, no data is available and, therefore, no report will print. Last Updated 12\/2008 115 REC Adjusted CEC Reports Menu *Hint: On adjusted claims, Claim Cert Sched Differences should be run first prior to reconciliation. DFA 327.6 and 327.7 available on Adjusted Claim only Scheduled Difference page on Adjusted Claim only Last Updated 12\/2008 116 REC County Expense Claim Reconciliation The CEC Reconciliation report determines if the input and the output pages of the CEC balance. After all data has been input into the CEC, go to the Export\/View\/Print (EX) to have the claim calculate the data. The reconciliation page is found on the Reports menu. Click on the CEC Reconciliation button and view the totals. If the variance is more than $35.00 on the first line, the claim is out of balance. If the other variances are more than $10.00, the claim is out of balance. Check the Reconciliation totals against the source documents to ensure that the claim balances to the source document totals. The first section is Total Allowable Welfare Cost from DFA 325.1 : If the claim is off in this section, look at the input pages on the expenditure schedule main menu (Support Operating Costs\/POS, Direct Cost Input, and Itemized Extraneous Costs). The second section is Staff Development from DFA 325.1c : If the claim is off in this section, look at the input pages on the staff development main menu (Staff Development Costs to Function, Staff Development Direct-to-Program, and Staff Development Personal Services). The third section is Support Staff from the DFA 7A and 7B : Check the input to the Support Staff Time Studies and Salaries. The last section is EDP EDP reports : If the claim is off in this section, look at the input pages on the Electronic Data Processing Main Menu (M&O by Functions, M&O Functions Allocation, M&O Direct to Program, Single & Multi-Function Development, Multiple Dev. Projects Charged to a Single Program Code, Development Direct to Program, and Personal Services\/Direct Billed\/Allocated). Last Updated 7\/2013 117 SUB. CEC Submitting the CEC Below are instructions for uploading completed CEC Claim files to the CDSS Extranet. This procedure requires Microsoft’s WinZip software. 1. Using Windows Explore, create a new folder and name it St_Files_Mo_YY (for example St_Files_Mar_07). 2. Using the CEC Claiming System Template, click on the \”EX\” button from the main menu and go through the system update process. Do not use Explore to determine which files to copy to the St_Files_Mo_YY folder. 3. Updating the CEC System Ledgers is optional. 4. Click the \”Select Directory\” button and the system will then allow you to select a folder to copy the required CEC files to. 5. Using the \”Select Directory\” dialogue box, locate and select the St_Files_Mo_YY folder. The system will now copy the files to the selected folder. 6. Close the CEC Claiming System Template 7. Using Windows Explore, locate and open the St_Files_Mo_YY folder. 8. Highlight any one of the files within the folder, and then hold down the control key (Ctrl) and press the letter \”A\” key. This will highlight all of the files within the folder. 9. Right click on any one of the highlighted files. A dialogue menu box will appear. Select \”Add to Zip\” option from the menu. 10. A new dialogue box will appear prompting a name for the zip file to be entered. Name the file cec.YY-YY.Mo.xx.zip; with the xx representing your County Number (for example cec.06-07.Mar.33.zip). * NOTE: Do not type the zip filename over the path displayed in the dialogue box. If the path is overwritten, the zip file will be stored in a location on the hard drive other than the folder where the highlighted files reside. 11. While still in the WinZip dialogue box, create a self-extracting executable file by selecting \”Actions\” from the options at the top of the WinZip dialog box. 12. From the \”Actions\” submenu, select the \”Make Exe File\” option. Last Updated 7\/2013 118 SUB. CEC 13. Once the process is complete, WinZip will provide a prompt asking the following question: \”Do you want to test it now?\”. Select \”No\”. 14. Close all of the WinZip dialogue boxes. 15. In your internet browser type in the following link and press enter: https:\/\/secure.dss.cahwnet.gov\/admin\/finance\/cec\/ 16. In the drop-down menu that is displays \”ALAMEDA\”, find your county’s name and click on it so that the name stays visible. 17. In the input field directly above the drop-down field, type your county’s name (this field is case sensitive and must be typed exactly as displayed in the field below). 18. Click the \”Submit Query\” button. 19. Click the \”Upload\” button on the right-hand side of the screen. 20. A County Uploads screen should appear. Working your way from the first input field to the last; input the following: \uf071 Where it says \”Please enter your full name\”, enter your name. \uf071 Where it says \”Please enter your Phone\”, enter 9166541084 (no parenthesis, period, or spaces) \uf071 Where it says \”Enter password\”, enter eric (lower case) * NOTE: The questions provided in step 20 are not examples. The entries for phone number and password must be performed exactly as stated. 21. Click the button named \”Browse . Use the Choose File window that appears to locate the file named cec.YY-YY.Mo.xx.exe from the folder named St_Files_Mo_YY. 22. Click on the file to highlight it, click \”Open\”, and then click \”submit file\”. If the system then indicates that the process is complete, you have successfully uploaded your claim and can now exit from the Extranet. 23. Send an e-mail message to the [email protected] address advising the County Support Section staff that you have uploaded your claim to the CDSS Extranet. Include in this e-mail a scanned copy of your CEC Certification page and the completed AFDC Foster Care Federal and Non-Federal Persons Count Form. https:\/\/secure.dss.cahwnet.gov\/admin\/finance\/cec\/ mailto:[email protected] Last Updated 7\/2013 LED 119 Ledgers Tracking System Menu Screen Ledger System should be run twice to guarantee complete information. Last Updated 7\/2013 LED 120 Ledger Reports #001 – 087 Menu *Hint: If screen flashes, no data is available and, therefore, no report will print. Last Updated 7\/2013 LED 121 Ledger Reports Greater than #087 Menu *Hint: If screen flashes, no data is available and, therefore, no report will print. Last Updated 7\/2013 LED 122 Ledger Reports Greater than #157 Menu *Hint: If screen flashes, no data is available and, therefore, no report will print. Last Updated 7\/2013 LED 123 CEC Ledgers The ledger pages within the CEC are used to track allocations that the County Agency receives to operate the welfare programs. Allocation amounts are transmitted to County Agency via CFL’s from the County Financial Analysis Bureau (CFAB) and entered into the ledgers by CDSS County Systems Unit. Total expenditures flow through the CEC from program codes utilized by the County Agency for a particular program. Purpose of the Ledgers The purpose of the ledgers is to track expenditures against allocations. It is important to remember the following about the CEC ledgers: \uf071 Not all expenditures are tracked on the ledger system (for example Medi-Cal). \uf071 The ledger system is set up to address CDSS needs. \uf071 The ledger system can assist the counties in tracking allocations. \uf071 Counties are cautioned not to entirely depend on the ledger system to track their allocations. \uf071 Counties should maintain their own ledger tracking systems to capture their federal\/state\/county expenditures. \uf071 Federal programs can have a state fiscal year. \uf071 Please note that allocation letters are updated each fiscal year and through out the year. You should always refer to the most recent CFL. \uf071 SUO codes are used when programs exceed their allocations to shift over runs to the appropriate funding source. \uf071 CDSS, if necessary, will transfer funds at close out. Description of Ledger by Column \uf071 Program Name: Displays the program name of the allocation. \uf071 Allocation: Displays the County Agency allocation for the program. \uf071 Total Exp: Displays the total federal or state expenditures for the program based on the ledger type. \uf071 Bal\/OM: Displays the remaining balance of the allocation. If the allocation has been exceeded the program is in overmatch status. \uf071 Ledger Number: Displays the number associated with the program and is assigned by the County Systems Unit. \uf071 Ledger Type: Displays whether the allocation is a federal or a state allocation. Last Updated 7\/2013 LED 124 \uf071 Reporting Period: Displays the reporting period of the allocation. The reporting period may be a federal fiscal year (FFY) which runs from October 1 through September 30, or a state fiscal year (SFY) which runs from July 1 through June 30. \uf071 Proc Dte: Displays the date the Quarterly Claim is processed. \uf071 Quarter: Displays the Quarter when the transaction is processed. \uf071 Tran Type: Displays the type of transaction. Transaction types include the following: OC Original Claim A1 Adjustment Claim (1 represents a first Adjustment Claim, 2 the second, etc.) C1 Closeout Claim (Round 1, etc.) SF Shift JE Journal Entry MO Maintenance of Effort OS Other shift \uf071 Prgcode: Displays the three digit program number. \uf071 Fed: Displays the federal reimbursement amount of the expenditures. \uf071 State: Displays the state reimbursement amount of the expenditures. \uf071 County: Displays the county share of the expenditures. Limitations of the Ledgers Some of the CWS related costs are not displayed in the CWS Basic Ledger (#008). The only codes whose costs will be displayed in this ledger are those for which there is a state share of costs, since this ledger is only concerned with controlling the state share of costs such as SUO codes. This is true for all ledgers that have a share of costs to be controlled to a specific capped allocation. Allocations not Tracked by a Ledger All ledgers capture expenditures from the Funding Pages (DFA 327.4’s and DFA 327.5’s for Original Claims and DFA 327.6’s and DFA 327.7’s for Adjustment Claims) after the Sharing Ratios have been applied. Since Performance Incentives are backed out prior to the application of Sharing Ratios, the performance incentives will not appear on the CEC Ledger System. Last Updated 7\/2013 LED 125 Medi-Cal has an allocation that is developed and controlled by the California Department of Health Services; and while these costs are reported on the CEC, there is no ledger to track Medi-Cal. Last Updated 12\/2008 126 SHIFT CEC Ledger Tracking System Shift Report The Shift Report is part of the Ledger Tracking System of the County Expense Claim. This report displays the shifts that have occurred for a particular quarter. \uf071 Allocation #\/Program #\/Title: Displays the allocation\/ledger number where the shift occurs, the type of shift that occurred (see CEC-Ledger page for reference), the program code, and the program title that the shift was applied to. \uf071 Note: Explains the various types of shifts (i.e., SF, OS, etc.). \uf071 Federal: Displays the amount of expenditures shifted to or from federal funds. \uf071 State: Displays the amount of expenditures shifted to or from state funds. \uf071 Health: Displays the amount of expenditures shifted to or from health funds. \uf071 County: Displays the amount of expenditures shifted to or from county funds. Last Updated 12\/2008 127 STATUS CEC Ledger Tracking System Status Report The Status Report displays each County Agency’s allocations and the expenditures to date against these allocations. The report also displays the expended percentage of the allocations. This report contains year-to-date information. \uf071 Allocation #\/Title: Displays the allocation\/ledger number where the expenditures are charged, the claim type, and the program title. \uf071 Note: Explain the various claim types (i.e. A1=adjustment claim). \uf071 Allocation: Displays the allocation amount by ledger. \uf071 Federal: Displays the amount of federal dollars expended for the allocation\/ledger. \uf071 State: Displays the amount of state dollars expended for the allocation\/ledger. \uf071 Health: Displays the amount of health reimbursement dollars expended for the allocation\/ledger. \uf071 Balance: Displays the balance remaining for the allocation. \uf071 Expend %: Displays the percentage of the allocation expended. Last Updated 7\/2013 128 SINGLE LED Single Shift Ledgers The County Expense Claim Ledger System for the single shift ledgers are as follows: Ledger # Program 004 Adoptions * 040 State Family Preservation Program (FPP) * 052 AB 2129-Foster Parent Training & Recruitment * 055 Promoting Safe & Stable Families (PSSF) 078 Foster Care * 085 Substance Abuse \/ HIV Infant Program * 100 Kinship Support Services * 105 Group Home Monthly Visits Probation * 115 Supportive & Therapeutic Options Program (STOP) * 121 Specialized Training for Adoptive Parents Program (STAP) * 133 Kin-GAP 134 Emancipated Youth Stipends (EYS) * 135 Foster Care Emergency Assistance (EA) TANF * 137 Non-Fed Kin-GAP 139 Kinship & Foster Care Emergency Funds * 141 Child Abuse Prevention, Intervention, and Treatment (CAPIT) * 142 Chafee Post Secondary Education and Training Vouchers (ETV) 150 CWSOIP\/Probation * 151 SB 1569 Non-Citizen 152 CFET 3rd Party Reimbursement 153 Technical Assistance Pilot 154 IHSS Fraud & Integrity Program 155 Fed-GAP Administration * 156 Non-Medical Out of Home Care (NMOHC) 157 CWD\/LHD Expansion for Community Nutrition 158 IHSS Adult Day Health Care (ADHC) 159 CalFresh Innovative Projects Please refer to your most recent Allocation CFL for specific information pertaining to the allocation of each program. For all programs that are classified as a single shift ledger, SUO codes are only used when a county exceeds their allocation. If or when a county exceeds their allocation, over-expenditures will be shifted to county share using a single SUO code specific to each program. * Effective July 1, 2011, AB 118 realigns the funding for these single shift ledgers from the State to local governments and redirects specified tax revenues to fund this effort. Please note that the ledgers for these programs will no longer work as originally intended since the allocation for these programs have been set to zero. Last Updated 7\/2013 129 SINGLE LED Effective with the September 2011 quarter claim, all costs to be covered by the county using the realignment funding will identified in the CEC using the SUO overmatch codes. External tracking of these costs will be required by the counties to ensure the appropriate level of realignment funds is being utilized. Programs Tracked on each Ledger: #004 Adoptions 117 Adoptions Case Management 118 Adoptions Independent 123 Adoptions Federal Direct Costs 191 SUO Adoptions #040 State Family Preservation Program (FPP) 159 FPP – SPMP 168 FPP – HR 174 FPP – Training 175 FPP Services\/Non-federal 177 FPP CM: Preventive Services (PS) 179 FPP CM: Foster Care 501 SUO FPP 0\/70\/0\/30 #052 AB 2129-Foster Parent Training & Recruitment 504 AB 2129 Foster Parent Training 505 AB 2129 Foster Parent Training\/Non-federal 506 AB 2129 Foster Parent Recruitment 507 AB 2129 Foster Parent Recruit\/Non-federal 508 SUO Foster Parent 504-507 #055 Promoting Safe & Stable Families (PSSF) 515 PSSF Family Preservation Service 516 PSSF Family Support Services 521 SUO PSSF 675 PSSF Adoption Promotion & Support 676 PSSF Time Limited Family Reunification #078 Foster Care 029 Rosales v. Thompson 230 Adoption Assistance Program 300 STEP Eligibility 345 AFDC Foster Care Eligibility 612 SUO Foster Care Overmatch (including AAP) 613 AFDC Foster Care Eligibility Voluntary #085 Substance Abuse \/ HIV Infant Program 137 Options for Recovery\/Foster Parent Training Last Updated 7\/2013 130 SINGLE LED 172 Options for Recovery 195 SUO Options for Recovery\/FPT Nonfed 523 Options for Recovery Recruitment 561 SUO Options for Recovery\/Rec Nonfed #100 Kinship Support Services 328 SUO Kinship Support Services 582 Kinship Support Services #105 Group Home Monthly Visits Probation 042 SUO Group Home Visits (Probation) 329 SUO Group Home Visits (Probation) 579 Monthly Visits for Group Home (Prob) 581 Nfed Monthly Visits\/Grp Homes\/Prob. #115 Supportive & Therapeutic Options Program (STOP) 549 SUO STOP 588 Supportive and Therapeutic Options (STOP) #121 Specialized Training for Adoptive Parents Program (STAP) 005 STAP Case Management 006 STAP Respite Care 050 SUO STAP #133 Kin-GAP 030 Federal Kin-GAP Program Eligibility 667 SUO Kin-GAP #134 Emancipated Youth Stipends 111 Emancipated Youth Stipends 112 SUO Emancipated Youth ILP #135 Foster Care Emergency Assistance (EA) TANF 199 SUO EA (FC) 223 EA Foster Care Eligibility #137 Non-Fed Kin-GAP 031 Non-Federal Kin-GAP Program Eligibility 044 SUO Non-Fed Kin-GAP #139 Kinship & Foster Care Emergency Funds 493 SUO Kinship\/FC Emergency Funds (Non-Fed Discount Code) 562 Kinship & Foster Care Emergency 563 SUO Kinship\/Foster Care Emergency Last Updated 7\/2013 131 SINGLE LED #141 Child Abuse Prevention, Intervention, and Treatment (CAPIT) 167 CAPIT 696 SUO CAPIT #142 Chafee Post Secondary Education and Training Vouchers (ETV) 067 Education and Training Voucher 068 SUO Education and Training Voucher #150 CWSOIP\/Probation 703 CWSOIP\/Probation (A 12\/07) 704 CWSOIP\/Probation Nonfed (A 12\/07) 705 SUO CWSOIP\/Probation (C 12\/07) #151 SB 1569 Non-Citizen 713 SB 1569 Noncitizen – Admin 714 SB 1569 Noncitizen Services 715 SUO SB 1569 Noncitizen ADM\/SVCS #152 CFET 3rd Party Reimbursement 339 SUO CFET 3rd Party Reimb. O\/M #153 Technical Assistance Pilot 668 Technical Assistance Pilot (A 6\/09) 669 SUO Technical Assistance Pilot #154 IHSS Fraud & Integrity Program 740 IHSS N-PCSP\/Plus Anti-Fraud Plan A 1209 741 IHSS PCSP\/Plus Anti-Fraud Plan (A 1209) 742 SUO IHSS Fraud & Program Integrity #155 Fed-GAP Administration 747 KinGAP Title IV-E Eligible (A 03\/11) 815 SUO KinGAP Title IV-E Elig (A 03\/11) #156 Non Medical Out of Home Care (NMOHC) 135 SSI-SSP \/ OHC 833 SUO SSI-SSP \/ OHC (A 09\/11) #157 CWD\/LHD Expansion for Community Nutrition 834 CWD\/LHD Exp for Comm Nutrition 835 SUO CWD\/LHD Exp for Comm Nutrition #158 IHSS Adult Day Health Care (ADHC) 783 IHSS-ADHC Transition (A 09\/11) 861 IHSS-ADHC Overmatch (A 03\/12) Last Updated 7\/2013 132 SINGLE LED #159 CalFresh Innovative Projects 856 CF Nutr Ed Innov Ideas Admin (A 03\/12) 883 CF Nutr Ed Innov Ideas Svcs (A 03\/12) 857 SUO-CF Nutr Ed Innov Ideas (A 03\/12) Example: #142 Chafee Post Secondary Education and Training Vouchers (ETV) For Ledger 142, if a county exceeds their allocation, over-expenditures will be transferred to county share using SUO code 068 (SUO ETV). For example, if a county’s allocation for the fiscal year is $100,000 and their total expenditures are $150,000; $50,000 will be shifted to the county using SUO code 068. Ledger: 142 Total Federal State County SUO 067 $150,000 $150,000 $0 $0 SUO 068 $0 ($50,000) $0 $50,000 Last Updated 7\/2013 133 IHSS LED In Home Supportive Services Ledger The County Expense Claim Ledger System for In Home Supportive Services (IHSS) is ledger number 001. Effective FY 12\/13, counties have an IHSS MOE requirement in lieu of paying a fixed share of the nonfederal IHSS costs. SUO Code 793 has been established to shift the county share of the IHSS administrative expenditures to the State General Fund. CDSS will be billing the counties for the MOE requirement outside of the CEC. Prior to FY 12\/13, IHSS was considered a single shift ledger, meaning an SUO code was only used when a county exceeded their allocation. If or when a county exceeds their IHSS allocation, over-expenditures were shifted to county share using a SUO 193. Currently, the IHSS ledger on the Original Submitted Claim is still tracking county expenditures as if there was no MOE in place. However, all county expenditures appearing on the IHSS Ledger is being shifted to State on the DFA 327.5’s pages of the CEC. Programs Tracked on IHSS Ledger: 003 IHSS Quality Assurance 023 IHSS Advisory Committee 102 IHSS Skilled Professional Medical Personnel 103 IHSS PCSP\/Waiver 104 IHSS IHSS-Non HR\/Non Waiver 330 IHSS Fraud 739 IHSS Anti-Fraud Background Checks 792 SUO IHSS MOE County Share Adjustment Example The county share calculated within the CEC for all expenditures claimed to the IHSS programs is shifted to SUO 792 on the DFA 327.5’s. DFA 327.5 (Funding Pages) Total Federal State County PC 003 $5,000 $2,500 $1,750 $750 PC 103 $10,000 $5,000 $3,500 $1,500 PC 104 $3,000 $0 $2,100 $900 PC 739 $5,000 $2,500 $2,500 $0 SUO 792 $0 $3,150 ($3,150) Last Updated 7\/2013 134 CWS LED Child Welfare Services Ledgers The County Expense Claim Ledger System for Child Welfare Services (CWS) is ledger numbers 008, 010, 116, 146 and 148. The CWS allocation consists of Federal Title IV-B, Title IV-E, Title XIX, Title XX, Temporary Assistance for Needy Families (TANF) funds, and SGF. All of these funding streams have different constraints as to their utilization and because of the complexities of the program; they are not tracked in a consistent manner. The shifts that occur between these ledgers are further explained in the FAQ section. The allocation has the following components. \uf071 CWS Basic Allocation \uf071 EA-TANF \uf071 EA Title IV-E \uf071 Special Care Incen & Asst Program (SCIAP) \uf071 CWS\/CMS System Support Staff \uf071 CWS\/CMS Staff Development \uf071 Kin-Gap Savings \uf071 Minor Parent Investigations \uf071 Minor Parent Services (MPS) \uf071 Livescan \/ Background Checks \uf071 Relative Home Approvals \uf071 Multiple Relative Home Approvals \uf071 Grievance Review for Relative Home Approvals \uf071 County Self Assessment & SIP \uf071 Data Requirements for New Activities \uf071 Peer Quality Case Review \uf071 AB-408 Child Relationships Effective July 1, 2011, AB 118 realigns the funding for CWS from the State to local governments and redirects specified tax revenues to fund this effort. Please note that the ledgers for the CWS programs will no longer work as originally intended since the allocations for CWS have been set to zero. Effective with the September 2011 quarter claim, all costs to be covered by the county using the realignment funding will identified in the CEC using the SUO overmatch codes. External tracking of these costs will be required by the counties to ensure the appropriate level of realignment funds is being utilized. Children Welfare Services (#008) Only state funds for all of the above components are tracked in this ledger. In effect, all of the components of the state funds are rolled together. Last Updated 7\/2013 135 CWS LED CWS IV-B (#010) Only Federal Title IV-B funds are tracked here. This is a small allocation and these funds are generally expended in the first quarter. Costs are claimed to PC 146. Through the use of SUO codes, funding will be shifted from SGF to Federal IV-B. This requires no input by the County. SUO code 164 funds those claimed costs at 75\/17.5\/7.5 (federal\/state\/county) to utilize the IV-B Funds. Expenditures exceeding the IV-B allocation are then moved to SUO code 596 and funds the overmatch at 70\/30 (state\/county). SUO code 596 is tracked in both the IV-B Ledger (010) and the CWS Basic Ledger (008). The federal costs of SUO code 596 is tracked to Ledger 010, and the SGF costs are tracked to Ledger 008. CWS Augmentation (#116) State funds, which are a portion of the CWS Augmentation, are tracked here. This allocation also includes federal funds, which are not tracked in a ledger. These funds are available after the state CWS funds are expended and require no county match. The system also includes SUO code 808 (the overmatch code for the CWS Basic allocation) and SUO code 122 (which funds the CWS Augment). Group Home Monthly Visits (#118) Group home monthly visits are conducted by social workers. Fifty percent of the allocation was distributed based on each county’s percent to the statewide total of actual Group Home Monthly Visits Welfare expenditures as claimed on the CEC for the four most recent quarters. The remaining fifty percent of funds were distributed based on each county’s percent to the statewide total welfare supervised group home placements extracted from the CWS\/CMS for calendar year. The out-of-state portion of the allocation was distributed based on each county’s percent to the statewide total of welfare supervised children in out-of- state group home placements extracted from the CWS\/CMS for the calendar year. Funds were adjusted to ensure counties a minimum floor of $1,000. The non-federal discount ratio is automatically applied to PC 577 and the non- federal portion is shifted via PC 586 which is funded at 100 percent of the SGF. Expenditures exceeding the Group Home Monthly Visits allocation, overmatch costs are shifted out of ledger 118 using SUO 045 and into the CWS Basic allocation using SUO 051. EA-TANF (#146) Only Federal EA-TANF funds are tracked here. CWS Augment Title XX (#148) CWS Augment Title XX funds are tracked here. SUO code 809 funds the Title XX Augment expenditures. SUO code 120 is used for the overmatch code. A shift will occur to Ledger 116 when the allocation is exceeded by the use of SUO code 122. Last Updated 7\/2013 136 CWS LED Federal Title XX These are alternative federal funds, which are available to the state. A SUO shift utilizes these funds using SUO codes 171 and 173. Federal Title IV-E These are the main federal funds available for CWS. These funds are not capped but have the restriction that they cannot be used for services. Program Tracked on the CWS Ledgers: #008 Child Welfare Services 004 Probation Peer Quality Case Review (PQCR) 007 Relative\/Non-Relative Home Approvals 008 SUO Relative\/Non-Relative Home 009 Extended Voluntary Court-Related 024 Shasta’s Children’s Prog. Consortia NF 051 SUO Group Home Monthly Visits 057 SUO Emergency Hotline IV-E to TANF 058 SUO Emergency Hotline TANF 088 Peer Quality Case Review 089 SUO Peer Quality Case Review 100 Special Care Incen. & Assist Program 106 EA-CO OP-ESC (1-30 Days) 107 EA-CO OP-ESC (Over 30 Days) 126 Shasta’s Children’s Program Consortia 134 EA-Contracted ESC (1-30 Days) 136 EA-Contracted ESC (Over 30 Days) 138 CWS-SPMP 143 CWS-Eligibility Determination 144 CWS-Health Related 145 CWS-Training 147 CWS-Court Related Activities 148 CWS-Case Management 164 SUO CWS IV-B 146 171 SUO CWS Title XX to Ledgers 176 Title IV-E CAP Develop 196 SUO EA\/IV-E Cost Shift (Pull Costs) 197 SUO EA\/IV-E Cost Shift (Funding) 198 SUO EA CWS Non-Fed Basic 358 SUO CWS\/Background Check 359 CWS Livescan\/CLETS Background Checks 513 EA Emergency Response (ER) 520 EA Crisis Resolution (CR) 531 SUO EA-Case Management TANF 536 SACWIS M & O 544 CWS Minor Parent Investigations (AB 908) Last Updated 7\/2013 137 CWS LED 556 CWS MPS (AB 908) 557 CWS\/CMS Staff Development 558 CWS\/CMS Staff Development NF 575 CWS Training Admin 596 SUO CWS IV-B Non-Fed 707 Gomez Grievance Hearings 709 State Mandated Activities 732 Family Case Planning for Better Outcomes 734 SUO CWS Case Management (A 9\/09) 841 EFC Court Related 842 EFC Case Management 808 SUO CWS Emergency Relief 70-30 #010 CWS IV-B 164 SUO CWS IV-B 146 596 SUO CWS IV-B Non-Fed #116 CWS Augmentation 122 SUO CWS Augment SGF 166 SUO CWS 146 #118 Group Home Monthly Visits 577 Monthly Visits for Group Home Placements\/CWD 586 Non-Federal Monthly Visits for Group Home Placements #146 EA-TANF 106 EA-CO OP-ESC (1-30 Days) 107 EA-CO OP-ESC (Over 30 Days) 134 EA-Contracted ESC (1-30 Days) 136 EA-Contracted ESC (Over 30 Days) 513 EA Emergency Response (ER) 520 EA Crisis Resolution (CR) #148 CWS Augment Title XX 120 SUO CWS AUG Title XX O\/M 809 SUO CWS AUG Title XX Fund Federal Title XX 171 SUO CWS Title XX to Ledgers 173 SUO CWS Title XX Funding The following examples demonstrate how the ledgers worked prior to the implementation of Realignment 2011. Example #1: Ledger 010 Last Updated 7\/2013 138 CWS LED Example of Ledger 010: All expenditures are claimed to PC 146 CWS Services\/Non-federal on the DFA 327.3’s and then carried forward to the DFA 327.5s P1 page to SUO code 164. Once the federal allocation has been exceeded, the overmatch expenditures are shifted to ledger 008 using SUO code 596 on the DFA 327.5s P1 page. IV-B Allocation = $5,000 Ledger: 010 Total Federal State County SUO 164 $15,000 $11,250 $2,625 $1,125 SUO 596 $0 ($6,250) $4,375 $1,875 In this example, the federal allocation is exceeded by $6,250 and shifted from the federal code by using PC 596. This SUO code ensures that the State does not overcharge the IV-B allocation. SUO codes 164 and 596 are then shifted from Ledger 010 to Ledger 008 CWS Basic and the state portion is tracked against that allocation. Example #2: Ledger 008 CWS IV-B (Ledger 010) Allocation = $5,000 Group Home Monthly Visits (Ledger 018) Allocation = $2,000 CWS Basic (Ledger 008) Allocation = $700 Ledger: 010 Total Federal State County SUO 164 $15,000 $11,250 $2,625 $1,125 SUO 596 $0 ($6,250) $4,375 $1,875 Ledger: 118 Total Federal State County PC 577 $4,000 $2,000 $2,000 $0 PC 586 $1,000 $0 $1,000 $0 SUO 045 ($1,000) $0 ($1,000) $0 Ledger: 008 Total Federal State County SUO 164 $15,000 $11,250 $2,625 $1,125 SUO 596 $0 ($6,250) $4,375 $1,875 SUO 051 $1,000 $0 $700 $300 This example depicts the overmatch codes from ledgers 010 and 118 that are tracked against the State portion of the CWS Basic ledger (008). Overmatches to ledger 010 are shifted to ledger 008 using SUO code 596. In additional, Last Updated 7\/2013 139 CWS LED expenditures reported to SUO 164 are also carried over to ledger 008 for tracking purposes. Overmatches to ledger 118 are shifted out using SUO code 045 to ledger 008 using SUO code 051. Example #3: Ledger 116 CWS Augment Title XX Allocation = $1,000 CWS Augmentation Allocation = $5,000 Ledger: 148 Total Federal State County SUO 809 $11,000 $11,000 $0 $0 SUO 120 ($10,000) ($10,000) $0 $0 Ledger: 116 Total Federal State County SUO 122 $10,000 $0 $10,000 $0 SUO 166 $0 $0 ($5,000) $5,000 In this example, the allocation for ledger 148 has been exceeded by $10,000. The overmatch expenditures are shifted out of ledger 148 using SUO code 120 to ledger 116 using SUO code 122 to be funded by the state. The allocation for ledger 116 is $5,000 in this example. Therefore, the state portion of the allocation was exceeded by $5,000 and the overmatch was shifted to county share via SUO code 166 leaving the county to pay $5,000. Example #4: Ledger 118, Group Home Monthly Visits The Nonfed\/CFAP Families Ratio from the DFA 325.1 (line AH; column AFDC FC) is applied to the total of all Casework & Allocable Support Costs, Total EDP Costs, EA Eligible Costs, and Direct Costs reported on the DFA 327.3’s to PC 577. The resulting costs are shifted to PC 586 on DFA 327.3’s as Non Fed Costs. For the example given below a Nonfed\/CFAP Families Ratio of 0.250000 was applied to the total costs for PC 577 of $4,000. DFA 327.3 Program Code Casework & Allocable Support EDP EA Eligible Direct Total Non Fed Costs PC 577 $3,000 $1,000 $4,000 $8,000 ($2,000) PC 586 $2,000 Last Updated 7\/2013 140 CWS LED DFA 327.5 (Funding Pages) Total Federal State County PC 577 $6,000 $3,000 $3,000 $0 PC 586 $2,000 $0 $2,000 $0 Example of Ledger 118: Group Home Monthly Visits allocation = $4,000 (Allocation is exceeded by $1,000) Ledger: 118 Total Federal State County SUO 045 ($1,000) $0 ($1,000) $0 Ledger: 008 Total Federal State County SUO 051 $1,000 $0 $700 $300 (Overmatch costs on ledger 118 are reported to SUO 045 and shift out to ledger 008 using SUO 051.) In this example, the state allocation is exceeded by $1,000 and shifted from the state and federal codes by the same amount (since they were funded 50\/50\/0 with PC 577). SUO code 051 then funds the exceeded amount at 0\/70\/30 on ledger 008: CWS Basic and the federal share will continue to be funded. The state share of SUO code 051 is tracked against the CWS Basic allocation on ledger 008. Example #5: Ledger 148, CWS Augment Title XX CWS Basic SGF Allocation = $200 CWS Augment Title XX Fed Allocation = $100 CWS Augment SGF Allocation = $100 Expenditures SGF = $500 Ledger: 008 Total Federal State County Cumulative CWS Exp. $1,429 $714 $500 $215 SUO 808 ($428) $0 ($300) ($128) Ledger: 148 Total Federal State County SUO 809 $428 $428 $0 $0 SUO 120 ($328) ($328) $0 $0 Ledger: 116 Total Federal State County Last Updated 7\/2013 141 CWS LED SUO 122 $328 $0 $328 $0 SUO 166 $0 $0 ($228) $228 Note: A flowchart that depicts how these ledgers works in conjunction with Ledger 118 can be found under the section titled Ledger Flowcharts . Example #6: Ledger 008 (Title XX Shift) CWS Title XX Allocation = $2,000,000 DFA 327.5 (Funding Pages) (Audited Sept Qtr Claim) Total Federal State County PC 143 $500,000 $250,000 $175,000 $75,000 PC 147 $1,000,000 $500,000 $350,000 $150,000 PC 148 $1,500,000 $750,000 $525,000 $225,000 SUO 171 ($1,000,000) $0 ($1,000,000) $0 SUO 173 $1,000,000 $1,000,000 $0 $0 Ledger: 008 (Sept Qtr Claim) Total Federal State County SUO 171 ($1,000,000) $0 ($1,000,000) $0 SUO code 171 and SUO code 173 were established to ensure counties are funded within the CWS Title XX allocation in lieu of CWS State General Fund allocation. In this example SUO code 171 credits the state share of expenditures in CWS basic and SUO code 173 charges these expenditures against County’s Title XX allocation. 33% of each County’s Title XX allocation is used in the September and December quarter claims and the remaining 34% is used in the March quarter claim. Please note that the federal shift of expenditures to SUO code 173 can only be seen on the DFA 327.5 Funding Pages on Audited Claims. Last Updated 12\/2008 142 #011 LED Community Care Licensing Foster Family Homes Ledger The County Expense Claim Ledger System for Community Care Licensing Foster Family Homes (CCL FFH) is ledger number 011. Counties performing FFH Licensing activities have funds allocated using a formula for each county’s average monthly FFH caseload for a calendar year and divided by the workload standards of 133 facilities per month per full-time equivalent (FTE). The result was the number of justified staff required to license this category of facility. A worker to supervisor ratio of 6.35:1 was applied to the justified staffing level and the total staffing level was then multiplied by the individual county’s actual FFH unit cost. Additional monies from the SGF were allocated to those counties performing FFH licensing activities for the Gresher v. Anderson premise. This premise covers costs for additional time necessary for the issuance of exemption needed notices and exemption denied notices to individuals with criminal convictions requiring exemptions. For counties not participating in the licensing program, the FFH Recruitment allocation funds were distributed based on each county’s average monthly cases in Family Reunification and Permanent Placement and the number of children under 18 years of age using the most recent data from the U.S. Census Bureau. The FFH Licensing and Recruitment administrative costs, including staff development, are charged to PC 155, PC 156, and PC 158. Expenditures exceeding the SGF CCL\/FFH allocation will be transferred to county share using SUO code 192. Through the use of SUO codes, funding will be shifted from SGF CCL\/FFH to Federal Title XX. This requires no input by the County. Expenditures reported to PC 156 are shifted from state ledger 011 to federal ledger 147. For this shift to occur, expenditures are shifted out of ledger 011 using SUO code 336 and shifted to ledger 147 using SUO code 337. All remaining expenditures to SUO code 337 will then be funded with Federal Title XX monies and will be tracked against the Title XX Licensing Ledger. Expenditures exceeding the ledger 147 allocation will be transferred back to ledger 011 using SUO code 338. Programs Tracked on CCL FFH Ledger: 155 Licensing \/ Foster Family Home 156 Foster Family Licensing Non-Federal 158 Foster Family Licensing Training 192 SUO CCL\/FFH 155 336 SUO CCL\/FFH to Title XX 337 SUO CCL Title XX Last Updated 12\/2008 143 #011 LED 338 SUO CCL Title XX O\/M to CCL\/FFH Example All expenditures come in on PC 155,156, and 158. SUO code 192 will be used for expenditures exceeding the SGF CCL\/FFH allocation which will be transferred to county share. Ledger: 011 Total Federal State County PC 155 $25,000 $30,000 $0 $0 PC 155 ($5,000) ($5,000) $0 $0 SUO 192 $5,000 $0 $0 $5,000 Note: A flowchart that depicts how this ledger works in conjunction with Ledger 147 can be found under the section titled Ledger Flowcharts . Last Updated 12\/2008 144 #012 LED Community Care Licensing Family Child Care Home Ledger The County Expense Claim Ledger System for Community Care Licensing Family Child Care Home (CCL FCCH) is ledger number 012. The FCCH Licensing administrative costs, including staff development are charged to PC 157 Licensing Day Care, on the CEC. Expenditures reported to PC 157 on ledger 012 are shift to ledger 132 using SUO code 062 to ensure that 100 percent of the reimbursement funds are expended before counties can access their SGF allocation. Once the federal allocation for ledger 147 has been exceeded, the overmatch expenditures are shifted back to ledger 012 using SUO code 061. Expenditures exceeding the SGF allocation will be transferred to county share using SUO code 153. Programs Tracked on CCL FCCH Ledger: 061 SUO CCL\/FDC Overmatch To 062 062 SUO CCL\/FDC CDE Reimburse 153 SUO CCL\/FDC 157 157 Licensing Day Care Note: A flowchart that depicts how this ledger works in conjunction with Ledger 132 can be found under the section titled Ledger Flowcharts . Last Updated 12\/2008 145 #017 LED CalFresh Ledger The County Expense Claim Ledger System for CalFresh is ledger number 017. If a county exceeds their state share allocation, over-expenditures will be transferred to county share using SUO code 284. All CalFresh county expenditures, except the 284 overmatch, are transferred to the federal share using SUO code 321, which is then part of the CalWORKs Single Allocation. Thus, expenditures in the CalFresh program ultimately impact the CalWORKs Single Allocation. Programs Tracked on CalFresh Ledger: 211 CF Issuance (& EBT Project for San Diego and San Bernardino Only) 214 FSOLIS 218 NACF IEVS 234 Fraud NACF AFIRM (LA County) 262 U.S. Residency Project NACF 268 SAVE Program NACF 275 EFD\/P NACF 284 SUO NACF 310 NACF Fraud 312 Fraud PA CalFresh 334 Fraud NACF AFIRM (LA County) 341 EFD\/P NACF (WFI) 343 NACF Eligibility 344 NACF Program Integrity 347 NACF Quality Control 393 PACF AFIRM (LA County) 606 CFAP Families 609 CFAP Singles 611 NACF Jail Match (SB 1556) Example Shared CW & CalFresh Program Code Shifts These shifts occur before the costs go to the ledgers. Costs claimed to PC 315, PC 320, and PC 342 will not currently be displayed on any ledger. Costs claimed to these program codes are shared between CalWORKs and CalFresh as follows: \uf0d8 Costs to PC 315 gets shifted to PC 301 and 312 \uf0d8 Costs to PC 320 gets shifted to PC 310 and 305 \uf0d8 Costs to PC 342 gets shifted to PC 340 and 341 Last Updated 12\/2008 146 #017 LED As a result the shifted costs are controlled in either ledger #076 or #017, based on their respective program titles. Total costs from the DFA 327.3 Pages for Casework & Allocable Support, EDP, EA Eligible, and Direct Costs are added together and then split 50\/50 between the respective program codes identified above. CalWORKs Program Code Casework & Allocable Support EDP EA Eligible Direct Total AFDC \/ TANF Adj. PC 301 $150,000 PC 305 $7,500 PC 312 $150,000 PC 315 $100,000 $50,000 $150,000 $300,000 ($300,000) PC 320 $15,000 $15,000 ($15,000) PC 340 $10,000 PC 342 $5,000 $5.000 $10,000 $20,000 ($20,000) OPW Program Code Casework & Allocable Support EDP EA Eligible Direct Total AFDC \/ TANF Adj. PC 310 $7,500 PC 341 $10,000 Last Updated 1\/2010 147 CFET LED CalFresh Employment and Training (CFET) Ledger The County Expense Claim Ledger System for CalFresh Employment and Training (CFET) programs is ledger numbers 028, 030, and 033. CFET 100% FFY (#028) & CFET 50\/50 Fed\/County (#030) If a county exceeds its federal share allocation for ledger #028, over- expenditures will be shifted to county share using SUO code 475. The county half of the overmatched amount will then be applied to SUO code 303 on ledger #030, transferring money from the County share to the federal share. This federal share is then applied to Ledger 030, CFET 50\/50 federal\/county, and any remaining overmatch is applied to the County as code 304. CFET Participant Reimb. Fed (#033) If a county exceeds its federal share allocation, over-expenditures will be transferred to county share using SUO code 071. SUO code 070 (SUO – CalFresh Grant Reduction) was established to back fill the loss of Federal CalFresh funds with State General Fund. The loss of this Federal funding was the result of a Federal Public Law 105-185 (signed June 23, 1998O. This shift does not impact individual county allocations and the amount shifted from Federal to State for each county is determined by the State. It should also be noted that this shift occurs only on the DFA 327.5’s CEC Report. Program Tracked on the CFET Ledgers: CFET 100% FFY (#028) 306 CFET ABAWDS Workfare 307 CFET ABAWDS Education\/Training 311 SUO CFET MOE County 464 Other CFET Activities 475 SUO CFET 100% O\/M CFET 50\/50 Fed\/County (#030) 303 SUO CFET 50\/50 304 SUO CFET 50\/50 O\/M CFET Participant Reimb. Fed (#033) 071 SUO CFET Supportive Services Fed 468 CFET Supportive Services Example: A County has an allocation of $2,000 for Ledger #028. Total expenditures claimed to this Ledger for the FY equaled $15,000. The $13,000 overmatch was Last Updated 1\/2010 148 CFET LED applied using PC 475 with a federal \/ county share of -$13,000 \/ $13,000. In addition, PC 303 was activated with a federal \/ county share of $6,500 \/ -$6,500. The federal share of SUO code 303 is now applied against Ledger #030 allocation of $6,000. The resulting overmatch of $500 appears using SUO code 304 with a federal \/ county share of -$500 \/ $500. Ledger: 028 Total Federal State County PC 306 $5,000 $5,000 $0 $0 PC 307 $5,000 $5,000 $0 $0 PC 464 $5,000 $5,000 $0 $0 SUO 475 $0 ($13,000) $0 $13,000 Ledger: 030 Total Federal State County SUO 303 $0 $6,500 $0 ($6,500) SUO 304 $0 ($500) $0 $500 Last Updated 7\/2013 149 ILP LED Independent Living Program Ledgers The County Expense Claim Ledger System for the Independent Living Program (ILP) 100% Federal ledger is number 064. The County Expense Claim Ledger System for the ILP State 100% ledger is number 104. A revision was made to align the ILP ledgers. It allows the ILP federal ledger to have the same reporting period as the ILP state ledger. It also enables all ILP expenditures to be posted to the federal ILP ledger, and any overages to the federal ledger’s allocation to be shifted to the ILP state ledger. ILP Federal Ledger The cost of personnel to provide ILP services should be claimed to PC 184. ILP Administrative\/Case Management costs should be claimed to PC 182. The Administrative costs of ILP are limited to 20% of the allocation. Counties that exceed this may see a shift at close out. Programs Tracked on the ILP Federal Ledger: 182 ILP Case Management 184 ILP Services 237 SUO ILP Fed\/State Example: Ledger #064 All expenditures for ILP come in on PC 182 and PC 184 Allocation = $300,000 Ledger: 064 Total Federal State County PC 182 $50,000 $50,000 $0 $0 PC 184 $400,000 $400,000 $0 $0 SUO 237 $0 ($150,000) $150,000 $0 In this example, the federal allocation is exceeded by $150,000 and shifted from the federal to state ledger by the use of SUO code 237. ILP State Ledger Costs that exceed the federal allocation will be moved to state funds using SUO code 237. This ledger also captures costs associated with state funded ILP Last Updated 7\/2013 150 ILP LED services pursuant to SB 654. Once the state allocation is expended, SUO code 810 is used for the overmatch code. Effective July 1, 2011, AB 118 realigns the funding for State ILP from the State to local governments and redirects specified tax revenues to fund this effort. Please note that the ledgers for State ILP will no longer work as originally intended since the allocations for this program have been set to zero. Effective with the September 2011 quarter claim, all costs to be covered by the county using the realignment funding will identified in the CEC using the SUO overmatch codes. External tracking of these costs will be required by the counties to ensure the appropriate level of realignment funds is being utilized. Programs Tracked on the ILP State Ledger: 237 SUO ILP Fed\/State 745 ILP NonRelative NonFed-CM 746 ILP NonRelative NonFed-SVCS 810 SUO ILP State 100% O\/M Example: Ledger #104 Allocation = $100,000 Ledger: 104 Total Federal State County SUO 237 $0 ($150,000) $150,000 $0 SUO 810 $50,000 $0 ($50,000) $50,000 In this example, the state allocation is exceeded by $50,000 and shifted from the state funds to overmatch by the use of SUO code 810. Last Updated 1\/2010 151 #076 LED CalWORKs Single Allocation Ledger The County Expense Claim Ledger System for the California Work Opportunity and Responsibility to Kids (CalWorks) Single Allocation ledger is number 076. The CalWORKs Single Allocation is a block grant consisting of Federal Temporary Assistance for Needy Families (TANF) Funds and SGF. Counties presently have the flexibility of using the funds within the Allocation interchangeably for any CalWORKs family. The ledger’s Balance and Overage (B\/O) column reflects the impact of both the federal and state funds. Shifts that occur in the CEC Some shifts to the CalWORKs Single Allocation are not seen in the ledgers. They are seen in the County Expense Claim (CEC) DFA 327.3 and the DFA 327.5’sP1 pages. The DFA327.3 columns that show the CalWORKs shifts are: AFDC\/TANF Adj., PACF,CFAP\/2 Parent Families, and CFAP Singles. For a detailed explanation of these shifts, refer to the CEC Manual’s DFA 327.3’s Program Cost Summary pages. The DFA 327.5P1 Misc. Adj. column shows the shift from CalWORKs PC 615 to Other Public Welfare (OPW) PCs 215 and 343. Shifts that occur in the Ledgers SUO code 321 (SUO-CalFresh County Share Reduction) is used to ensure the county share of costs will not be overstated by shifting costs from county to federal. SUO code 639 (SUO-CalWORKs MOE Adjustment) is used to ensure each county meets their individual Maintenance of Effort (MOE) obligation by shifting costs from the federal share to the county share on a quarterly basis. SUO code 666 (SUO-Administrative CAP Adjustment) is used to ensure that the State does not use more than 15% of federal money on administrative costs. Therefore, anything greater than 15% of administrative costs is shifted from the federal share to the state share. This shift does not impact individual county allocations and the amount shifted from Federal to State for each county is determined by the State. Other Ledgers that have an impact on the CalWORKs Single Allocation during close out are: CalFresh Ledger 017. Last Updated 1\/2010 152 #076 LED Programs Tracked on the CalWORKs Single Allocation Ledger: CalWORKs Eligibility Programs: 040 CSA Demonstration Project 065 2 Parent Family State-Only CalWORKs Eligibility, Admin. 066 2 Parent Family State-Only CalWORKs Case Management 204 CalWORKs IEVS 226 Child Spousal Support Disregards 238 Program Income – San Diego Only 263 U.S. Residency Project CalWORKs 269 CalWORKs SAVE Program 278 CalWORKs Overpayment Collections 293 CalWORKs AFIRM – Los Angeles County 301 CalWORKs Fraud 305 Non-Federal CalWORKs Fraud 340 EFD\/P – Federal CalWORKs 392 Fraud – CalWORKs AFIRM – Los Angeles County 394 Fraud – CalWORKs AFIRM Evaluation 610 CalWORKs – Jail Match (SB 1556) 614 CalWORKs Eligibility 615 Initial Eligibility Determination CalWORKs\/CF\/Medi-Cal 616 Non-Federal CalWORKs Eligibility 618 CalWORKs Program Integrity 643 San Mateo – SUCCESS Evaluation 663 CalWORKs Case Management 664 Information & Referral 665 Non-Federal CalWORKs Case Management: Legal Aliens CalWORKs Cal-Learn Programs: 026 State Only Cal Learn Eligibility 027 State Only Cal Learn Case Management 028 State Only Cal Learn Support Services 432 Cal Learn Support Services, Transportation & Ancillary 617 Cal Learn Case Management 630 Cal Learn Eligibility 640 Non-Federal Cal Learn Eligibility 641 Non-Federal Cal Learn Case Management 649 Non-Federal Cal Learn Support Services CalWORKs Welfare-to-Work (WTW) Employment Services Programs: 055 Safety Net Employment Services – Non-Assistance 056 Safety Net Employment Services – Assistance 109 WTW 2 Parent Family General 233 CalWORKs-Support Svcs: Grants & Loans 257 Supportive Services Outreach 451 Non-Federal WTW Last Updated 1\/2010 153 #076 LED 620 WTW Pre-Assessment 621 WTW Post-Assessment: Community Service 622 WTW Post-Assessment: Other 623 WTW Post-Assessment: Vocational Education 624 WTW Assessment 631 CalWORKs Transitional Services 633 WTW General 648 Non-Federal CalWORKs Transitional Services 678 WTW 2 Parent Family Pre-Assessment: Non-Admin. 679 WTW 2 Parent Family Post-Assessment: Non-Admin. 680 WTW 2 Parent Family Post-Assessment: Voc. Ed., Non-Admin. 681 WTW 2 Parent Family Assessment: Non-Admin. 682 WTW 2 Parent Family Post-Assessment: Other, Non-Admin. 683 2 Parent Recipient Child Care Training 685 Domestic Violence 686 Recipient Child Care Training CalWORKs Child Care Programs: 036 2 Parent Family State-Only Stage One Child Care 053 Safety Net Child Care – Non-Assistance 054 Safety Net Child Care – Assistance 453 Stage One Child Care 811 State-Only Cal Learn Child Care 900 Unable to Transfer Stage 1 to 2 901 Child Care Health & Safety Requirements Self-Certification 902 Child Care Health & Safety Requirements Trustline 903 Non-Federal Child Care 906 Child Care Capacity Building Program 909 Cal-Learn Child Care 910 SUO – Title XX Stage One Costs 912 Non-Federal Cal Learn Child Care 914 SUO – TANF \/ Title XX Transfer CalWORKs Substance Abuse (SA) & Mental Health (MH) Programs: 625 CalWORKs MH Services 628 CalWORKs SA Treatment 632 SUO CalWORKs SA\/MH Treatment State Use Only Codes: 052 SUO ISAWS CF M&O Abatement 086 SUO Merit System Contract CalFresh 087 SUO A-87 Contract CalFresh 298 SUO NACF SB90 CalWORKs County MOE 321 SUO CalFresh County Share Reduction 401 SUO Merit System Contract County Only 402 SUO A-87 Contract County Only Last Updated 1\/2010 154 #076 LED 639 SUO CalWORKs MOE Adjustment 657 SUO CalWORKs Single Allocation 666 SUO Administrative CAP Adjustment Example #1 Shared CW & CalFresh Program Code Shifts These shifts occur before the costs go to the ledgers. Costs claimed to PC 315, PC 320, and PC 342 will not currently be displayed on any ledger. Costs claimed to these program codes are shared between CalWORKs and CalFresh as follows: \uf0d8 Costs to PC 315 gets shifted to PC 301 and 312 \uf0d8 Costs to PC 320 gets shifted to PC 310 and 305 \uf0d8 Costs to PC 342 gets shifted to PC 340 and 341 As a result the shifted costs are controlled in either ledger #076 or #017, based on their respective program titles. Total costs from the DFA 327.3 Pages for Casework & Allocable Support, EDP, EA Eligible, and Direct Costs are added together and then split 50\/50 between the respective program codes identified above. CalWORKs Program Code Casework & Allocable Support EDP EA Eligible Direct Total AFDC \/ TANF Adj. PC 301 $150,000 PC 305 $7,500 PC 312 $150,000 PC 315 $100,000 $50,000 $150,000 $300,000 ($300,000) PC 320 $15,000 $15,000 ($15,000) PC 340 $10,000 PC 342 $5,000 $5.000 $10,000 $20,000 ($20,000) OPW Program Code Casework & Allocable Support EDP EA Eligible Direct Total AFDC \/ TANF Adj. PC 310 $7,500 PC 341 $10,000 Last Updated 1\/2010 155 #076 LED Example #2 PACF Shift These shifts occur before the costs go to the ledgers. Total costs from the DFA 327.3 Pages for Casework & Allocable Support and EDP Costs for PC 614 are added together. The PACF ratio found on the DFA 325.1, line AQ\/AR is then applied to the total amount. Half of the resulting expenditures are shifted to PC 343. You follow these same steps for PC 663 and 618 with the resulting expenditures being shifted to PC 343 and PC 344 respectively. Total Casework\/Allocable Support & EDP PC 614= 1,100,000 PACF Ratio = .600000 1,100,000 * .600000 = 660,000 \/ 2 = 330,000 CalWORKs Program Code Casework & Allocable Support EDP Total PACF Shifts PC 614 $1,000,000 $100,000 $1,100,000 ($330,000) PC 618 $320,229 $17,713 $337,942 ($101,383) PC 663 $900,000 $100,000 $1,000,000 ($300,000) OPW Program Code Casework & Allocable Support EDP Total PACF Shifts PC 343 $630,000 PC 344 $101,383 Example #3 2 Parent Shift Total costs from the DFA 327.3 Pages for Casework & Allocable Support, EDP, and PACF Shift Costs for PC 614 are added together. The 2 Parent ratio found on the DFA 325.1, line AP is then applied to the total amount. The resulting expenditures are shifted to PC 065. You follow these same steps for PC 663 and then shift the resulting expenditures to PC 066. Total Casework\/Allocable Support, EDP, & PACF PC 614= 770,000 2 Parent Families Ratio = .1 770,000 * .100000 = 77,000 CalWORKs Program Casework EDP PACF Direct Total CFAP \/ 2 Last Updated 1\/2010 156 #076 LED Code & Allocable Support Shift Parent Families PC 065 $77,000 PC 066 $70,000 PC 614 $1,000,000 $100,000 ($330,000) $770,000 ($77,000) PC 663 $900,000 $100,000 ($300,000) $700,000 ($70,000) Example #4 CFAP and Single Shift Total costs from the DFA 327.3 Pages for Casework & Allocable Support, EDP, EA Eligible, Direct, AFDC\/TANF Adj., Non Fed, and PACF Shift Costs for PC 312 are added together. The Nonfed\/CFAP Families ratio for CalFresh found on the DFA 325.1, line AH is then applied to the total amount. The resulting expenditures are shifted to PC 606. You follow these same steps for PC’s 211, 218, 268, 275, 310, 312, 341, 343, 344, and 347. The resulting expenditures for all program codes are then shifted to PC 606. To calculate the Single Shift you follow these same steps using the CFAP Singles ratio for CalFresh found on the DFA 325.1, line AI and shifting the costs to PC 609. For the example given below a ratio of .001000 was used. Numerical Example for PC 606 Shift: Total Costs PC 312= 150,000 Nonfed\/CFAP Ratio = .010000 150,000 * .010000 = 1,500 CalWORKs Program Code Casewo rk & Allocabl e Support EDP EA Eligible Direct AFDC \/ TANF Adj. PACF Shifts Total CFAP\/ 2 Parent Families CFAP Singles PC 312 150,000 150,000 (1,500) (150) OPW Program Code Casewo rk & Allocabl e Support EDP EA Eligible Direct AFDC \/ TANF Adj. PACF Shifts Total CFAP\/ 2 Parent Families CFAP Singles PC 211 160,000 160,000 (1,600) (160) PC 218 114,000 15,000 7,000 136,000 (1,360) (136) PC 268 78,000 10,000 5,000 93,000 (930) (93) PC 275 207,000 26,000 17,000 250,000 (2,500) (250) PC 310 114,000 10,000 6,000 130,000 (1,300) (130) PC 343 300,000 25,000 25,000 630,000 980,000 (9,800) (980) PC 347 81,000 10,000 5,000 96,000 (960) (96) PC 341 10,000 10,000 (100) (10) Last Updated 1\/2010 157 #076 LED PC 344 110,476 110,476 (1,105) (110) PC 606 21,155 PC 609 2,115 Example #5 PC 615 Shift Total costs from the DFA 327.5 P1 PC 615 is divided evenly between PC 615, PC 215, and PC 343. Therefore, two-thirds of the total costs are subtracted from PC 615 and then divided evenly between PC 215 and 343. CalWORKs Program Code Program Costs from DFA 327.3 Misc. Adj. Total Program Costs PC 615 $1,500,000 ($1,000,000) $500,000 OPW Program Code Program Costs from DFA 327.3 Misc. Adj. Total Program Costs PC 215 $2,700,000 $500,000 $3,200,000 PC 343 $3,500,000 $500,000 $4,000,000 Example #6: Ledger 076 (Title XX Shift) CW Child Care Title XX State Allocation = $1,000,000 Ledger: 076 (Audited March Qtr Claim) Total Federal State County PC 453 $3,000,000 $3,000,000 $0 $0 SUO 910 $500,000 $500,000 $0 $0 SUO 914 ($500,000) ($500,000) $0 $0 SUO code 910 and SUO code 914 were established to ensure the State utilizes the annual Title XX allocation for CW Child Care given at the State level. Counties do not receive individual allocations for this funding. The State identifies which counties have the highest CW Child Care expenditures and shift the CW Child Care TANF funding from these counties to Title XX. These shifts typically occur on the March and June audited quarter claims. In this example SUO code 914 credits the federal share of expenditures to CW Child Care (PC 453) and SUO code 914 charges these expenditures against the State’s Title XX allocation. Last Updated 1\/2010 158 #076 LED Please note that the federal shift of expenditures from SUO code 914 to SUO code 910 can only be seen on the DFA 327.5 Funding Pages on Audited Claims. Last Updated 7\/2013 159 #112 LED APS \/ CSBG Ledger The County Expense Claim Ledger System for APS\/CSBG is ledger number 112. On a quarterly basis, SUO codes 589 (SUO-APS\/CSBG\/MOE) and 597 (SUO- CSBG\/APS County Share) will be used to ensure that each county meets their individual MOE obligation by moving the county share of costs associated with the program codes outlined below for APS and CSBG, from county share to state share and moving one-fourth of the county’s annual MOE from state share back to county share. If a county exceeds their allocation, over-expenditures will be transferred to county share using SUO code 656. Effective July 1, 2011, this shift is no longer required; as AB 118 realigns the State funds to local governments. As stated in CFL 05\/06-03, Although CSBG and APS are combined for control purposes; appropriate adjustments will be made during the year-end closeout to ensure that surplus APS funds are not used to cover CSBG over-expenditures. Over-expenditures will be transferred to county share. However, CSBG can fund APS activities. Effective July 1, 2011, AB 118 realigns the funding for APS\/CSBG from the State to local governments and redirects specified tax revenues to fund this effort. Please note that the ledger for this program will no longer work as originally intended since the allocation for this program have been set to zero. Effective with the September 2011 quarter claim, all costs to be covered by the county using the realignment funding will identified in the CEC using the SUO overmatch codes. External tracking of these costs will be required by the counties to ensure the appropriate level of realignment funds is being utilized. Programs Tracked on APS\/CSBG Ledger: APS Programs: 569 Emergency Response 570 Case Management 571 SPMP Response 572 SPMP Case Management 573 HR Response 574 HR Case Management CSBG Programs: 113 SPMP 114 Health Related 115 CSBG State Use Only Codes: 589 SUO-APS\/CSBG\/MOE Last Updated 7\/2013 160 #112 LED 597 SUO-CSBG\/APS County Share 656 SUO-NMOHC The following examples demonstrate how the ledgers worked prior to the implementation of Realignment 2011. Examples: PC 589 (SUO APS\/ CSBG\/MOE) is used to ensure counties meet their MOE by shifting one-fourth of their total MOE from the state to the county. For example, if a county’s MOE for one fiscal year is $100,000; $25,000 will be shifted from the state share and shifted to the county share on a quarterly basis. Ledger: 112 Total Federal State County SUO 589 $0 $0 ($25,000) $25,000 PC 597 (SUO-CSBG\/APS County Share) is used to transfer 100% of each quarter’s expenditures that are reported as county share from the county to the state. For example, the sharing ratio for PC 115 is 00\/70\/30 (federal\/state\/county). If in the first quarter a county expends $70,000 for PC 115; the state share is $49,000 and the county share is $21,000. SUO code 597 would then be utilized to transfer the $21,000 from county to state. Ledger: 112 Total Federal State County PC 115 $70,000 $0 $49,000 $21,000 SUO 597 $0 $0 $21,000 ($21,000) PC 656 (SUO NMOHC) is used to ensure counties do not exceed their allocation for APS\/CSBG. For example, if a county’s allocation for the fiscal year is $500,000 and their total expenditures are $525,000; $25,000 will be shifted from the state share back to the county share once they have exceeded the allocation. Ledger: 112 Total Federal State County PC 569 $200,000 $0 $140,000 $60,000 PC 570 $125,000 $0 $87,500 $37,500 PC 115 $200,000 $0 $140,000 $60,000 SUO 656 $0 $0 ($25,000) $25,000 Last Updated 12\/2008 161 #132 LED Community Care Licensing Family Day Care Ledger The County Expense Claim Ledger System for Community Care Licensing Family Day Care (CCL FDC) is ledger number 132. FDC administrative costs, including staff development are charged to PC 157, on the CEC. Expenditures reported to PC 157 on ledger 012 are shift to ledger 132 using SUO code 062 to ensure that 100 percent of the reimbursement funds are expended before counties can access their SGF allocation. Once the federal allocation for ledger 147 has been exceeded, the overmatch expenditures are shifted back to ledger 012 using SUO code 061. Programs Tracked on CCL FDC Ledger: 062 SUO CCL\/FDC CDE Reimburse Note: A flowchart that depicts how this ledger works in conjunction with Ledger 012 can be found under the section titled Ledger Flowcharts . Last Updated 12\/2008 162 #147 LED Community Care Licensing Title XX Ledger The County Expense Claim Ledger System for CCL Title XX is ledger number 147. This ledger tracks the Federal Title XX allocation funds. These funds are distributed based on a percentage of the total of each county’s Foster Family Home (FFH) Licensing allocation. Through the use of SUO codes, funding will be shifted from SGF CCL\/FFH to Federal Title XX. This requires no input by the County. Expenditures reported to PC 156 are shifted from state ledger 011 to federal ledger 147. For this shift to occur, expenditures are shifted out of ledger 011 using SUO code 336 and shifted to ledger 147 using SUO code 337. All remaining expenditures to SUO code 337 will then be funded with Federal Title XX monies and will be tracked against the Title XX Licensing Ledger. Expenditures exceeding the Title XX Licensing Allocation will be transferred back to ledger 011 using SUO code 338. SUO code 336 was not designed to be displayed in any of the numerous CEC ledgers. This code is used by the CEC as a mechanism to shift costs claimed to PC 156, which is funded with 100% SGF, to SUO code 337 in order to utilize Title XX funding. Programs Tracked on CCL Title XX Ledger: 337 SUO CCL Title XX Example All expenditures come in on PC 155 and are shifted to SUO code 156 on the DFA 327.3’s page. CCL Title XX Allocation = $5,000 Ledger: 147 Total Federal State County SUO 337 $15,000 $5,000 $0 $0 SUO 338 $0 ($10,000) $10,000 $0 Ledger: 011 Total Federal State County SUO 338 $10,000 ($10,000) $10,000 $0 In this example, the federal allocation is exceeded by $10,000 and shifted from the federal code by using PC 338. This SUO ensures that the State does not Last Updated 12\/2008 163 #147 LED overcharge the CCL Title XX allocation. SUO 338 is then shifted from Ledger 147 to Ledger 011 CCL – Foster Family Homes and the state portion is tracked against that allocation. Note: A flowchart that depicts how this ledger works in conjunction with Ledger 011 can be found under the section titled Ledger Flowcharts . Last Updated 7\/2011 164 #149 LED PSSF Monthly Casework Visits Grant (CVG) Ledger The County Expense Claim Ledger System for PSSF Monthly Casework Visits is ledger number 149. The PSSF grant was established under Title IV-B to provide funding for community-based family support and preservation services to promote better outcomes for children. In keeping with this goal, additional funding has been added to the PSSF grant for the purpose of increasing monthly visits to children in foster care. The federal grant stipulates that funding is to be used only for monthly caseworker visits and for activities to support caseworker retention, recruitment training, and ability to access the benefits of technology. Administrative costs associated with increase funding for Caseworker Visits can be captured using existing PC 677 (PSSF Monthly Caseworker Visits). Once a county exceeds their PSSF Caseworker Visits allocation, SUO Code 684 will be utilized to shift the overmatch costs. Since these activities are also eligible CWS activities, the overmatch amount shifted to SUO Code 684 will be shifted to SUO 734, funded at 50\/35\/15 (fed\/state\/county), and tracked against the counties CWS Allocation (Ledger 008). The non fed costs will be shifted to SUO Code 146. Programs Tracked on PSSF Monthly Casework Visits Ledger: 677 PSSF Monthly Casework Visits (A9\/07) 684 SUO PSSF Monthly CW Visits Example PSSF Monthly Casework Visits Allocation = $1,000 Ledger: 149 Total Federal State County PC 677 $1,100 $1,100 $0 $0 SUO 684 ($100) ($100) $0 $0 Ledger: 008 Total Federal State County SUO 734 $100 $50 $35 $15 In this example, the allocation for ledger 149 has been exceeded by $100. The overmatch expenditures are shifted out of ledger 149 using SUO code 684 to ledger 008 using SUO code 734 to be funded by the state. Note: A flowchart that depicts how this ledger works in conjunction with Ledger 008 can be found under the section titled Ledger Flowcharts . Last Updated 7\/2013 165 LED FLOW Ledger Flowcharts This section provides Counties with flowcharts of some of the more complicated shifts that happen between the CEC ledgers. Community Care Licensing Ledgers 011 & 147 Shifts Ledger 011 Community Care Licensing – Foster Family Homes Expenditures are reported to PC 155, PC 156, and PC 158. Expenditures exceeding the SGF CCL\/FFH allocation are shifted to county share using SUO 192. Expenditures reported to PC 156 are shifted from State ledger 011 to Federal ledger 147. For this shift to occur, expenditures are shifted out of ledger 011 using SUO 336 and shifted to ledger 147 using SUO 337. Ledger 147 Community Care Licensing – Title XX Expenditures reported to PC 156 on ledger 011 are shifted from ledger 011, SUO 336 to ledger 147 using SUO 337. Once the Federal allocation for ledger 147 has been exceeded, the overmatch expenditures are shifted back to ledger 011 using SUO 338. Ledger 011 Community Care Licensing – Foster Family Homes Overmatch expenditures from ledger 147 are shifted back to ledger 011 using SUO 338. Last Updated 7\/2013 166 LED FLOW Community Care Licensing Ledgers 012 & 0132 Shifts Ledger 012 Community Care Licensing – Family Child Care Home Expenditures are reported to PC 157. Expenditures reported to PC 157 are shifted from State ledger 012 to Federal ledger 132 using SUO 062. Ledger 132 Community Care Licensing – Family Day Care Expenditures reported to PC 157 on ledger 012 are shifted to ledger 132 using SUO 062. Once the Federal allocation for ledger 132 has been exceeded, the overmatch expenditures are shifted back to ledger 012 using SUO 061. Ledger 012 Community Care Licensing – Family Child Care Home Overmatch expenditures from ledger 132 are shifted back to ledger 012 using SUO 061. Expenditures exceeding the State allocation are shifted to county share using SUO 153. Last Updated 7\/2013 167 LED FLOW Child Welfare Services Ledgers 008, 010, 116, 118, 146, 148, and 149 Shifts (Depicts how the CWS Ledgers worked prior to Realignment 2011) Ledger 010 CWS IV-B Expenditures are claimed to PC 146 and reported in the CEC to SUOC 164 Once the Federal allocation has been exceeded, the overmatch expenditures are shifted to ledger 008 using SUO 596. Ledger 118 Group Homes Monthly Visits Expenditures are reported to PC 577 and PC 586. Overmatch expenditures are reported on ledger 118 to SUO 045 and shifted to ledger 008 using SUO 051. Ledger 146 EA TANF Expenditures are reported to PC 134 and PC 513. Once the Federal allocation has been exceeded, overmatch expenditures are reported on ledger 146 to SUO 196 and shifted to ledger 008 using SUO 198. Ledger 008 CWS Basic Expenditures are reported to various PC’s. The State portion of the overmatches from ledgers 010, 118, and 146 are shifted and tracked to ledger 008 using SUO codes 596, 051, and 198 respectively. Overmatch expenditures for this ledger are reported on ledger 008 to SUO code 808 and shifted to ledger 148 using SUO 809. Ledger 148 CWS Augment Title XX Overmatch expenditures from ledger 008 (SUO code 808) are shifted to ledger 148 using SUO code 809. Overmatch Expenditures for this ledger are reported on ledger 148 to SUO code 120 and shifted to ledger 116 using SUO code 122. Ledger 116 CWS Augment Overmatch expenditures from ledger 148 (SUO code 120) are shifted to ledger 116 using SUO code 122. Overmatch expenditures for ledger 116 are reported here and are shifted to County Funds using SUO code 166. Flowchart of Child Welfare Services Ledgers Ledger 149 PSSF Monthly Caseworker Visits Expenditures are reported to PC 677. Once the Federal allocation has been exceeded, overmatch expenditures are reported on ledger 149 to SUO 684 and shifted to ledger 008 using SUO 734. Last Updated 12\/2008 168 CR Single Funding Reports Menu For County Information Only Reconciliation buttons are not available for use in audited claims. Last Updated 12\/2008 169 CR Single Funding Reports County Accounts Menu For County Information Only Last Updated 12\/2008 170 CR County Reports Menu For County Information Only Last Updated 12\/2008 171 CR Additional County Reports Menu For County Information Only Last Updated 12\/2008 172 CR CEC County Reports The CEC produces many County Reports. These reports are located in the view\/print claim reports. Click on the County report button. In this section, you will find the following reports: 1. Total Program Cost (DFA C-420) This report combines the DFA 327.4’s and DFA 327.5’s.). 2. Consolidated Cost (DFA 427.45) This report is a funding summary of all costs for the current quarter by claiming category. 3. DFA 419 Variance (DFA 419A) This report compares the current quarter costs to the prior quarter costs and states the variance. 4. Total Program Cost YTD (DFA C-420 YTD) This report combines the DFA 327.4’s and DFA 327.5’s for all quarters. 5. Consolidated Cost YTD (DFA 427.45 YTD) This report displays the same information as report #2, but this one combines all quarters in the fiscal year. 6. Consolidated Cost No Zeros (DFA 427.45) Same as above except without the zeros. 7. DFA 7A Comparison (DFA C7A) This report compares the current quarter costs and hours for the Support Staff to the prior quarter costs and hours of the Support Staff. 8. DFA 55 Comparison (C 55) This report compares the current quarter Caseworker Staff costs and hours to the prior quarter Casework Staff costs and hours. 9. DFA 55 Comparison Tab (C 55 T) Same as above. Additional County Reports: 1. Allocation Program Codes 2. Admin\/Non-Admin Exp. (DFA C 450) 3. Sharing Ratios (SR1) 4. Assist\/Non-Assist Exp (DFA 325.1B) 5. CMSP (Code 217) Certify 6. FTE’S by Program Code (DFA 453) 7. FTE’S by Allocation (DFA 453) 8. Direct Cost Comparison (DFA 325.1cc) 9. Allocation Report Excel Spread Sheets 1. Consolidated Cost to Excel (DFA 427.45) 2. Consolidated Cost YTD to Excel (DFA 427.45 YTD) 3. DFA 327.4 to Excel 4. DFA 327.5 to Excel Last Updated 12\/2008 173 CR 5. DFA 55 to Excel 6. FTE DFA 453 to Excel 7. Total Program Cost to Excel (Tot_Prg_Excel) 8. Total Program Cost YTD to Excel (Tot_Prg_YTD) Additional Excel Options 1. Single Funding Page (C-430) to Excel 2. DFA 327.6 to Excel (Adj Claims Only) 3. DFA 327.7 to Excel (Adj Claims Only) 4. DFA 325.1B Direct Cost Detail to Excel 5. Allocation Table to Excel 6. Allocation Status Report to Excel 7. Program Code Table to Excel 8. Allocation Name & Number to Excel Ledger Tracking System Single Funding Reports 1. Detail Data (DFA C-430) 2. Summary (DFA C-431) 3. Advanced (DFA C-433) 4. Cash Claim (DFA C-434) Last Updated 12\/2008 174 PC Program Code List ProCodes ProCodes is a reports only database included with the original quarter claim and represents two of the five Quarterly CEC files received through the extranet from CDSS County Systems Unit. Each individual user of this database needs to create the icon, once only, on their desktop in order to access the information. Unzipping the two attachments automatically updates the ProCodes information for that quarter. The reports that are available, quarter specific, through this icon are as follows: \uf071 Sharing Ratio Report: Displays the sharing ratio percentage for federal\/welfare\/health by function and program code number. \uf071 County Program Code Reports: Five options are available. \uf0d8 County Program Code Report (All Codes by Function) \uf0d8 County Program Code Report (without deleted codes) \uf0d8 County Program Code Report (Deleted Codes Only) \uf0d8 County Program Code Report (All Codes in Code Order) \uf0d8 County PIN Report (Prints all valid 6 digit PINs) \uf071 Single Funding Crosswalk Reports: Two options are available. \uf0d8 Single Funding Crosswalk (All Quarters) \uf0d8 Single Funding Crosswalk (by Appropriate # order and Allocation #s) \uf071 Type of Expense Code Report: Displays all the two-digit Program Identifier Numbers and their descriptions. \uf071 Program Codes by Allocation Reports: Displays the allocation numbers and the associated program codes. This report is available by fiscal years. Additional information on the Single Funding Crosswalk Report can be found in the Revenue section of this Manual. County Expense Claim CEC Other References Section III – Additional Reference Information Lasted Updated 12\/2008 176 QR Quick Reference Guide Summary of CEC Reports Report Title Expenditure Certification for the County Welfare Dept. Expense Claim (CEC) Report # DFA 325.5 Menu Options Print Reports-Claim Certification Contents This report summarizes the CEC expenditures, classified as Allowable and Extraneous. This report also contains the signature and date of the County Welfare Director and the County Auditor, certifying that the amounts reported have been expended in accordance with all provisions of the Welfare and Institutions Code and rules and regulations of CDSS. Report Title Claim Letter Report # N\/A Menu Options Print Reports-Claim Letter Contents The claim letter transmits information to CDSS regarding the quarter’s expenditures. This letter is required for the first quarter original claim and when submitting an adjustment claim to explain the changes reported in the adjustment claim vs. the original claim. Report Title County Expense Claim (CEC) Expenditure Schedule Report # DFA 325.1 Menu Options Print Reports-325.1 Expenditure Schedule Contents This report summarizes the County Agency’s expenditures for the claiming period (quarter). Report Title Itemized Extraneous Costs Report # DFA 325.1 Attachment Menu Options Print Reports-Extraneous Costs Contents This report displays all Extraneous costs by description. Input Report Title EDP-Cost Detail Schedule (M & O by function) Report # DFA 325.1A Menu Options Print Reports-EDP Reports- EDP M & O by Function 325.1A Contents This report displays EDP maintenance and operations costs by function and reallocates Generic cost by case counts and time study hours. Report Title EDP-Cost Detail Schedule (M & O Direct Cost) Report # DFA 325.1A Menu Options Print Reports-EDP Reports- EDP M & O Direct 325.1A Contents This report displays EDP maintenance and operations costs by program. Lasted Updated 12\/2008 177 QR Report Title EDP Cost Detail Schedule Developmental Projects\/Direct Cost (including SACWIS) Report # DFA 325.1A Menu Options Print Reports-EDP Reports- EDP DevDirect 325.1A Contents This report displays direct-to-program developmental projects by program and project number. Report Title EDP-Cost Detail Schedule Developmental Project\/Single and Multi- Functions Report # DFA 325.1A Menu Options Print Reports-EDP Reports- EDP Dev by Function 325.1A Contents This report displays the developmental projects that have been entered as single and multi-function. Report Title Multiple Developmental Projects Charged to a Single Program Code Report # DFA 325.1A Menu Options Print Reports-EDP Reports- EDP Dev Dir Multi-Proj 325.1A Contents This report displays the developmental projects that are charged to a single program code. Report Title County Expense Claim Direct Cost Input Schedule Report # DFA 325.1B Menu Options Print Reports-325.1B\/Direct Cost Contents This report displays the costs claimed directly to a specific program by PIN number. Additional Info This report can be exported to Excel. Report Title Staff Development Detail Schedule Report # DFA 325.1C Menu Options Print Reports-Stf Dev Detail 325.1C Contents This report displays Staff Development costs by function and direct-to- program. Report Title Direct to Program Support Staff Salary Input Report # DFA 325.1E Menu Options Print Reports-Direct\/Program Support Staff Salary Input 325-1E Contents This report displays the costs of Support staff salaries that are charged direct-to- program. Report Title Support Staff Summary DFA 7A Report # DFA 7A Page 1 Menu Options Print Reports-DFA 7 Reports-Support Staff Summary DFA 7A Contents This report displays Support Staff hours and salaries by program code. Report Title DFA 7A Input Data Lasted Updated 12\/2008 178 QR Report # DFA 7A Menu Options Print Reports-DFA 7A Input Contents This report displays the Support Staff time study hours as they have been input into the DFA 7 section of the CEC. Report Title DFA 7A Distribution of Multi-Function Salaries Report # DFA 7A Menu Options Print Reports-DFA 7 Reports-DFA 7A Input Contents This report displays how the Multi-function Support Staff salaries are distributed to the appropriate functions and direct-to-program. Report Title Reconciliation of General Administration; Program Administration; & Clerical Support Staff Salaries and FTE’s Report # DFA 7B Menu Options Print Reports-DFA 7 Reports-DFA 7 Reconciliation Contents This report displays Support Staff salary costs and FTE’s by function and direct-to-program. Report Title Support Staff Salary Distribution to Program Report # DFA 7B2 Menu Options Print Reports-DFA 7 Reports-Support Staff Salary Dist-DFA 7B Contents This report displays the Support Staff salaries that have been distributed to the program. Report Title Distribution if Generic Support Staff Costs to General Admin: Program Admin: and Clerical Support Staff Report # DFA 7B3 Menu Options Print Reports-DFA 7 Reports-DFA 7 Generic Cost Distribution Contents This report displays the distribution of Generic Support Staff costs to the function level. Report Title Caseworker Time Study and Salary Distribution Summary Time Study Hours\/Observations by Salary Pool\/Program Report # DFA 55 Menu Options Print Reports-DFA 55 Caseworker TS Contents This report displays the Caseworker time study hours by cost pool and time study program code. Additional Info This report can be exported to Excel. Report Title Caseworker Time Study and Salary Distribution Summary Time Study Hours\/Observations by Salary Pool\/Program Report # DFA 55A Menu Options Print Reports-DFA 55 Caseworker TS Contents This report displays the distribution of salary costs by pool \/ program, total hours \/ observation \/ ratios, and the generic distribution by time study code. Lasted Updated 12\/2008 179 QR Report Title DFA 55 Time Study Input Report # DFA 55 Menu Options Print Reports-DFA 55 Input Contents This report displays the caseworker time study hours as they have been input into the DFA 55 section of the CEC. Report Title Full Time Equivalents Calculation Report # DFA 403 Menu Options Print Reports-FTE’s\/DFA 403 Contents This report displays FTE’s by cost pool. Report Title Claim Summary Sheet Report # DFA 419 Menu Options Print Reports-DFA 419 Claim Summary Contents This report specifies reasons for substantial variances of 15% or more in the total costs by function from the prior quarter. Output Report Title Distribution of Salary Cost and Allocable Support Staff and Operating Costs Report # DFA 327.1 Menu Options Print Reports-Sal Cost\/ Alloc Supp\/ Oper Cost 327.1 Contents This report displays caseworker salary costs, time study hours, generic salary costs, allocable and direct-to-program support staff costs, allocable support operating costs, and adjustments by program codes. Report Title EDP – Cost Schedule Report # DFA 327.2 Menu Options Print Reports-EDP Reports- EDP Total Cost 327.2 Contents This report displays the total of all EDP costs. Report Title Allocation of M & O EDP Costs and M & O Direct Cost Report # DFA 327.2 Menu Options Print Reports-EDP Reports- M & O Alloc\/Direct 327.2 Contents This report displays the total M & O costs allocated to function and direct-to- program. Report Title EDP Multi-Function Developmental Projects Report # DFA 327.2 (1-4) (5-8) (9-12) (13-16) (17-20) (21-24) Menu Options Print Reports-EDP Reports- EDP EDP Dev Multi-Function 327.2 Contents This report displays multi-function project costs by program code. Report Title DFA 327.3 Program Cost Summary Report # DFA 327.3 Lasted Updated 12\/2008 180 QR Menu Options Print Reports-Welfare Program Cost Sum 327.3 Contents This report displays Casework and allocable Support costs, EDP costs, EA costs, direct costs, AFDC\/TANF adjustments, and the Non-Fed, PACF and CFAP shifts for each program. Report Title CEC Staff Development Cost Summary and Funding Report # DFA 327.4 A-E Menu Options Print Reports-Staff Dev Summary 327.4 Contents This report first displays, by program, allocable general staff development and direct-to-program staff development costs, then displays by funding source, federal\/state\/health\/county shares. Additional Info This report can be exported to Excel. Report Title DFA 327.5.P1’s Welfare Program Adjustments and Fiscal Incentives Report # DFA 327.5’s P1 Menu Options Print Reports-Welfare Program Funding 327.5 Contents This report displays Performance Incentive shifts and miscellaneous adjustments to total program costs. Report Title DFA 327.5 Welfare Program Funding Report # DFA 327.5’s Menu Options Print Reports-Welfare Program Funding 327.5 Contents This report displays the total program costs to fund and the distribution by funding source – federal\/state\/health\/county. Additional Info This report can be exported to Excel. Report Title CEC Staff Development Cost Summary and Funding Scheduled Differences Report # DFA 327.6 Menu Options Print Reports-Staff Dev Summary 327.4\/327.6 Contents This report displays the differences between an audited original claim and the adjustment claim for staff development costs. Additional Info This report can be exported to Excel. Report Title Welfare Program Funding Scheduled Differences Report # DFA 327.7 Menu Options Print Reports-Welfare Program Funding 327.5\/327.7 Contents This report displays the differences between an audited original claim and the adjustment claim for the program costs reported on the DFA 327.5. Additional Info This report can be exported to Excel. Report Title DFA 327.8 Close Out Payment Report Report # DFA 327.8 Menu Options This report is not available through the CEC Template. Contents This report displays all Closeout related CEC Ledger System shifts and any journal entries (manually adjustments entered by the CEC Administrator) that Lasted Updated 12\/2008 181 QR are determined and provided by other CDSS stakeholders to include in the Closeout rounds . Report Title Performance\/Fraud Incentives Report # DFA 329 Menu Options Print Reports-Performance Incentive-Incentives Contents This report displays the total amount of Performance Incentives charged to each Program. Report Title TANF Incentive Funds Expenditures Report # DFA 335 Menu Options Print Reports-Performance Incentive-Addendum Contents This report displays Performance Incentive amounts by claiming category. County Reports For County Use Only: Data is Unofficial and is NOT Maintained By CSU Report Title Assist\/Non-Assist Expenditures Report # DFA 325.1B Menu Options Print Reports-County Reports-Additional County Reports-Assist\/Non-Assist Exp Contents This report displays Assistance and Non-Assistance Direct costs by PIN number. Report Title Direct Cost Comparison Report # DFA 325.1CC Menu Options Print Reports-County Reports-Additional County Reports-Direct Cost Comparison Contents This report compares current quarter Direct costs to prior quarter Direct costs by PIN number. Report Title DFA 419 Variance. Claim Summary Sheet Report # DFA 419A Menu Options Print Reports-County Reports-DFA 419 Variance Contents This report categorizes costs by function into Caseworker costs, Support Staff costs, Support Operating costs, EDP costs, Staff Development costs, Direct costs, and Caseworker Hours. It compares current quarter costs to prior quarter costs. Report Title Consolidated Cost\/Funding Summary Report # DFA 427.45 Menu Options Print Reports-County Reports-Consolidated Cost No Zeros Lasted Updated 12\/2008 182 QR Contents This report displays total current quarter costs by Caseworker costs, Support Staff costs, Allocable Operating costs, Adjustments, EDP costs, Direct costs, Costs Shifts & Adjustments, Staff Development costs, and Fiscal Incentives for each program. The total program cost is then displayed by federal\/state\/health\/county funding. Additional Info This report can be exported to Excel. Report Title Consolidated Cost\/Funding Summary – No Zeros Report # DFA 427.45 YTD Menu Options Print Reports-County Reports-Consolidated Cost No Zeros Contents This report summarizes each quarter’s cost for year-to-date expenditures by Caseworker costs, Supports Staff costs, Allocable Operating costs, Adjustments, EDP costs, Direct costs, Costs Shifts & Adjustments, Staff Development costs, and Fiscal Incentives for each program. The total program cost is then displayed by federal\/state\/health\/county funding. Report Title Consolidated Cost YTD Report # DFA 427.45 YTD Menu Options Print Reports-County Reports-Consolidated Cost YTD Contents This report summarizes each quarter’s cost for year-to-date expenditures by Caseworker costs, Supports Staff costs, Allocable Operating costs, Adjustments, EDP costs, Direct costs, Costs Shifts & Adjustments, Staff Development costs, and Fiscal Incentives for each program. The total program cost is then displayed by federal\/state\/health\/county funding. Additional Info This report can be exported to Excel. Report Title FTE’s By Allocation & Program Code Report # DFA 453 Menu Options Print Reports-County Reports-Additional County Reports-FTE’s by Allocation and Program Code Contents This report displays total hours, salaries, and FTE’s by allocation and time study code. Report Title FTE’s By Program Code Report # DFA 453 Menu Options Print Reports-County Reports-Additional County Reports-FTE’s by Program Code Contents This report displays FTE’s, hours, and salaries by time study code. Additional Info This report can be exported to Excel. Report Title DFA 7A Comparison Report # DFA C7A Menu Options Print Reports-County Reports-DFA 7A Comparison Contents This report compares the current quarter’s Support Staff hours and costs to the prior quarter’s Support Staff hours and costs. Lasted Updated 12\/2008 183 QR Report Title DFA 55 Comparison Report # C55 Menu Options Print Reports-County Reports-DFA 55 Comparison Contents This report compares current quarter and prior quarter Caseworker salaries and hours by program code for each cost pool. Report Title Total Program Cost (Welfare and Staff Development) Report # DFA C-420 Menu Options Print Reports-County Reports-Total Program Cost Contents This report first displays the total Welfare and Staff Development costs by Program. Then it displays the federal\/state\/health\/county funding shares, subtotaled by function. Additional Info This report can be exported to Excel. Report Title Total Program Costs – YTD Report # DFA C-420 YTD Menu Options Print Reports-County Reports-Total Program Costs YTD Contents This report first displays the total Welfare and Staff Development costs by Program by each quarter for the year-to-date expenditures. Then it displays the federal\/state\/health\/county funding shares, subtotaled by function. Additional Info This report can be exported to Excel. Report Title County Funding – Summary Detail Data by Program Code Report # DFA C 430 Menu Options Print Reports-County Reports-Single Funding Reports-Detail Data Contents This report displays the Allocation costs by program code and by federal\/state\/health\/county funding shares. Additional Info This report can be exported to Excel. Report Title County Funding Summary – Detail Data by Program Code Report # DFA C 430F Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-Federal Detail Contents This report displays all federal costs by Program and by federal catalog number. Report Title County Funding – Summary Detail Data by Program Code ADVANCED Funds Only Report # DFA C 430_FADV Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-Federal Advance Contents This report displays all federal costs by programs that are advanced. Report Title County Funding – Summary Detail Data by Program Code CASH Claim Funding Only Lasted Updated 12\/2008 184 QR Report # DFA C 430_FCC Menu Options Print Reports-County Reports-Single Funding Reports- County Single Fund Reports-Federal Cash Contents This report displays all federal costs by programs that are cash claimed. Report Title County Funding – Summary Detail Data by Program Code Report # DFA C 430_R Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-Reimbursements-Detail Contents This report displays all Health\/Reimbursement Funds by Program. Report Title County Funding – Summary Detail Data by Program Code Advanced Funded ONLY Report # DFA C 430_RADV Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-Reimbursements-Advance Contents This report displays all Health Reimbursement funds by programs that are advanced. Report Title County Funding – Summary Detail Data by Program Code Cash Claim Funds ONLY Report # DFA C 430_RCC Menu Options Print Reports-County Reports-Single Funding Reports- County Single Fund Reports-Reimbursements-Cash Contents This report displays all Health Reimbursement funds by programs that are cash claimed. Report Title County Funding – Summary Detail Data by Program Code Report # DFA C 430_S Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-State-Detail Contents This report displays all state costs by program and federal catalog numbers. Report Title County Funding – Summary Detail Data by Program Code Advanced Funds ONLY Report # DFA C 430_SADV Menu Options Print Reports-County Reports-Single Funding Reports-County Single Fund Reports-State-Advance Contents This report displays all state costs by programs that are advanced. Report Title County Funding – Summary Detail Data by Program Code Cash Claimed Funds ONLY Report # DFA C 430_SCC Menu Options Print Reports-County Reports-Single Funding Reports- County Single Fund Reports-State-Cash Contents This report displays all state costs by programs that are cash claimed. Lasted Updated 12\/2008 185 QR Report Title County Funding – Summary Summarized by Funding Source Report # DFA C 431 Menu Options Print Reports-County Reports-Single Funding Reports-Summary Contents This report displays all costs categorized by funding source, i.e., federal\/state\/health\/county fund. Report Title County Funding – Summary Detail Data by Program Code Advanced Funding ONLY Report # DFA C 433 Menu Options Print Reports-County Reports-Single Funding Reports-Advanced Contents This report displays all costs for programs that are advanced by funding source, federal\/state\/health\/county. Report Title County Funding Summary \/ Detail Data by Program Code-Cash Claim Funding Only Report # DFA C 434 Menu Options Print Reports-County Reports-Single Funding Reports-Cash Claim Contents This report displays all costs by programs that are cash claimed by funding source. Report Title Admin\/Non-Admin Expenditures Report # DFA C 450 Menu Options Print Reports-County Reports-Additional County Reports-Admin\/Non-Admin Expenditures Contents This report displays programs by Admin and Non-Admin costs. Then the costs are displayed by Welfare Program costs and Staff Development costs, by funding source. Report Title Claim Notes Report # N\/A Menu Options Print Reports-Claim Notes Contents This report displays the area supplied in claim to make any notes for use by the County only. Miscellaneous Reports Report Title Allocations and Associated Programs Codes Report # N\/A Menu Options Print Reports-County Reports-Additional County Reports-Allocation Programs Codes Contents This report displays each allocation ledger number and all of the Programs that are tracked to that allocation. Lasted Updated 12\/2008 186 QR Report Title CEC-Ledger Tracking System Allocation Report – Current State Fiscal Year Report # N\/A Menu Options Print Reports-County Reports-Additional County Reports-Allocation Reports Contents This report displays the programs that have either a federal or state allocation. The allocation number is the ledger number that is used for tracking purposes. The Report displays the current allocation amount for tracking purposes (SFY or FFY). Report Title County Medical Services Program Eligibility Expenditure Report Report # N\/A Menu Options Print Reports-County Reports-Additional County Reports-CMSP (Code 217) Certify Contents This report is to be submitted quarterly for Staff Development costs (DFA 327.4) and Welfare Program costs (DFA 327.5) associated with Program 217. Report Title Sharing Ratios Report # SR 1 Menu Options Print Reports-County Reports-Additional County Reports- Sharing Ratios Contents This report displays funding by federal\/state\/health\/county ratios. Reconciliation Reports Report Title (CEC) System Reconciliation Report # N\/A Menu Options Print Reports-CEC Reconciliation Contents This report determines if the CEC inputs and outputs balance. Report Title Expenditure Reconciliation for the County Welfare Department Expense Claim (CEC) After Ledger Processing Report # N\/A Menu Options Print Reports-County Reports-Single Funding Reports-Reconciliation Contents This report displays the Total Allowable Welfare costs and Staff Development costs by federal\/state\/health\/county funding and the variance between the inputs and the outputs. Lasted Updated 7\/2013 187 ACR CEC Definitions Abatement A reduction of expenditures, refund, to a program, i.e., a negative input. Adjustment Claims An adjustment to an original claim filed within nine (9) months of the original quarter. Aid See cash aid\/cash grant. All County Information Notice (ACIN) Disseminates statewide information and does not need to be retained for future reference. All County Letter (ACL) Provides specific direction on matters requiring statewide compliance, i.e., implementation of court orders, changes or additions to department policy, and new reporting requirements. Also, provides instructions or information requiring response or action by all counties. Allocable, Allocate, Allocation Spreading a cost among programs on an equitable basis; to spread the cost among programs; and, the equitable basis methodology for spreading costs to benefiting programs. Assistance A cash grant payment to a recipient (public assistance). Also, under TANF, Welfare to Work, refers to the unemployed public assistance client. CalFresh Population served receives food assistance only. Formerly referred to as NAFS. California County Welfare Department (CWD) Cost Allocation Plan (CAP) A state developed, federally approved written description of the methodology that will be used to allocate costs to the appropriate benefiting level in the administration of public assistance programs administered by the County Welfare Departments. California Department of Health Services (CDHS) Cognizant State agency for Medi-Cal programs. California Department of Social Services (CDSS) Cognizant State agency for the administration of public assistance programs. California Work Opportunity and Responsibility to Kids (CalWORKs) Program that replaced Aid to Families with Dependent Children (AFDC) under federal welfare reform. Provides cash assistance and services to California’s needy families. Lasted Updated 7\/2013 188 ACR Case Counts Counts of active cases used to allocate costs between programs. Caseload The number of clients in a program. Caseworkers The County Agency staff that work directly with the client. Cash Grant\/Aid The funds a public assistance client receives for daily living expenses. Child Care Child care assistance for needy families. Child Welfare Services\/Case Management System (CWS\/CMS) A statewide, state administered EDP case management system dedicated to the Child Welfare Services programs. Claim Auditor The state staff person who performs a desk audit of the CEC. Client A resident of the County who receives services that are provided by the County Agency. Code of Federal Regulations (CFR) General rules and regulations for the administration of federal funds. Compensating Time Off (CTO) Time taken in lieu of salary. Continuous Time Study The daily recording of time spent on a job activity during each month of the report quarter. Contract A mutually binding legal relationship obligating the seller to furnish the supplies or services and the buyer to pay for them. Cost Pools The type of expenditure reported to the function or program level, i.e., salary and benefits. County Agency See County Welfare Department definition. County Allocations Unit (formerly CFAB) The CDSS organization that prepares and transmits program allocation information to the County Agencies for the operation of programs. County Cost Allocation Plan (CCAP) A yearly county central service plan, approved by the State Controller’s Office, that includes all central service costs that will be claimed, allocated or direct billed, under federal awards. Lasted Updated 7\/2013 189 ACR County Expense Claim (CEC) An automated quarterly reporting document for County Agencies to enter program expenditures for reimbursement of federal and state shares. County Expense Claim Manual Workgroup This workgroup reports to Fiscal. The workgroup is responsible for writing and updating the CEC Manual. County Expense Claim Users (CEC Users) This is a subcommittee of Fiscal. This committee maintains and updates information related to the CEC. County Fiscal Letter (CFL) A letter that transmits quarterly, or on an as needed basis, instructions for County Agency staff on time studying activities and claiming of expenditures for reimbursement and allocation of federal and state program funds to County Agencies. County Welfare Department (CWD) The cognizant agency to administer public assistance programs in California, supervised by the California Department of Social Services. Could also be known as Health and Human Services Agency, Human Services Department, Social Services, or Public Social Services. County Welfare Director’s Association (CWDA) Consists of the directors from the human services or social services agencies from each of the 58 counties, who collaborate as a single body to promote the goals of human services programs throughout the state. County Share The percent of cost reimbursement a county will contribute for the provision of programs they operate. Developmental Projects Represents the development of a new Electronic Data Processing System that benefits the delivery of program activities. Direct Billed CCAP billed central services means central services that are billed to benefiting agencies and\/or programs on an individual fee-for-service or similar basis. Non-CCAP administrative services performed for the County Agency under some type of agreement, i.e., Memorandum of Understanding (MOU). Direct Charge Overhead costs of the County Agency that can be identified to a function or program level as opposed to generic. Direct Cost A service delivery cost that can be identified specifically with a particular final cost objective. Direct Deposit An aid payment directly deposited to a bank account for the recipient. No warrant issued. Lasted Updated 7\/2013 190 ACR Direct Service Delivery Time spent by support staff providing a service directly to a recipient, i.e., transportation to appointments, etc. Caseworkers do not use this identifier. Direct-to-Function For use by support staff who only support one function. Direct-to-Program For use by support staff who can identify their activities directly to the program level. Electronic Benefit Transfer (EBT) An ATM system for recipients to access their eligible benefits. Developed for CalFresh but cash assistance programs can be added. Electronic Data Processing (EDP) A computer\/system used by the County Agency to process and track recipients, expenditures and\/or daily work. Can be specific to a program or generic. Extraneous A cost that is not a part of federal and state funded programs and\/or cannot be allocated through the CEC. This cost must be reported by the County Agency as an expenditure of their department. Federal The departments within the United States of America’s government that provide grants for public assistance programs. Federal Fiscal Year (FFY) A 12 month period which begins in October and ends in September. Federal Funds The dollars allocated to a state for the administration of public assistance programs that must be matched by state and\/or county funds. Federal Share The percent of cost reimbursement the Federal government will contribute for the provision of public assistance programs. Financial Analysis and Data Systems (FAADS) County agency fiscal staff analyze technical aspects of human services program funding, allocations, and cost allocation methodologies in conjunction with State oversight agency fiscal staff, and develop policy recommendations as directed by the CWDA Fiscal Committee. Fiscal Committee Consists of senior financial officers from the county agencies to identify, analyze, and develop recommendations regarding the financial policies of human services programs for the Board of Directors. Lasted Updated 7\/2013 191 ACR Fiscal Policy Bureau (FPB) The CDSS organization that prepares and transmits time study and claiming instructions to the County Agencies for the operation of program administration and services. Fiscal Year See state fiscal year definition. Foster Care The placement of a child removed from their home based on an investigation of abuse, neglect or exploitation. FoxPro An automated database system, template, for the County Expense Claim. Fraud A dishonest act by a recipient with the intent to defraud. Fraud Investigator A County Agency or District Attorney staff who is a licensed peace officer who investigates suspected fraud activities. Function One of the major roles performed by the County Agencies. All programs relate to a function. Funding Ratios Relates to the percent of cost reimbursement that each entity (federal, state, or county) will contribute toward expenditures for programs. (See county, federal, or state share.) Generic Refers to costs that are general administrative in nature, have department-wide benefit, or costs that cannot be reasonably identified as benefiting a specific program or group of programs. Generic Casework Refers to casework staff that spend some of their time on generic administrative duties or attend some type of generic meeting, not program specific. Health Funds Refers to Title XIX, Medi-Cal funds. Cognizant agency is the California Department of Health Services. Health and Human Services Data Center (HHSDC) The State organization that manages State level EDP projects for CDSS and approves the purchase of EDP equipment for County Agency’s. Health Related Refers to activities for CDSS programs that are funded with Title XIX Health funds. Indirect Cost Rate (ICR) A ratio to calculate overhead cost for specific activities that cannot be calculated through the CEC. Lasted Updated 7\/2013 192 ACR Indirect Cost Rate Proposal (ICRP) A request for approval of a methodology that calculates an indirect cost rate. Interim Statewide Automated Welfare System (ISAWS) One of the four county consortia welfare systems within the Statewide Automated Welfare System Project. Maintenance and Operations (M&O) Activities\/costs for an EDP system to keep the system operational, i.e., purchase software, printers, new PC’s, etc. Maintenance of Effort (MOE) A specific dollar amount the state and\/or counties must spend as a match to receive federal and\/or state funds. Manual of Policy and Procedures (MPP) The State regulations that governs public assistance programs. Division 25 is the Financial Management and Control section. Medi-Cal Health related funds distributed through the Department of Health Services. Memorandum of Understanding (MOU) A short, written statement outlining the terms of an agreement, transaction or contract. Non-Assistance Refers to the eligible client population who is employed and receives some services. Non-CCAP Administrative costs that are not part of the central support services of the county. Non-federal Refers to an activity or population served that is not eligible for federal financial participation. Non-welfare Programs administered by a County Agency where funds are provided from another source, i.e., veteran’s affairs. Office of Management and Budgets (OMB) The federal organization that issues OMB Circulars which establishes principles and standards to provide a uniform approach for determining costs and to promote effective program delivery, efficiency, and better relationships between governmental units and the federal government. The principles are for determining allowable costs only. On-the Job Training (OJT) A training activity where a recipient learns the work process while employed. Operating Costs The overhead expenditures of the County Agency; the cost of doing business. Lasted Updated 7\/2013 193 ACR Original Quarter The CEC counties file within 30 days of the end of a quarter. Other County Only Program (OCOP) Refers to programs administered by a County Agency that are funded with county only funds, i.e., General Relief. Other Shift (OS) An other shift occurs when one ledger’s overmatch is another ledger’s expenditure. For example the overmatch for Ledger 008-SUO code 808 is reflected on Ledger 148-SUO code 809. Overmatch A County Agency receives an allocation of federal and\/or state funds to administer a program and expends more than they are allocated. Participant See Client definition. Performance Incentive A financial incentive earned by counties for assisting recipients in finding and retaining work. Person Count Counts of active people in a case that are used to allocate costs between programs. Program Identifier Number (PIN) A six-digit number that determines the program, program component, and the type of expense to which the cost is directly identified. Programs Contained within the functions and are the activities\/services used to assist clients. Public Agencies A Federal, State, or County government entity. Public Assistance A means to assist needy families with a cash grant and\/or services. Public Assistance CalFresh (PACF) Clients served who receive food stamps and cash grant assistance, formerly referred to as Public Assistance Food Stamps (previously referred to as PAFS). Public Authority An organization, separate and apart from the County Agency, that works with the providers of services for the In-Home Supportive Services program. Purchase of Service (POS) Refers to the County Agency obtaining specific services from either another County Department or the private sector in the administration of programs. Lasted Updated 7\/2013 194 ACR Random Moment Time Study The caseworker time recorded for an activity being performed at a given point in time. Reallocation A process usually implemented at the close-out of a fiscal year for those program allocations that have unspent funds. Unspent funds may be reallocated to counties that are in an overmatch situation. Request for Proposals (RFP) A description, in document form, of a specific problem or need to which a vendor describes an approach to a solution or solutions. Also contains other contract requirements. Salary Pool The way of collecting the salary and benefits of specific groups of staff. Shift A movement in the CEC and\/or ledgers that shifts expenditures captured in a specific program to a connected program funded in a different manner. Example: A shift occurs to expenditures recorded to PC 148 to capture a non- federally eligible share of cost. Single Shift (SF) A single shift occurs when your total expenditures for a specific program exceed (overmatch) its fiscal year allocation. Space The building\/facility used by the County Agency to house staff in the operation of the programs. Staff Development A training program for County Agency staff. State Controller’s Office The State agency who issues payments and is the cognizant agency, for the federal government, of the 58 County Cost Allocation Plans. State Fiscal Year (SFY) A 12 month period which begins in July and ends in June. Statewide Automated Child Welfare Information System (SACWIS) Refer to Child Welfare Services\/Case Management System. Statewide Automated Welfare System (SAWS) The automation of county welfare business processes that includes four county consortia welfare systems and a state level database to track time on aid. State of California Automated Template (SOCAT) Refer to Foxpro. State Use Only (SUO) A program code generated by CDSS that performs a shift occurring on the CEC, i.e., from fed to state, for allocation control, or used at year-end close out. Lasted Updated 7\/2013 195 ACR State Welfare Funds Refers to the state share of cost reimbursement for public assistance programs. Support Staff Staff who performs generic or direct-to-program activities, e.g., personnel, administration, or direct support of the caseworker. Support Staff Time Reporting Plan (SSTRP) A plan that details the benefiting level (generic, function, or program) of the salaries and benefits of support staff, non- casework carrying employees. Temporary Assistance to Needy Families (TANF) The federal government program that provides assistance and work opportunity for needy families by granting states the federal funds and wide flexibility to develop and implement their own public assistance programs. Replaced the Aid to Families with Dependent Children program. Time Certify The reporting of total time worked for the month, when work activities benefit only one level (generic, function, or a single program). Time Study Refers to County Agency staff accounting for their work activities daily during a specified period of time. Time Study Hours Refers to the total time study hours of the County Agency caseworker that are used as the basis for distribution of costs through the CEC. Transportation This identifier pertains to transporting the County Agency clients to various types of appointments. Travel This identifier pertains to the County Agency staff as they travel in the performance of their job duties or attend off site training. Type of Expense (TOE) An activity or service provided, generally, directly to a recipient represented by a two-digit number used in conjunction with a program code. Welfare & Institution Code (WIC) State regulations that governs organizations that administer programs for various State departments and use SGF dollars. Welfare-To-Work (WTW) The federal program administered by Employment Development Department, Private Industry Councils, which requires a mandated state match to the federal funds. Welfare-to-Work (WtW) Employment services under CalWORKs, the State TANF program. Lasted Updated 7\/2013 196 ACR Acronym List A1 Adjustment Claim No. 1 A2 Adjustment Claim No. 2 – i.e., funding ratio changed at state level A-87 OMB Circular – Cost Principles for State and Local Governments A-102 OMB Circular – Uniform Administrative Requirement for Grants and Cooperative Agreements with State and Local Governments A-122 Cost Principles for Non-Profit Organizations A-128 OMB Circular Single Audit Act federally mandated financial audit performed annually to States and Counties to verify sound financial practices AAP Adoption Assistance Program AB Assembly Bill ABAWD Able-Bodied Adults Without Dependents ABD Aged, Blind, and Disabled ABD-MN Aged, Blind, and Disabled Medical Needy ACF Administration for Children and Families ACIN All County Information Notice ACL All County Letter AFIRM Automated Fingerprint Image Reporting and Match (LA only) APD Advance Planning Document APS Adult Protective Services AU Assistance Unit AUD Audited BCP Budget Change Proposal C1 Close Out Claim No. 1 C2 Close Out Claim No. 2 CalWORKs California Work Opportunity and Responsibility to Kids CA-CPI California Consumer Price Index CalWIN California Welfare Integrated Network CAP Cost Allocation Plan CAPI Cash Assistance Program for Immigrants CAPIT Child Abuse Prevention, Intervention, and Treatment (Grant) CCAP Countywide Cost Allocation Plan CCDBG Child Care and Development Block Grant CCL Community Care Licensing CDE California Department of Education CDHS California Department of Health Services CDSS California Department of Social Services CEC County Expense Claim CECD County Expense Claim Database CF CalFresh CFAB County Financial Analysis Bureau CFAP California Food Assistance Program Lasted Updated 7\/2013 197 ACR CFET CalFresh Employment and Training CFL County Fiscal Letter CFR Code of Federal Regulations CMIPS Case Management Information and Payrolling System CMS Case Management System CMSP County Medical Services Program CNI California Necessities Index CODB Cost of Doing Business COLA Cost of Living Adjustment CPI Consumer Price Index CSBG County Service Block Grant CSU County Systems Unit CTO Compensating Time Off CWD County Welfare Department CWDA County Welfare Directors’ Association CWS Child Welfare Services CWS\/CMS Child Welfare Services\/Case Management System CY Calendar Year (January through December) CYA California Youth Authority DA District Attorney DADP Department of Alcohol and Drug Program DCA Division of Cost Allocation DGS Department of General Services DHHS (U.S.) Department of Health and Human Services DHS Department of Health Services DMS Department of Mental Health DSD Direct Service Delivery EA Emergency Assistance EBT Electronic Benefit Transfer EDD Employment Development Department ED\/PP Early Detection and Prevention Program EDP Electronic Data Processing EFD\/P Early Fraud Detection\/Prevention EFT Electronic Fund Transfer EPSDT Early Periodic Screening & Diagnostic Treatment ER Emergency Response ERAS Employment Retention and Advancement Services ERDP Employment Readiness Demonstration Project ESC Emergency Shelter Care ESL English as a Second Language EW Eligibility Worker FAADS Financial Analysis And Data Systems FC Foster Care FCCH Family Child Care Homes FDC Family Dare Care FFA Foster Family Agency Lasted Updated 7\/2013 198 ACR FFH Foster Family Home FFM Fleeing Felon Match FFP Federal Financial Participation FFY Federal Fiscal Year (October through September) FMAP Federal Medi-Cal Assistance Percentage FPB Fiscal Policy Bureau FPP Family Preservation Program FS Food Stamp FSET Food Stamp Employment and Training FTE Full Time Equivalent FY Fiscal Year (July June) GA General Assistance GAIN Greater Avenues for Independence GDSA Guide Dog Special Allowance GH Group Home (See FC) GR General Relief HAP Homeless Assistance Payment HHSDC Health and Human Services Data Center HR Health Related IAR Interim Assistance Reimbursement ICR Indirect Cost Rate ICRP Indirect Cost Rate Proposal IEC Incentive Expenditure by Assistance and Non-Assistance Categories IEVS Income and Eligibility Verification System IHSS In-Home Supportive Services ILP Independent Living Program IP Individual Provider IPC Incentive Expenditure by Program Category IRCA Immigration Reform and Control Act ISAWS Interim Statewide Automated Welfare System ISF Internal Service Fund ISM In-kind Support and Maintenance JE Journal Entry KinGAP Kinship Guardianship Assistance Payment LANS Local Area Network System (linked PCs) LEADER Los Angeles Eligibility, Automated Determination, Evaluation, and Reporting System MAO Medi-Cal Assistance Only M&O or M\/O Maintenance and Operations MAGIC Merced Automated Global Information and Control System Medi-Cal California Medical Assistance Program\/Medicaid MEDS Medi-Cal Eligibility Data Systems MNO Medical Needy Only MO Maintenance Of Effort MOE Maintenance Of Effort Lasted Updated 7\/2013 199 ACR MOU Memorandum of Understanding MPI Minor Parent Investigation MPP Manual of Policy and Procedures NACF Non-Assistance CalFresh NAFS Non-Assistance Food Stamp Program NCP Non-Custodial Parent NMOHC Non-Medical Out of Home Care NNR Non-Needy Caretaker Relative NPM Nationwide Prisoner Match NPRM Notice of Proposed Rule Making OC Original Claim OCOP Other County Only Program OHC Out-of-Home Care OJT On-the-Job Training OM Overmatch OMB Office of Management and Budget OS Other Shift PA Public Assistance PACF Public Assistance CalFresh PAFS Public Assistance Food Stamps PC Program Code PCA Program Cost Accounts PCAB Proposed County Administrative Budget PCD Program Code Description PCSP Personal Care Services Program PCU Program Code Update PI Performance Incentives PIN Program Identifier Number PL Public Law PP Permanent Placement PRF Program Request Form PRUCOL Permanently Residing (in the U.S.) Under Color of Law PSSF Promoting Safe and Stable Families QA Quality Assurance QC Quality Control RCA Refugee Cash Assistance RESS Refugee Employment Social Services RFP Request For Proposal RISP Reduced Income Supplemental Program RMR Regional Market Rate RMTS Random Moments Time Study RRP Refugee Resettlement Program SAVE Systematic Alien Verification for Entitlement SAWS Statewide Automated Welfare System SB Senate Bill SCC Supplemental Child Care Lasted Updated 7\/2013 200 ACR SCIAP Specialized Care Incentives and Assistance Program SCO State Controller’s Office SCP Special Circumstances Program SDI State Disability Income SED Seriously Emotionally Disturbed SF Shift SFIS Statewide Fingerprint Imaging System SFY State Fiscal Year (July through June) SGF State General Fund SLIAG State Legalization Impact Assistance Grant SOC Share of Costs SOCAT State Of California Automated Template SPMP Skilled Professional Medical Personnel SRT Sharing Ratio Table SSC Support Staff Code SSI\/SSP Supplemental Security Income\/State Supplementary Payment SSP Separate State Programs SSTRP Support Staff Time Reporting Plan STAP Specialized Training for Adoptive Parents STEP Supportive Transitional Emancipation Program STOP Supportive Therapeutic Options Program SUO State Use Only codes TANF Temporary Assistance for Needy Families T\/C Time Certify TOE Type of Expense TPD Teen Pregnancy Disincentive TS Time Study TSC Time Study Code VACS Ventura Automated Collection System WCDS Welfare Case Data System WFI Welfare Fraud Investigator WIA Workforce Investment Act W&IC Welfare and Institution Code WTW Welfare To Work (TANF, Federal Grant) WtW Welfare to Work (State match grant) Lasted Updated 7\/2013 201 CEC FAQs CEC Frequently Asked Questions (FAQs) Q. How do I run mock claims? A. Budget and miscellaneous mock claims are processed for internal reporting purposes, and therefore are not submitted to the State. The procedures for processing a budget claim are very similar to processing a quarterly claim with the following exceptions: 1. Never run the ledgers for budget or mock claims (this is very important, as doing so will affect county ledgers). 2. Export the files for the mock claim to a separate (and distinctly named) folder created by the user (for example Mock Claim_FY 1112 S1_Budget ). 3. Once the mock claim has been completed and the appropriate files have been exported, run the official version one last time so that the ledger data is not skewed (this must be done). Open the template that will be used for the mock claim and in the Tell Us Who You Are screen replace your County Name with the name of your mock claim (for example FY 11\/12 Budget Claim S2 ). This will help to easily distinguish between your mock claims and actual claims; as the name will print on all CEC Reports printed for the mock claim. Prior to entering into the CEC Template; delete out all time study, expenditure, and case count information (or just the data that will be updated through the mock claim process). For example if a mock claim is being run to demonstrate the impact of time study shifts on current quarter expenditures, it is only necessary to delete the time study data that will be updated during the mock claim. Once the template is blank or the necessary data has been deleted, enter all essential data for the mock claim. Once everything is entered into the CEC Template for the mock claim and the claim is balanced the following must be done: 1. Calculate the claim twice, but do not run the ledgers. 2. Print all necessary reports and export the files to a separate folder. Exporting the files to a separate folder will provide the user with an electronic copy of the mock claim and will allow users to re-import the files at a later date if necessary. 3. Re-import and calculate the official version of the template used in the mock claim process so that the ledger data is not skewed. Lasted Updated 7\/2013 202 CEC FAQs Q. How do the CWS-related Ledgers interact with each other? A. There are four interacting ledgers that are CWS-related in the CEC Ledger System. They are activated in a sequence that will be described below. A brief discussion regarding the role SUO codes play in the process will also be provided. Please note that there are instances when a program code will be shown in more than one ledger for a quarter. In such cases, the program code is being tracked against different funding sources and is not counted twice against federal, state, or county funds. The following material provides information on how the ledgers worked prior to the implementation of Realignment 2011. Ledger 010: CWS IV-B This ledger’s costs are tracked within a federal fiscal year context (October 1st through September 30th). Costs are charged to PC 146 CWS-Services\/Non-federal and are shifted to SUO code 164 and funded 75\/17.5\/7.5 (federal\/state\/county), without regard to your county’s IV-B allocation. Therefore, the federal share of SUO code 164 is controlled against this ledgers’ allocation and any costs exceeding the allocation are shifted from the federal share via SUO code 596 SUO-CWS IV-B Non-Fed which is funded 0\/70\/30. The state shares of SUO codes 164 and 596 are included as tracking items in ledger 008: CWS Basic. Ledger 118: Group Home Monthly Visits (CWD) This ledger’s costs are tracked within a state fiscal year context (July 1st through June 30th) with the state portion tracked against the allocation. Costs are charged to PC 577 Mo. Visits\/Group Homes\/CWD with the non-federal portion shifted to PC 586 NF Mo. Visits\/Group Homes\/CWD on the DFA 327.3 page of the CEC. When the allocation is exceeded, SUO code 045 SUO-Grp Home Mo. Visits (CWD) (funded at 50\/50\/0) shifts the exceeded amount to SUO code 051 SUO-Grp Home Mo. Visits (CWS) which is funded 50\/35\/15 on Ledger 008: CWS Basic. Ledger 008: CWS Basic The CWS Basic Ledger captures the expenditures directly charged to the CWS program as well as the overmatch expenditures from Ledger Lasted Updated 7\/2013 203 CEC FAQs 010 via SUO code 164 and 596 and ledger 118 via SUO code 051. Costs are reported within a state fiscal year context with the state portion being tracked against the allocation. If the CWS Basic allocation is exceeded, shifts occur on SUO codes 808 SUO-CWS Emergency Relief 70-30 (0\/-70\/-30) and 809 SUO-Emergency Relief 100% State (0\/100\/0). The state share of SUO code 809 is included as a tracking item in ledger 148 CWS-Augmentation Title XX. Ledger 148: CWS Augmentation Title XX This allocation is only utilized if the CWS Basic allocation has been exceeded. Overmatch expenditures from ledger 008 (SUO code 808) are shifted to ledger 148 using SUO code 809 and the state portion is being tracked against the allocation. Costs are tracked within a state fiscal year context and once this allocation is exceeded, costs are shifted from ledger 148 (SUO code 120) to ledger 116 using SUO code 122. Ledger 116: CWS Augment Overmatch expenditures from ledger 148 (SUO code 120) are shifted to ledger 116 using SUO code 122. Once the state allocation for ledger 116 has been exceeded, overmatch expenditures are shifted to the county share using SUO code 166 (0\/0\/100). A flowchart that depicts how the CWS ledgers work in conjunction with one another can be found under the section titled Ledger Flowcharts . Q. What role does the DFA 327.4s and 327.5s play in relation to Adjustment Claims? A. There is a common misconception when reviewing an audited adjustment (a.k.a. supplemental ) CEC that expenditure data reflected on the DFA 327.4 and 327.5 Reports represents a completely updated version of the Staff Development and Welfare Program Expenditures for that particular quarter. Unfortunately, this is not the case. The 327.4s and 327.5s on an adjustment claim are strictly limited to scheduling non-ledger expenditures that, along with ledger-produced shifts, are ultimately displayed on the DFA 327.6 and 327.7 (Scheduled Difference) Reports. The best way to determine audited expenditures for any specific quarter is to combine the data reflected on the audited ORIGINAL quarter 327.4 and 327.5 reports with any data reflected on the audited ADJUSTMENT (supplemental) quarter 327.6 and 327.7 reports (assuming that a supplemental claim was processed for your county for the quarter in question). For June (SFY) and September (FFY) quarters, data from the DFA 327.8 Closeout Lasted Updated 7\/2013 204 CEC FAQs Payment Report must also be included. Using any other method could result in erroneous information. Q. Why do some reports not work properly in the audited version of the CEC? A. Several county reports were not designed to run in the audited version of the claim, because the majority of the buttons have been deactivated so that the data cannot be altered. The ability to import the audited data into the prior-to-audit folder, which should allow the user to print all of the County Reports, is an option. For example, assume there are two shortcut icons for March 2002. One should be for the Cec_032002 project (which is prior-to- audit), and one should be for the Aud_Cec_032002 project (which represents audited data). Select the Cec_032002 icon, click Yes on the computer monitor graphic, and select the folder on the C:\\ drive named Aud_Cec_032002. At this point, the audited 3\/02 files have been copied into the prior-to-audit 3\/02 working folder. As such, all buttons that were deactivated in the Aud folder are now running, because the user in now in the Cec folder for the same quarter. Please take special note to NEVER import one quarters’ audited data into a different quarters’ prior-to-audit folder. For example, do not import December 2000 into a March 2001 folder. Other than that one caveat, those counties that have experimented with this option have met with positive results. Q. When setting up a new PC to run the FoxPro template, which folders and files should I copy from the old PC? A. All FoxPro related files from the old PC should be copied to the new PC. These items include all FoxPro shortcut icons residing on the Desktop, and all folders on the C:\\ drive named Cec , Adj , Aud , Ledgers , fox_lib , and Procodes . If you have a folder named fox_lib and you copied it to the new PC, you must locate a file named setup.exe , which should be located in a subdirectory of fox_lib named disk1 . Once located, double-click on the file and follow the prompts. Installation of the Support Library should take no more than 5 minutes. If you inadvertently forget to install the Support Library, the following message will appear on your screen when attempting to run the CEC template: Cannot locate the Microsoft Visual FoxPro Support Library. Lasted Updated 7\/2013 205 CEC FAQs If you do not have the folder named fox_lib , please contact County Systems Unit (CSU) staff and request the FoxPro Support Library. The e-mail messages contain easy-to-follow instructions that will allow you to quickly install the necessary files. Q. How many quarters should I keep on my computer? A. The rule of thumb is to keep one full fiscal year plus one quarter. Therefore, at any one given time, you will have 5 full quarters (the original, audited original, adjustment, and audited adjustment) on your computer. Q. Why does the CEC Reconciliation appear to be completely out of balance on my adjustment (also referred to as revised or supplemental ) claim? A. When running an Adjustment Claim and accessing the View or Print Report buttons, remember to always select the Claim Cert Sched Differences button before selecting the CEC Reconciliation button if the expectation is to see a reconciliation of the differences between the Original and the Adjustment Claims. If you select the CEC Reconciliation button first, your claim may appear to be completely out of balance. Additionally, if you select the button named Claim Certification and then select CEC Reconciliation , each should reflect the updated TOTALS, as opposed to the DIFFERENCES (referred to as scheduled difference ) between your Original Claim and your Adjusted Claim. Q. How can I receive the CEC if my county has a restriction ( firewall ) on receiving attachments with filename extensions of .exe ? A. Until such time that CDSS migrates to a different way of doing business, the optimum solution to the problem of firewalls is for each county to create an Exclusion List (see below for the specific addresses that should be included in the list) allowing self-extracting executable files to be attached to e-mail messages without being deleted or converted to text (such a MIME, for example). Counties who have firewalls and do not create Exclusion Lists risk not receiving the CEC template in a timely manner, which could impact the user’s ability to submit their claim timely to CDSS for reimbursement. The 5 addresses that should be incorporated into an Exclusion List are: [email protected] [email protected] mailto:[email protected] mailto:[email protected] Lasted Updated 7\/2013 206 CEC FAQs [email protected] [email protected] [email protected] An option would be for the county to open an alternate e-mail account (for example, Hotmail or Yahoo ) that does not restrict attachments of any kind. However, if you choose this option, please be aware that opening standard accounts may cause additional problems. Some accounts may have restrictions on individual message size as well as Inbox capacity that could impact your ability to receive all of the messages and attachments needed to run a claim. Please keep in mind that an Original Claim currently consists of five e-mail messages with five self-extracting attachments (each attachment can be up to 1.3 megabytes in size), and an Adjustment Claim consists of four messages with four attachments. Q. What do the Tran_type abbreviations stand for on the ledger pages of the claim? A. Each county’s ledgers may or may not display the following abbreviations: Tran_type Transaction type OC Original Claim A1 Adjustment Claim ( 1 ) signifying the first Adjustment Claim for that county for that quarter) C1 Closeout Claim (Round 1, etc.) SF Shift JE Journal Entry MO Maintenance of Effort OS Other Shift typically this is applied when one ledger’s overmatch is another ledger’s expenditure. For example, SUO code 808 displays SF and is a typical shift whereas SUO code 809 is an OS in Ledger 116 for SUO code 808 from Ledger 008. Q. How does CDSS utilize the County Reports listed in the CEC template? A. CDSS does not utilize any of the County Reports in the audit process. The reports were designed for county use only; they are not referred to or available to state staff, and as such, are not to be considered an official document. mailto:[email protected] mailto:[email protected] mailto:[email protected] Lasted Updated 7\/2013 207 CEC FAQs Q. I have a new e-mail address. Should I notify CSU of this change? A. Absolutely! CSU needs to know the current and correct e-mail address in order for county staff to receive the claim templates and audited claims in a timely manner. Q. How do I update my Ledgers folder? A. When the County Claims Unit (CCU) sends the audited version of a claim to the counties (i.e. Audited June 2002) a History file is typically sent at the same time. This History file, named Hist_XX (where XX is the county number), is the county’s Ledger history from March 1998 to the most current audited claim quarter. The CSU strongly recommends that each county keep the most current History file sent by the claim auditors so that if something happens to the Ledgers, there will be a starting point to update the folder. To update the Ledgers folder information (i.e., the prior-to-audit June 2002 CEC), unzip the latest History file sent by the CCU, which in this case would have accompanied the Audited March 2002 claim. Next, if the county submitted an adjustment claim for the September 2001 quarter, the county would have to run that adjustment claim. After that claim has been processed through Ledgers, the county would run the June 2002 unaudited claim through Ledgers. The Ledgers folder has now been updated with the most current information. Q. I am trying to input costs to a direct cost (6-digit) code and I get a message stating that my county is unable to charge costs to the code. What should I do? A. Anytime FoxPro blocks a county from using selected program codes, time study codes, program identifier numbers, or a support cost code, the county should contact the CCU. The CCU will work with the county to resolve the problem. However, if a certain code was on the template one quarter and is not on the template the next quarter, call the Fiscal Policy Bureau (FPB) for an explanation. The FPB determines the basis for the deletion of program codes. Q. Why do I need to provide you with a copy of my Budget Units every new Fiscal Year? A. Per CFL # 02\/03-68 all counties must submit a copy of their cover letter to CDSS identifying specific county budget units and corresponding total dollar amounts budgeted for the fiscal year. These budget units and amounts are listed on the Supplemental Information Checklist (Exhibit 1303) of the approved plan. This information is used Lasted Updated 7\/2013 208 CEC FAQs during the audit process to insure that the CCAP amounts claimed on the CEC do not exceed your approved plan amounts. Q. Why am I blocked from using a certain code? A. The codes available for use are county specific. If you feel you should be allowed to claim to a specific code, please contact [email protected]. Q. How do I input part-time hours on the DFA 403? A. Please refer to CFL # 03\/04 34. Q. Why am I required to input information on the DFA 419? A. The purpose of the DFA 419 is to provide explanatory data for any significant fluctuations in the various claiming areas between the current and prior quarter claims. The completed form will aid in our audit process and provide support to the Federal Government concerning quarterly fluctuations on the claims. Variances with a 15 percent change for each line item of the DFA 325.1 (either positive or negative) are considered significant and must be reported on the DFA 419. Reference may be made to the Fiscal Management and Control Handbook, 25-820.6. Q. Why won’t my Direct-to-Program EDP costs on the DFA 325.1A spread to my funding pages? A. Direct-to-Program EDP costs will only spread to the funding pages when caseworker time study hours have been entered to the associated code on the DFA 55. Q. What is an Indirect Cost Rate (ICR) and what is it used for? A. CDSS has developed ICRs for use by counties to identify overhead costs associated with support staff who perform activities for non- welfare programs with no equivalent casework hours. CDSS County Allocations Unit develops ICRs based on actual indirect costs (i.e. Travel, Space, Space CCAP, Other Operating Costs, Public Agencies CCAP, and Public\/Private Agencies Direct Billed) that were reported as generic for each county for a given state fiscal year. The totals are divided by the total direct salary and benefit costs (caseworker, administrative\/clerical support and electronic data mailto:[email protected] Lasted Updated 7\/2013 209 CEC FAQs processing [EDP] staff salaries and benefits). The resulting percentages are each county’s individual ICR. CWDs have the option of either using the predetermined ICR developed by CDSS or developing an ICR specific to allocable support staff. An ICR developed by a CWD must be developed in accordance with A Guide for State, Local and Indian Tribal Government-Cost Principles and Procedures for Developing Cost Allocation Plans and Indirect Cost Rates for Agreements with the Federal Government (ASMB C-10). ICRs are applied to the salaries and benefits of support staff performing activities for non-welfare programs only. The salaries and benefits plus overhead are reported as Direct Costs on the CEC using Program Identifier Number (PIN) 805068 (non-welfare Programs) or PIN 806068 (non-welfare Programs-Non EDP). Counties are reminded that non-welfare activities must be reported in the non-welfare function, which will draw down associated overhead through the CEC based on the time study hours of caseworkers performing the non-welfare activity. Q. What are the claiming requirements for PQCR? A. Pursuant to CFL 12\/13-17; any county claiming direct costs to PQCR (PC 088) should take the following steps in allocating and claiming all hours and\/or costs: Prior to inputting the hours and\/or costs into the CEC Template; the total costs should be divided between PC 088 and 828 according to the percentages in the PQCR methodology. The costs should then be entered to appropriate time study code and\/or pin code accordingly. Examples of this methodology can be found within the DFA 55 and DFA 325.1B sections of this manual. County Expense Claim Page, Column, and Line Descriptions Section IV – Revenue Last Updated 12\/2008 211 REV Revenue Revenues are received from the State as either Cash or Advance payments. To determine the revenue type (Cash or Advance) refer to the crosswalk located in the ProCodes section of the FoxPro template. \uf071 Cash Programs: Cash programs and reimbursements are paid after the expenditures have been claimed or audited on the CEC. These programs generally appear on the AA190 form under a heading of Misc. Adjustment and it is possible that they will be in a group that also contains advanced programs. The crosswalk will indicate which programs are advanced and which programs are cash. \uf071 Advance Programs: CDSS advances cash to the counties for administrative and service costs for the larger programs. These advances are based on historical expenditures. The advance expenditures are located on the advance section of the AA190, and are not applicable for the adjusted claim. Last Updated 12\/2008 212 CP CEC Payments ADMINISTRATIVE ADVANCES Costs of administrative programs are shared by the federal, state, and county agencies based on ratios developed from the County Expense Claim. CDSS advances cash to the counties for their administrative and services costs. Each quarter, the advance amount is determined by CDSS using historical expenditures, within the allocation amounts, if appropriate. Every month CDSS advances to each county their estimated federal and state shares of administrative and services costs. At least once each quarter, CDSS adjusts the monthly advance by the difference between a prior period advance and the actual audited costs for that period based on the audited CEC. All administrative advances and adjustments are released on the 15th of each month. The Statement of Cash Advance (AA190 Form), distributed by CDSS, displays all the program categories included in the advance itemized by month, funding source, estimate, and actual costs for the quarter. The release of the AA190 and remittance advice provides advance notification to the counties of upcoming warrants to be issued by CDSS. \uf071 Trust Fund Requirements: The Accounting Standards and Procedures for California Counties , page 19.3 says that the county may deposit advances in a public assistance advance trust fund until such time as the monies are earned as revenue through the expenditure and claiming process. Division 25-220.1 (State of California Manual of Policies and Procedures Fiscal Management and Control) requires that these advances be deposited into a trust account. \uf071 Administrative Program: The name of the program being advanced. The title of the Advance is based on the Single Funding Page Crosswalk Name. \uf071 AA190 Form: The Statement of Cash Advance form identifies the monthly advances and the quarterly costs for each administrative program. It displays the program categories by month, funding source, the estimated advances and the actual costs for the quarter. \uf071 Advances: Each program that meets the criteria receives one advance per month on the 15th of each month. \uf071 Advance Criteria: The state determines which programs meet the advance criteria. The rule of thumb for advances is: Large programs with $8,000,000 expenditures statewide per year or $2,000,000 per quarter statewide are advanced monthly. New programs that start during the fiscal year are not advanced. Last Updated 12\/2008 213 CP \uf071 Currently Advanced Programs: Please refer to the Single Funding Page Crosswalk in the Column heading Adv\/Cash to determine which Programs are advanced. Please note that the reimbursement portion of a program is not advanced. CASH PROGRAM REVENUES Cash program revenues and reimbursements are paid after the County Expense Claim is filed. Cash program revenues are generally related to the smaller programs. They are identified in detail by program and program code in the county use only report, DFA C 434 (County Funding Summary Detail Data by Program Code Cash Claim Funding ONLY). Also included with cash revenues are the DHS funds, even though they are reported on the DFA C 433 (County Funding Summary Detail Data by Program Code Advance Claim Funding ONLY). Health reimbursement funds must be received by CDSS from the designated State agency before CDSS can issue these funds to the counties. It can take anywhere from 60 90 days for CDSS to receive payment from another agency. CDSS will schedule payment to the counties 30 days from the receipt of funds. \uf071 AA190: The Statement of Cash Advance is the document which reports the program and the quarter in which the funds were transferred to the county. The Cash programs are identified in the Misc. Adjustment portion of the AA190. Last Updated 12\/2008 214 Non-CEC Extraneous\/Addendums The following programs are claimed as extraneous or as addendums to the CEC but not paid through the CEC. Programs that are not funded through the CEC are reimbursed through other funding sources. The other funding sources may include but are not limited to Non-CEC claims, invoices, and State Controller invoices as shown in the examples below. Non CEC Claims \uf0a8 EBT Claimed on the EBT Project, County Expenditure Claim . Notice of payment is a Statement of Cash Advance AA190 . \uf0a8 Public Authority Claimed on the SOC 448 Public Authority Invoice . Counties receive only a remittance advice with payment. \uf0a8 SAWS\/CALWIN\/C-IV Claimed on the SAWS\/CALWIN\/C-IV Project Implementation Expenditure Claim . Notice of payment is an ADMINISTRATIVE Statement of Cash Advance AA190 . Invoices \uf0a8 FC IV-E Waiver Assist. Claimed on the CEC, DFA 430 (ends 9\/03). Notice of payment is an ASSISTANCE Statement of Cash Advance AA190 . \uf0a8 Fraud Incentives Claimed on the CEC, DFA 335 and DFA 329. Notice of payment is an ASSISTANCE Statement of Cash Advance AA190 . \uf0a8 Performance Incentives Claimed on the CEC, DFA 335 and DFA 329. Notice of payment is an ASSISTANCE Statement of Cash Advance AA190 . The following table summarizes how programs that are treated as extraneous or as an addendum to the CEC are claimed and paid. Claimed by: Paid by: CEC Other Advance Reimb. Other EBT X X FC IV-E Waiver Assist. X X Performance Incentives X X Fraud Incentives X X Public Authority X X SAWS\/CALWIN\/C-IV X X Last Updated 12\/2008 215 Pass Thru Revenue Pass Thru County welfare agencies or departments often act as a claiming conduit for other County agencies (also referred to as dependent departments). Such is the case between county welfare agencies and probation departments. These dependent departments perform activities that fall within the claiming scope of the CEC. To receive pass thru revenue, their claim is incorporated into the larger welfare agency claim. After the county receives the CEC reimbursement, the county controller, or the welfare agency, transfers the relevant portion to the dependent departments. A Memorandum of Understanding (MOU) between the County Welfare Department and the dependent departments is necessary as the basis for claiming funds (refer to MPP, Division 10, Section 203.2). The MOU must specify the services and placement activities performed by the recipient. The MOU should also specify the procedures the department will use in developing and submitting claims to the County Welfare Department. Care needs to be taken to ensure that the MOU remains consistent with actual practice. A sample MOU, designed for easy modification by individual counties, is provided. The welfare department and dependent departments should establish mutually satisfactory methods for the exchange of any necessary information for each party to perform its duties and functions under this MOU agreement. Information must be submitted to the county welfare department in time to be included in that department’s quarterly County Expense Claim to CDSS. County Welfare Departments must report expenses by category using Program Identification Numbers (PINs) in the County Expense Claim. For that reason, claims submitted to County Welfare Departments must be in a format which allows welfare department staff to report the expenses correctly. The welfare department and dependent departments should establish mutually satisfactory procedures for the readjustment of claims and reimbursements. Last Updated 12\/2008 216 Pass Thru Sample MEMORANDUM OF UNDERSTANDING REGARDING PROBATION TITLE IV-E ADMINISTRATIVE EXPENSE CLAIMS This agreement between the Probation Department of the County of _________, State of California, referred to as the probation department , and the Welfare Department of the County of __________, State of California, referred to as the welfare department , establishes and\/or ratifies existing relationships and procedures between these parties effective the date of execution. Section 472 of the Social Security Act requires an agreement between the California Department of Social Services, as the single state agency responsible for Title IV-E foster care and adoption assistance programs, and County Welfare Departments regarding the provision of Title IV-E services. A similar agreement insuring compliance with the Title IV-E state plan is required between welfare departments and probation departments before probation departments may claim federal reimbursement for provision of Title IV-E services. Therefore, it is agreed as follows: I. RESPONSIBILITIES A. PROBATION DEPARTMENT RESPONSIBILITIES 1. The probation department agrees to develop and implement a case plan for each child who appears to be a candidate for foster care. This case plan will focus on the needs of the child and his\/her family. The case plan will ensure that reasonable efforts are made to eliminate the need to remove the child from his\/her home, or if the child is in foster care, to reduce the period of foster care. 2. The probation department will adhere to policy guidelines contained in DHHS ACYF Policy Announcement 87-05. 3. The probation department will utilize a time study method authorized in the County Welfare Department Cost Allocation Plan as promulgated by the California Department of Social Services (CDSS). 4. The probation department will utilize an indirect cost rate consistent with standard accounting practices. 5. The probation department will utilize the percentage of children eligible for federal participation in foster care Last Updated 12\/2008 217 Pass Thru maintenance supplied by the welfare department in the construction of each quarter’s claim. 6. The probation department will submit a statement of Title IV-E administrative expenses eligible for federal reimbursement to the welfare department no later than the eighth work day following the end of each quarter. The statement will identify expenses by Program Identification Numbers provided by the CDSS. 7. The probation department will maintain records to support all requests for reimbursement for the period required by federal regulations. 8. The probation department agrees to comply with the Civil Rights Act of 1964 as amended, Executive Order 11246 and Regulations issued by the United States Department of Labor contained in 41 Code of Federal Regulations Part 60. In addition, the probation department agrees to comply with the Rehabilitation Act of 1973 and Regulations issued pursuant thereto contained in 45 Code of Federal Regulations Part 84 entitled Nondiscrimination on the basis of handicap for programs and activities receiving or benefiting from federal financial participation . B. WELFARE DEPARTMENT RESPONSIBILITES 1. The welfare department agrees to provide the probation department with the percentage of children who are eligible for federal financial participation in foster care maintenance costs each quarter. 2. The welfare department agrees to accept claims for federal reimbursement of Title IV-E administrative costs from the probation department. 3. The welfare department will remit to the probation department any revenue received as federal reimbursement for Title IV-E administrative cost claims submitted by the probation department. C. MUTUAL RESPONSIBILITIES 1. The probation department and welfare department will establish mutually satisfactory methods for the exchange of any necessary information so that each party may perform its duties and functions under this agreement. They will mutually establish appropriate procedures to insure that all information is safeguarded from improper disclosure in accordance with applicable state and federal laws and regulations. Last Updated 12\/2008 218 Pass Thru 2. The probation department and welfare department will establish mutually satisfactory procedures for the readjustment of claims and reimbursements in the event that expenditures claimed do not qualify for federal funds. II. GENERAL TERMS A. PERIOD OF OPERATION AND TERMINATION This agreement shall take effect immediately upon signing by both parties to the agreement and shall remain in effect until terminated. Each party shall have the right to terminate this agreement upon ninety days prior to written notice to the other party. B. ALTERATION OF TERMS It is mutually agreed that this may be modified or amended upon the written mutual consent of the parties hereto. Executed this __________ day of __________ Signature block for Signature block for Chief Probation Officer County Welfare Director Last Updated 12\/2008 219 Crosswalk Single Funding Page Crosswalk The Crosswalk is a reference guide to funding sources for programs reimbursed through the CEC. It is a cross-reference for the DFA 327.4 and DFA 327.5. It is also used as a reference for the DFA C 430. The Catalog of Federal Domestic Assistance (CFDA) is used as a reference for programs funded by the federal government. The Crosswalk identifies whether a program is paid on a cash advance or a cash payment method. The Crosswalk is quarter specific. When reviewing the crosswalk; be sure to input the appropriate quarter when entering the ProCodes icon. For example, to review the June 07 crosswalk, 06\/30\/2007 must be entered into the date field upon entering the ProCodes icon. \uf0a8 The CFDA is referenced for the Single Audit. FINDING THE CROSSWALK Follow these steps to access the crosswalk: 1) Locate and enter the ProCodes icon 2) Press the Click Here to Start button 3) Enter the quarter ending date 4) Press the Single Funding Crosswalk Reports button 5) Press the Single Funding Crosswalk (All Qtrs) button or the Single Funding Crosswalk (by Appropriate # & Allocation #) button Input quarter here Last Updated 12\/2008 220 Crosswalk There are two reports: Single Funding Crosswalk (all Qtrs.) and Single Funding Crosswalk (by Appropriate # Order & Allocation #’s). Using the Crosswalk The Single Funding Crosswalk (all Qtrs.) lists all program codes from the CEC, grouped by the single funding program name and description in alphabetical order. This makes it easy to find a specific single funding program and all related programs. Reference to the Crosswalk from the DFA 327.4, DFA 327.5 or DFA C 430 can determine if the funding for a particular program is paid with an advance schedule or with a cash claim method of payment. The Single Funding Crosswalk (by Appropriate # Order & Allocation #’s) lists the programs by the Appropriation Item number. The Appropriation Item number is the line item in the Governor’s Budget from which the program is paid. As not all programs are state funded, those programs without an Appropriation Item number are listed first. Programs are listed under their Appropriation Item number by the single funding program name and description in alphabetical order. When the AA 190 – Statement of Cash Advance and AA 215 – Remittance Advice is received it can be matched to the final audited hard copy Crosswalk to determine additional information about that program (i.e. program code, appropriation item, payment method, etc.). Select Single Funding Crosswalk Report Last Updated 12\/2008 221 Crosswalk Single Funding Page Crosswalk The Single Funding Page Crosswalk is available to all users of the County Expense Claim and is also available, by quarter, through the ProCodes icon. The purpose of this report is to display the funding source by which each program code is reimbursed. \uf071 Single Funding Page Program Name\/Descriptions: Displays the State assigned naming convention. The title is used by CDSS when payment is made. \uf071 Program Name: Displays the program code name. \uf071 Prog. Codes from page 4A-4E 5A-5E: These two columns display the program code number and indicates the code on the Staff Development funding pages (4A-4E) and\/or on the Welfare funding pages (5A-5E). \uf071 PCAs (Federal\/State\/Reimbursement Code): Displays Program Cost Accounts that are used by CDSS for payment and tracking purposes. \uf071 Appropriation Item: Displays the line item in the Governor’s Budget from which the program is paid. \uf071 Federal Grt\/Cat: Displays the title of the federal funding source. \uf071 CFDA#: Displays the Catalog of Federal Domestic Assistance Number. This number is used by the County Agency to identify the federal grant number for reports that are submitted to the Federal Government. \uf071 TANF Flg: Displays if the program is State TANF MOE eligible. \uf071 Adv\/Cash: Displays a program code paid in an advance schedule or paid with the cash claim. Last Updated 12\/2008 222 Crosswalk Last Updated 7\/2011 223 Rev FAQs CEC Payment and Audit Frequently Asked Questions (FAQs) Address Changes Q. How can I change the Attention Line on my labels (For either Admin Claims, AA190’s, Remittance Advises, or DFA C430)? A. Send a letter signed by your Director with the updated information to CDSS, Financial Services Bureau, 744 P Street MS 9-5-01, Sacramento, CA; 95814. Advance Q. How is the Quarterly Advance amount determined? A. Each quarter, the advance amount is determined by CDSS using historical expenditures, within the allocation amounts, if appropriate. Every month CDSS advances to each county their estimated federal and state shares of administrative and services costs. At least once each quarter, CDSS adjusts the monthly advance by the difference between a prior period advance and the actual audited costs for that period based on the audited CEC. Q. Why did my Advance amount change? A. Usually, the advance amount is the same for each of the 3 months in a quarter. Changes occur between quarters based on your county’s historical expenditure trend, as well as the statewide expenditure trends. During unusual circumstances, a change can occur during a quarter in a specific month. This is usually attributed to a revised Allocation or lack of funds available when a Budget Revision is being processed. Claim Letter Q. I don’t understand an audit finding in my Audited Claim Letter. A. Since these are County specific, please send your question to [email protected]. Copies Q. Can you please send a copy of the AA190 or RA? A. Please check with your county’s contact person. Every Friday prior to the schedule pay date (Warrant Release Date), the green copy of the RA for the County Auditor, and the pink copy of the RA for the County Welfare Director are sent along with the AA190 to each county’s contact person. Please call your county contact and\/or County Auditor for a copy of either the AA190 or mailto:[email protected] Last Updated 12\/2008 224 Rev FAQs RA. If you are still unable to locate either the AA190 or the RA, please have your county contact send a request to [email protected]. General Fiscal Policy Questions Any general Fiscal Policy questions should be sent to [email protected]. Offsets Q. Why can’t offsets be done against the Original Advance (in the same Program or Schedule)? A. Occasionally, a county is over-advanced, and we must recoup monies from another Schedule or Program in accordance with the Federal Cash Management Act. Q. Why haven’t all my positive offset amounts been paid? A. Usually, this is attributed to the timing of our payments. At any given time, a county will have an outstanding advance amount for the current period, as well as a positive offset amount for the actual audited claim. When these two amounts exceed your allocated amount for the particular program, we are unable to pay the positive offset amount until we receive the current period actual audited claim amounts. Also, during unusual circumstances, this could be attributed to a revised Allocation or lack of funds available when a Budget Revision is being processed. Outstanding Payments Q. Where shall inquiries, requests for research and reconciliations of outstanding payments, or discrepancies in payment be directed to? A. All requests for Research and Reconciliations should be sent via email to [email protected]. Any inquiries should be made within 9 months of the Audited Claim. Provide a detailed spreadsheet using the Single Funding Crosswalk, Final DFA C430 (hard copy), and AA190’s to identify your questions. You should include all research you have already done at the county level and identify the discrepancies that still exist after your research. Payments \/ Reimbursements Q. Why does Reimbursement payment show in the State column of the AA190? A. When CDSS makes payment to the counties for another State Agency, it is treated as a state fund. mailto:[email protected] mailto:[email protected] mailto:[email protected] Last Updated 12\/2008 225 Rev FAQs Q. When will the Reimbursement portion of my claim be paid? A. For items that are reimbursed through DHS, or other state agencies, CDSS must first receive the federal funds from the designated state agency (DHS). CDSS accounting has to invoice the Agency designated to receive the Grant (DHS, EDD, Etc.). It can take up to 60-90 days to receive payment from another agency. CDSS will schedule payment within 30 days from the receipt of the funds. Q. My payment does not match our DFA C430 in the Audited FoxPro template. A. The official DFA C430 is the hard-copy version marked final audit which is mailed to your county. Please ensure you are using the Final Audited (Mailed) version of the DFA C430 to compare to your payment information. If changes are made to the Crosswalk between the time the template is sent to the Counties, and the time payment is made to the Counties, the changes will not be updated in the FoxPro version of the DFA C430. Q. When will I receive my payment for Close-out? A. Close-out is done in multiple Rounds . After all Rounds are completed, the Audited Claim Letter and payment will be made. Q. I haven’t received a payment or offset for a particular quarter. How long should I wait before questioning the payment of these funds? A. Normally, payment should be made within 60 days of receiving the Audited Claim Letter, unless it is a reimbursement item. Reimbursement items may take up to 9 months to pay since the funds are coming from another state agency. Any outstanding payments should be indicated on your AA190. In addition, the AA190 will sometimes include a footnote describing why the payment cannot be made (i.e., over an allocation, or a Budget Revision is in process, etc.). Q. The County Treasurer wants to know the Banking Schedule amount the day before the Warrant Release Date (WRD). A. For counties who participate in the Banking Schedule program, the original white RA is mailed directly to the Treasurer’s office five days prior to the WRD. For Non-Banking Schedules, the original white RA is mailed with the warrant on the date the schedule is released. The green copy of the RA for the County Auditor and the pink copy of the RA for the County Welfare Director are sent along with the AA190 to each county’s contact on the Friday prior to the WRD. Please call your county contact and\/or County Auditor for the payment amount. Q. I don’t recognize the amount or entry on my Deposit slip from the Bank. Last Updated 12\/2008 226 Rev FAQs A. All CEC payments are made on the 15th of the month. Please contact the Bank directly, and work with your County Treasurer to identify the amounts prior to contacting CDSS. Performance Incentives Q. Where is my Performance Incentive Payment? A. Please contact the County Assistance Payment Unit at [email protected]. Reconciliations Q. Why haven’t I received my annual TANF-Probation Reconciliation Report? A. In prior years, CDSS was providing you a payment reconciliation report for the TANF-Probation program. Due to recent staffing reductions, CDSS will no longer provide you such reconciliations. Status Report\/Shift Report from the Audited CEC Q. What does an Allocation with a negative balance mean in my Status Report? A. Either you have exceeded your allocation amount or you have charged costs to an allocation that has not been allotted funds. Warrant Release Date (WRD) Q. What is the warrant release date for CEC payments? A. The warrant release date (WRD) for all CEC payments is the 15th of the month. mailto:[email protected] Last Updated 12\/2012 227 CEC Revenues What are CEC Revenues? CEC Revenues are basically the CDSS approved federal and state share of expenses on the County Expense Claim. The federal and state share of expenses paid to the counties come in two forms of payment: \uf0a8 Advances paid on the 15th of each month. \uf0a8 Reimbursements paid on the 4th or the 5th month following the CEC quarter. Examples of the monthly advances issued by the State for Fiscal Year 03\/04 include the following: \uf0a8 CalWORKs Single (B) \uf0a8 CWS IVE, NON CWS ALLOC, CWS IVB, CWS TANF, ILP, PSSF (NB) \uf0a8 IHSS, CAPIT, APS\/CSBG (NB) \uf0a8 TANF Probation, CYA, PROB IVE GHMV (PT) (NB) \uf0a8 Foster Care, CFET, CFET Enhanced FED, CalFresh (NB) \uf0a8 Adoptions, Licensing (NB) \uf0a8 CalWORKs MH & Sub Abuse, WTW Match (NB) Source CFL No. 03\/04-033 To find current advanced programs, refer to the current quarter crosswalk or most recent remittance advice, DFA C430, and DFA C431. These advances and reimbursements are remitted by the State to the counties by either depositing the funds directly into the designated county bank (B) or by mailing the funds to the county (NB). The following documents accompany advances and reimbursements: \uf0a8 Remittance Advice (Form AA215 D) \uf0a8 Statement of Cash Advance (Form AA190) Last Updated 12\/2012 228 CEC Revenues C A L IF O R N IA D E P A R T M E N T O F S O C IA L S E R V IC E S F E D E R A L S T A T E 7 4 4 P S T R E E T , S A C R A M E N T O , C A L IF O R N IA 9 5 8 1 4 (9 1 6 ) 6 5 7 -3 3 9 0 R E M IT T A N C E A D V IC E M O N T H O F S C H E D U L E N O . O F F IC E C O P Y T o ta l A m o u n t o f W a rr a n t A A 2 1 5 D ( 5 \/0 1 ) T h e e n c lo s e d w a rr a n ts c o v e r a d v a n c e s f o r th e i n d ic a te d p u rp o s e s , a s a u th o ri z e d b y th e W e lf a re a n d I n s ti tu ti o n s C o d e . A c o p y o f th is f o rm h a s b e e n t ra n s m it te d t o t h e C o u n ty A u d it o r a s r e q u ir e d b y 2 6 9 0 3 G o v e rn m e n t C o d e . A D M IN IS T R A T IV E A D V A N C E B A N K IN G S C H N O W A R R A N T E N C L O S E D C A L W O R K S C E C P R G S C a ll- E A R N B O N U S M A R 2 0 1 0 0 2 0 1 2 6 4 0 3 \/1 5 \/2 0 1 Last Updated 12\/2012 229 CEC Revenues Last Updated 12\/2012 230 CEC Revenues Mail Date: 03\/04\/2010 CONTACTS: COUNTY ADMINISTRATIVE PAYMENT UNIT 1) PAYMENT PROBLEMS, AA190, AND CLAIM LETTER INQUIRES ADVANCE MONTH: SHOULD BE ADDRESSED VIA [email protected] COUNTY: FEDERAL REPORTING SECTION Warrant Release Date: 2) FNS209 AND FEDERAL CATALOG INQUIRIES: [email protected] 3) ADMINISTRATIVE PROGRAM 16) CALWORKS CEC PROGRAMS (CFDA #93.558) 100% ADVANCE MAR 10 MO Total Advances 4) ADJUSTMENT FOR PRIOR PERIOD: 5) Actual Expenditures 6) Less: Advance 7) Net Adjustment 8) Net Adjustment Deferred – Recoupment 9) Net Adjustment Deferred – Payment 10) Total Prior Period Adjustment 11) MISC. ADJUSTMENT: CALWORKS CEC PGMS ADJ 03\/09 A1 SB 1569 NONCITIZEN 03\/09 A1 Total Miscellaneous Adjustment TOTAL CALWORKS CEC PROGRAMS 12) SCH 020126H 13) COMMENTS: ADMINISTRATIVE PROGRAM CalLEARN BONUS Total Advances ADJUSTMENT FOR PRIOR PERIOD: Actual Expenditures Less: Advance Net Adjustment Net Adjustment Deferred – Recoupment Net Adjustment Deferred – Payment Total Prior Period Adjustment MISC. ADJUSTMENT: Total Miscellaneous Adjustment TOTAL CalLEARN BONUS SCH 020126H COMMENTS: 14) SHOWN ON REMITTANCE ADVICES AS CALWORKS CEC PRM FED & ST: CALWORKS CEC PROGRAMS 15) TOTAL REMITTANCE 12) SCH 020126H 18) STATEMENT OF CASH ADVANCE – AA190 STATE OF CALIFORNIA HEALTH AND HUMAN SERVICES AGENCY – DEPARTMENT OF SOCIAL SERVICES TOTALSTATE FUNDSFEDERAL FUNDS MAR 2010 Control MAR 15 ,2010 17) 141,878,000.00 0.00 141,878,000.00 0.00 116,831,000.00 0.00 116,831,000.00 25,047,000.00 0.00 25,047,000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 237,269.00 (34,001.00) 203,268.00 0.00 0.00 68.00 68.00 237,269.00 (33,933.00) 203,336.00 117,068,269.00 25,013,067.00 142,081,336.00 FEDERAL FUNDS STATE FUNDS TOTAL 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 117,068,269.00 25,013,067.00 142,081,336.00 0.00 0.00 0.00 117,068,269.00 25,013,067.00 142,081,336.00 19) 20) Last Updated 12\/2012 231 CEC Revenues 1) 2) 3) Administrative Program: The AA190 was created by the County Admin. Payment Unit. 4) 5) Actual Expenditures: After audit expenditures from the County Expense Claim (CEC). 6) 7) 8) 9) 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) Warrant Release Date: Date funds were disbursed to counties. Advance Month: The Administrative Programs are claimed quarterly. All advances for Administrative Programs are paid on the 15th of the month. FNS209 and Federal Catalog Inquiries: This line provides the contact for county inquires on Federal Catalog numbers. Total Remittance: The total remittance amount is the total of all Federal and State funds paid in all programs in this individual schedule. This amount will match the amount on the Remittance Advice that is sent to the County Treasurer when the payment is made. Misc. Adjustment: Miscellaneous adjustments include claim payment adjustments for periods other than the immediately prior period, and additional payments or charges to counties for items such as SFIS, FNS 209, etc. Sch No: This is the payment schedule number used for reference by both CDSS and the State Controller’s Office. CFDA (formerly Fed Cat): The Catalog of Federal Domestic Assistance number associated with federal funds. This number is used by the State and Counties to report federal expenditures on their annual single audit reports, information on CFDA numbers and associated federal programs can be obtained from www.cfda.gov. Payment Problems, AA190, and Claim Inquiries: This line provides the contact for county inquires on the AA190 and the County Expense Claim Letter. The County Expense Claim Letter is provided after CDSS has completed a claim audit and identifies audit findings or changes to the claim. DICTIONARY OF HEADINGS ON THE AA190 FOR CEC PAYMENTS Adjustment for Prior Period: This adjustment is calculated as follows: Actual Audited expenditures as provided by the County on their prior period claim minus the total of all advances provided for that period. Note that Administrative Programs are claimed quarterly, so the adjustment for advances will include all 3 advances provided for the three months that make up the prior period quarter. Less Advance: This is the amount advanced to counties for the expenditures on the line above. The prior period advance is quarterly for the County Admin. Payment Unit. Net Adjustment: This amount is the actual audited expenditures minus the advance for that period. The amount reflects the total adjustment the county is entitled to. Net Adjustment Deferred Recoupment: Recoupment of an Advance amount that is deferred in this schedule and will be recouped at a later date in another schedule (example: need to recoup an advance but the schedule has insufficient expenditures to cover the recoupment). Net Adjustment Deferred Payment: Payment amount to be deferred and paid at a later date in another schedule (example: Payment of expenditures deferred due to a pending budget revision). Total Prior Period Adjustment: This amount is the actual audited expenditures minus the advance and any deferred amounts. This amount is the amount actually paid in this schedule. Comments: The State uses this section to provide important information that counties may need to reconcile their books or general information to help counties identify any changes in the way programs are being paid. \”Shown on Remittance Advices\”: Presents the summary information that appears on the associated remittance advice (copies of the Remittance Advice are sent to the County Welfare Director and Treasurer’s Office to notify them of a forthcoming payment). Federal Funds: Funds identified as federal when disbursed by CDSS to counties. Note that some funds originally coming from the federal government may be treated as State funds by CDSS if they have already passed through another State agency (such as the State departments of Health or Education). State Funds: Funds identified as State when disbursed by CDSS to Counties. Note that this may include funds that are federal in origin, but which are passed through other (such as State Department of Health Services and State Department of Education). Last Updated 4\/2013 232 CEC Revenues What is a Zero Balance AA190? An AA190 with a zero balance is an AA190 in which the overall adjustments equal the advances. The adjustments may be spread out through various programs and AA190’s. They may include an entry on a \”Net Adjustment Deferred – Recoupment\” line in order to achieve a zero balance. The \”Net Adjustment Deferred – Recoupment\” line would be collected on a subsequent AA190. A zero balance AA190 has no revenues associated with it, therefore an AA215 is not issued. Although there are no revenues, it is an important document for balancing your County’s revenues against the State’s system. If an individual county needs further information on a specific zero balance AA190, please contact: [email protected] mailto:[email protected] Last Updated 4\/2013 233 CEC Revenues Last Updated 4\/2013 234 CEC Revenues Last Updated 4\/2013 235 CEC Revenues Last Updated 7\/2013 236 Realign 2011 County Expense Claim Section V Realignment 2011 Last Updated 7\/2013 237 Realign 2011 AB 118 (Realignment 2011) Introduction Effective July 1, 2011, AB 118 realigns the funding for the Adoption Services, Foster Care (FC), Child Welfare Services (CWS), Adult Protective Services (APS), and Child Abuse Prevention, Intervention, & Treatment (CAPIT) programs. This means the funding for these programs has been shifted from the State to the Counties. Specified tax (sales & use tax) revenues will be redirected by the State to the counties on an ongoing basis to cover costs previously funded by the State. Additional information on Realignment 2011 pertaining to FY 11\/12 only is addressed in the following CFL’s: \uf0b7 CFL 11\/12-18 \uf0b7 CFL 11\/12-39 Information on Realignment 2011 pertaining to FY 12\/13 is addressed in CFL 12\/13-16. Prior to July 1, 2011 these programs would have had guaranteed allocations. AB 118 replaced these allocations with subaccount distributions. Subaccount distributions are not guaranteed. They are simply projections. The County Expense Claim (CEC) process will not change. However, effective with the September 2011 quarter claim, all costs will be covered by the county with realignment funding using the State-Use-Only (SUO) overmatch codes. This will be accomplished by setting the affected allocation’s ledger to zero for the realigned program ledgers. For the affected programs, the allocation on the Ledger Tracking System Status Report will be blank where an allocation amount would normally have appeared. The following Ledgers are impacted by this realignment. LED# Program SUO 004 Adoptions 191 008 CWS 166 040 State Family Preservation Program (FPP) 501 052 AB 2129-Foster Parent Training & Recruitment 508 078 Foster Care 612 085 Substance Abuse \/ HIV Infant Program 552 100 Kinship Support Services 328 104 ILP State 100% 810 105 Group Home Monthly Visits Probation 329 112 APS \/ CSBG 656 115 Supportive & Therapeutic Options Program (STOP) 549 118 Group Home Monthly Visits (CWD) 045, 051 121 Specialized Training for Adoptive Parents Program (STAP) 050 134 Emancipated Youth Stipends (EYS) 112 135 Foster Care Emergency Assistance (EA) TANF 199 139 Kinship & Foster Care Emergency Funds 563 141 Child Abuse Prevention, Intervention, & Treatment (CAPIT) 696 Last Updated 7\/2011 238 Realign 2011 144 CWSOIP\/Cohort 1 038 150 CWSOIP\/Probation 705 155 Fed-GAP Administration 815 Previously Ledger 148 (CWS Augment Title XX) controlled the Title XX CWS Augmentation. This ledger will no longer be used. Instead, the Title XX CWS Basic and CWS Augmentation will be combined and Program Codes (PC) 171 (SUO CWS- Title XX) will be utilized to shift funds from county to federal in each of the four quarters. ”

” Using Brain Science to Design new Pathways Out of Poverty Elisabeth D. Babcock, MCRP, PhD A publication of Crittenton Women’s Union Childcare Family Transportation Healthcare Work School Food Rent Relationships Stress Juggling Housing Debt Safety Future Clothing grades Forms Time Money groceries Bills Exams Time Money groceries Bills Exams Our Mission Crittenton Women’s Union transforms the course of low-income women’s lives so that they can attain economic independence and create better futures for themselves and their families. We accomplish this by: Providing safe housing, caring supports, education, and training programs; Innovating new programmatic designs based on research and client experience; Using this knowledge and experience to shape public policy and achieve social change. \u00a92014 by Crittenton Women’s Union All rights reserved. Published 2014 Printed in the United States of America Using Brain Science to Design New Pathways Out of Poverty 1 Table of Contents Executive Summary Introduction Today’s Challenges to Overcoming Poverty Impacts of Social Bias, Poverty, and Trauma on Brain Development and Function Cognitive, Behavioral, and Health Challenges Created by Poverty-Related Stress Applying Brain Science to Social Policy and Program Design Conclusion Appendix A: Specific brain science-informed approaches and case examples Appendix B: How Crittenton Women’s Union applies an executive function lens Bibliography 2 3 4 6 10 12 14 15 25 30 2 Crittenton Women’s Union Executive Summary Moving out of poverty is no longer a short process of following a simple roadmap to a good job. It has become a lengthy, complex navigational challenge requiring individuals to rely on strong executive function (EF) skills (impulse control, working memory, and mental flexibility) in order to effectively manage life’s competing demands and optimize their decisions over many years.1 Experiences of social bias, persistent poverty, and trauma can directly undermine brain development and the EF skills most needed for success. The specific EF challenges in managing thoughts, behavior, and health caused by such adverse experiences are increasingly well understood, and this understanding may be used to improve policy and program design. The areas of the brain affected by adverse experiences of social bias, persistent poverty, and trauma remain plastic well into adulthood and, through proper coaching, may be strengthened and improved. Improvements in executive functioning are likely to positively impact outcomes in all areas of life, including parenting, personal relationships, money management, educational attainment, and career success. Policy makers and program leaders should attempt to use new learning from brain science to strengthen policy and program design targeting those impacted by social bias, persistent poverty, and trauma and to create frameworks and coaching approaches to augment and improve executive functioning. Based on early learning from brain science and its application to programs at Crittenton Women’s Union (CWU), this white paper offers recommendations on ways this science may be used to improve policy and program design and participant outcomes. 1 The terms executive functioning and executive function skills are, respectively, used to describe the mental processes and skills that include impulse control, working memory, and mental flexibility and govern such processes of strategic thinking as problem-solving, goal-setting, and goal attainment. A more detailed explanation of executive functioning may be found on page 8 of this white paper. Using Brain Science to Design New Pathways Out of Poverty 3 Introduction A healthy economy built for long-term sustainability requires that businesses have access to skilled workers, communities have a broad base of contributing taxpayers, and individuals have sufficient income to both support their families and contribute to a robust marketplace. Moreover, children raised in households that are stable economically are far more likely to have better health, higher school achievement levels, and more long-term job prospects. For all of these reasons, it has never been more important to find a way to break the cycle of poverty. Yet our methods for doing so have not changed significantly since the War on Poverty in the 1960s, and disparities in opportunity caused by poverty continue to increase. Finding a way to remove the obstacles that prevent people from escaping poverty today is a much more complicated process than it was in the past. The buying power of the federal minimum wage has been eroded by more than 30 percent since the 1960s. Changes in US public policy have resulted in drastic cuts in public benefits and training programs for the poor. More than 1 in 5 children in the US live in poverty, and the child poverty rate has increased nearly 35 percent since 2000 (Children’s Defense Fund, 2012).2 The shift from an industrial to a knowledge-based economy has meant that virtually all jobs paying a family-sustaining wage require post- secondary education. To get ahead, low-income, single parents often face the formidable task of caring for and supporting their children while obtaining the education and training necessary to qualify for higher-paying jobs. At the same time, the public benefits necessary to supplement their low wages and help them transition to economic independence continue to shrink. In this context, economic independence is defined as being able to achieve a fair standard for housing, health care, nutrition, and child care while avoiding dependence on public 2 These data were taken from the US Census via Children’s Defense Fund: http:\/\/ www.childrensdefense.org\/child-research-data-publications\/data\/child-poverty-in- america-2012.pdf income or work supports such as subsidized housing or nutrition assistance. Recognizing that this is a high standard to achieve for many low-income families, it is nevertheless an important goal to aim towards. In order to attain this standard of living, low-income families must navigate complicated challenges for years because there are no short-term career paths to the family-sustaining jobs of today. However, as much as the conditions for overcoming poverty have changed over the past 50 years, most public policies and programs are still designed to help poor adults become employed as quickly as possible in jobs assumed to pay enough to support a family along with minimal public benefits. This straightforward road map to employment worked effectively when well-paid, unskilled jobs were abundant and public benefits, such as affordable housing and child care, were better funded. To attain the higher-skilled, well-paying jobs of today’s knowledge-based economy, adults need enhanced strategic-thinking skills to guide them through the innumerable decisions and trade-offs required in the complicated journey to economic independence. The benefits of supporting low-income adults in acquiring these skills accrue to the US economy as a whole. Half of US employers report that they cannot find adequate numbers of qualified applicants for current job openings, and the US is losing global competitiveness as other industrialized nations invest heavily in educating workers and connecting them to knowledge-based jobs. The resultant earnings and skills gap creates a drag on the US economy that affects the stability of both government and the private sector, and will be increasingly difficult to remediate over time (Manpower Group, 2012) (OECD, 2013). Transformational policies and programs are required to meet these challenges, and brain science offers a promising, practicable foundation for future direction. New brain science research shows that the most crucial decision-making skills adults draw upon to manage the complex challenges of moving ahead are often compromised by situational and chronic experiences of social bias, persistent poverty, and trauma.3 Awareness of the consequences of such experiences on learning, strategic thinking, and behavior has the potential to inform program and policy design in ways that can create significant new opportunities for low-income families. This white paper explores the impact of factors such as social bias, persistent poverty, and trauma on human experience and development. It suggests how such knowledge can be translated into design principles that, when applied to social policies and programs, can improve participant outcomes. Finally, it offers a case example of one such program model, Mobility Mentoring\u00ae at Crittenton Women’s Union, which has incorporated the recommended design principles and, although nascent, is yielding highly promising family stability and economic mobility outcomes. 3 The term brain science is used in this white paper to describe the array of scientific research on brain structures and functions emerging from such varied fields as the biological, behavioral, and social sciences. 4 Crittenton Women’s Union Today’s challenges to overcoming poverty When President Lyndon Johnson launched the War on Poverty in 1964, the majority of families were two-parent households supported by the earnings of one working adult. The era’s landmark anti-poverty initiatives were designed to provide a road map with quick connections to jobs. In the industrially-based economy of the 1960s, this worked reasonably well. Unskilled manufacturing jobs were plentiful and paid an adult worker a family-sustaining wage. In instances when earnings were not enough to make ends meet, publicly funded housing, child care, and food subsidy programs filled many of the gaps. Today’s anti-poverty programs have changed little since that time. What has changed is the amount of public funding available for these programs and how complex and increasingly sinkhole-riven the pathway to economic independence has become for low- income families. Between 1965 and today, single-parent births have increased from 7 percent to 41 percent of all births and account for 53 percent of births to women under age 30 (Hymowitz, 2012). In today’s knowledge-based economy, jobs that pay enough to support a family require post-secondary education, while education costs have vastly outstripped increases in earnings. At the same time, unemployment for those without such training is three to four times higher than for skilled workers (Youngblood, Dowd, Morgera, Melnik and Liberman, 2013). The federal minimum wage of $7.25 an hour has lost more than 30 percent in buying power since 1968 and no longer represents a stable floor for family income.4 In addition, increased competition for unskilled jobs has depressed average wages at the bottom of the earnings scale and the recovery from the recent recession has not reversed these dynamics. Today, the gross wages of a full-time, low-wage worker will not cover the average rent for a two-bedroom apartment in many of our nation’s lowest-cost urban neighborhoods. Economists at The Brookings Institution and Pew Charitable Trusts refer to poverty in the US as sticky, meaning nearly half of children born in the bottom fifth of the income distribution will remain there for their lifetimes (Isaacs, Sawhill and Haskins, 2007). Yet policy makers and program leaders continue to rely on the same roadmap to help families move out of poverty: short-term, one- size-fits-all job training and referral programs designed to be direct pipelines to jobs. While these programs may provide employment, most often the jobs are low-paying and do not offer a path to a secure career and, ultimately, economic independence. To attain economic independence, low-income families today must navigate a complex environment requiring strong strategic- thinking skills to set a career destination and optimize their lives in the five key areas Crittenton Women’s Union has identified as pillars of its Bridge to Self-Sufficiency\u00ae (Bridge) theory of change: family stability (principally housing and child stability); well- being (principally health\/behavioral health and social supports); education; financial management; and career management. Research by CWU and others has shown that families experiencing significant deficits in any of the pillars of the Bridge are unlikely to be able to reach and maintain their economic independence. Not only is each pillar individually critical to supporting the Bridge as a whole, but the five pillars are also mutually connected and reinforcing. Deficits in one pillar cause weaknesses in others. When one pillar falls, the others often do as well (Babcock, 2012) (Banerjee and Mullainathan, 2008) (Briggs, 2003) (Curtis, Corman, and Noonan and Reichman, 2010) (Isaacs, Sawhill and Haskins, 2007) (Settersten and Ray, 2010) (ICPH, July 2013) (Thompson, 2012) (Palomar-Lever and Victorio-Estrada, 2012). CRITTEnTOn WOMEn’S UnIOn’S THEORy OF CHAngE BRIDgE TO SElF-SUFFICIEnCy\u00ae STARTING POINT MOBILITY MENTORING\u2122 SELF-SUFFICIENCY She is spending less than 30% of her after-tax income on housing. Her children’s needs are being met and do not prevent her from pursuing schooling or work. She is fully engaged in her work and her family, and no health or behavioral issues prevent her from pursuing schooling or employment. She is a part of a strong social network, serving as an advocate, organizer, and support to others. She has achieved a level of post-secondary education and\/or training that has prepared her for a job paying enough to support her family. She has savings equal to three months’ worth of living expenses. She has good credit and is managing her debts in balance with her income. Her earnings from her job are greater than the real costs of basic living expenses for her family, as determined by CWU’s Massachusetts Economic Independence Index. FAMILY STABILITY WELL-BEING EDUCATION ANDTRAINING FINANCIAL MANAGEMENT EMPLOYMENT AND CAREER MANAGEMENT Crittenton Women’s Union Bridge to Self-Sufficiency\u2122 Starting Point Mobility Mentoring\u00ae Self-Sufficiency\u00ae 4 In 1968, the minimum wage was $1.60\/hour and, indexed by the federal Bureau of Labor Statistics Consumer Price Index, would be the equivalent of $10.56\/hour today. Because the minimum wage is not indexed, the difference between the price-indexed level of $10.56 and the actual level of $7.25 represents an erosion of more than 31 percent in the minimum wage. Using Brain Science to Design New Pathways Out of Poverty 5 DIFFICUlTIES OF gOAl ATTAInMEnT Key to moving ahead on the Bridge is setting goals in each pillar that simultaneously support and strengthen an individual’s progress in all the pillars. If clients attempt to concentrate on one pillar alone, weaknesses in the others can cause the entire Bridge to collapse. This carefully calibrated goal-setting is a formidable task. The process of achieving individual goals, in and of itself, is a difficult one. To date, research in the fields of psychology, neuroscience, and behavioral economics has made relatively limited impact on success rates in such diverse and important goal-setting areas as health behaviors, money management, and educational attainment. Although most adults know the health risks associated with obesity, for example, and many set goals to improve in this area, very few achieve and maintain their goals. Just 20 percent of US residents expressing a desire to lose weight have successfully done so and kept it off (Dawson, Grant, Stinson, Chou and Huang, November 2006) (Hill and Wing, Summer 2003). Further, personal savings rates in the US have declined substantially over the past two decades and are currently at 4.4 percent of disposable income, even though 82 percent of people are less than fully confident they are adequately saving (US Department of Commerce, Bureau of Economic Analysis, 2013) (American Family Financial Statistics, 2012).5 Finally, in a national study of college completion only 26.4 percent of first-time matriculants in two-year community colleges attain a certificate or degree of any kind within five cumulative years of persistence (US Department of Education, November 2011). Although individuals may have powerful reasons for setting goals, consistently achieving them is not easy and even more challenging for the poor. With limited access to time and money, the poor are unlikely to have the resources to try again should they fail. What may be a simple lapse to a well-resourced individual with the reserves to start over can be an irremediable mistake for a person without assets. As a result, the poor achieve lower rates of goal attainment than the general population (Mullainathan, 2012). 5 Disposable personal income is defined as total personal income minus personal current taxes. POvERTy-RElATED SITUATIOnAl STRESS AnD DECISIOn MAkIng Emerging science indicates the inherent stress of living in poverty has the capacity to negatively impact the decision- making processes involved in problem-solving, goal-setting, and goal attainment. The prefrontal cortex of the brain the area of the brain that is associated with many of the analytic processes necessary to solve problems, set goals, and optimally execute chosen strategies works in tandem with the limbic system, which processes and triggers emotional reactions to environmental stimuli. This partnership works in an individual’s favor when the limbic brain registers a strong desire and signals this to the prefrontal cortex. The activated prefrontal cortex applies itself to attaining the goal or solving the problem. However, when the limbic brain is overactive and sending out too many powerful signals of desire, stress, or fear, the prefrontal brain can get swamped and the wave of emotion can drown out clear focus and judgment (Casey et al., 2011). Cornell University neuroscientist BJ Casey describes the process this way: Thus, sensitivity to environmental cues influences an individual’s ability to suppress thoughts and actions such that the control systems may be hijacked by a primitive limbic system rendering control systems unable to appropriately modulate behavior (Casey, Somerville and et al., 2011). In addition to situational stress triggering emotional reactions that can hijack decision making, the constant struggle to make ends meet, deal with the pressures of social bias, and protect against trauma also places extraordinary demands on cognitive bandwidth. Consequently, available brain capacity for impulse control, memory, and judgment is taxed to the limit. This so- called bandwidth tax imposed by ever-present preoccupation, fear, and worry causes significant compromises in the overall quality of decision making by the poor for whom every decision is that much more critical (Vohs, 2013 ) (Mani, Mullainathan, Shafir and Zhao, 2013). Behavioral economist Sendhil Mullainathan and his co-author, psychologist Eldar Shafir, have shown in their research that such situational stresses can lower average IQ levels by almost one standard deviation. Mullainathan and Shafir compare the impact of this change to the way individuals function when they have been deprived of an entire night’s sleep (Mullainathan and Shafir, 2013). Therefore, between the inherent situational stress of poverty and its ability to compromise decision making and the intolerance for error in decision making created by the impoverished person’s lack of reserves for multiple attempts at goal attainment, it is not surprising that income is directly correlated with the ability to achieve goals. 6 Crittenton Women’s Union High school dropout rates are four and one half times higher among low-income students than high-income students (National Center for Education Statistics, 2010). Low-income eighth-grade students with high academic proficiency in math are 60 percent less likely to complete a bachelor’s degree than their high-income counterparts (29 percent vs. 74 percent bachelor’s attainment) (Roy, October 12, 2005). The SAT score gap between the poorest 10 percent of test-takers and the wealthiest 10 percent is 125 points (out of an 800-point scale). This gap has grown by 42 percent since the 1980s and is almost double the current score gap between African-American and Caucasian test-takers (Reardon, 2013). As these data indicate, poverty has a unique effect on learning and educational goal attainment. Importantly, research has also shown education to be the single most important leveraging tool for improving economic opportunity (Isaacs, Sawhill and Haskins, 2007). Navigating the pathway to economically stable adulthood has become a significant challenge for even the nation’s most successful young adults. Forty-five percent of college graduates ages 18 to 24 live with their parents and 21 percent of those ages 18 to 34 remain at home. Overall, independent household formation by adults age 35 or younger has decreased by 42 percent over the past decade. Today, only 33 out of 100 young adults live in their own households (Weissmann, February 26, 2013) (Fry, 2013). But the challenges faced by adults who have been raised in poverty are even greater. In its most recent study, Pathways to the Middle Class, The Brookings Institution reports that the likelihood of an individual making it to the middle class (defined as 300 percent of the federal poverty level) by age 40 is determined largely by circumstances of birth. If a child is born with low birth weight or has a mother who is poor, unmarried, or a high school dropout, the child has less than a one-in-four chance of making it to the middle class (Sawhill, Winship and Grannis, 2012). Researchers have found that disadvantages at birth seem to generate the first in a cascade of subsequent negative outcomes, including lack of early school readiness; poor school performance and social and emotional development in middle childhood; lower grades, higher crime convictions, and pregnancy in teen years; and lower college completion, earnings, and independent household formation in young adulthood, which cumulatively severely impaired the ability to attain economic independence in adulthood (Sawhill, Winship and Grannis, 2012). Societal obstacles to family stability and economic mobility have outstripped the capacities of the policy and program interventions designed to deal with them. The US now faces the problem of a growing population of impoverished families, with their earnings and public supports eroding daily, their path to economic independence increasingly complicated, and their inner capacities to navigate that path progressively compromised by the stresses created by these dynamics. Impacts of social bias, poverty, and trauma on brain development and function As policy makers and program leaders have searched for clues for developing interventions that would address the increasing inequities in opportunity, new discoveries about brain development and the manner in which that development is impacted by environmental conditions have begun to yield helpful insights. Recent research shows that brain development is not just a result of genetic inheritance, but is also strongly affected by environmental risk factors, including exposure to toxins, poor nutrition, prenatal drug use, low social status, stress, and violence, all of which are more prevalent in low-income households (Hackman, Farah and Meaney, 2010) (Sapolsky, 2005). This research shows that such exposure has a direct impact on the development of the prefrontal cortex and limbic system, which potentiate many of the key problem-solving, decision-making, goal- setting, and goal-attainment skills critically important to achieving social and economic stability. Sometimes referred to as cognitive skills, they largely describe the processes by which individuals consciously reflect upon, rather than merely instinctively react to, circumstances and, after reflecting, make reasoned decisions on how to proceed based on prior learning, current conditions, and future objectives. EFFECTS On PERSOnAl AgEnCy AnD gOAl ATTAInMEnT For individuals to routinely and powerfully reflect upon and decide what they want to do, they must first develop a sense of agency \u2014 an understanding of themselves as individual actors capable of making their own judgments and decisions and of successfully acting upon and shaping their environment. Alternatively referred to as sense of self, voice, locus of control, or personal power, it is the necessary precursor of self- determination that spurs individuals to decide to take action. The more forceful and fully developed the sense of agency, the more readily and automatically people pause, reflect, and decide, Using Brain Science to Design New Pathways Out of Poverty 7 rather than react impulsively. The more frequently their decisions prove to be correct and valuable to them, the more this reinforces their sense of agency, then the readier they are to trust themselves and their judgment in the future, and the more powerful they feel (de Vignemont and Fourneret, 2004) (Hofstadter, 2007). The development of agency is highly influenced by environment. Multiple studies have shown that independent of an individual’s financial resources, the place he or she occupies in the social hierarchy and the level of control associated with that place correlate directly with stress and health outcomes. In the Whitehall Studies of British civil servants whose jobs were categorized by hierarchical order, life expectancy was so closely related to an individual’s civil-service rank that employees in the second rank from the top died at younger ages than those in the top rank. This difference persisted all the way through the rankings to the bottom. In one age group (ages 40-64), the death rates for those at the lower status rankings were almost three times higher than for those at the top. Interestingly, all study participants had the same access to health care. Still, the differences in mortality extended to most major causes of death (Marmot, 2006). After subsequent research, Sir Michael Marmot, chair of the World Health Organization Commission on the Social Determinants of Health and principal researcher on the Whitehall Studies, concluded that the place an individual occupies in the social order and the associated lack of, or freedom to exercise control correlated directly with the level of disease-producing stress an individual experienced in life. The less control an individual had, the higher the rates of stress, mental illness, disease, and mortality: This richer understanding of poverty allows us then to approach the social gradient in health, and poverty and health, with the same framework. Social conditions will determine the degree of limitation on freedom or autonomy. The greater the limitation, the worse the health (Marmot, 2006) .6 In addition to the pressures of low social status, low-income families experience greater instability in obtaining the basic resources for survival. They move and change jobs more frequently and experience more episodes of hunger, food insecurity, homelessness, and unemployment than their wealthier counterparts. These experiences, in combination with low social 6 The research on correlations between social rank and health outcomes is extensive. Findings clearly show that the relative lack of personal control over life circumstances, the struggle for resources, and increased experience of violent or oppressive social behaviors trigger measurable elevation of stress hormones such as cortisol which are correlated with increased morbidity and mortality (Sapolsky, 2005). Also of great interest is new research by behavioral psychologists suggesting that humans appear to be wired to associate social dominance with particular body postures (so-called power poses ) which if assumed, even for brief periods of time, seem to trick the body’s neuroendocrine system into responding as if the person occupies a high order of social rank. This, in turn, has been shown in randomized controlled trials to lower levels of cortisol, decrease stress, increase personal sense of self-worth, and improve participant outcomes in social evaluation tests, such as job interviews, to statistically significant levels (Carney, Cuddy and Yap, 2010) (Cuddy, Wilmuth and Carney, 2012). status, often cause families to feel they have little control of their lives. They spend much of their time reacting to crises and can feel there is little value in trying to think ahead since their plans never work out. Individuals who feel they are being controlled by external events, rather than by their own internal decisions, are said to have an external locus of control, which has been shown to be passed on to the children in their care (Freed and Tompson, 2011). Children feel the stress and volatility their caregivers experience and this is reinforced by the ways in which low-income caregivers interact with their children. Overall, low-income caregivers converse far less with children than do higher-income caregivers. A widely quoted piece of research conducted in the early 1990s suggested that by the age of four, children of caregivers receiving welfare heard 32 million fewer words than children raised in what the researchers termed professional families (Hart and Risley, 1995). Subsequent research found that not only was the quantity of conversation less in low-income homes, but the nature of the conversation was different as well. Lower-income caregivers asked fewer questions (particularly guiding questions) and were more negative and directive than higher-income caregivers. Higher-income caregivers initiated with children more conversations of a type that foster what childhood development specialists refer to as serve and return (National Scientific Council on the Developing Child, 2007). In other words, wealthier caregivers asked more leading questions that call for a child’s thoughtful response: Isn’t this pretty? What do you think about that? Is that really the best way to do that? Can you think of a better way? They thereby initiate conversations that go back and forth, creating richer dialogue and more stimulation for thinking than the less wordy, more directive language of their lower-income counterparts such as Go get that for me. Sit there until I call you. (Hart and Risley, 1995) (Perkins, Finegood and Swain, 2013) (Rosenberg, 2013). Researchers have offered a wide range of reasons for these differing child-rearing patterns. One of the simplest and most straightforward comes from behavioral economists such as Sendhil Mullainathan who suggests that the stresses of poverty simply do not leave parents the time or what he calls the freedom of mind to richly engage with their children. Making ends meet and solving constant crises leave low-income families little bandwidth beyond securing the basics for survival (Mullainathan, 2012) (Banerjee and Mullainathan, 2008) (Mullainathan and Shafir, 2013). As a result of social bias and more directive child-rearing, low- income children are less likely to have been coached to develop a powerful sense of agency or high locus of control. They are less likely to have practice in identifying goals and the strategies to reach them, or in reflecting on their motivations and wants and how to obtain them. And, without the benefit of serve and return conversations, they are less likely to have cultivated practiced insights into the wants and motivations of those around them. 8 Crittenton Women’s Union EFFECTS OF CHROnIC STRESS On ExECUTIvE FUnCTIOn SkIllS The highly stressful and volatile nature of growing up in poverty reinforces these developmental differences in powerful ways. The toll taken by social bias, stress of persistent poverty, exposure to trauma, and violence (all of which are more prevalent in lower- income environments) has impacts far beyond diminution of personal agency, self-awareness, or understanding of others. It causes physiological changes in brain development that deeply affect the ways people react to the world around them. Stress and fear cause the limbic brain to trigger the release of dozens of hormones, such as adrenalin and the glucocorticoids (particularly cortisol), developed to help the mind and body prepare for self-protection. These hormones, in conjunction with activation of the inflammatory response, create the potent effects referred to as the fight or flight or acute stress response. These effects include rapid acceleration of the heart rate, increased blood flow to the limbs, activation of the immune response, increased blood sugar, and the override of many of the reflective, analytic mental processes that might slow the body’s rapid response to danger. This latter component of the chain reaction is referred to in academic literature as swamping or hijacking. Although these bodily reactions evolved to be protective, persistent hyperactivation of the stress response can, over time, create significant negative effects, such as increased rates of disease (e.g., heart disease, hypertension, diabetes), due to overexposure to stress-related hormones and persistently elevated blood sugar and inflammatory chemicals (National Scientific Council on the Developing Child, 2005). Chronic activation of the stress response can also create hypersensitivity to danger that often manifests itself in behaviors in which individuals’ responses appear exaggerated or unwarranted by the circumstances around them. This can include behaviors commonly described as having a hair-trigger temper, reacting first and thinking later, and looking for trouble around every corner. These are all plausible responses when individuals have a history of acute stress or trauma and therefore have learned to keenly anticipate danger and protect themselves. The hyperactivation of the limbic system also affects other mental processes beyond the stress response because, as previously mentioned, the limbic brain works in tandem with the prefrontal cortex to control memory, motivations, and beliefs, which in turn influence how an individual solves problems, sets priorities, and invests attention and resources. Growing up in socially stigmatized, impoverished, and\/or violent environments, children experience life as not only full of stress and danger, but also highly unpredictable and lacking in resources and options for improvement. These factors inhibit the prefrontal cortex from optimally developing key decision-making skills known as executive function (EF) skills. The primary EF skills are: 1. Impulse control (or inhibitory control): the skills used to filter distractions, override impulses, resist temptation, maintain focus, pause and reflect before taking action, and maintain persistence in the face of worry or despair; 2. Working memory: the ability to mentally hold and manipulate information over short periods of time, simultaneously think of multiple things, temporarily focus on something while retaining something else in the back of the mind, retain information from one place and connect it to information from another, follow multi-step instructions, and temporarily stop doing something and return to it later without confusion or loss of continuity; 3. Mental flexibility (or cognitive flexibility, mental shifting, set shifting): the ability to readily switch gears, multitask, adjust plans, re-establish priorities, apply different rules or social skills in different settings, translate between languages, alter strategies based on feedback, and innovate (Center on the Developing Child at Harvard University, 2011) (Carlock, 2011). These skills are developed relative to an individual’s opportunity and support for practicing them. If the opportunities to practice EF skills are robust, the brain physically develops increasingly rich networks of neural connections in the areas of the prefrontal cortex that support these functions. If children are raised in environments that are mentally stimulating with rich caregiver serve and return conversation, if they are allowed to puzzle and explore, if they are encouraged to think about what they would like to do and have many options for achieving their goals, if they experience positive gains from not heeding an impulse but instead holding off for something more important later, they will start from the very earliest age to build neural networks that will grow increasingly powerful, making all the EF mental processes easier, more efficient, and more effective over time. But, if children find the world full of tension and danger and their bodies are often flooded with stress hormones that swamp their prefrontal cortex and hijack their attention, if their environment is highly unpredictable with the relationships between cause and effect constantly disrupted, if the schedules and rules they live by are always changing, if they have few resources or choices, if they experience limited opportunities for serve and return conversation, then the neural connections for executive functioning will not be as well developed. Using Brain Science to Design New Pathways Out of Poverty 9 The differences in the brain architecture of children born into homes at opposite ends of the economic spectrum widen over time because neural networks are like systems of roads that get built based on patterns of use. In the early years of life, billions of neurons located throughout the brain branch out in every direction. As the child practices thinking in patterns that use the nerve paths in a particular direction, new links in the pathways are built, get reinforced, and become richly connected to each other in the direction of use. The more the same paths and connections are used, the more direct and expeditious the routes between those connections become, evolving from slow and meandering paths into straighter and faster roads. Finally, the most active pathways become heavy-duty superhighways that allow for efficiency. As these active pathways are being built, unused pathways are being pared down so that the mind chases down fewer dead ends in performing its functions. This proliferation and pruning process creates a personalized brain architecture robustly built in the areas of an individual’s highest usage. Children who do not have opportunities in early life to build strong neural foundations fall behind their counterparts unless intensive efforts are made along the way to help them catch up. Otherwise, childhood disadvantages become magnified over time. However, although some areas of the brain have age-related windows of opportunity, called critical periods, during which new neural networks can be built, but after which development becomes more difficult if not impossible, the prefrontal cortex remains responsive to stimulation well into adulthood. Its plasticity enables it to continue, even in adulthood, to grow and strengthen new neural pathways that can support EF skills. 7 8 In fact, recent evidence from coaching interventions for elders shows statistically significant gains in executive functioning and processing speed with as little as one month of playing brain- training games for fifteen minutes per day (Nouchi, Taki, Takeuchi, Akitsuki et al., 2012) (Smith, Housen, Yaffe, Ruff et al., 2009). Randomized controlled trials examining the effects of similar amounts of brain training interventions on young adults with average age of 21 also showed statistically significant improvement in executive functioning, working memory, and processing speed (Nouchi, Taki, Takeuchi, Nozawa et al., 2013). 7 Examples of brain functions that appear to have critical periods or windows of development include those areas of the brain responsible for hearing, vision, and acquisition of language. 8 Although the brain remains plastic and can develop EF skills at any age, there appear to be two periods of particularly rich bursts in neural growth associated with EF skills: birth to age 5 and adolescence. In another investigation, young adults enrolled in a Kaplan Law School Admission Test (LSAT) test-preparation program were IQ- matched with a similar control group of students planning to take the test in the future. Those in the preparation course received 100 hours of training hypothesized to create improvements in executive functioning. The training consisted of 35 hours of logic games, 35 hours of logical reasoning, and 30 hours of class-based reading comprehension. Results of training showed improvements in LSAT scores equating with a shift from the 44th percentile at inception to the 73rd percentile at completion, as well as statistically significant improvements in logic and reasoning tests. MRIs9 taken of the study participants showed demonstrable physical growth in brain connectivity in the group that had taken the preparation course and no similar increase in connectivity in the control group. The areas of the brain exhibiting growth were those most associated with the problem-solving and reasoning skills for which participants were being coached (Mackey, Miller, Singley and Bunge, 2013) (Mackey, Whitaker and Bunge, 2012). Studies such as these and many others have caused increasing numbers of scientists to reassess previous thinking about intelligence and IQ as being inherited or static and rather to suggest that: Instead of interpreting a person’s reasoning test performance at any one moment in time as reflecting that person’s hardwired cognitive potential, these results suggest that it’s more sensible to interpret that score as reflecting the individual’s cognitive history his or her prior levels of engagement of specific neural networks (Kaufman, 2013). 9 MRI or Magnetic Resonance Imaging is a radiological imaging technique that allows for detailed three-dimensional visualization of internal body structures including soft tissues. This visualization process enables observation of brain changes in response to sensory stimuli or to requests for the brain to process tasks or questions. 10 Crittenton Women’s Union Cognitive, behavioral, and health challenges associated with poverty-related stress As has been discussed, the process of moving out of poverty is complicated, demanding patience, determination, and resilience. Beyond that, it requires personal initiative and agency, a good understanding of ourselves and others, memory, focus, problem-solving and decision-making skills, and the abilities to multitask and juggle competing priorities. The degree to which individuals possess these traits and skills depends on many variables, including but not limited to: genetic makeup, the health of their environment, the way they were raised, social rank, history of economic deprivation, and the amount of trauma, danger, and fear they have experienced. No individual will have exactly the same mixture of genes and experiences as another. Therefore, it cannot be predicted that an individual who has experienced social bias, persistent poverty, or trauma will exhibit specific characteristics or suffer from certain deficits. However, significant exposure to social bias, poverty, and trauma impacts the human stress response and executive functioning in ways that greatly increase the likelihood that an individual will experience some or all of the following life challenges listed in Table 1. Table 1 Cognitive, behavioral, and health challenges associated with chronic exposure to social bias, persistent poverty, or trauma, including difficulties with any or all of the following: Managing Thoughts, Organization, and Learning Verbal fluency, including auditory learning and following verbal directions Maintaining focus and attention; increased distractibility Optimizing behavior or decision making in highly stimulating environments Memory retention, including general retention of information and following multi-step instructions Organizational skills, including keeping track of belongings or tasks Following plans or goals through to completion Thinking of logical alternatives to a particular course of action; surfacing choices and\/or options Juggling competing priorities and multitasking Time management; organizing tasks to meet deadlines Weighing future implications of current decisions Building mastery through repeated practice or long-term investment in skill-building Taking tools or information learned in one setting and applying them in another Spatial awareness and spatial memory; navigating to new locations using maps or written directions; reading tables or diagrams Managing life changes and changes in rules or expectations Managing Behavior, Emotions, and Feelings Developing and maintaining self-confidence, self-esteem, or agency Controlling impulsive behaviors and regulating risk-taking Delaying gratification Controlling responses to perceived threats or anger Calming down after dealing with stressful events or perceived threats Maintaining a course of action in the face of new stimuli; persisting in the face of worry or despair Understanding the behavior and motivations of self and\/or others (EQ-emotional quotient or social competence) Effectively working in partnerships, teams, or groups Building, navigating, and using social networks Internalizing recommendations; accepting and using feedback or advice Maintaining equanimity when dealing with authority Managing Health and Well-being Higher rates of major illnesses, such as heart disease, high blood pressure, atherosclerosis, diabetes, cancer, and obesity Higher rates of anxiety, depression, addiction disorders, and other mental illnesses Compromised immunity to diseases and elevated rates of autoimmune diseases Higher rates of diagnosed disabilities Slower rates of post-illness recovery Using Brain Science to Design New Pathways Out of Poverty 11 (Sapolsky, 2005) (Hackman, Farah and Meaney, 2010 (11)) (Carlock, EF in Adult Education Programs, 2011) (Carlock, Executive Functions: A Review of the Literature to Inform Practice and Policy, 2011) (Center on the Developing Child at Harvard University, 2011) 12 Crittenton Women’s Union Applying brain science to social policy and program design As can be gleaned from Table 1 and prior sections of this white paper, researchers have begun to produce increasingly concrete and actionable depictions of how the stresses of poverty impact human development and decision making. In a few cases, they have even made tentative recommendations on potential program and policy design changes. However, the science in this area is very new, the specific recommendations are few and almost entirely untested, and huge gaps remain between researchers’ understanding of the impacts of poverty, trauma, and social bias on human development and how to apply this emerging knowledge. In 2006, Crittenton Women’s Union began research and development (R&D) on a new program platform designed to assist low-income families in reaching economic independence. This R&D process led the organization to many of the exciting new brain-science research discoveries and to design and implement a brain-science informed theory of change, called the Bridge to Self-Sufficiency\u00ae (Bridge), and its accompanying service-delivery platform called Mobility Mentoring\u00ae. The Bridge serves as the basic framework on which all CWU’s programs rest. Since 2008, CWU has served thousands of families in traditional housing, job readiness, adult education, and parenting programs using this theory of change. In addition, since 2009, CWU has served more than 400 families in tailored Mobility Mentoring\u00ae programs that engage families in brain-science based goal-setting and coaching processes. A detailed description of the Bridge and the Mobility Mentoring\u00ae platform, as well as outcomes achieved to date, can be found in Appendix B. Although still early in its deployment, Mobility Mentoring\u00ae is producing impressive client outcomes. Formerly extremely low-income, marginally-educated families have moved out of subsidized housing into their own homes, attained college degrees and family-sustaining careers, saved thousands of dollars, and increased their measurements of well-being. None of CWU’s prior work had ever led to such outcomes. CWU attributes much of the credit for these outcomes to having built programs and tools designed to work with and ameliorate the specific EF challenges outlined in Table 1. Based on data the organization has compiled on participants’ histories of adverse childhood experiences, current exposure to poverty and trauma, and current levels of diagnosed disabilities, CWU estimates approximately three-quarters of its program participants have many of the EF challenges outlined above. Lessons learned through working with these clients within a brain- science informed framework, coupled with recommendations from other researchers in the field, led CWU to make the following policy and program suggestions to improve social service outcomes. Appendix A also includes a collection of more detailed suggestions, along with additional resources for further research and implementation. IMPROvE THE QUAlITy OF TOOlS AnD PROCESSES MEAnT TO SUPPORT lOW-InCOME FAMIlIES Individuals with EF challenges are often easily distracted and taken off task. Therefore, it is important to convey essential information to clients in ways that maximize focus and attention. This requires delivering information through as many media channels as possible (orally, in writing, using pictures, video, and sound) and repeating the delivery of information. It also involves creating easy-to- understand written documents that are cleanly laid out, clear in content, concise, free of jargon, and absent complicated tables. Whether due to current stress levels or prior negative experiences, clients may be unable to provide focused attention to service- delivery interactions with staff. Interactions occurring in locations free of distractions and in a manner that is warm and inviting are more likely to retain participant focus. The more programs and services relate content to the participants’ particular needs\/ perspectives, as opposed to more directive and authoritarian approaches, the better. This principle also extends to service- delivery environment and materials \u2014 the friendlier and more accessible the surroundings and presentation, the more likely to attract and retain client focus. Program participants with EF challenges often have problems with personal organization, remembering deadlines, adhering to schedules, and following multi-step processes. Therefore, it is useful to build service-delivery elements that can assist with these personal challenges. Organizational tools (e.g., checklists, mechanisms for organizing personal space or program materials, routine reminders, and prompts) that are built into service-delivery systems will improve follow-through and outcomes. Research suggests that having a shortened time horizon of personal focus and accurately weighing current needs or actions against future ramifications are frequent challenges for those with EF issues. More user-friendly service-delivery elements can break extended tasks into incremental steps and deliver program content in discrete, measurable modules. This approach shortens the time frames required for assessment and provides frequent supportive\/ constructive feedback to improve client outcomes. This is especially the case if the completion of goals is associated with awarding incentives and ongoing clear and consistent measurement of both interim and cumulative progress. Because of client deficits in organizational skills and taxes on time and personal resources, designing services with a permissible path Using Brain Science to Design New Pathways Out of Poverty 13 for clients to return and complete a particular course of action or program requirements should they drop out will improve overall participant outcomes. As indicated in goal-attainment research, CWU has found that mechanisms permitting multiple attempts toward completing a difficult goal especially if the efforts are cumulative increase the likelihood of ultimate success. COACH PROgRAM PARTICIPAnTS FOR SUSTAInED EF IMPROvEMEnTS Programs that have the potential to work with clients intensively or over extended periods of time may have the capacity to coach clients to significantly improve their executive functioning. As noted earlier, EF skills and the neural connections that potentiate them can be built well into adulthood. Unlike the general recommendations above, which primarily seek to provide more effective frameworks for working with participants with EF challenges, the explicit goal of coaching frameworks is to remediate the challenges themselves and improve cognition and behavior over time. Programs wishing to support clients in improving EF skills might think about the process as one of first developing and then regularly practicing new routines of thought and behavior. Because new neural connections are built through repeated use, program designers should think about the specific habits and behaviors they hope to change and then create concrete program opportunities for participants to repeatedly practice these habits of thought or behavior. The more frequently a specific habit is practiced, the more likely it is to become expertly executed and internalized. For example, to promote participants’ paying rent on time, they should not merely receive instruction on the importance of timely rent payments. Rather, the program should create actual opportunities for participants to make timely rent payments with consistent and frequent feedback and tracking of follow-through. Ideally, incentives would be available for those families who do pay rent punctually over a prolonged period of time. 10 Any significant skill building or behavior change is extremely difficult to achieve and maintain and must be initiated with full participant engagement and commitment. To create effective skill-building processes, a program must first tap into or stimulate individual participant agency. Participants must want change, understand the process of achieving it, and believe they are capable of carrying out the process to gain new skills. Therefore, successful skill-building interventions do not usually begin with didactic or instructional approaches, but instead with careful assessment of participant readiness for engagement. When clients do not exhibit readiness, they can receive coaching through personal empowerment or agency-building approaches to become more prepared. However effective a particular intervention may be at tapping into and unleashing participant agency, unless this facilitation of readiness is followed by systematic opportunities to practice new habits of thought or behavior, empowerment programming alone is unlikely to create significant or sustained change in participant behavior or skills. Creating interventions that allow individual participants to exercise choice in their approach to skill building and goals completion can help increase their decision-making skills at the same time that it increases persistence. In coaching for improvements in executive functioning, it is key to help participants surface many ways to solve a problem, array and evaluate those options, and ultimately choose the one they find most likely to help them attain their goal. Interventions that allow participants to consistently practice such decision-making skills help foster EF skill building. When individuals personally choose their own approaches, such choice increases personal allegiance and commitment to behavior change or skill building and improves outcomes.11 Because brain science is creating an explosion of new insights into executive functioning, new coaching technologies are also emerging. Computer games specifically designed to create fun ways for adults to improve memory, focus and attention, impulse control, organization, problem solving, and multi-tasking skills are now widely available and beginning to create positive outcomes. CWU has incorporated some of these computer games into its service delivery. Although no substantive data on this intervention were available at time of publication, early client feedback is positive. Other coaching models incorporate video of clients’ interactions with others. The video is then used as a basis for coaching improvements in executive functioning by allowing clients to view their behaviors, suggest more effective alternative behaviors, implement those behaviors, and, over time, observe improved outcomes. 11 Behavioral economists such as David Laibson refer to the process of building out of personal agency to goal setting and goal attainment as channeling intent. The critical value of creating a process that channels intent (i.e., sequentially finding a problem that matters to the client, identifying a specific goal to help solve the problem, surfacing options for attaining that goal, making a choice of the best option, and then acting on that choice) is supported by new research showing that, even in low-income families with very high stress, such a process can not only increase effective problem solving, but also significantly reduce levels of clinical depression (Feinberg, Augustyn, Fitzgerald, Sandler et al., 2013). 10 This principle is particularly well-explained in the book by Charles Duhigg, The Power of Habit (2012) and also well illustrated in Malcolm Gladwell’s popular book, Outliers (2008). 14 Crittenton Women’s Union Simply educating staff about the special EF challenges low-income families face and the causative factors for these challenges can significantly improve staff interactions with clients and the quality of program delivery. Staff who formerly might have attributed willful intent to participants’ seemingly counterintuitive decision making or behaviors, instead will realize that such thinking or behaviors is quite logical given the participants’ history and experience. This realization alters staff behavior, increases tolerance, and generates more useful ideas and interventions that improve outcomes. As noted above, although brain science is just beginning to produce information on how social bias, persistent poverty, and trauma affect executive functioning, many practical steps can be taken to apply this knowledge to improve policies and programs. Very little is known at this point about the actual impact created by such applications, but research suggests that the potential is great. MInIMIZE ADDITIOnAl OBSTAClES TO OPTIMIZIng ClIEnT ExECUTIvE FUnCTIOnIng Because individuals living under the stresses of significant social bias, poverty, and trauma suffer a situational bandwidth tax that compromises executive functioning, and because individuals raised under such stresses experience fundamental changes in brain development that impede executive functioning, policies and program designs should include mechanisms to mitigate the challenges to executive functioning created by the policies and programs themselves.12 Program designs can first and most fundamentally reduce bandwidth tax by increasing the basic resources of low-income households. Making more resources available to low-income families is likely to reduce their worry and preoccupation with securing the basics for survival and to demonstrably improve their capacity to more effectively engage in parenting, work, money- management, and education and training. Decreasing the tax on an individual’s time can ensure a program does not intolerably increase a client’s already stressed bandwidth. Any design efforts that decrease the time needed to apply for, maintain, travel to, or participate in programs or services should increase the likelihood of successful client participation and improved outcomes. 12 Bandwidth tax is discussed more fully on page 5 of this white paper. Minimizing the complexity of program and policy requirements\/ expectations so that they are easier to understand and require fewer steps for completion and improving coordination among programs and systems through efforts such as silo-busting 13 co- location, and collaboration among community services are steps that should ease client interface with programs, thus optimizing outcomes. A much more comprehensive list of EF-informed design considerations can be found in Appendix A, along with specific examples of how those particular design elements have been applied within CWU programs. Appendix B is an overview of both the processes CWU applied to incorporate an EF lens into its tools and programs, as well as the encouraging early outcomes from these programs. Conclusion Creating economic opportunity for low-income families in the 21st century means helping them to simultaneously improve their family stability, well-being, money management, education, and careers. This difficult navigational process requires problem- solving, decision-making, goal-setting, and social skills of the highest order. Science shows us that these skills are often compromised in the childhoods of low-income families and by their struggle for survival. But awareness of the special EF challenges faced by low-income families can improve the effectiveness of policies and program design. Leaders need to follow brain science to formulate strategies for a 21st century War on Poverty and create interventions that will improve the common set of EF skills at the heart of success in parenting, school, and the workplace. In doing this, leaders will help ensure low-income families attain family-sustaining jobs, employers will have access to the skilled workers required for a competitive US economy, and children will be raised with the right tools and in healthy environments to support their future success. 13 Silo-busting is defined as breaking down the barriers among programs, public systems, and funding streams to promote more integrated, efficient, comprehensive, and effective service delivery. Using Brain Science to Design New Pathways Out of Poverty 15 Appendix A BRAIn-SCIEnCE InFORMED APPROACHES AnD CASE ExAMPlES FOR IMPROvIng PUBlIC POlICIES AnD PROgRAMS TARgETIng lOW-InCOME FAMIlIES I. APPROACHES TO EASE PROGRAM ACCESS AND INCREASE PARTICIPANT RETENTION 1. Programs and policies should be designed to lower barriers to entry. Streamlining procedures so that applications for programs and benefits will be easy to understand and complete, as well as logistically accessible, will aid those with EF challenges to gain access to necessary programs and services. 2. Processes for program\/benefit recertification, compliance, and maintenance of eligibility should also be simplified, clearly articulated, and logistically accessible. Wherever intervals between recertification periods can be extended, policy makers and program leaders should do so unless the recertification process also provides added program value for the participant. 3. Wherever possible, program and policy silos for service delivery should be eliminated and bundled goods or services provided to minimize the navigational challenges created by separate systems. Ample evidence exists that silo-busting and increased coordination among services or systems improve participant outcomes. 4. Where possible, ongoing programs should be designed in a way that allows clients who must drop out of programming to return and resume participation with as few negative repercussions as possible. It is clear that high hurdles for program resumption prevent many clients in persisting to completion. 5. Wherever possible, differentiated funding streams should be combined at the organizational or systems level rather than at the client level. For example, in many industrialized nations, when citizens become unemployed, they automatically qualify for a basket of supports, including unemployment compensation, housing allowance, health care, job search, job training, and education. Applicants do not need to separately qualify and maintain eligibility for each. Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform Mobility Mentoring\u00ae is most commonly delivered in community locations, such as public housing, or within program sites where clients already receive services. Initial services start with a drop-in model that requires no application process and no payment for services. CWU’s theory of change, the Bridge to Self-Sufficiency\u00ae, ensures that all services are inherently silo-busting and holistic. Most Mobility Mentoring\u00ae programs allow clients who have discontinued services to return without penalty. 16 Crittenton Women’s Union II. APPROACHES TO InCREASE ClIEnT COMPREHEnSIOn AnD PROPER UTIlIZATIOn OF PROgRAMS AnD BEnEFITS\u2014 RUlES AnD TOOlS 1. Critical policy and program information, requirements, and expectations should not be conveyed by oral communications alone. All critical communications should also be provided in writing and should be conveyed in as clear and concise a manner possible. Wherever visual illustrations or multimedia can be used to reinforce understanding of critical information, this should be instituted. Multimodal means of communication ensure more complete understanding by those with learning differences. 2. Instructions should be limited to the fewest steps possible and conveyed in a manner that is clear and concise. Documents should avoid complex jargon and fine print. The most important content should be conveyed up front and highlighted through document layout and formatting. 3. Documents or training materials containing friendly pictures can help to overcome initial intimidation associated with dense or official-looking content and can promote learning and understanding. 4. Many participants will find abstract or theoretical content, such as tables, theorems, diagrams, or maps, particularly challenging. These types of information vehicles can discourage attention\/ focus. Finding alternative ways to convey such content can help facilitate comprehension. 5. Communications should be consistent across all levels and locations of policy and programming. Participants should not encounter confusing or mixed messages at different levels or locations of service delivery. 6. Style of verbal communications can greatly enhance client understanding. Interactive communications designed to clarify the level of client understanding can be particularly useful. This means not just asking a client whether they understand something after it has been communicated, but asking leading or exploratory questions like, What do you think about this? What kind of problems do you think might get in your way? Such forms of communication permit staff to clarify the true level of participant understanding and also promote participant agency. 7. Interactive computerized applications, games, or other learning processes that approximate serve and return, i.e., conveying information and asking for a participant’s response to the information, content, or questions, can also be useful ways to engage and promote attention and absorption of information. 8. Information given in a friendly or encouraging manner is more likely to be retained and understood than information given in a more factual, directive, authoritarian, terse, or unsupportive manner. 9. Repetition of material delivered in a variety of ways will reinforce the understanding of critical information and help to increase effectiveness of absorption. 10. Whenever possible, information should be conveyed in an environment without competing stimuli (noises, high levels of activity, and external demands for client attention). For example, oral explanations of program expectations delivered in an open area with people walking by and with a participant’s child on her lap are far less likely to be completely understood than those given in a quiet room with the child occupied elsewhere and with handouts or other multimedia resources provided for the participant to review and to take with her to revisit later. continued Using Brain Science to Design New Pathways Out of Poverty 17 11. Whenever possible, the most complex instructions or learning processes should be scheduled for morning hours where cognitive levels are usually highest (exceptions to this would be for third-shift workers), and\/or for periods during the month when financial resources are highest and participants are likely to be less stressed, e.g., on the days of benefits payments or receipt of paychecks. 12. Ramifications for failure to adhere to instructions or benefits gained from successful adherence should be clearly delineated and explained early in the chain of instructions\/ expectations, not buried in dense text or fine print. Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform All program rules and tools are provided to clients in writing and are regularly discussed. Assess- ments are conducted jointly by clients and staff and not withheld from clients. Assessment and goal-setting are conducted in a private, quiet office with a one-on-one coaching serve and return process that leads to written documentation of expectations for both the participant and the staff. All agreements and expectations are entered into a computerized record as well. continued 14 Decision-making scientists refer to this process as channeling intent and find that this process is highly effective in increasing goal- attainment rates (Gollwitzer and Sheeran, 2006 Vol. 38). 15 Motivational Interviewing theory provides a very good foundation of approaches for fostering client agency and connecting this agency to proposed program outcomes. Motivational Interviewing approaches encourage clients to actively talk about the changes they wish to create and to clearly depict those changes (Miller and Rose, 2009 64(6)). 16 Behavioral psychologists have also found that clear depiction and identification with change state is useful in improving behaviors like follow-through with retirement savings when clients are encouraged to view age-progressed pictures of themselves as elderly and encouraged to save for that elderly self. Such clear identification of the goal state increased retirement savings by statistically significant rates (Hershfield, Goldstein, Sharpe and Fox, 2011). The principle this research reinforces is that the clearer, more well-defined, and more multimedia vehicles used in the depiction of goals, the higher the likelihood of attainment. Programs with components that allow clients to visually depict themselves or their family’s future when their goals are achieved can increase client identification with the goal state and enhance goal achievement rates. Depictions can be done through drawings, cut and paste collages, or through use of computer images. continued III. APPROACHES TO FOSTER AgEnCy, EngAgEMEnT, AnD FOllOW-THROUgH 1. Whenever possible, leaders should create core program elements that encourage the development of clients’ self-awareness of their needs, desires, and goals; and provide relevant, useful information and resources that allow clients to take informed actions based on their preferences and beliefs toward their articulated goals.14 It is clearly understood that individuals are most likely to achieve goals they personally desire. Therefore, whenever programs can be built out of, or foster that desire, they stand a greater likelihood of being successful.15 16 2. Self-empowerment programming (programming elements designed to explicitly build participants’ sense of agency, self-esteem, initiative, and locus of control) is demonstrably useful in conjunction with additional program elements that can help clients identify a goal, develop a concrete path to that goal, and then follow through on intent. 18 Crittenton Women’s Union Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform Participants are engaged from the very beginning in a process of clarifying and stating their own needs, achievement goals, and preferred pathways for achievement. Mentors act as informed and supportive consultants to client decision making. The overall frame is one of co-investment. As clients’ agency and effort increase, the Mobility Mentoring\u00ae frame increases the resources available to the client. Over time, clients progressively lead Mobility Mentoring\u00ae team and group processes with their peers and develop external leadership and advocacy roles as well. 17 CWU calls strategies that progressively match increasing client agency and efforts with higher levels of program investment of resources and rewards co-investment strategies. Such strategies run counter to most prevailing social service interventions that ex- pend greatest resources on those most in crisis. Such crisis interventions work well for the alleviation of immediate needs, but do not build client capacity. In capacity-building frameworks, participants need to be provided program resources and tools when they can most productively engage with and use them. Providing programs with high expectations of engagement and significant program infrastructure to those who are not ready can actually inhibit or diminish agency and be counterproductive. 18 Sometimes increased client agency will initially be expressed in negative or accusatory behavior. It is important, whenever pos- sible, not to meet such initiative with equally negative or domineering responses, but rather to try and coach or redirect the energy and expression toward positive attainment of a goal the client desires to achieve. 3. Empowerment programs as independent, short-term interventions, designed solely to develop agency but unconnected to follow-up programming, are likely to have limited impact on outcomes due to the lack of opportunity to practice new skills and thereby cement the learning. New learning that is not utilized rapidly fades. Promoting agency without clear paths to develop and implement intentions can sometimes create a sense of personal failure, frustration, and future resistance to engagement. 4. Programs with frameworks for clients to concurrently array and understand choices, to grasp potential future ramifications of those choices, and finally to explore, weigh, and execute their choices create the greatest likelihood of fostering strong ownership and participation. The availability of choices in implementing intentions is positively correlated with successful outcomes because it allows for strong personal identification and ownership of not only the goal but the plan to get there. 5. Program elements that reward patterns of increased agency, self-efficacy, and investment with progressive systems of incentives and supports can also enhance building of agency and engagement. The general design principle is to match client investment of initiative, efforts, and actions with comparable levels of program commitment, benefits, and supports.17 This includes having the capacity to track and reward\/encourage client investment and intermediate progress as well as desired longer-term outcomes.18 6. Creating opportunities for clients to develop group agendas, lead projects or meetings, teach something they know, advocate for something they care about, or provide systematic and meaningful feedback on programs and policies in which they are involved, are particularly muscular ways of creating and reinforcing agency, engagement, and self-esteem. 7. Where possible, leaders should consider implementing procedures that minimize overly directive or authoritarian staff behaviors and instead emphasize professional coaching or mentorship. Highly dominant or rigid patterns of staff behavior in service delivery can suppress nascent client initiative and expression of intent. They can also trigger hypersensitive or reactive client behaviors that inhibit successful engagement. Using Brain Science to Design New Pathways Out of Poverty 19 Iv. APPROACHES AnD REWARD SySTEMS TO PROMOTE gOAl ATTAInMEnT 1. Service-delivery goals frameworks (program\/goals expectations, tools, and goals contracts) should be extremely clear and shared in as many media channels as possible (oral discussion, in writing, and reinforced with charts or other visual explanations or frameworks). To assure that the goals are truly clear, they should follow the SMART goal criteria. They should be Specific, Measurable, Attainable, Relevant, and Time-bound.19 2. Goals contracts should be documented in writing and should explicitly state how goals will be measured and verified, the expected actions required by both staff (for support) and participants (for completion) of goals, and the expected time of completion. Expected actions include clear descriptions of the steps to be taken to achieve the goals and may also include prompts or reminders to be provided by staff or clients about key steps in the action plan. Careful prompts have been shown to increase goal attainment rates by statistically significant levels. 3. Overall goals frameworks should include both goals expectations for program conclusion and also for the next anticipated point of interim goals review. For example, in the case of two-year Temporary Assistance for Needy Families (TANF) welfare-to-work programs, goals would be set for program completion two years hence and for shorter interim periods as well. 4. Interim goals should be simultaneously set for both the immediate and the succeeding goal period. In other words, if using three-month interim goal periods, goals should always be in place for both the current and following three-month period so that participants can clearly see the staging of the tasks ahead of them. 5. Wherever possible, goals reviews should happen every six months or more frequently, depending upon the program model. Timing of goal setting and reviews should be established to minimize logistical complications for clients while maximizing frequency and relevance of feedback. 6. When goals are set, they should be accompanied by a clear explanation of the positive and negative ramifications for their attainment or lack of attainment. The rewards for success and penalties for failure, and the manner in which those rewards or penalties will be administered, should be clearly understood. Routine systems of reward\/penalty should be, as much as possible, codified and not subject to individual interpretation. Rewards\/penalties should be triggered by client initiative and achievement as opposed to being awarded by the supposed largesse or authority of staff. 7. Incentive and measurement systems should, wherever possible, be gauged to level of effort and complexity of goals achieved. For example, a client who wants to go to college might have an initial goal to complete a Free Application for Federal Student Aid (FAFSA). This goal, when completed, might be rewarded with a $25 incentive and the completion deadline might be set for two weeks to a month away; whereas completing a semester in college with solid grades might be rewarded with a $250 incentive and the goal measurement time frame would be set for semester end (months away). 8. Ideally, incentive systems will be multifaceted and keyed into the particular motivational preferences of a given population. For example, clients who participate in substance abuse treatment programs often express desire for rewards of coffee shop gift cards because attending meetings with coffee is a norm for such groups and promotes a sense of belonging. Clients participating in job-training programs may express preferences for special access to 19 A useful tutorial on developing SMART goals within an academic environment can be found on the Massachusetts Department of Education website: http:\/\/www.doe.mass.edu\/edeval\/training\/modules\/M4Handouts.docx continued 20 Crittenton Women’s Union Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform SMART goals are used in all goal setting. Goals and other program frameworks are meticulously set and routinely re-measured at established intervals of no longer than six months. Goals are set for program completion and interim measurement periods; interim goals are always in place for the current and following goals periods. Multifaceted incentive systems are deployed and used to support and reward participant achievement. Participants are routinely encouraged to think of potential problems they are likely to face in achieving goals and to plan ahead for those problems. When clients encounter significant difficulties that might derail their goals’ achievement, they are coached on how to re-calibrate and get back on track. Goals are aligned and reported at all levels of the organization. The same goals are measured and reported at the client, staff, program, department, organization, and public levels. 20 For example, a job-training program might have a goal of graduating 80 percent of students and placing 75 percent of those graduates in full-time jobs within six months of graduation. In this case, the board of directors should be measuring the level of organizational achievement and rewarding leadership based on its percentage of success of those goals. Leadership should measure departments on their performance achieving the same goals. Direct service staff reviews should be based on the same performance goals and clients’ goals should be set and measured in the same way. professional networking opportunities as a performance reward because such networking opportunities can be perceived as positive recognition of having climbed a rung in the social or professional hierarchy. 9. Incentive systems may vary widely based on the goal-setting milieu and might include any or all of the following: opportunities for special public recognition, communications of encouragement, visual or other records of client progress, financial rewards, access to special privileges or opportunities, and in-kind rewards such as goods or services. 10. Failure to meet specified goals should, where possible, include not just systems of penalties, but also systems for recalibration, developing a Plan B to help the client get back on track, practice resilience, and understand that problems may be successfully overcome. 11. All such plan reassessment should still fit within a firm set of expectations and not be allowed to derail the established program completion ramifications. When setting goals, it is useful from the beginning to explore potential areas where the goals’ plans are most likely to fail, to practice scenario planning, and to develop alternative coping strategies that can be included in the established goals from inception. 12. It is critical that all systems of goal setting, measurement, and rewards be consistently and methodically executed. They are only as effective as they are systematically deployed. Allowing goal-review time frames to lag or lapse and not following through on promised rewards or penalties seriously undermine effectiveness of goals frameworks. 13. Goals expectations should be, whenever possible, measured and aligned at all levels of the system of deployment. Such alignment assures clear shared expectation of outcomes and methodical implementation of the systems designed to reinforce goals achievement at all levels. It thereby increases the likelihood of client success.20 Using Brain Science to Design New Pathways Out of Poverty 21 v. APPROACHES TO COACHIng FOR SUSTAInED IMPROvEMEnTS In EF SkIllS 1. If the policy or program intervention has goals to create significant sustained improvements in clients’ cognitive and behavioral skills, scaffolding frameworks reinforced by coaching and greater resources of staff and time will be required. The amount of growth of new neural pathways is directly related to the time and intensity with which individuals have opportunities to practice new skills and ways of thinking.21 2. Coaching should be offered in a positive and encouraging manner. Sometimes referred to as strength-based, such coaching emphasizes routinely identifying opportunities to recognize the positive qualities a participant possesses, ideas or insights they have conveyed, and the improvements they have made. Such coaching makes suggestions for improvement in ways that emphasize how the changes are likely to help the participant achieve her own goals. In this manner, advice or recommended changes can be used to reinforce agency and positive self- ideation. 3. In order to reinforce skill building, program policies and procedures need to be created that systematically allow clients to practice alone and with staff, the key self-assessment, problem- solving, goal-setting, and other EF skills. 4. In particular, reinforcing skills of pausing and reflecting before making decisions, trying to find alternative courses of action, thinking ahead for Plan B in anticipation of problems, reframing constant negative self-assessment, and weighing verbal or physical responses to stress before acting should be practiced and coached as often as the program frameworks permit. 5. Coaching frameworks that help participants ignore (even on a temporary basis) competing stimuli or problems that may derail them so that they can maintain attention to goals and stay on task are critical to improving goals achievement rates.22 6. Coaching staff should routinely meet with their supervisors and peers to help maintain objectivity and their own professional boundaries when working with clients; seek input and advice on how to help clients move ahead; and maintain adherence to the program frame. 7. Staff performance of tasks and problem solving on behalf of clients should be avoided. Instead, staff should encourage clients to be increasingly independent in the completion of their own tasks. 8. Multimedia and interactive interventions for coaching behaviors and learning can be particularly powerful. Examples include role-play, videotaping and review of interpersonal interactions, and\/or skill-building computer-gaming applications. 9. Successful coaching requires environmental conditions that are safe and free from excessive extraneous stimulation. Coaches should be encouraging and work more through interactive exploratory prompts than from directive instructions. They should be clear that the interpersonal relationship is one of professional mentoring, and not dominance of the client. 21 In scaffolding instruction, structured tools and lessons are provided to facilitate the learner’s development. An important aspect of scaffolding instruction is that the scaffolds are temporary. As the learner’s abilities increase, the scaffolding provided is progressively withdrawn. As a teaching strategy, it originates in Lev Vygotsky’s sociocultural theory of learning, in particular his notion of the zone of proximal development, the distance between what a learner can do without help and the next learning s\/ he can achieve with competent assistance [Raymond, 2000, p.176] (R.R. Van Der Stuyf, Adolescent Learning and Development, Scaffolding as a Teaching Strategy (New York, NY: City College of City University of New York, 2002). 22 This framework is very different from typical case management models that usually focus on helping participants eliminate perceived barriers to goals completion. But such processes can cause both staff and client to enter into a never-ending process of dealing with one immediate crisis after another and are frequently the reason for goal derailment. Research shows that those who consistently attain goals usually do so, at least in part, by developing skills that permit them to take their minds off of competing problems (rather than directly engage in and battle them) and retain focus, when needed, on goals-related tasks (Babcock, 2012). 22 Crittenton Women’s Union Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform Serious effort is made to capture all clients, no matter their obstacles to family stability or economic mobility, and initiate a process of engagement that continues until self-sufficiency is attained. Coaching processes start in a light touch manner during a process of administering assessment and goal-setting tools (EF scaffolding), but become increasingly intense as the length of engagement increases. As coaching processes deepen, staff work more frequently with clients on alternative scenario building (finding Plan B ) and taking corrective courses of action to promote behavior change. This is done to help clients internalize skill-building scaffolds. Emphasis is placed on containing competing life stimuli in order to maintain goals’ focus. Computerized EF coaching applications are also being introduced to assist in skill building. vI. APPROACHES TO COACHIng FOR IMPROvEMEnTS In SOCIAl SkIllS 1. Clients should be coached to reflect upon their own and others’ motivations for actions and behaviors. Ideally, assisting clients to better understand their own, and\/or to reframe their interpretations of others’ motivations and behaviors will lead to more constructive ways of handling future social interactions and better align social behaviors with the goals the clients wish to achieve. 2. Opportunities should be created for clients to test ideas with staff as to how to improve their social interactions before they deploy the new approaches with others. Clients (especially when under stress) can be encouraged to call staff, a peer, or an outside professional mentor to test their reasoning or proposed actions before making major decisions. When time and staffing permit, role-playing can be a useful mechanism for trying alternative strategies of social engagement. 3. Participants should be actively coached to join social networks and environments beyond those in which they normally participate. Particular attention should be paid to social leveraging networks that have the potential to help clients improve their chances to increase earnings, education, or other leveraging assets. Staff can suggest opportunities to clients for volunteering and joining educational, professional, and social groups or clubs. Incentive systems can be built to reward networking behavior. 4. Program-based cohorts or peer support groups offer particularly rich avenues for improving interpersonal skills and self-esteem. When working in groups, clients should be encouraged to develop and deploy their own rules and expectations for respectful and supportive group behavior and governance. As mentioned in Section III.6, above, clients should be encouraged to assume leadership roles in groups and use groups to complete projects. Social complexities will inevitably arise and the program should offer a secure environment in which to gain valuable new social skills. 5. Written social and professional communications (e.g., differentiating between the rules for professional versus personal e-mails) can be challenging for many participants. Program frameworks that encourage exploration and rule building around, and practice of, such communications can greatly enhance these social skills. For example, cohorts can develop Using Brain Science to Design New Pathways Out of Poverty 23 Facebook groups, determine how the groups are to be used and managed and develop appropriate rules for communication. Sample social networking communications can be shared with staff and peer groups to evaluate their effectiveness. 6. Program participants should be encouraged to think of their own personal, social, and professional networks and how those resources could be used by their peers. For example, clients can be encouraged to engage in group problem solving around a particular issue many find challenging (e.g., raising children with special needs), and can share resources and useful approaches. Or, clients who work in a particular setting such as a hospital might be encouraged to alert their peers to upcoming career open houses and introduce them to a human resources staff member. Participants can create need one, give one newsletters or message boards where they can post resources they need or are prepared to share. 7. Clients and their families should be encouraged to expand the normal geographic areas they frequent. This can be done through goal-setting processes related to education or career, or by taking social trips to events, parks, museums, and other locations. Such disruption of normal patterns of travel and social concourse has significant potential to increase agency and skill building and to reframe pre-established beliefs and values. Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform Individual mentoring and group processes routinely encourage participants to explore their own and others’ reasoning and motivations for behavior. Much of Mobility Mentoring\u00ae goes on in small and larger peer group meetings; participants are encouraged to develop the rules for these meetings and to lead them. Participants routinely build online social networking groups (such as LinkedIn or Facebook groups) and then use them to share resources, create and manage joint projects, and maintain social ties. Clients also set explicit personal goals that involve joining other social networks, expanding their geographic experiences, and sharing resources from these engagements with their peers. vII. APPROACHES FOR IMPROvIng HEAlTH-RElATED PROgRAM OUTCOMES 1. Higher rates of illness and physical disability, as well as slower rates of recovery, in low-income populations suggest that program elements promoting good access to primary medical, mental health, and dental care are critical. It is also valuable to anticipate, plan for, and coach participants on how they would manage, if necessary, health-related interruptions in participation or goals attainment. 2. Because stress has such a significant impact on executive functioning, behavior, and health, connecting clients to interventions that can alleviate stress or introducing such interventions into standard programming can be highly impactful. Stress reduction techniques, such as yoga, meditation, prayer, neuro- or bio-feedback, talk therapies, acupuncture, and more, can be life- changing for clients and create the breathing room they require to introduce other behavioral changes into their lives. 3. Stress-reduction techniques are also commonly used at the beginning of program sessions to create increased readiness for focused engagement. For example, a training session on job- search techniques might open with a few minutes of stretching and deep breathing to help decrease the bandwidth tax on participants and increase likelihood of successful training engagement. 4. Physical exercise is also known to increase executive functioning by increasing blood and nutrient flow to the brain, decrease stress through increased metabolization of stress-related hormones, improve the sense of well-being through release of endorphins, and directly improve health outcomes of the major diseases related to disability and death, such as hypertension, diabetes, and obesity. Therefore, program components that include, encourage, and reward physical activity can have multiple positive effects on program outcomes. 5. When faced with consistently limited resources of time and the basics of survival, many participants routinely place the needs of those around them before their own. Introducing concepts of self-care as a means of strengthening the self in order to then provide greater assistance to others can be a useful framework for helping clients improve their goal setting and outcomes around personal development and care. Case Example: How these design considerations are incorporated into CWU’s Mobility Mentoring\u00ae platform The Bridge theory of change includes explicit goal setting in areas of health and well-being. Participants work individually and in groups on projects related to improving their own and their families’ health. They develop and participate in nutrition, exercise, and stress-reduction programs. They also practice scenario planning for how to deal with interruptions with work and school due to health or illness. Group meetings often include opportunities to practice stress-reduction techniques and have agendas covering topics related to stress reduction and health improvement. (Senko and Hulleman, 2013 105:2) (Messersmith and Schulenberg, 2010 130) (Etkin and Ratner, 2012 (38)) (Walker, Sterling, Latimer, Kim et al., 2012) (Broussard, Joseph, Thompson and Thompson, 2012 27:190) (Gollwitzer and Sheeran, 2006 Vol. 38) (Milkman, Beshears, Choi, Laibson and Madrian, 2011 108:26) (Lowe, 2012) (Vohs, 2013) (Mani, Mullainathan, Shafir and Zhao, 2013) 24 Crittenton Women’s Union Using Brain Science to Design New Pathways Out of Poverty 25 Appendix B HOW CRITTEnTOn WOMEn’S UnIOn APPlIES An ExECUTIvE FUnCTIOn lEnS TO CREATE STROngER PROgRAMS AnD OUTCOMES Crittenton Women’s Union was formed in 2006 by the merger of two of Massachusetts’ oldest nonprofit organizations serving low-income women. This merger created an entirely new operating structure for the organization. CWU now operates as an action tank an organization that provides direct services and uses this service-delivery platform, in conjunction with research, to develop better economic mobility tools and program approaches, test them, take them to the broader field, and ultimately create systems change. From the outset, CWU’s goal was to develop interventions that would create demonstrable economic gains for low-income families and to move as many of those families as possible to full economic independence.23 Through an early partnership with the Center on the Developing Child at Harvard University, it became increasingly clear to CWU leadership that emerging learning from brain science had the potential to significantly improve its program designs and participant outcomes. This new research suggested that, for CWU to create transformative outcomes, it would need to build interventions designed to accommodate participants’ executive function challenges and, where possible, coach for actual improvements in participant executive functioning. Through a multi-year research and development process that included research on participant obstacles to economic independence, current best practices by creative programs active in the field, and emerging learning from many fields, including the brain sciences, CWU’s theory of change, the Bridge to Self- Sufficiency\u00ae and the program platform designed to deliver that theory of change, Mobility Mentoring\u00ae, were created. The Bridge was designed as an EF tool or scaffold that allows an individual participant to be concurrently assessed in what CWU determined to be the five most significant areas contributing to economic independence: family stability, well-being, education, financial management, and career management. By arraying and evaluating strengths and weaknesses in all five areas at once, it allowed staff and participants to contextualize and explore the causal relationships among all five areas and thus to begin creating a logical hierarchy of importance for intervention and goal setting. (See the horizontal axis of the Bridge to Self-Sufficiency\u00ae diagram on page 27.) 23 CWU defines economic independence as a family’s earnings reaching the level specified by the Massachusetts Economic Independence Index and also having saved an amount equivalent to three months’ household expenses, the minimum asset base recommended for family stability by experts in the field (Shapiro and Wolff, eds., 2001). This tool and the process of its administration are particularly useful because many low-income families have EF-related memory and mental flexibility challenges that prevent them from thinking about and evaluating more than one problem at a time, teasing apart how the problems interconnect, and creating strategies for addressing those problems. An EF scaffold like the Bridge permits people to record on paper multiple items (goals, steps) that their minds might not readily hold, and manipulate them in the same manner a written to do list helps people remember multiple tasks and organize them. The Bridge tool also allows staff and participants to identify where the participants’ stand in each pillar area relative to the future steps required to attain self-sufficiency. In this manner, clients can visualize the steps they must complete in each pillar if they are to advance (See the vertical axis of the Bridge to Self-Sufficiency\u00ae diagram opposite). This ability to contextualize where they stand relative to the steps ahead is useful because many low-income families have challenges thinking beyond the most immediate needs confronting them. Finally, the Bridge is a visual as well as a written framework and therefore allows for a multimodal depiction of client status and goals that, when delivered with a guided conversation, offers many avenues for comprehension. This is especially useful because individuals with EF challenges usually benefit from content being conveyed in a variety of approaches that can accommodate different learning styles. The Bridge, therefore, is a classic learning scaffold that allows staff and client to perform analytic and goal-setting tasks that could not be readily performed without such a tool. As the client establishes goals for personal improvement and as those goals are achieved, the Bridge allows the client to clearly track her own progress and the scaffold becomes a reward framework as well. Since it was first deployed with clients in 2009, the Bridge has been used with many hundreds of participants. Although initial designers worried that the tool might be overly complicated or depressing for clients, clients consistently give positive feedback about its value. Participants frequently state that they can now see why they have been stuck, felt overwhelmed, and find ways to move ahead to make their lives better. As clients repeatedly use the Bridge, they become increasingly used to thinking about all the pillars and how they affect each other. Thinking about future implications of their decisions also becomes habituated and, eventually, clients improve their decision making without using the tool. The ultimate goal of a scaffold is to become unnecessary as strong internal skills take its place. The Mobility Mentoring\u00ae platform is designed to deliver the Bridge theory of change in the most methodical and impactful manner possible. It incorporates most of the brain-science recommended design considerations outlined in Appendix A. Staff, called Mobility Mentors, work in partnership with clients to deliver Mobility Mentoring\u00ae services. The Mobility Mentor’s role is quite different from that of a case manager. Whereas the role of the case manager is typically to help participants deal with crises that may be preventing them from achieving a particular program outcome, Mobility Mentors help participants stand back from their current problems, examine them, and ultimately create the larger life changes that permanently eliminate those problems. Also, unlike most case management relationships, Mobility Mentoring\u00ae is not hierarchical, but instead is a coaching partnership specifically designed to support the participant in finding her own agency, setting and achieving her own goals, gaining new cognitive and behavioral skills, navigating available networks of learning and support, strengthening persistence and resilience, and helping her life to unfold in a way that is holistic and optimizes all areas of the Bridge. 26 Crittenton Women’s Union The Bridge was designed as an EF tool or scaffold that allows an individual participant to be concurrently assessed in what CWU determined to be the five most significant areas contributing to economic independence: family stability, well-being, education, financial management, and career management. FAMILY STABILITY Housing Dependents No subsidy, housing costs less than 1\/3 household take- home pay Dependent needs met; serving as no barrier to parent\/ guardian school or work No subsidy, housing costs exceed 1\/3 household take- home pay Dependent needs serving as minimal disruption to parent\/ guardian school or work Partial subsidy (shallow): Paying $200 or more towards rent Dependent needs serving as intermittent disruption to parent\/ guardian school or work Full subsidy, permanent housing: Paying $200 or less towards rent Dependent needs serving as significant obstacle to parent\/ guardian school or work A. Homeless \/ co-housed with family or friends B. Homeless \/ transitional housing Recently emergent or not yet addressed dependent needs, requiring additional attention Homeless \/ emergency shelter WELL-BEING Health and Behavioral Health Social Networks Fully engaged in work, school, and\/or family Health \/ behavioral health issues serving as no obstacle Advocate\/ Networker: Uses own and other resources and connections to advance the mobility goals of others Minimal disruption to work, school, and\/or family due to health \/ behavioral health issues Developed Network: Consistent source of both support and leveraging connections Intermittent disruptions to work, school, and\/or family due to health \/ behavioral health issues Emerging Network: Consistent source of support and occasional leveraging connections Regular and recurring disruptions to work, school, and\/or family due to health \/behavioral health issues Limited network: Occasional source of support Severely limited engagement in work, school, and\/ or family due to significant health \/ behavioral health issues Isolated or draining network EDUCATION AND TRAINING Educational Attainment Completed bachelor’s degree or higher Completed associate’s degree or postsecondary job training or certificate program Attending college or postsecondary job training program Completed postsecondary remedial education classes, college preparatory program, or prerequisites for job training\/ readiness program Attending postsecondary remedial education classes, college preparatory program, or fulfilling prerequisites for job training\/readiness program High school diploma or General Educational Development certif\u00edcate GED obtained No high school diploma or GED FINANCIAL MANAGEMENT Savings Debts Savings of three months’ expenses or more Current on all balances and no outstanding debt other than mortgage or educational and\/or car loans Savings of more than two months’ expenses but less than three months’ expenses Current in payments and plans and paying more than minimum payments Savings of at least one months’ and up to two months’ expenses Structured payment plans in place and meeting minimum payments Savings of less than one months’ expenses Debts in excess of ability to pay, behind in payments No savings Defaults or nonpayment on all or most loans and accounts EMPLOYMENT AND CAREER MANAGEMENT Earnings Levels Job with earnings \u2265 Mass. Index wage (If not calculated for specific family, use income \u2265 $65,880) Job with earnings of 66-99% of Mass. Index wage (If not calculated for specific family, use income range of $43,481 – $65,879) Job with earnings of 33%-65% Mass. Index wage (If not calculated for specific family, use income range of $21,741-$43,480) Job with earnings less than 33% Mass. Index wage Unemployed CRITTEnTOn WOMEn’S UnIOn’S THEORy OF CHAngE BRIDgE TO SElF-SUFFICIEnCy\u00ae STARTING POINT MOBILITY MENTORING\u2122 SELF-SUFFICIENCY She is spending less than 30% of her after-tax income on housing. Her children’s needs are being met and do not prevent her from pursuing schooling or work. She is fully engaged in her work and her family, and no health or behavioral issues prevent her from pursuing schooling or employment. She is a part of a strong social network, serving as an advocate, organizer, and support to others. She has achieved a level of post-secondary education and\/or training that has prepared her for a job paying enough to support her family. She has savings equal to three months’ worth of living expenses. She has good credit and is managing her debts in balance with her income. Her earnings from her job are greater than the real costs of basic living expenses for her family, as determined by CWU’s Massachusetts Economic Independence Index. FAMILY STABILITY WELL-BEING EDUCATION ANDTRAINING FINANCIAL MANAGEMENT EMPLOYMENT AND CAREER MANAGEMENT Crittenton Women’s Union Bridge to Self-Sufficiency\u2122 Starting Point Mobility Mentoring\u00ae Self-Sufficiency\u00ae FU TU RE O RI En TE D D EC IS IO n M Ak In g COnTExTUAlIZED DECISIOn MAkIng Using Brain Science to Design New Pathways Out of Poverty 27 28 Crittenton Women’s Union DESCRIPTIOn OF MOBIlITy MEnTORIng\u00ae Mobility Mentoring\u00ae is the professional practice of partnering with clients so that over time they may acquire the resources, skills, and sustained behavior changes necessary to attain and preserve their economic independence (Babcock, 2012). Mobility Mentoring\u00ae services are delivered by Crittenton Women’s Union in three levels of engagement. Level One is a light touch engagement provided primarily in conveniently located drop-in centers, shelters, and other CWU program settings. The principal focus of this level is promoting engagement and agency. Clients typically set one or more simple goals with fairly short time horizons (six months or less). Level Two is a medium level of engagement provided in the same settings as Level One. The primary focus of this level is increasing agency and promoting persistence. Clients at this level typically set multiple goals at a time. These goals are usually multi-step (e.g., completing a multi-week or month training process or receiving family intervention), take six months to 18 months to complete, and are usually set and monitored in six-month increments. Level Three is the deepest level of Mobility Mentoring\u00ae engagement. These services are provided in the locations listed above, but also in supported-housing programs. Clients must apply to get into Level Three programs which are designed to promote resilience, coach for EF skill building, and help clients internalize scaffolding such as the Bridge. Goals are established in all five areas of the Bridge, usually take multiple years to complete, and are set and evaluated in six-month increments. CWU’s Career Family Opportunity (CFO) Program is a Level Three Mobility Mentoring\u00ae program that CWU started in 2009. Since that time, outcomes from the intervention have been encouraging and significantly better than community benchmarks or prior CWU outcomes. Examples of some of these outcomes achieved at CWU in fiscal year 2013 (July 1, 2012 through June 30, 2013) are illustrated on the opposite page. Using Brain Science to Design New Pathways Out of Poverty 29 By Bridge to Self-Suffi ciency\u00ae Pillar Bridge to Self-Suffciency Pillar At Mobility Mentoring\u00ae program entry As of last FY13 outcome measurement Comparison to community benchmarks Family Stability 100% of participants in CWU’s Career Family Opportunity (CFO) program were residing in subsidized housing 89% of CFO participants resided in subsidized housing 9% have purchased homes 2% have moved to market-rate rental units Nationally, 6% of homebuyers are single mothers and 4% of homebuyers are single mothers with an income of 0-80% of area median income (AMI) CWU served 158 families in housing stabilization, all of whom originated from emergency family shelter 100% of CWU families in stabilization for 12+ months maintained permanent housing after exiting shelter 75-91% of families participating in three Mass. Homelessness prevention efforts maintained housing stability after 12 months Well-Being 20.3 Overall Quality of Life Score for CFO participants2 66% of CFO participants scored above 19 21.5 Overall Quality of Life Score for CFO participants 89% of CFO participants scored above 19 Scores below 19 indicate a poor quality of life. A difference in two to three points in the overall score has been found to be clinically meaningful Education and Training 32% of CFO participants had an AA degree or higher broken down as follows: 14% Associates; 14% Bachelors; 4% Masters 52% of CFO participants have an AA degree or higher broken down as follows: 27% Associates; 14% Bachelors; 2% graduate certifi cate; 9% Masters Six-year college completion rate for low-income students is approximately 11% 46% of adults of any income level in Mass. have an Associates degree or higher Financial Management $0 saved into matched savings account by CFO participants $1,528 average saved into matched savings account by CFO participants 76% of families in the bottom quintile have bank accounts. Of those with bank accounts, the median balance is $60021% of adults entering shelter had any money saved 40% of adults in shelter saved at least $150 or contributed at least $150 towards debt Employment and Career Management 59% of CFO participants were employed: average wage $14.82\/hr. 0% of CFO participants were earning a family-sustaining wage at entry 68% of CFOs are employed; average wage $20.18\/hr. 30% of CFO participants are earning a family-sustaining wage The median income for single mothers in Mass. is $13.13\/hr.3 45% of adults were either enrolled in school OR employed at program entry 80% of adults were either enrolled in school OR employed in FY13 64% of low-income families in Mass. are employed; 53% of the non-elderly, non-disabled HUD public housing authority-assisted households are employed Mobility Mentoring\u00ae Outcomes for Adults Served in Fy20131 (July 1, 2012 June 30, 2013) 1. Results in grey are for short-term program delivery in CWU shelters in Boston and Cambridge with average participation of 12-18 months. Participation numbers (N) vary based on program type. Results in blue are for CWU’s multi-year program delivery called Career Family Opportunity (CFO)(N = 44 participants). Participants enter this program on a rolling basis after an application process, and had achieved 2.5 years average program participation at the time these data were gathered. 2. The Ferrans and Powers Quality of Life Score measures both satisfaction and importance of various aspects of life. Scores are weighted in order to refl ect an individual’s satis- faction with areas of her life that she values most. Scores are calculated for psychological, social, economic and family satisfaction, as well as life satisfaction overall. 3. CWU publishes a cost of living measure called the Massachusetts Economic Independence Index (Mass. 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Acknowledgements The author would like to thank the following inspiring colleagues for their kind review and thoughtful comments: Dr. Silvia Bunge, Associate Professor and Vice Chair, Department of Psychology, University of California at Berkeley; Dr. Robert Giloth, Vice President, Center for Community & Economic Opportunity, Annie E. Casey Foundation; Dr. LaDonna Pavetti, Vice President for Family Income Support Policy, the Center on Budget and Policy Priorities; Al Race, Deputy Director and Director of Communications and Public Engagement, Center on the Developing Child at Harvard University; Dr. James A. Riccio, Director, Low-Wage Workers and Communities Policy Area, MDRC; Brandon Roberts, Manager, Working Poor Families Project; Dr. Jack P. Shonkoff, Julius B. Richmond FAMRI Professor of Child Health and Development at the Harvard School of Public Health and the Harvard Graduate School of Education, Professor of Pediatrics at Harvard Medical School and Boston Children’s Hospital, and Director of the Center on the Developing Child at Harvard University; Tassy Warren, Project Director, Frontiers of Innovation Initiative, Center on the Developing Child at Harvard University. Crittenton Women’s Union would like to thank the Frontiers of Innovation Initiative (FOI) at the Center on the Developing Child at Harvard University for its support in the development of these ideas, and for helping to connect CWU with others interested in leveraging the science of brain development to improve programs and policies to better support vulnerable families. The goal of FOI is to bring about substantially improved outcomes for vulnerable young children whose needs (or whose caregivers’ needs) are not being fully met by existing policies and programs. To do that, FOI seeks to spur change in the field by forging cross-sector collaborations that promote creativity, support experimentation, and foster learning from experience. Elisabeth (Beth) Babcock has been the President and CEO of the Crittenton Women’s Union since 2006. Prior to that, she was the CEO of two other non-profit organizations. She obtained a Master’s Degree and PhD in non-profit strategy from Harvard University; her leadership and academic work have focused on the creation of stronger social impact through improved non-profit program and policy design. Economic Mobility Pathways (EMPath) is formerly known as Crittenton Women’s Union (CWU). Every document with Economic Mobility Pathways, EMPath, Crittenton Women’s Union, or CWU name or logo are under the same copyright restrictions. Copyright \u00a9 2016 Economic Mobility Pathways. All rights reserved. Crittenton Women’s Union One Washington Mall Boston, MA 02108 Tel: 617.259.2900 www.liveworkthrive.org The research of this publication has been funded by the Annie E. Casey Foundation. We thank them for their support but acknowledge that the findings and conclusions presented in this report are those of the author alone, and do not necessarily reflect the opinions of the Foundation. The research and production of this publication were also supported by Visit our website for more information. ”

” The Temporary Assistance for Needy Families (TANF) Block Grant: Responses to Frequently Asked Questions Gene Falk Specialist in Social Policy July 9, 2015 Author Contact Information Gene Falk Specialist in Social Policy [email protected] 202-707-5000 Congressional Research Service 7-5700 www.crs.gov RL32760 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service Summary The Temporary Assistance for Needy Families (TANF) block grant funds a wide range of benefits and services for low-income families with children. TANF was created in the 1996 welfare reform law (P.L. 104-193). This report responds to some frequently asked questions about TANF; it does not describe TANF rules (see, instead, CRS Report RL32748, The Temporary Assistance for Needy Families (TANF) Block Grant: A Primer on TANF Financing and Federal Requirements, by Gene Falk). TANF Funding. TANF provides fixed funding to states, the bulk of which is provided in a $16.5 billion-per-year basic federal block grant. States are also required in total to contribute, from their own funds, at least $10.4 billion under a maintenance-of-effort (MOE) requirement. Federal and State TANF Expenditures. Though TANF is best known for funding cash assistance payments for needy families with children, the block grant and MOE funds are used for a wide variety of benefits and activities. In FY2013, expenditures on basic assistance (cash assistance) totaled $8.7 billion\u201428% of total federal TANF and MOE dollars. TANF also contributes funds for child care and services for children who have been, or are at risk of being, abused and neglected. Cash Assistance Caseload. A total of 1.7 million families, composed of 4.2 million recipients, received TANF- or MOE-funded cash in December 2014. The bulk of the recipients were children\u20143.1 million in that month. The cash assistance caseload is heterogeneous. The type of family historically thought of as the typical cash assistance family\u2014one with an unemployed adult recipient\u2014accounted for less than half of all families on the rolls in FY2012. Additionally, 18% of cash assistance families had an employed adult, while 36% of all TANF families were child-only and had no adult recipient. Child-only families include those with disabled adults receiving Supplemental Security Income (SSI), adults who are nonparents (e.g., grandparents, aunts, uncles) caring for children, and families consisting of citizen children and ineligible noncitizen parents. Cash Assistance Benefits. TANF cash benefits are set by states. In July 2013, the maximum monthly benefit for a family of three ranged from $923 in Alaska to $170 in Mississippi. Benefits in all states represent a fraction of poverty-level income. In the median jurisdiction (the District of Columbia), the maximum monthly benefit of $428 for a family of three represents 26% of poverty-level income. Cash Assistance Work Requirements. TANF requires states to engage 50% of all families and 90% of two-parent families in work activities. However, these standards are reduced by the amount of a state’s caseload reduction from FY2005. Further, states may get an extra credit against these standards by spending more than required under the TANF MOE. Therefore, the effective standards states face are often less than the 50% or 90% targets, and vary by state. In FY2012 states achieved an all-family participation rate of 34.4% and a two-parent rate of 33.9%. That year, 16 jurisdictions failed the all-family standard, and 20 jurisdictions failed the two-parent standard. States that fail to meet work standards are at risk of being penalized by a reduction in their block grant. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service Contents Introduction …………………………………………………………………………………………………………………….. 1 Current Topics …………………………………………………………………………………………………………………. 1 What Is TANF’s Current Funding Status? ……………………………………………………………………… 1 What Is TANF’s Funding Level? ………………………………………………………………………………….. 1 May States Require Drug Testing of TANF Cash Assistance Recipients? ………………………….. 2 What Are TANF’s Rules for Drug Felons? …………………………………………………………………….. 2 What Are TANF’s Rules for Substance Abuse Treatment? ………………………………………………. 2 What Is the Administration’s Waiver Initiative? ………………………………………………………….. 3 Has Any State Formally Applied for a Waiver of TANF Work Participation Standards? ……………………………………………………………………………………………………………… 3 Are there Restrictions on a Family’s Use of TANF Benefits? …………………………………………… 3 Funding and Expenditures ………………………………………………………………………………………………… 4 How Much Has the TANF Grant Declined in Value Because of Inflation? ………………………… 4 How May States Use Federal TANF Funds? ………………………………………………………………….. 5 What Expenditures May a State Count Toward its Maintenance of Effort (MOE) Requirement?………………………………………………………………………………………………………….. 5 How Have States Used TANF Funds? …………………………………………………………………………… 6 How Much of the TANF Grant Has Gone Unspent? ……………………………………………………….. 7 The Caseload ………………………………………………………………………………………………………………….. 7 How Many Families Receive TANF- or MOE-Funded Benefits and Services? ………………….. 7 How Many Families and People Currently Receive TANF- or MOE-Funded Cash Assistance? …………………………………………………………………………………………………………….. 7 How Does the Current Cash Assistance Caseload Level Compare with Historical Levels? ………………………………………………………………………………………………………………….. 8 What Are the Characteristics of Cash Assistance Families? …………………………………………….. 9 TANF Cash Benefits: How Much Does a Family Receive in TANF Cash Per Month? ……………. 11 TANF Work Participation Standards ………………………………………………………………………………… 12 What Is the TANF Work Participation Standard States Must Meet? ………………………………… 12 Have There Been Changes in the Work Participation Rules Enacted Since the 1996 Welfare Reform Law? ……………………………………………………………………………………………. 13 What Work Participation Rates Have the States Achieved? ……………………………………………. 13 How Many Jurisdictions Have Failed the All-Families Standard From FY2002 Through FY2012? …………………………………………………………………………………………………. 14 Have States Met the Two-Parent Work Participation Standard? ……………………………………… 16 Figures Figure 1. Uses of TANF Federal Grants and State MOE Funds: FY2013 ………………………………… 6 Figure 2. Number of Families Receiving Cash Assistance, July 1959-December 2014……………… 9 Figure 3. Characteristics of Cash Assistance Families, Selected Years FY1988 to FY2012 ……… 10 Figure 4. TANF Cash Assistance Maximum Monthly Benefit Amounts for a Single Parent Family with Two Children, July 2013 ……………………………………………………………………………. 12 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service Figure 5. National Average TANF Work Participation Rate for All Families, FY2002- FY2012 ……………………………………………………………………………………………………………………… 14 Tables Table 1. Federal Funding for TANF Grants: FY2007 Through FY2015 ………………………………….. 1 Table 2. TANF Basic Block Grant Funding in Constant Dollars …………………………………………….. 4 Table 3. TANF Cash Assistance Caseload: December 2014 …………………………………………………… 8 Table 4. States Failing TANF All-Families Work Participation Standard: FY2002-FY2012 …….. 15 Table 5. Two-Parent TANF Work Participation Standard, Status by State: FY2002-FY2012 …………………………………………………………………………………………………………. 17 Table A-1. Temporary Extensions of TANF, FY2003-FY2006 …………………………………………….. 20 Table A-2. Temporary Extensions of TANF, FY2011-FY2015 …………………………………………….. 21 Table A-3. Use of TANF and State Maintenance of Effort Funds: FY2013 ……………………………. 22 Table A-4. Trends in the Cash Assistance Caseload: 1961 to 2014 ……………………………………….. 22 Table B-1. Use of FY2013 TANF and MOE Funds by Category ………………………………………….. 25 Table B-2. Use of FY2013 TANF and MOE Funds by Category as a Percent of Total Federal TANF and State MOE Funding …………………………………………………………………………. 28 Table B-3. Unspent TANF Funds at the End of FY2013 ……………………………………………………… 31 Table B-4. Number of Families, Recipients, Children, and Adults Receiving TANF Cash Assistance by State, December 2014 ……………………………………………………………………………… 32 Table B-5. Number of Needy Families with Children Receiving Cash Assistance by State, December of Selected Years …………………………………………………………………………………………. 34 Table B-6. TANF Families by Number of Parents in Assisted Unit by State: December 2014 ………………………………………………………………………………………………………………………….. 36 Table B-7. TANF Caseload Reduction Credits, Effective (After Credit) Standards, and Work Participation Rates by State, All Families, FY2012 …………………………………………………. 38 Table B-8. TANF Caseload Reduction Credits, Effective (After Credit) Standards, and Work Participation Rates by State, Two-Parent Families, FY2012 …………………………………….. 40 Appendixes Appendix A. Supplementary Tables …………………………………………………………………………………. 20 Appendix B. State Tables ………………………………………………………………………………………………… 25 Contacts Author Contact Information…………………………………………………………………………………………….. 42 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 1 Introduction This report provides responses to frequently asked questions about the Temporary Assistance for Needy Families (TANF) block grant. It is intended to serve as a quick reference to provide easy access to information and data. This report does not provide information on TANF program rules. For such information, see CRS Report RL32748, The Temporary Assistance for Needy Families (TANF) Block Grant: A Primer on TANF Financing and Federal Requirements, by Gene Falk. For a non-technical overview of TANF, see CRS Report R40946, The Temporary Assistance for Needy Families Block Grant: An Overview, by Gene Falk. Current Topics What Is TANF’s Current Funding Status? P.L. 113-235, the omnibus appropriation act for FY2015, extends TANF funding through September 30, 2015.1 What Is TANF’s Funding Level? Table 1 shows TANF funding for FY2007 through FY2015. The bulk of TANF funding is in a basic block grant (the state family assistance grant), which provides annual funding totaling $16.5 billion for the 50 states and District of Columbia. This grant amount was established in the 1996 welfare reform law and has not been changed since then. FY2015 funding for TANF grants is the same as in previous years, except for the TANF contingency fund. A total of $583 million is available for FY2015 contingency fund grants to states, compared with $610 million in FY2014. A total FY2015 contingency fund appropriation of $608 million includes set-asides of $15 million for HHS TANF research activities and $10 million for Census Bureau research activities related to TANF, leaving $583 million for contingency fund grants to states. Table 1. Federal Funding for TANF Grants: FY2007 Through FY2015 (Dollars in millions) 2007 2008 2009 2010 2011 2012 2013 2014 2015 State family assistance grant $16,489 $16,489 $16,489 $16,489 $16,489 $16,489 $16,489 $16,489 $16,489 Supplemental grants 319 319 319 319 211 0 0 0 0 Healthy marriage\/responsible fatherhood grants 150 150 150 150 150 150 150 150 150 Grants to the territories 78 78 78 78 78 78 78 78 78 Grants for tribal work programs 8 8 8 8 8 8 8 8 8 1 See Section 228 of Division G of P.L. 113-235. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 2 2007 2008 2009 2010 2011 2012 2013 2014 2015 Contingency fund 59 428 1,107 212 334 612 610a 610a 583b Emergency contingency fund 617 4,383 Totals 17,103 17,472 18,768 21,639 17,270 17,337 17,335 17,335 17,308 Source: Congressional Research Service (CRS), based on data from HHS. a. P.L. 112-275 appropriated $612 million to the TANF contingency fund for FY2013 and FY2014, and reserved $2 million in each year of these funds for a commission on child abuse and neglect fatalities. Thus, $610 million was available for FY2013 and FY2014 TANF contingency fund grants to states. b. P.L. 113-235 appropriated $608 million to the TANF contingency fund for FY2015 and FY2016, but sets aside from those funds $15 million for HHS welfare research activities and $10 million for U.S. Census Bureau activities related to welfare research. In addition to federal TANF funds, states are required in total to contribute, from their own funds, at least $10.4 billion per year for TANF-related activities for low-income families with children. This level of state funding, known as maintenance-of-effort (MOE) funding, was also established in the 1996 welfare law and has not been changed since then. May States Require Drug Testing of TANF Cash Assistance Recipients? Yes. The 1996 assistance reform law gave states the option of requiring drug tests for assistance recipients and penalizing those who fail such tests. (See Section 902 of P.L. 104-193.) However, specific state policies regarding drug testing raise constitutional issues. For a discussion of states that require drug testing in TANF and related programs, see CRS Report R42394, Drug Testing and Crime-Related Restrictions in TANF, SNAP, and Housing Assistance, by Maggie McCarty et al. See also CRS Report R42326, Constitutional Analysis of Suspicionless Drug Testing Requirements for the Receipt of Governmental Benefits, by David H. Carpenter. What Are TANF’s Rules for Drug Felons? The 1996 welfare reform law established a lifetime ban on eligibility for TANF and food stamps for those convicted of a drug-related felony. However, states may either opt out entirely or modify and limit this lifetime ban. (See Section 115 of P.L. 104-193.)2 What Are TANF’s Rules for Substance Abuse Treatment? States may use TANF funds for substance abuse treatment. Federal TANF dollars cannot be used for medical services, but can be used for non-medical treatment such as counseling. State MOE dollars can be used for medical services connected with substance abuse treatment. 2 TANF also bars aid to fleeing felons and people convicted of welfare fraud by misrepresenting their state of residence. For an overview of rules for TANF, as well as those for the Supplemental Nutrition Assistance Program (SNAP) and housing assistance programs related to drug testing and crime-related issues, see CRS Report R42394, Drug Testing and Crime-Related Restrictions in TANF, SNAP, and Housing Assistance, by Maggie McCarty et al. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 3 TANF requires states to conduct an employability assessment of adult recipients, and allows states to establish Individual Responsibility Plans (IRPs) for their TANF families. The IRP may require participation in a substance abuse treatment program. A family may be sanctioned for failure to comply with its IRP. Additionally, a state may engage recipients in substance abuse treatment and count that activity toward its work participation standard, though such an activity is counted only for a limited period of time. Substance abuse treatment is considered a job readiness activity; a state may count job search and job readiness activities for a maximum of 12 weeks in a year toward its work participation standards. What Is the Administration’s Waiver Initiative? On July 12, 2012, the Department of Health and Human Services (HHS) announced that it would accept applications for waivers of the TANF work participation standards. In general, these are waivers of the way the performance of state welfare-to-work programs are assessed, the federal work participation standards. For a discussion, see CRS Report R42627, Temporary Assistance for Needy Families (TANF): Welfare Waivers, by Gene Falk. Has Any State Formally Applied for a Waiver of TANF Work Participation Standards? As of July 7, 2015, no state had formally applied for a waiver of TANF work participation standards under the Administration’s waiver initiative. Are there Restrictions on a Family’s Use of TANF Benefits? TANF funds a wide range of benefits and services, many of which are for specific purposes. However, TANF is best known for helping states finance their cash public assistance programs for needy families with children. The cash benefits are often paid on an Electronic Benefit Transaction (EBT) card that a recipient can take to an Automated Teller Machine (ATM) to draw cash or use to purchase goods and services at a point-of-sale device. As cash, there are no restrictions on the types of goods and services that can be purchased with a TANF benefit. However, TANF law does restrict where a recipient might access benefits at an ATM. P.L. 112-96 prevents electronic benefit transaction access to TANF cash at liquor stores, casinos, and strip clubs. States are required to prohibit access to TANF cash at Automated Teller Machines (ATMs) at such establishments. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 4 Funding and Expenditures How Much Has the TANF Grant Declined in Value Because of Inflation? From FY1997 (the first full year of TANF funding) through FY2014 (ended September 30, 2014), the real value of the TANF block grant declined by 32.3%. Table 2 shows the impact of inflation on the value of the TANF block grant for each year, FY1997 through FY2014. On average, the TANF basic block grant has lost 2.3% of its value each year over that period. Table 2. TANF Basic Block Grant Funding in Constant Dollars Fiscal Year Value of the Basic TANF Block Grant in FY1997 Dollars ($ in billions) Cumulative Change in Value of the Basic Block Grant from FY1997 Levels 1997 $16.5 1998 16.2 -1.6% 1999 15.9 -3.5 2000 15.4 -6.4 2001 14.9 -9.4 2002 14.7 -10.7 2003 14.4 -12.7 2004 14.1 -14.7 2005 13.6 -17.4 2006 13.1 -20.4 2007 12.8 -22.2 2008 12.3 -25.5 2009 12.3 -25.3 2010 12.1 -26.5 2011 11.8 -28.4 2012 11.5 -30.1 2013 11.3 -31.2 2014 11.2 -32.3 Average Annual Rate of Change in the Value of the Block Grant -2.3% Source: Congressional Research Service (CRS) based on data from the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Labor, Bureau of Labor Statistics (BLS). Notes: Constant dollars were computed using the Consumer Price Index for all Urban Consumers (CPI-U). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 5 How May States Use Federal TANF Funds? TANF is a broad-purpose block grant that gives states the flexibility to use its funds to address both the effects of, and the root causes of, childhood economic disadvantage. There are two sets of rules: those that relate to the use of federal TANF grants, and those for which state expenditures count toward meeting the TANF MOE state spending requirement. States have broad discretion on how they expend federal TANF grants. States may use TANF funds in any manner that is reasonably calculated to accomplish the block grant’s statutory purpose. That purpose is to increase the flexibility of states in operating a program designed to 1. provide assistance to needy families so that children may be cared for in their own homes or in the homes of relatives; 2. end the dependence of needy parents on government benefits by promoting job preparation, work, and marriage; 3. prevent and reduce the incidence of out-of-wedlock pregnancies and establish annual numerical goals for preventing and reducing the incidence of these pregnancies; and 4. encourage the formation and maintenance of two-parent families. In addition, states may also expend federal TANF grants on any activity financed by pre-TANF programs. These are known as grandfathered activities. Examples of activities that do not meet a TANF goal but may be financed by TANF grants include foster care payments and funding for juvenile justice activities, if they were financed in the pre-TANF programs. In addition to expending federal funds on allowable TANF activities, federal law permits a limited amount of the federal TANF basic block grant to be used for other programs. A maximum of 30% of the TANF block grant may be used for the following combined transfers or expenditures: (1) transfers to the Child Care and Development Block Grant; (2) transfers to the Social Services Block Grant (SSBG), with a maximum transfer to the SSBG set at 10% of the basic block grant; (3) as state match for reverse commuter grants, providing public transportation from inner cities to the suburbs. What Expenditures May a State Count Toward its Maintenance of Effort (MOE) Requirement? The range of expenditures on activities that states may count toward the maintenance of effort requirement is\u2014like the authority to spend federal funds\u2014quite broad. The expenditures need not be in the TANF program itself, but in any program that provides benefits and services to TANF-eligible families in cash assistance, child care assistance, education and job training, administrative costs, or any other activity designed to meet TANF’s statutory goals. States may count expenditures made by local governments toward the MOE requirement. Additionally, there is a general rule of federal grants management that permits states to count as a state expenditure third-party in-kind donations, as long as they meet the requirements of providing benefits or services to TANF-eligible families and meet the requirements of the types of activities that states may count toward the MOE requirement. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 6 The MOE requirement sets a minimum amount that states must expend from their own funds. Under current law, there are incentives for states to expend funds beyond this minimum. States must spend more than the minimum MOE to access TANF contingency funds. Additionally, states can receive extra credit toward their work participation standards for spending more than the minimum required. How Have States Used TANF Funds? Figure 1 shows the uses of federal TANF grants to states and state MOE funds in FY2013. In FY2013, a total of $31.6 billion of both federal TANF and state MOE expenditures were either expended or transferred to other block grant programs. Basic assistance, the category that most closely reflects cash assistance, represented 28% ($8.7 billion) of total FY2013 TANF and MOE dollars. TANF is a major contributor of child care funding. In FY2013, 16% of all TANF funds used were either expended on child care or transferred to the child care block grant (the Child Care and Development Fund, or CCDF). TANF is also a major contributor to the child welfare system, which provides foster care, adoption assistance, and services to families with children who either have experienced or are at risk of experiencing child abuse or neglect. However, TANF’s accounting system does a poor job of capturing expenditures associated with spending on the child welfare system. Most TANF funding for these programs is subsumed in the catch-all other expenditure category. Figure 1. Uses of TANF Federal Grants and State MOE Funds: FY2013 (Total = $31.6 Billion) Source: : Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). See Appendix A, Table A-3 for dollar amounts of total federal TANF and state MOE funds associated with each of these categories. For state-specific information on the use of TANF funds, see Table B-1 and Table B-2. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 7 How Much of the TANF Grant Has Gone Unspent? TANF law permits states to reserve unused funds without time limit. This permits flexibility in timing of the use of TANF funds, including the ability to save funds for unexpected occurrences that might increase costs (such as recessions or natural disasters). At the end of FY2013 (September 30, 2013, the latest data currently available), a total of $3.0 billion of federal TANF funding remained neither transferred nor spent. However, some of these unspent funds represent monies that states had already committed to spend later. At the end of FY2013, states had made such commitments to spend\u2014that is, had obligated\u2014a total of $1.5 billion. Generally, obligations are binding commitments to spend, and they come in the form of contracts and grants to provide benefits and services. However, the definition of obligation varies from program to program, and because TANF essentially consists of 54 different programs (one for each state, the District of Columbia, and the territories), what constitutes an obligation may vary. At the end of FY2013, states also had $1.5 billion of unobligated balances. These funds are available to states to make new spending commitments. Table B-3 shows unspent TANF funds by state. The Caseload How Many Families Receive TANF- or MOE-Funded Benefits and Services? This number is not known. Federal TANF reporting requirements focus on families receiving only ongoing cash assistance, with no complete reporting on families receiving other TANF benefits and services. As discussed in a previous section of this report, TANF basic assistance accounts for about 28% of all TANF expenditures. Therefore, the federal reporting requirements that pertain to families receiving assistance are likely to undercount the number of families receiving any TANF-funded benefit or service. How Many Families and People Currently Receive TANF- or MOE- Funded Cash Assistance? Table 3 provides cash assistance caseload information. A total of 1.7 million families, composed of 4.2 million recipients, received TANF- or MOE-funded cash in December 2014. The bulk of the recipients were children\u20143.1 million in that month. For state-by-state cash assistance caseloads, see Table B-4. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 8 Table 3. TANF Cash Assistance Caseload: December 2014 Families 1,674,536 Total Recipients 4,216,251 Total Children 3,055,382 Total Adults 1,160,869 Source: Congressional Research Service (CRS) based on data from the U.S. Department of Health and Human Services (HHS). Notes: TANF cash assistance caseload includes families receiving assistance in state-funded programs counted toward the TANF maintenance of effort (MOE) requirement. How Does the Current Cash Assistance Caseload Level Compare with Historical Levels? Figure 2 provides a long-term historical perspective on the number of families receiving cash assistance, from July 1959 to December 2014. Before 1996, these are families that received cash assistance from the Aid to Families with Dependent Children (AFDC) program. From 1997 onward, these are families that received cash assistance from TANF. The shaded areas of the figure represent months when the national economy was in recession. Though the health of the national economy affected the trend in the cash assistance caseload, the long-term trend in receipt of cash assistance does not follow a classic counter-cyclical pattern. (Such a pattern would have the caseload rise during economic slumps, and then fall again during periods of economic growth.) Factors other than the health of the economy (demographic trends, policy changes) also influenced the caseload trend. The figure shows two periods of sustained caseload increases: the period from the mid-1960s to the mid-1970s and a second period from 1988 to 1994. The number of families receiving cash assistance peaked in March 1994 at 5.1 million families. The cash assistance caseload fell rapidly in the late 1990s (after the 1996 welfare reform law) before leveling off in 2001. In 2004, the caseload began another decline, albeit at a slower pace than in the late 1990s. During the recent 2007-2009 recession and its aftermath, the caseload began to rise from its post- welfare reform low in August 2008 (1.7 million families), peaking in December 2010 at close to 2.0 million families. By December 2014, the cash assistance caseload had declined to approximately match its post-welfare reform low at about 1.7 million families. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 9 Figure 2. Number of Families Receiving Cash Assistance, July 1959-December 2014 0 1 2 3 4 5 6 1959 1964 1969 1974 1979 1984 1989 1994 1999 2004 2009 2014 MAR 1994 Historic Peak: 5.1 million families DEC 2014 1.7 million families Millions of Families Source: Congressional Research Service (CRS) with data from the U.S. Department of Health and Human Services (HHS). Notes: Shaded areas denotes months when the national economy was in recession. Information represents families receiving cash assistance from Aid to Dependent Children (ADC), Aid to Families with Dependent Children (AFDC), and TANF. For October 1999 through December 2014, includes families receiving assistance from Separate State Programs (SSPs) with expenditures countable toward the TANF maintenance of effort requirement. See Table A-4 for average annual data on families, recipients, adult recipients, and child recipients of ADC,\/AFDC and TANF cash assistance for 1961 to 2014. Table B-5 shows recent trends in the number of cash assistance families by state. What Are the Characteristics of Cash Assistance Families? Historically, the typical cash assistance family has been headed by a single parent (usually the mother) with one or two children. The single parent has also typically been unemployed. However, the cash assistance caseload decline has occurred together with a major shift in the composition of the rolls. Figure 3 shows the change in the size and composition of the cash assistance caseload under both AFDC (1988 and 1994) and under TANF. In FY1988, 84% of AFDC families were headed by an unemployed adult recipient. In FY2012, families with an unemployed adult recipients represented 45% of all cash assistance families. This decline occurred, in large part, as the number of families headed by unemployed adult recipients declined. With the decline in families headed by unemployed adults, the share of the caseload that represented families with employed adults and child only families has increased. In FY2012, families with employed adult recipients represented 18% of all cash assistance families. Child- only families are those where no adult recipient receives benefits in their own right; the family receives benefits on behalf of its children. The share of the caseload that was child-only in The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 10 FY2012 was 36.5%. In FY2012, families with a non-recipient, non-parent relative (grandparents, aunts, uncles) represented 12% of all cash assistance families. Families with ineligible, noncitizen adults or adults who have not reported their citizenship status made up 11% of the cash assistance caseload in that year. Families where the parent received Supplemental Security Income (SSI) and the children received TANF made up 9% of all cash assistance families in FY2012. Figure 3. Characteristics of Cash Assistance Families, Selected Years FY1988 to FY2012 Source: Congressional Research Service (CRS) tabulations of the TANF national data files. Notes: TANF cash assistance caseload includes families receiving assistance in state-funded programs counted toward the TANF maintenance of effort (MOE) requirement. For more information on the characteristics and the changes in the composition of the cash assistance caseload, see CRS Report R43187, Temporary Assistance for Needy Families (TANF): Size and Characteristics of the Cash Assistance Caseload, by Gene Falk. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 11 TANF Cash Benefits: How Much Does a Family Receive in TANF Cash Per Month? There are no federal rules that help determine the amount of TANF cash benefits paid to a family. (There are also no federal rules that require states to use TANF to pay cash benefits, though all states do so.) Benefit amounts are determined solely by the states. Most states base TANF cash benefit amounts on family size, paying larger cash benefits to larger families on the presumption that they have greater financial needs. The maximum monthly cash benefit is usually paid to a family that receives no other income (e.g., no earned or unearned income) and complies with program rules. Families with income other than TANF often are paid a reduced benefit. Moreover, some families are financially sanctioned for failure to meet a program requirement (e.g., a work requirement), and are also paid a lower benefit. Figure 4 shows the maximum monthly TANF cash benefit by state for a single mother caring for two children (family of three) in July 2013.3 The benefit amounts shown are those for a single- parent family with two children. Some states vary their benefit amounts for other family types such as two-parent families or child-only cases. States also vary their benefits by other factors such as housing costs and sub-state geography. For a family of three, the maximum TANF benefit paid in July 2013 varied from $170 per month in Mississippi to $923 per month in Alaska. In all states, the maximum TANF cash assistance amount for this sized family was less than 50% of poverty-level income. 4 3 States are not required to report to the federal government their cash assistance benefit amounts in either the TANF state plan (under Section 402 of the Social Security Act) or in annual program reports (under Section 411 of the Social Security Act). The benefit amounts shown are from the Welfare Rules Database, maintained by the Urban Institute and funded by the Department of Health and Human Services (HHS). 4 In 2013, the HHS poverty guidelines for the contiguous 48 states and the District of Columbia for a family of 3 was $1,628 per month. Higher poverty lines applied in Alaska ($2,034 per month for a family of 3) and Hawaii ($1,873 per month for a family of 3). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 12 Figure 4. TANF Cash Assistance Maximum Monthly Benefit Amounts for a Single Parent Family with Two Children, July 2013 Source: Congressional Research Service (CRS), based on data from the Urban Institute’s Welfare Rules Database. For additional information on TANF benefit amounts by state, see CRS Report R43634, Temporary Assistance for Needy Families (TANF): Eligibility and Benefit Amounts in State TANF Cash Assistance Programs, by Gene Falk. TANF Work Participation Standards What Is the TANF Work Participation Standard States Must Meet? The TANF statute requires states to have 50% of their caseload meet standards of participation in work or activities\u2014that is, a family member must be in specified activities for a minimum number of hours.5 There is a separate participation standard that applies to the two-parent portion of a state’s caseload, requiring 90% of the state’s two-parent caseload to meet participation standards. States that fail the TANF work participation standards are at risk of being penalized by a reduction in their block grant amounts. 5 Some families are excluded from the participation rate calculation. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 13 However, the statutory work participation standards are reduced by a caseload reduction credit. The caseload reduction credit reduces the participation standard one percentage point for each percentage point decline in a state’s caseload. Additionally, under a regulatory provision, a state may get extra credit for caseload reduction if it spends more than required under the TANF MOE. Therefore, the effective standards states face are often less than the 50% and 90% targets, and vary by state and by year. States that fail to meet the TANF work participation standard are at risk of being penalized through a reduction in their block grant. However, penalties can be forgiven if a state claims, and the Secretary of HHS finds, that it had reasonable cause for failing the standard. Penalties can also be forgiven for states that enter into corrective compliance plans, and subsequently meet the work standard. Have There Been Changes in the Work Participation Rules Enacted Since the 1996 Welfare Reform Law? The 50% and 90% target standards that states face, as well as the caseload reduction credit, date back to the 1996 welfare reform law. However, the Deficit Reduction Act of 2005 (P.L. 109-171) made several changes to the work participation rules effective in FY2007: The caseload reduction credit was changed to measure caseload reduction from FY2005, rather than the original law’s FY1995. The work participation standards were broadened to include families receiving cash aid in separate state programs. Separate state programs are programs run with state funds, distinct from a state’s TANF program, but with expenditures countable toward the TANF MOE. HHS was instructed to provide definition to the allowable TANF work activities listed in law. HHS was also required to define what is meant by a work-eligible individual, expanding the number of families that are included in the work participation calculation. States were required to develop plans and procedures to verify work activities. The American Recovery and Reinvestment Act of 2009 (ARRA, P.L. 111-5), a law enacted in response to the sharp economic downturn of 2007-2009, held states harmless for caseload increases affecting the work participation standards for FY2009 through FY2011. It did so by allowing states to freeze caseload reduction credits at pre-recession levels through the FY2011 standards. What Work Participation Rates Have the States Achieved? HHS computes two work participation rates for each state that are then compared with the effective (after-credit) standard to determine if it has met the TANF work standard. An all- families work participation rate is computed and compared with the all-families effective standard (50% minus the state’s caseload reduction credit). HHS also computes a two-parent work participation rate that is compared with the two-parent effective standard (90% minus the state’s caseload reduction credit). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 14 Figure 5 shows the national average all-families work participation rate for FY2002 through FY2012. For the period FY2002 through FY2011, states have achieved an all-families work participation rate hovering around 30%. In FY2012, the all-families work participation rate ticked up to 34.4%. In that year, states faced higher work participation standards because the freeze to the caseload reduction credit enacted in ARRA expired. Figure 5. National Average TANF Work Participation Rate for All Families, FY2002- FY2012 28.9% 27.5% 29.4% 30.3% 30.6% 29.7% 29.4% 29.4% 29.0% 29.5% 34.4% 0% 10% 20% 30% 40% 50% FY02 FY03 FY04 FY05 FY06 FY07 FY08 FY09 FY10 FY11 FY12 Work Participation Rate Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). How Many Jurisdictions Have Failed the All-Families Standard From FY2002 Through FY2012? Table 4 shows which states failed the TANF all-families work participation standards from FY2002 through FY2012. Before FY2007, only a few jurisdictions failed to meet TANF all- families work participation standards. However, in FY2007, 15 jurisdictions failed to meet the all-families standard. FY2007 was the first year policies under the DRA were effective. This number declined to nine in FY2008 and eight in FY2009. In FY2012, despite the uptick in the national average work participation rate, 16 states failed to meet the all-family standard, the largest number of states that did not meet their participation standards in any one year since the enactment of TANF. FY2012 was the year that ARRA’s freeze of the caseload reduction credit expired, and states were generally required to meet higher standards than in previous years. For state-by-state information on FY2012 caseload reduction credits, effective (after credit) standards, and work participation rates related to the all families standard, see Table B-7. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 15 Table 4. States Failing TANF All-Families Work Participation Standard: FY2002-FY2012 (Changes to TANF Work Participation Standard Rules Under the Deficit Reduction Act of 2005 (DRA) Effective in FY2007) Pre-DRA Post-DRA State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Alabama Alaska X Arizona Arkansas California X X X X X X Colorado X Connecticut X Delaware District of Columbia X X X Florida Georgia Hawaii Idaho X Illinois Indiana X X X Iowa Kansas Kentucky X Louisiana Maine X X X X X X Maryland Massachusetts Michigan X X X X Minnesota X Mississippi Missouri X X X X Montana Nebraska Nevada X X X New Hampshire New Jersey New Mexico X The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 16 Pre-DRA Post-DRA State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 New York North Carolina North Dakota Ohio X X X X X Oklahoma Oregon X X X X X X Pennsylvania Puerto Rico X X X X X X Rhode Island X South Carolina X South Dakota Tennessee Texas Utah Vermont X X Virginia X Washington X West Virginia X X Wisconsin X Wyoming Guam X X X X X X X X X X X Virgin Islands X Totals 1 2 1 2 3 15 9 8 8 9 16 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Have States Met the Two-Parent Work Participation Standard? In addition to meeting a work standard for all families, TANF also imposes a second, 90% standard for the two-parent portion of its cash assistance caseload. This standard too can be reduced for caseload reduction. Table 5 shows whether each state met its two-parent work participation standard for FY2002 through FY2012. However, the display on the table is more complex than that for reporting whether a state failed its all family rate. A substantial number of states have reported no two- The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 17 parent families subject to the work participation standard.6 These states are denoted on the table with an NA, indicating that the two-parent standard was not applicable to the state in that year. For states with two-parent families in its caseload, the table reports Yes for states that met the two-parent standard, and No for states that failed the two-parent standard. In FY2012, 27 jurisdictions reported that no two-parent families were included in the TANF work participation standard calculation. Of the 27 jurisdictions that had two-parent families in their TANF work participation calculation, 7 met the standard and 20 did not. For state-by-state information on FY2012 caseload reduction credits, effective (after credit) standards, and work participation rates related to two-parent families, see Table B-8. Table 5. Two-Parent TANF Work Participation Standard, Status by State: FY2002-FY2012 ( Yes indicates a state met the standard; No indicates the state failed to meet the standard; and NA means the standard was not applicable to the state in that year [no two-parent families in its caseload].) Pre- Deficit Reduction Act (DRA) Post-Deficit Reduction Act (DRA) State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Alabama NA NA NA NA NA YES YES YES YES YES YES Alaska YES YES YES YES YES NO NO NO NO YES NO Arizona YES YES YES YES YES YES YES YES YES YES YES Arkansas NO NO NO YES NO YES YES YES YES YES NO California NA NA NA NA NA YES YES YES YES YES NO Colorado YES YES YES YES YES YES YES YES YES YES NO Connecticut NA NA NA NA NA YES NA NA NA NA NA Delaware NA NA NA NA NA NA NA NA NA NA NA District of Columbia NO NO NO NO NO NA NA NA NA NA NA Florida NA NA NA NA NA YES YES YES YES YES NO Georgia NA NA NA NA NA NA NA NA NA NA NA Hawaii NA NA NA NA NA NA YES NA YES YES YES Idaho YES YES YES YES YES NA NA NA NA NA NA Illinois NA NA NA NA NA NA NA NA NA NA NA Indiana NA NA NA NA NA NO YES YES YES YES NO Iowa YES YES NA NA NA YES YES YES YES YES NO Kansas YES YES YES YES YES YES YES YES YES YES NO Kentucky YES YES YES YES YES YES NO NO YES YES NO Louisiana YES YES YES YES YES NA NA NA NA NA NA 6 Before the changes made by the DRA were effective, a number of states had their two-parent families in separate state programs that were not included in the work participation calculation. When DRA brought families receiving assistance in separate state programs into the work participation rate calculations, a number of states moved these families into solely-state-funded programs. These are state-funded programs with expenditures not countable toward the TANF maintenance of effort requirement, and hence are outside of TANF’s rules. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 18 Pre- Deficit Reduction Act (DRA) Post-Deficit Reduction Act (DRA) State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Maine YES YES NA NA NA YES NO NO NO NO NO Maryland NA NA NA NA NA NA NA NA NA NA NA Massachusetts YES YES YES YES MA NA YES YES YES NA YES Michigan YES YES YES YES YES NA NA NA NA NA NA Minnesota NA NA NA NA NA NA NA NA NA NA NA Mississippi NA NA NA NA NA NA NA NA NA NA NA Missouri NO NA NA NA NA NA NA NA NA NA NA Montana YES YES YES YES YES YES YES YES YES YES YES Nebraska NA NA NA NA NA NA NA NA NA NA NA Nevada NA NA NA NA NA NO NO NO NO NO NO New Hampshire YES NA NA NA NA NA NA NA NA NA NA New Jersey NA NA NA NA NA NA NA NA NA NA NA New Mexico YES YES YES YES YES NO YES YES YES YES NO New York YES YES YES YES YES NA NA NA NA NA NA North Carolina YES YES YES YES YES YES YES YES YES YES YES North Dakota NA NA NA NA NA NA NA NA NA NA NA Ohio YES YES YES YES YES NO YES YES YES YES NO Oklahoma NA YES NA NA NA NA NA NA NA NA NA Oregon YES YES YES YES YES NO NO NO NO NO NO Pennsylvania YES YES YES YES YES YES YES YES YES YES YES Puerto Rico NA NA NA NA NA NA NA NA NA NA NA Rhode Island YES YES YES YES YES YES YES NO NO NO NO South Carolina YES YES YES YES YES YES NA NA NA NA NA South Dakota NA NA NA NA NA NA NA NA NA NA NA Tennessee NA NA NA NA NA YES YES YES YES YES NA Texas NA NA NA NA NA YES NA NA NA NA NA Utah NA NA NA NA NA NA NA NA NA NA NA Vermont YES YES YES YES YES YES YES YES YES YES NO Virginia NA NA NA NA NA NA NA NA NA NA NA Washington YES YES NO YES YES YES YES YES YES YES NO West Virginia NO NO NA NA NA NO NA NA YES NA NA Wisconsin YES YES YES YES YES YES YES YES YES YES NO Wyoming YES YES YES YES YES YES YES YES YES YES NO Guam NO NO NO NO NO NO NO NO NO NO NO Virgin Islands NA NA NA NA NA NA NA NA NA NA NA The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 19 Pre- Deficit Reduction Act (DRA) Post-Deficit Reduction Act (DRA) State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Number of Jurisdictions without Two-Parent Families 24 25 29 29 29 24 26 27 25 27 27 Number of Jurisdictions with Two-Parent Families 30 29 25 25 25 30 28 27 29 27 27 Number of Jurisdictions Meeting Two-Parent Standard 25 25 21 23 21 22 22 20 23 22 7 Number of Jurisdictions Failing Two-Parent Standard 5 4 4 2 3 7 6 7 6 5 20 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 20 Appendix A. Supplementary Tables Table A-1. Temporary Extensions of TANF, FY2003-FY2006 Public Law Time Period Notes P.L. 107-229 Oct. 1, 2002-Dec. 31, 2002 Extension as part of a continuing resolution. P.L. 107-294 Jan. 1, 2003-Mar. 31, 2003 Extension as part of a continuing resolution. P.L. 108-7 Apr. 1, 2003-June 30, 2003 Extension as part of the Consolidated Appropriations Act. P.L. 108-40 July 1, 2003-Sept. 30, 2003 Free-standing bill that amended the Social Security Act to extend TANF and related programs. P.L. 108-89 Oct. 1, 2003-Mar. 31, 2004 Multipurpose bill that extended programs through the first half of FY2004. P.L. 108-210 Apr. 1, 2004-June 30, 2004 Freestanding bill that extended funding authority for the program through June 30, 2004. P.L. 108-262 July 1, 2004-Sept. 30, 2004 Freestanding bill that extended funding authority for the program through Sept. 30, 2004. P.L. 108-308 Oct. 1, 2004- Mar. 31, 2005 Freestanding bill that extended funding authority for the programs through Mar. 31, 2005. P.L. 109-4 Apr. 1, 2005-June 30, 2005 Freestanding bill that extended funding authority for the programs through June 30, 2005. P.L. 109-19 July 1, 2005-Sept. 30, 2005 Freestanding bill that extended funding authority for the programs through Sept. 30, 2005. P.L. 109-68 Oct. 1, 2005-Dec. 31, 2005 Bill to provide extra funding to help states provide benefits to families affected by Hurricane Katrina, suspend certain requirements in states affected by the hurricane, and extend the funding authority for the programs through December 31, 2005. P.L. 109-161 Jan. 1, 2006-Mar. 31, 2006 Freestanding bill that extended funding authority for the programs through March 31, 2006. It reduced the bonus for reducing out-of-wedlock births for FY2006-FY2010 to offset the costs of the temporary extension. Source: Congressional Research Service (CRS). Note: Table shows extensions through 2006, when the Deficit Reduction Act of 2005 (P.L. 109-171) extended TANF through FY2010. Temporary extensions after 2010 are shown in Table A-2. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 21 Table A-2. Temporary Extensions of TANF, FY2011-FY2015 Public Law Time Period Notes P.L. 111-242 Oct. 1, 2010-Dec. 3, 2010 Extension as part of a continuing resolution. P.L. 111-290 Dec. 4, 2010-Dec. 7, 2010 Extension as part of a continuing resolution. P.L. 111-291 Dec. 8, 2010-Sept. 30, 2011 (except supplemental grants, Dec. 8, 2010-June 30, 2011) Extension as part of the Claims Resolution Act of 2010. It funded supplemental grants only through the first three quarters of FY2011 and at a reduced rate. P.L. 112-35 Oct. 1, 2011-Dec. 31, 2011 Free-standing bill to extend TANF for three months. No funding for TANF supplemental grants. P.L. 112-78 Jan 1, 2012-Feb. 21, 2012 Extension of TANF for two months, as part of a bill to provide a two-month extension for the 2011 payroll tax reduction, extended unemployment compensation, and other expiring provisions. P.L. 112-96 Feb. 22, 2012-Sept. 30, 2012 Extension of TANF for the remainder of FY2012 included as part of a bill to extend the 2011 payroll tax reduction, unemployment compensation, and other expiring provisions. P.L. 112-175 Oct. 1, 2011-March 27, 2013 Extension of TANF for the first six months of FY2013 as part of a continuing resolution. P.L. 113-6 March 28, 2013-Sept. 30, 2013 Extension of TANF for the remainder of FY2013 as part of a continuing resolution. P.L. 113-46 Oct. 17, 2013-Jan 15, 2014 Extension of TANF as a part of a continuing resolution. The resolution ended the government shutdown, and a TANF funding gap between Oct 1 and Oct 16, 2013 P.L. 113-73 Jan. 16, 2014-Jan. 18, 2014 Extension of TANF funding as part of a short-term continuing resolution. P.L. 113-76 Jan 19, 2014-Sept. 30, 2014 Extension of TANF funding for the remainder of FY2014 as part of an omnibus appropriation act. P.L. 113-164 Oct. 1, 2014-Dec 11, 2014 Extension of TANF funding through Dec. 11, 2014, as part of a continuing resolution. P.L. 113-202 Dec. 12, 2014-Dec 13, 2014 Extension of TANF funding through Dec. 13, 2014, as part of a short-term continuing resolution. P.L. 113-203 Dec 14, 2014-Dec 17, 2014 Extension of TANF funding through Dec. 17, 2014, as part of a short-term continuing resolution. P.L. 113-235 Dec. 18, 2014-Sept. 30, 2015 Extension of TANF funding for the remainder of FY2015 as part of an omnibus appropriations act. Source: Congressional Research Service (CRS). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 22 Table A-3. Use of TANF and State Maintenance of Effort Funds: FY2013 (Dollars in Billions) Billions of Dollars Percent of Total Federal TANF and State MOE Dollars Basic Assistance $8.7 27.6% Administration 2.3 7.2 Work Program Expenditures 2.0 6.4 Child Care 5.0 15.8 Other Work Supports 2.8 9.0 Other Expenditures 10.7 33.9 Totals 31.6 100.0 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services. Table A-4. Trends in the Cash Assistance Caseload: 1961 to 2014 TANF Child Recipients Year Families (millions) Recipients (millions) Adults (millions) Children (millions) As a Percent of All Children As a Percent of All Poor Children 1961 0.873 3.363 0.765 2.598 3.7% 14.3% 1962 0.939 3.704 0.860 2.844 4.0 15.7 1963 0.963 3.945 0.988 2.957 4.1 17.4 1964 1.010 4.195 1.050 3.145 4.3 18.6 1965 1.060 4.422 1.101 3.321 4.5 21.5 1966 1.096 4.546 1.112 3.434 4.7 26.5 1967 1.220 5.014 1.243 3.771 5.2 31.2 1968 1.410 5.702 1.429 4.274 5.9 37.8 1969 1.696 6.689 1.716 4.973 6.9 49.7 1970 2.207 8.462 2.250 6.212 8.6 57.7 1971 2.763 10.242 2.808 7.435 10.4 68.5 1972 3.048 10.944 3.039 7.905 11.1 74.9 1973 3.148 10.949 3.046 7.903 11.2 79.9 1974 3.219 10.847 3.041 7.805 11.2 75.0 1975 3.481 11.319 3.248 8.071 11.8 71.2 1976 3.565 11.284 3.302 7.982 11.8 76.2 1977 3.568 11.015 3.273 7.743 11.6 73.9 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 23 TANF Child Recipients Year Families (millions) Recipients (millions) Adults (millions) Children (millions) As a Percent of All Children As a Percent of All Poor Children 1978 3.517 10.551 3.188 7.363 11.2 72.8 1979 3.509 10.312 3.130 7.181 11.0 68.0 1980 3.712 10.774 3.355 7.419 11.5 63.2 1981 3.835 11.079 3.552 7.527 11.7 59.2 1982 3.542 10.358 3.455 6.903 10.8 49.6 1983 3.686 10.761 3.663 7.098 11.1 50.1 1984 3.714 10.831 3.687 7.144 11.2 52.3 1985 3.701 10.855 3.658 7.198 11.3 54.4 1986 3.763 11.038 3.704 7.334 11.5 56.0 1987 3.776 11.027 3.661 7.366 11.5 56.4 1988 3.749 10.915 3.586 7.329 11.4 57.8 1989 3.798 10.992 3.573 7.419 11.5 57.9 1990 4.057 11.695 3.784 7.911 12.1 57.9 1991 4.497 12.930 4.216 8.715 13.2 59.8 1992 4.829 13.773 4.470 9.303 13.9 59.9 1993 5.012 14.205 4.631 9.574 14.1 60.0 1994 5.033 14.161 4.593 9.568 13.9 61.7 1995 4.791 13.418 4.284 9.135 13.1 61.5 1996 4.434 12.321 3.928 8.600 12.3 58.7 1997 3.740 10.376 NA NA 10.0 50.1 1998 3.050 8.347 NA NA 8.1 42.9 1999 2.578 6.924 NA NA 6.7 39.4 2000 2.303 6.143 1.655 4.479 6.1 38.1 2001 2.192 5.717 1.514 4.195 5.7 35.3 2002 2.187 5.609 1.479 4.119 5.6 33.6 2003 2.180 5.490 1.416 4.063 5.5 31.3 2004 2.153 5.342 1.362 3.969 5.4 30.2 2005 2.061 5.028 1.261 3.756 5.1 28.9 2006 1.906 4.582 1.120 3.453 4.6 26.7 2007 1.730 4.075 0.956 3.119 4.2 23.2 2008 1.701 4.005 0.946 3.059 4.1 21.6 2009 1.838 4.371 1.074 3.296 4.4 21.2 2010 1.919 4.598 1.163 3.435 4.6 20.9 2011 1.907 4.557 1.149 3.408 4.6 20.9 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 24 TANF Child Recipients Year Families (millions) Recipients (millions) Adults (millions) Children (millions) As a Percent of All Children As a Percent of All Poor Children 2012 1.852 4.402 1.104 3.298 4.4 20.3 2013 1.726 4.042 0.993 3.050 4.1 20.6 2014 1.650 3.957 1.007 2.949 4.0 NA Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS) and the U.S. Census Bureau. Notes: NA denotes not available. During transition reporting from AFDC to TANF, caseload statistics on adult and child recipients were not collected. For those years, TANF children as a percent of all children and percent of all poor children were estimated by HHS and published in Welfare Indicators and Risk Factors, Annual Report to Congress, Table TANF 2, p. A-7. See http:\/\/aspe.hhs.gov\/hsp\/14\/indicators\/rpt_indicators.pdf. Child poverty data for 2014 will not be available until September 2015. CRS-25 Appendix B. State Tables Table B-1. Use of FY2013 TANF and MOE Funds by Category (Dollars in millions) State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Alabama $45.9 $24.4 $21.0 $5.5 $3.8 $70.3 $170.9 Alaska 38.7 4.6 12.6 27.4 0.6 5.4 89.2 Arizona -21.8 44.4 8.8 10.1 0.2 337.7 379.4 Arkansas 13.2 14.0 23.5 8.6 3.2 94.2 156.6 California 3,225.3 556.6 507.3 840.4 183.5 1,718.7 7,031.8 Colorado 70.7 20.7 2.1 1.2 8.3 212.7 315.7 Connecticut 81.3 29.3 16.1 35.5 4.9 318.1 485.2 Delaware 12.9 -0.2 1.4 57.2 0.0 11.9 83.2 District of Columbia 59.0 7.4 37.4 76.4 16.0 57.4 253.7 Florida 173.2 30.3 58.4 342.7 5.5 387.4 997.5 Georgia 47.5 15.7 -0.7 22.2 20.1 389.1 493.9 Hawaii 64.1 14.9 94.7 13.0 4.0 53.9 244.5 Idaho 6.5 5.6 6.2 10.8 0.3 16.8 46.3 Illinois 81.0 27.5 31.1 645.5 25.1 350.7 1,160.9 Indiana 28.9 18.0 16.0 77.7 33.9 104.9 279.3 Iowa 54.1 7.1 15.9 44.2 13.3 76.1 210.7 Kansas 27.5 13.5 0.4 22.5 54.2 55.5 173.6 Kentucky 102.1 11.9 34.1 74.4 21.7 33.5 277.7 Louisiana 25.7 20.4 6.4 5.2 19.0 145.1 221.7 CRS-26 State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Maine 49.8 2.7 12.4 9.9 11.9 9.2 95.9 Maryland 139.2 61.2 36.3 24.2 147.6 175.9 584.2 Massachusetts 338.7 33.3 6.5 296.2 109.3 354.3 1,138.4 Michigan 206.6 180.5 81.0 19.5 51.6 890.4 1,429.6 Minnesota 94.1 46.3 54.7 53.7 134.7 53.4 437.0 Mississippi 16.7 3.2 33.0 19.1 16.8 17.6 106.4 Missouri 101.3 9.4 17.4 42.3 0.0 232.7 403.1 Montana 15.3 8.4 12.1 10.0 0.0 7.8 53.6 Nebraska 24.2 3.5 19.4 23.5 36.0 2.3 108.9 Nevada 43.5 8.1 1.8 0.0 1.1 35.5 90.1 New Hampshire 23.9 12.0 6.9 8.8 1.3 20.1 73.0 New Jersey 304.0 81.5 87.6 73.2 190.5 558.1 1,295.0 New Mexico 53.1 10.7 8.7 36.3 47.6 57.1 213.5 New York 1,606.0 333.9 124.4 536.9 1,432.6 1,576.8 5,610.7 North Carolina 59.1 47.8 42.6 172.3 60.8 240.4 623.0 North Dakota 5.1 4.0 4.0 1.0 1.3 18.5 33.9 Ohio 301.9 146.0 36.1 382.0 9.9 126.5 1,002.3 Oklahoma 19.8 23.9 0.0 70.0 25.7 59.6 199.0 Oregon 141.8 37.3 17.1 11.1 3.8 112.8 324.0 Pennsylvania 271.5 80.0 78.1 395.4 9.5 208.2 1,042.8 Rhode Island 42.4 16.2 9.4 24.4 13.6 80.4 186.4 South Carolina 34.8 19.1 20.1 4.1 1.9 150.3 230.2 South Dakota 12.6 2.8 4.2 0.8 0.1 7.1 27.6 CRS-27 State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Tennessee 108.2 31.4 71.2 29.5 0.0 77.7 318.1 Texas 75.4 68.3 87.8 26.8 5.6 591.0 854.9 Utah 23.2 7.6 18.0 10.5 0.3 18.1 77.6 Vermont 20.0 7.1 0.1 28.9 24.9 11.4 92.5 Virginia 100.5 22.3 52.7 30.8 8.7 66.0 281.0 Washington 201.7 59.9 159.5 130.7 2.5 308.9 863.3 West Virginia 31.0 26.2 1.8 10.4 29.8 45.4 144.6 Wisconsin 134.2 23.0 34.2 200.0 47.8 164.7 603.9 Wyoming 2.5 7.4 1.8 3.7 0.0 17.5 32.8 Totals 8,737.9 2,290.9 2,033.7 5,006.5 2,844.8 10,735.3 31,649.2 Source: Congressional Research Service (CRS) based on data from the U.S. Department of Health and Human Services (HHS). Notes: Negative entries denote adjustments for prior year reporting changes. CRS-28 Table B-2. Use of FY2013 TANF and MOE Funds by Category as a Percent of Total Federal TANF and State MOE Funding State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Alabama 26.9% 14.3% 12.3% 3.2% 2.2% 41.1% 100.0% Alaska 43.3 5.2 14.1 30.7 0.6 6.0 100.0 Arizona -5.8 11.7 2.3 2.7 0.1 89.0 100.0 Arkansas 8.4 8.9 15.0 5.5 2.0 60.2 100.0 California 45.9 7.9 7.2 12.0 2.6 24.4 100.0 Colorado 22.4 6.6 0.7 0.4 2.6 67.4 100.0 Connecticut 16.8 6.0 3.3 7.3 1.0 65.6 100.0 Delaware 15.5 -0.2 1.7 68.7 0.0 14.3 100.0 District of Columbia 23.3 2.9 14.8 30.1 6.3 22.6 100.0 Florida 17.4 3.0 5.8 34.4 0.6 38.8 100.0 Georgia 9.6 3.2 -0.1 4.5 4.1 78.8 100.0 Hawaii 26.2 6.1 38.7 5.3 1.6 22.0 100.0 Idaho 14.2 12.1 13.5 23.3 0.6 36.4 100.0 Illinois 7.0 2.4 2.7 55.6 2.2 30.2 100.0 Indiana 10.4 6.4 5.7 27.8 12.1 37.6 100.0 Iowa 25.7 3.4 7.5 21.0 6.3 36.1 100.0 Kansas 15.8 7.8 0.2 13.0 31.2 32.0 100.0 Kentucky 36.8 4.3 12.3 26.8 7.8 12.1 100.0 Louisiana 11.6 9.2 2.9 2.4 8.6 65.4 100.0 Maine 51.9 2.8 12.9 10.3 12.4 9.6 100.0 Maryland 23.8 10.5 6.2 4.1 25.3 30.1 100.0 Massachusetts 29.8 2.9 0.6 26.0 9.6 31.1 100.0 CRS-29 State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Michigan 14.5 12.6 5.7 1.4 3.6 62.3 100.0 Minnesota 21.5 10.6 12.5 12.3 30.8 12.2 100.0 Mississippi 15.7 3.0 31.0 17.9 15.8 16.5 100.0 Missouri 25.1 2.3 4.3 10.5 0.0 57.7 100.0 Montana 28.6 15.7 22.6 18.6 0.0 14.5 100.0 Nebraska 22.3 3.2 17.8 21.6 33.0 2.1 100.0 Nevada 48.2 9.0 2.0 0.0 1.3 39.4 100.0 New Hampshire 32.7 16.4 9.5 12.0 1.8 27.5 100.0 New Jersey 23.5 6.3 6.8 5.7 14.7 43.1 100.0 New Mexico 24.9 5.0 4.1 17.0 22.3 26.8 100.0 New York 28.6 6.0 2.2 9.6 25.5 28.1 100.0 North Carolina 9.5 7.7 6.8 27.7 9.8 38.6 100.0 North Dakota 15.0 11.7 11.9 3.0 3.8 54.6 100.0 Ohio 30.1 14.6 3.6 38.1 1.0 12.6 100.0 Oklahoma 10.0 12.0 0.0 35.2 12.9 29.9 100.0 Oregon 43.8 11.5 5.3 3.4 1.2 34.8 100.0 Pennsylvania 26.0 7.7 7.5 37.9 0.9 20.0 100.0 Rhode Island 22.7 8.7 5.1 13.1 7.3 43.2 100.0 South Carolina 15.1 8.3 8.7 1.8 0.8 65.3 100.0 South Dakota 45.7 10.0 15.3 2.9 0.4 25.7 100.0 Tennessee 34.0 9.9 22.4 9.3 0.0 24.4 100.0 Texas 8.8 8.0 10.3 3.1 0.6 69.1 100.0 Utah 29.9 9.8 23.2 13.5 0.3 23.3 100.0 CRS-30 State Basic Assistance Administration Work Child Care Other Work Supports Other Expenditures Total Vermont 21.7 7.7 0.1 31.2 27.0 12.3 100.0 Virginia 35.8 7.9 18.8 11.0 3.1 23.5 100.0 Washington 23.4 6.9 18.5 15.1 0.3 35.8 100.0 West Virginia 21.4 18.1 1.3 7.2 20.6 31.4 100.0 Wisconsin 22.2 3.8 5.7 33.1 7.9 27.3 100.0 Wyoming 7.5 22.5 5.4 11.1 0.0 53.4 100.0 Totals 27.6 7.2 6.4 15.8 9.0 33.9 100.0 Source: Congressional Research Service (CRS) based on data from the U.S. Department of Health and Human Services (HHS). Notes: Negative entries denote adjustments for prior year reporting changes. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 31 Table B-3. Unspent TANF Funds at the End of FY2013 (September 30, 2013, in millions of dollars) State Obligated but not Spent Unobligated Total Unspent Funds Alabama $3.7 $10.6 $14.3 Alaska 0.0 69.7 69.7 Arizona 2.7 0.0 2.7 Arkansas 18.3 16.0 34.3 California 8.4 0.0 8.4 Colorado 0.0 19.1 19.1 Connecticut 0.0 6.3 6.3 Delaware 9.6 10.4 20.0 District of Columbia 6.5 54.4 60.9 Florida 29.6 0.5 30.1 Georgia 21.2 60.9 82.1 Hawaii 5.8 59.5 65.2 Idaho 31.7 0.0 31.7 Illinois 0.0 16.0 16.0 Indiana 238.1 21.7 259.7 Iowa 14.1 3.0 17.1 Kansas 11.6 32.3 43.9 Kentucky 0.0 3.5 3.5 Louisiana 0.0 0.0 0.0 Maine 0.0 24.6 24.6 Maryland 4.9 0.0 4.9 Massachusetts 0.0 0.0 0.0 Michigan 0.0 42.4 42.4 Minnesota 0.0 161.4 161.4 Mississippi 4.0 7.9 11.9 Missouri 22.3 -0.2 22.1 Montana 0.4 42.7 43.1 Nebraska 0.0 59.6 59.6 Nevada 0.0 12.7 12.7 New Hampshire 0.0 13.2 13.2 New Jersey 32.4 37.5 69.9 New Mexico 50.2 0.0 50.2 New York 273.4 104.0 377.4 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 32 State Obligated but not Spent Unobligated Total Unspent Funds North Carolina 192.6 3.5 196.1 North Dakota 0.0 15.8 15.8 Ohio 201.3 34.0 235.4 Oklahoma 53.3 0.0 53.3 Oregon 0.0 17.9 17.9 Pennsylvania 52.1 300.1 352.2 Rhode Island 0.0 0.0 0.0 South Carolina 0.0 12.4 12.4 South Dakota 0.0 14.9 14.9 Tennessee 0.0 59.3 59.3 Texas 152.7 0.0 152.7 Utah 0.0 109.2 109.2 Vermont 0.0 0.0 0.0 Virginia 5.1 33.9 39.0 Washington 69.5 0.0 69.6 West Virginia 0.0 0.1 0.1 Wisconsin 0.0 12.9 12.9 Wyoming 3.2 21.2 24.5 Totals 1,518.7 1,525.0 3,043.7 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Table B-4. Number of Families, Recipients, Children, and Adults Receiving TANF Cash Assistance by State, December 2014 State Families Recipients Children Adults Alabama 14,835 35,066 26,859 8,207 Alaska 3,066 8,277 5,618 2,659 Arizona 12,193 27,292 20,203 7,089 Arkansas 5,447 12,171 8,908 3,263 California 626,297 1,745,407 1,237,834 507,573 Colorado 17,680 46,925 33,119 13,806 Connecticut 13,711 27,512 19,350 8,162 Delaware 4,670 13,178 8,071 5,107 District of Columbia 5,027 12,637 9,230 3,407 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 33 State Families Recipients Children Adults Florida 50,288 87,711 72,331 15,380 Georgia 13,910 27,197 24,168 3,029 Guam 1,133 2,545 2,030 515 Hawaii 8,166 23,547 15,804 7,743 Idaho 1,903 2,830 2,708 122 Illinois 19,410 43,526 35,829 7,697 Indiana 9,753 19,736 17,745 1,991 Iowa 14,169 35,460 25,361 10,099 Kansas 6,478 15,424 11,453 3,971 Kentucky 26,486 53,071 42,998 10,073 Louisiana 5,619 12,686 11,006 1,680 Maine 23,345 48,172 26,662 21,510 Maryland 20,803 50,484 37,250 13,234 Massachusetts 63,094 149,391 101,532 47,859 Michigan 23,364 57,661 44,255 13,406 Minnesota 19,055 41,193 32,390 8,803 Mississippi 7,642 15,572 11,760 3,812 Missouri 28,870 70,128 48,501 21,627 Montana 3,068 7,457 5,595 1,862 Nebraska 5,803 14,029 11,455 2,574 Nevada 12,015 31,578 23,005 8,573 New Hampshire 5,816 14,185 9,698 4,487 New Jersey 26,397 61,824 44,981 16,843 New Mexico 11,522 34,081 26,864 7,217 New York 150,121 386,055 275,109 110,946 North Carolina 6,806 14,818 11,189 3,629 North Dakota 1,208 3,025 2,452 573 Ohio 61,872 118,421 100,551 17,870 Oklahoma 7,373 16,416 13,926 2,490 Oregon 57,659 174,750 109,621 65,129 Pennsylvania 68,231 170,018 122,507 47,511 Puerto Rico 11,818 32,495 20,228 12,267 Rhode Island 5,237 12,512 8,817 3,695 South Carolina 11,064 25,089 19,999 5,090 South Dakota 3,042 6,053 5,366 687 Tennessee 41,109 96,181 71,628 24,553 Texas 34,110 75,102 66,362 8,740 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 34 State Families Recipients Children Adults Utah 4,004 9,894 7,204 2,690 Vermont 3,470 8,059 5,675 2,384 Virgin Islands 381 1,207 824 383 Virginia 26,293 57,457 42,359 15,098 Washington 36,004 81,972 57,822 24,150 West Virginia 8,130 17,407 13,342 4,065 Wisconsin 25,225 60,670 45,262 15,408 Wyoming 344 697 566 131 Totals 1,674,536 4,216,251 3,055,382 1,160,869 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Notes: TANF cash assistance caseload includes families receiving assistance in state-funded programs counted toward the TANF maintenance of effort (MOE) requirement. Table B-5. Number of Needy Families with Children Receiving Cash Assistance by State, December of Selected Years Percentage Change to 2014 from … State 1994 2007 2010 2013 2014 1994 2007 2013 Alabama 47,903 18,584 24,212 18,394 14,835 -69.0% -20.2% -19.3% Alaska 12,370 2,989 3,572 3,439 3,066 -75.2 2.6 -10.8 Arizona 72,158 37,122 19,366 14,036 12,193 -83.1 -67.2 -13.1 Arkansas 25,047 8,741 8,632 6,395 5,447 -78.3 -37.7 -14.8 California 923,358 477,465 601,286 533,081 626,297 -32.2 31.2 17.5 Colorado 40,244 9,094 8,064 17,270 17,680 -56.1 94.4 2.4 Connecticut 60,965 19,424 16,750 14,335 13,711 -77.5 -29.4 -4.4 Delaware 11,227 3,997 5,745 4,792 4,670 -58.4 16.8 -2.5 District of Columbia 27,420 5,237 9,410 6,021 5,027 -81.7 -4.0 -16.5 Florida 238,564 48,608 58,144 53,087 50,288 -78.9 3.5 -5.3 Georgia 141,154 22,740 20,686 16,481 13,910 -90.1 -38.8 -15.6 Guam 2,088 NA 1,260 1,342 1,133 -45.7 NA -15.6 Hawaii 21,489 6,621 10,240 8,865 8,166 -62.0 23.3 -7.9 Idaho 8,953 1,527 1,848 1,838 1,903 -78.7 24.6 3.5 Illinois 241,091 20,562 27,177 20,354 19,410 -91.9 -5.6 -4.6 Indiana 69,933 31,103 31,461 11,195 9,753 -86.1 -68.6 -12.9 Iowa 38,022 19,762 21,037 16,126 14,169 -62.7 -28.3 -12.1 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 35 Percentage Change to 2014 from … State 1994 2007 2010 2013 2014 1994 2007 2013 Kansas 28,838 12,853 15,647 7,553 6,478 -77.5 -49.6 -14.2 Kentucky 76,824 29,323 31,336 29,488 26,486 -65.5 -9.7 -10.2 Louisiana 82,792 11,106 11,117 6,151 5,619 -93.2 -49.4 -8.6 Maine 22,025 12,235 15,435 26,604 23,345 6.0 90.8 -12.3 Maryland 80,890 20,466 26,160 21,310 20,803 -74.3 1.6 -2.4 Massachusetts 105,769 52,473 51,179 71,012 63,094 -40.3 20.2 -11.2 Michigan 209,695 69,327 67,596 29,782 23,364 -88.9 -66.3 -21.5 Minnesota 61,343 26,387 24,726 22,267 19,055 -68.9 -27.8 -14.4 Mississippi 53,221 11,631 12,078 9,260 7,642 -85.6 -34.3 -17.5 Missouri 91,802 39,054 39,617 32,172 28,870 -68.6 -26.1 -10.3 Montana 11,660 3,192 3,694 3,149 3,068 -73.7 -3.9 -2.6 Nebraska 15,427 7,515 8,406 6,379 5,803 -62.4 -22.8 -9.0 Nevada 15,559 7,410 11,066 11,914 12,015 -22.8 62.1 0.8 New Hampshire 11,078 4,497 6,168 6,080 5,816 -47.5 29.3 -4.3 New Jersey 113,293 34,175 35,153 28,658 26,397 -76.7 -22.8 -7.9 New Mexico 34,854 12,195 21,664 13,206 11,522 -66.9 -5.5 -12.8 New York 463,692 155,798 158,133 153,078 150,121 -67.6 -3.6 -1.9 North Carolina 128,848 24,544 23,639 18,575 6,806 -94.7 -72.3 -63.4 North Dakota 5,309 2,072 1,931 1,366 1,208 -77.2 -41.7 -11.6 Ohio 236,298 80,629 103,513 64,371 61,872 -73.8 -23.3 -3.9 Oklahoma 45,893 8,951 9,472 7,270 7,373 -83.9 -17.6 1.4 Oregon 39,967 19,299 33,123 45,270 57,659 44.3 198.8 27.4 Pennsylvania 208,949 55,389 59,034 69,667 68,231 -67.3 23.2 -2.1 Puerto Rico 56,132 12,356 14,621 12,818 11,818 -78.9 -4.4 -7.8 Rhode Island 22,599 8,349 6,778 5,815 5,237 -76.8 -37.3 -9.9 South Carolina 50,251 14,428 19,038 11,770 11,064 -78.0 -23.3 -6.0 South Dakota 6,521 2,904 3,290 3,204 3,042 -53.4 4.8 -5.1 Tennessee 105,616 55,161 63,150 50,850 41,109 -61.1 -25.5 -19.2 Texas 281,011 57,002 52,972 38,460 34,110 -87.9 -40.2 -11.3 Utah 17,240 5,140 6,811 4,382 4,004 -76.8 -22.1 -8.6 Vermont 9,707 4,242 3,335 3,638 3,470 -64.3 -18.2 -4.6 Virgin Islands 1,264 399 511 432 381 -69.9 -4.5 -11.8 Virginia 74,203 31,041 37,105 28,866 26,293 -64.6 -15.3 -8.9 Washington 102,603 52,013 69,805 42,747 36,004 -64.9 -30.8 -15.8 West Virginia 39,546 8,725 10,676 8,862 8,130 -79.4 -6.8 -8.3 Wisconsin 73,714 17,788 25,270 27,522 25,225 -65.8 41.8 -8.3 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 36 Percentage Change to 2014 from … State 1994 2007 2010 2013 2014 1994 2007 2013 Wyoming 5,400 265 312 380 344 -93.6 29.8 -9.5 Totals 4,971,819 1,703,910 1,952,451 1,671,379 1,674,536 -66.3 -1.8 0.2 Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Notes: Caseload data for 2007 through 2014 include those families in Separate State Programs with expenditures countable toward the TANF maintenance of effort (MOE) requirement. Table B-6. TANF Families by Number of Parents in Assisted Unit by State: December 2014 State Single Parent Two Parent No Parent Single Parent Two Parent No Parent Alabama 8,028 129 6,678 54.1 0.9 45.0 Alaska 1,874 362 830 61.1 11.8 27.1 Arizona 6,197 356 5,640 50.8 2.9 46.3 Arkansas 3,092 110 2,245 56.8 2.0 41.2 California 344,136 110,621 171,540 54.9 17.7 27.4 Colorado 10,355 1,380 5,945 58.6 7.8 33.6 Connecticut 8,087 0 5,624 59.0 0.0 41.0 Delaware 1,586 22 3,062 34.0 0.5 65.6 District of Columbia 3,561 0 1,466 70.8 0.0 29.2 Florida 11,677 693 37,918 23.2 1.4 75.4 Georgia 2,946 0 10,964 21.2 0.0 78.8 Guam 363 106 664 32.0 9.4 58.6 Hawaii 4,712 1,871 1,583 57.7 22.9 19.4 Idaho 121 0 1,782 6.4 0.0 93.6 Illinois 6,731 0 12,679 34.7 0.0 65.3 Indiana 2,491 133 7,129 25.5 1.4 73.1 Iowa 8,235 863 5,071 58.1 6.1 35.8 Kansas 3,018 419 3,041 46.6 6.5 46.9 Kentucky 8,674 657 17,155 32.7 2.5 64.8 Louisiana 1,645 0 3,974 29.3 0.0 70.7 Maine 20,645 436 2,264 88.4 1.9 9.7 Maryland 13,322 0 7,481 64.0 0.0 36.0 Massachusetts 41,362 4,418 17,314 65.6 7.0 27.4 Michigan 12,067 0 11,297 51.6 0.0 48.4 Minnesota 8,949 0 10,106 47.0 0.0 53.0 The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 37 State Single Parent Two Parent No Parent Single Parent Two Parent No Parent Mississippi 3,783 0 3,859 49.5 0.0 50.5 Missouri 22,082 0 6,788 76.5 0.0 23.5 Montana 1,605 291 1,172 52.3 9.5 38.2 Nebraska 2,692 0 3,111 46.4 0.0 53.6 Nevada 5,681 1,388 4,946 47.3 11.6 41.2 New Hampshire 4,341 48 1,427 74.6 0.8 24.5 New Jersey 18,427 0 7,970 69.8 0.0 30.2 New Mexico 5,573 822 5,127 48.4 7.1 44.5 New York 96,025 3,129 50,967 64.0 2.1 34.0 North Carolina 3,354 144 3,308 49.3 2.1 48.6 North Dakota 572 0 636 47.4 0.0 52.6 Ohio 14,333 1,520 46,019 23.2 2.5 74.4 Oklahoma 2,490 0 4,883 33.8 0.0 66.2 Oregon 49,333 2,918 5,408 85.6 5.1 9.4 Pennsylvania 49,875 1,450 16,906 73.1 2.1 24.8 Puerto Rico 10,816 712 290 91.5 6.0 2.5 Rhode Island 3,150 319 1,768 60.1 6.1 33.8 South Carolina 5,277 0 5,787 47.7 0.0 52.3 South Dakota 687 0 2,355 22.6 0.0 77.4 Tennessee 23,199 182 17,728 56.4 0.4 43.1 Texas 8,740 0 25,370 25.6 0.0 74.4 Utah 2,102 0 1,902 52.5 0.0 47.5 Vermont 1,662 352 1,456 47.9 10.1 42.0 Virgin Islands 338 0 43 88.7 0.0 11.3 Virginia 15,477 0 10,816 58.9 0.0 41.1 Washington 17,759 3,093 15,152 49.3 8.6 42.1 West Virginia 3,224 0 4,906 39.7 0.0 60.3 Wisconsin 12,845 862 11,518 50.9 3.4 45.7 Wyoming 125 3 216 36.3 0.9 62.8 Totals 919,441 139,809 615,286 54.9 8.3 36.7 Source: : Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Notes: TANF cash assistance caseload includes families receiving assistance in state-funded programs counted toward the TANF maintenance of effort (MOE) requirement. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 38 Table B-7. TANF Caseload Reduction Credits, Effective (After Credit) Standards, and Work Participation Rates by State, All Families, FY2012 State Caseload Reduction Credit (Percentage Points) Effective (After Caseload Reduction Credit) Standard Work Participation Rate Met Standard? United States 34.4% Alabama 7.7 42.3% 46.0 Yes Alaska 9.8 40.2 36.7 No Arizona 38.0 12.0 27.1 Yes Arkansas 50.0 0.0 40.2 Yes California 0.0 50.0 27.2 No Colorado 14.9 35.1 23.8 No Connecticut 24.2 25.8 52.7 Yes Delaware 12.8 37.2 41.5 Yes District of Col. 17.8 32.2 34.8 Yes Florida 9.7 40.3 45.1 Yes Georgia 50.0 0.0 64.5 Yes Guam 0.0 50.0 29.0 No Hawaii 50.0 0.0 50.6 Yes Idaho 0.0 50.0 49.8 No Illinois 17.5 32.5 38.6 Yes Indiana 38.8 11.2 31.0 Yes Iowa 17.3 32.7 38.4 Yes Kansas 39.8 10.2 28.4 Yes Kentucky 19.6 30.4 53.3 Yes Louisiana 34.8 15.2 26.8 Yes Maine 0.0 50.0 34.9 No Maryland 5.1 44.9 46.1 Yes Massachusetts 24.2 25.8 39.7 Yes Michigan 12.5 37.5 43.1 Yes Minnesota 8.8 41.2 45.3 Yes Mississippi 26.8 23.2 67.6 Yes Missouri 12.9 37.1 20.5 No Montana 3.1 46.9 47.3 Yes Nebraska 50.0 0.0 53.4 Yes Nevada 2.9 47.1 35.1 No New Hampshire 0.0 50.0 73.0 Yes The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 39 State Caseload Reduction Credit (Percentage Points) Effective (After Caseload Reduction Credit) Standard Work Participation Rate Met Standard? New Jersey 47.6 2.4 19.6 Yes New Mexico 16.1 33.9 46.0 Yes New York 31.4 18.6 31.6 Yes North Carolina 29.4 20.6 47.3 Yes North Dakota 36.0 14.0 71.1 Yes Ohio 0.0 50.0 61.9 Yes Oklahoma 25.8 24.2 24.7 Yes Oregon 0.0 50.0 33.8 No Pennsylvania 21.4 28.6 29.8 Yes Puerto Rico 9.0 41.0 16.3 No Rhode Island 0.0 50.0 10.0 No South Carolina 0.0 50.0 36.8 No South Dakota 0.0 50.0 55.0 Yes Tennessee 28.5 21.5 30.5 Yes Texas 43.4 6.6 29.1 Yes Utah 24.8 25.2 41.4 Yes Vermont 4.7 45.3 42.2 No Virgin Islands 42.9 7.1 15.1 Yes Virginia 7.0 43.0 42.6 No Washington 32.7 17.3 11.1 No West Virginia 11.9 38.1 38.7 Yes Wisconsin 0.0 50.0 32.4 No Wyoming 0.6 49.4 79.4 Yes Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 40 Table B-8. TANF Caseload Reduction Credits, Effective (After Credit) Standards, and Work Participation Rates by State, Two-Parent Families, FY2012 State Caseload Reduction Credit (Percentage Points) Effective (After Caseload Reduction Credit) Standard Work Participation Rate Met Standard? United States 33.9% Alabama 56.5 33.5% 40.0 Yes Alaska 18.9 71.1 38.1 No Arizona 38.0 52.0 66.1 Yes Arkansas 53.7 36.3 27.4 No California 0.0 90.0 30.8 No Colorado 14.9 75.1 20.1 No Connecticut NA NA NA NA Delaware NA NA NA NA District of Col. NA NA NA NA Florida 19.4 70.6 53.0 No Georgia NA NA NA NA Guam 0.0 90.0 62.3 No Hawaii 55.6 34.4 58.7 Yes Idaho NA NA NA NA Illinois NA NA NA NA Indiana 38.8 51.2 24.0 No Iowa 45.8 44.2 29.3 No Kansas 39.8 50.2 30.8 No Kentucky 19.6 70.4 51.8 No Louisiana NA NA NA NA Maine 0.0 90.0 19.0 No Maryland NA NA NA NA Massachusetts 24.2 65.8 83.9 Yes Michigan NA NA NA NA Minnesota NA NA NA NA Mississippi NA NA NA NA Missouri NA NA NA NA Montana 34.1 55.9 56.6 Yes Nebraska NA NA NA NA Nevada 2.9 87.1 41.6 No New Hampshire NA NA NA NA The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 41 State Caseload Reduction Credit (Percentage Points) Effective (After Caseload Reduction Credit) Standard Work Participation Rate Met Standard? New Jersey NA NA NA NA New Mexico 16.1 73.9 53.5 No New York NA NA NA NA North Carolina 29.4 60.6 63.6 Yes North Dakota NA NA NA NA Ohio 0.0 90.0 60.1 No Oklahoma NA NA NA NA Oregon 0.0 90.0 8.7 No Pennsylvania 72.7 17.3 54.0 Yes Puerto Rico NA NA NA NA Rhode Island 0.0 90.0 6.3 No South Carolina NA NA NA NA South Dakota NA NA NA NA Tennessee NA NA NA NA Texas NA NA NA NA Utah NA NA NA NA Vermont 4.7 85.3 52.2 No Virgin Islands NA NA NA NA Virginia NA NA NA NA Washington 32.7 57.3 11.8 No West Virginia NA NA NA NA Wisconsin 0.0 90.0 16.9 No Wyoming 0.6 89.4 77.4 No Source: Congressional Research Service (CRS), based on data from the U.S. Department of Health and Human Services (HHS). Notes: NA denotes that the state does not have two-parent families in their TANF or MOE programs. The Temporary Assistance for Needy Families (TANF) Block Grant: FAQs Congressional Research Service 42 Author Contact Information Gene Falk Specialist in Social Policy [email protected], 7-7344 ”

” A Descriptive Study of County- versus State-Administered Temporary Assistance for Needy Families Programs OPRE Report 2015-42 May 2015 A DESCRIPTIVE STUDY OF COUNTY- VERSUS STATE- ADMINISTERED TEMPORARY ASSISTANCE FOR NEEDY FAMILIES PROGRAMS FINAL REPORT OPRE Report 2015-42 Heather Hahn David Kassabian Lina Breslav Yvette Lamb URBAN INSTITUTE URBAN INSTITUTE URBAN INSTITUTE ICF INTERNATIONAL May 2015 Submitted to: Girley Wright, Project Officer Office of Planning, Research and Evaluation Administration for Children and Families U.S. Department of Health and Human Services Project Director: Heather Hahn Urban Institute 2100 M St NW 5th Floor Washington, DC 20037 Contract Number HHSP23320095654WC This report is in the public domain. Permission to reproduce is not necessary. Suggested citation: Hahn, Heather, David Kassabian, Lina Breslav, and Yvette Lamb (2015). A Descriptive Study of County- Versus State-Administered Temporary Assistance for Needy Families Programs. OPRE Report # 2015-42, Washington, DC: Office of Planning, Research and Evaluation, Administration for Children and Families, U.S. Department of Health and Human Services. Disclaimer: The views expressed in this publication do not necessarily reflect the views or policies of the Office of Planning, Research, and Evaluation, the Administration for Children and Families, or the U.S. Department of Health and Human Services. This report and other reports sponsored by the Office of Planning, Research, and Evaluation are available at http:\/\/www.acf.hhs.gov\/programs\/opre\/index.html http:\/\/www.acf.hhs.gov\/programs\/opre\/index.html ABOUT THE URBAN INSTITUTE The nonprofit Urban Institute is dedicated to elevating the debate on social and economic policy. For nearly five decades, Urban scholars have conducted research and offered evidence-based solutions that improve lives and strengthen communities across a rapidly urbanizing world. Their objective research helps expand opportunities for all, reduce hardship among the most vulnerable, and strengthen the effectiveness of the public sector. ABOUT ICF INTERNATIONAL ICF International is a publically traded consulting firm providing end-to-end solutions to complex social and environmental issues through research, evaluation, and technical assistance. Founded in 1969 as the Inner City Fund, ICF’s Family Self-Sufficiency line of business works with families, communities, and organizations to reduce risk for vulnerable populations and increase the capacity for self-sufficiency. Overview One-half of all families receiving cash assistance from the Temporary Assistance for Needy Families (TANF) program live in states with county-administered TANF programs. But what does county-administered mean? States take different approaches to TANF administration, and county-administered can mean several different things. States do not report details about how they supervise counties or how counties administer TANF, but these details and how they differ from the details of state-administered TANF programs, have implications for federal policies, regulations, and technical assistance. To address this knowledge gap, this report closely examines the TANF programs in four states with state- supervised, county-administered systems (California, Colorado, Minnesota, and North Dakota) and provides detailed information on TANF administration in selected counties in these states. The report also identifies differences between county- and state-administered TANF programs and describes the technical assistance needs of county-administered programs. The report draws on in-person interviews with state and county TANF administrators in each of the four states, telephone interviews or survey responses from state TANF administrators in 29 states with state-administered TANF programs, and other data sources. What do county-administered TANF programs look like? The four county-administered TANF programs examined share three elements that set them apart from state-administered programs: county employees deliver TANF services in county-run local offices; county governments contribute funding for TANF; and county elected officials have a role in reviewing the local TANF budget, policy, or both. Beyond these three broad consistencies, no two county-administered TANF programs look alike. Across the four states, counties have widely different authority over TANF implementation and policy. In states where counties have greater flexibility to shape their TANF programs, a family’s TANF experience, such as specific work requirements, training opportunities, services provided to teen parents, can differ depending on the county in which they live. Even in these states, though, basic rules about who is eligible for TANF and how much cash assistance families can receive are applied uniformly across counties in each state. How do county-administered TANF programs differ from state-administered programs? Beyond the three core elements of county-administration, most practical differences between state- and county- administered programs are a matter of degree. State-administered programs offer a range of authority and flexibility to their local offices, but it is generally much less than offered to county-administered TANF programs. Despite their structural differences, county-administered TANF programs as a group do not differ systematically from state-administered programs in client outcomes, nor are they systemically different in population size, political party, or other state characteristics. Nonetheless, proponents of county-administered programs value the flexibility to adjust to local circumstances, and proponents of state-administered programs highlight the consistent support low-income families receive throughout the state. Whether a state’s TANF program is county-administered or state-administered, each state seeks its own balance between providing consistent support for families and adjusting to local circumstances. Concluding Observations. The extent of county control and the limits on state control are important for federal lawmakers and regulators to recognize. Governors and other state-level officials may not have direct authority to mandate specific actions at the county level. Though states are ultimately responsible for complying with federal laws and regulations and ensuring that their counties do also, the process of implementing federal policies in a state with a county-administered TANF program can be complex. Further, because county administrators in some states are directly implementing federal policies, technical assistance on these matters needs to be directed to county administrators as well as state officials in these states. Contents Acknowledgments IV Executive Summary V What Do County-Administered TANF Programs Look Like? V How Do County-Administered TANF Programs Differ from State-Administered Programs? VII What Are the Technical Assistance Needs of County-Administered TANF Programs? VII Concluding Observations VIII Introduction 1 Background 1 Research Design and Methods 3 What Do County-Administered TANF Programs Look Like? 11 History of TANF Administrative Structure 12 Bureaucratic Responsibilities 14 Financial Management and Fiscal Reporting 20 Policy Authority and Development at the State and County Levels 28 Program Oversight 33 Service Delivery 41 Information Technology 51 How Do County-Administered Programs Differ from State-Administered TANF Programs? 62 History of TANF Administrative Structure 64 Bureaucratic Structure and Communication 65 Financial Management and Fiscal Reporting 67 Policy Authority and Development 68 Program Oversight 69 Service Delivery 70 Information Technology 71 Implications of TANF Administrative Structure 73 Technical Assistance Needs of County-Administered TANF Programs 78 Key Findings and Conclusions 83 Appendix A. State-Administered TANF Programs Included in the Study 85 Appendix B. Site Visit Interview Guide for State TANF Directors 86 Notes 97 References 99 About the Authors 100 Statement of Independence 101 Acknowledgments This report was funded by the US Department of Health and Human Services. We are grateful to them and to all our funders, who make it possible for Urban to advance its mission. Funders do not, however, determine our research findings or the insights and recommendations of our experts. The views expressed are those of the authors and should not be attributed to the Urban Institute, its trustees, or its funders. This report was prepared as part of a study funded by the US Department of Health and Human Services (DHHS), Office of Planning, Research and Evaluation (OPRE) under Task Order Number HHSP23320095654WC. The authors would like to thank all the individuals who participated in interviews and discussions for this project, particularly state, county, work services contractor, and county association staff who gave their time so others could learn from their expertise and experience. We also appreciate the comments we received from our project officers (Michael Dubinsky, Matt Borus, and Girley Wright) and other OPRE and DHHS staff. We would like to acknowledge the excellent research of our other project team members, Olivia Healy (Urban Institute), Teresa Derrick-Mills (Urban Institute), Julia Isaacs (Urban Institute), Jeanette Hercik (ICF International), Bill Brumfield (ICF International), and Louisa Jones (ICF International). All errors and omissions remain those of the authors. I V A C K N O W L E D G M E N T S Executive Summary One-half of all families receiving cash assistance from the Temporary Assistance for Needy Families (TANF) program live in states that have county-administered TANF programs. But no common, precise definition of county administration exists. Since the implementation of TANF in 1997, states have chosen a variety of approaches to administration; consequently, county-administered can mean several different things. States do not report in detail to the federal government on how they supervise counties or how counties administer TANF. Nonetheless, the details of how states and counties administer TANF, and how these arrangements differ from state-administered TANF programs, have implications for federal regulations, policies, and technical assistance. To address this knowledge gap, this report provides detailed information on the TANF programs in four states with state-supervised, county-administered systems (California, Colorado, Minnesota, and North Dakota) and on TANF administration in selected counties in these states. The report also identifies differences between county- and state-administered TANF programs and describes county- administered programs’ technical assistance needs. The report draws on data collected during on-site interviews with state and county TANF administrators in each of the four states; telephone interviews or survey responses from state TANF administrators in 29 states with state-administered TANF programs and from state TANF administrators in 2 states with county-administered TANF programs;1 and secondary data sources. What Do County-Administered TANF Programs Look Like? The four county-administered TANF programs examined share three elements that set them apart from state-administered programs: county employees deliver TANF services in county-run local offices; county governments contribute funding for TANF; and county elected officials have a role in reviewing the local TANF budget, policy, or both. Beyond these three broad consistencies, no two county- administered TANF programs look alike. Counties across the four states vary vastly in autonomy and responsibility for TANF implementation and policy. The experiences of families receiving TANF cash assistance differ across both states and counties. Each state has different rules about who is eligible for TANF and how much cash assistance families can receive, but these rules are applied uniformly across E X E C U T I V E S U M M A R Y V counties in each state. Other aspects of a family’s TANF experience, however, such as their specific work requirements or training opportunities or what services are provided to teen parents, can differ across counties. Those county-by-county differences are greater in some states with county- administered TANF programs than others because counties in some states have great flexibility to shape their TANF programs, but others’ ability is limited. Colorado counties have the most extensive autonomy and responsibility. Selected county commissioners and community stakeholders play a formal role in approving statewide program rules for the Colorado Department of Human Services (CDHS), and counties have considerable flexibility in designing their TANF programs within those parameters. This flexibility includes designing not only the employment and supportive services but also the approaches for serving teen parents and other fundamental program elements. Colorado counties join with state staff to collectively determine how federal funds are distributed to counties. Counties are responsible for contributing the full amount of the required nonfederal spending; individual counties are responsible for managing these funds to meet all county-level program and administrative costs (except for major information technology [IT] system costs). In California, the state and counties share considerable authority and responsibility. The state pays most of the costs and establishes statewide eligibility rules, benefit levels, and other program rules, but the counties have significant input into the process. Within statutory and regulatory parameters, California counties have flexibility in designing and administering an array of services that meet local needs. In stark contrast to Colorado and California, North Dakota offers its counties almost no direct authority to shape policy, determine employment services, or determine the allocation or use of federal and state funds, though the state convenes a workgroup of county eligibility workers to discuss policy changes and revisions. Nonetheless, North Dakota’s counties must cover all of their TANF programs’ administrative costs with county funds. Minnesota falls somewhere in the middle. Minnesota counties share financial responsibility for the program’s administrative costs equally with the state, and they have authority to decide how to spend their allotment of state and federal funds for emergency cash assistance and employment services, including whether to provide services themselves or contract with employment service providers. The four study states differ from each other in many other ways, most notably population size, but these differences do not align neatly with differences in approaches to TANF. V I E X E C U T I V E S U M M A R Y How Do County-Administered TANF Programs Differ from State-Administered Programs? Beyond the three core elements of county-administration\u2014county employees, county financial responsibility, and an oversight role for county elected officials\u2014differences between state- and county-administered programs are mostly a matter of degree. State-administered programs, like county-administered programs, offer a range of authority and flexibility to their local or regional offices, though state-administered TANF programs generally retain considerable authority at the state level and allow much less flexibility locally than county-administered TANF programs. For example, although state-administered programs primarily retain authority for policy development, a few such programs allow local offices or regions some flexibility in implementing those policies. The structural differences between state- and county-administered TANF programs do not correlate with any quantifiable differences in key program or client outcomes. For example, county- administered TANF programs as a group do not have higher or lower work participation rates than state-administered programs, nor do they systematically serve more or fewer of the population’s poor families or offer larger or smaller benefit amounts. In addition, states with county-administered TANF programs are not systemically different from other states in terms of population size, political party, or other state characteristics. What Are the Technical Assistance Needs of County- Administered TANF Programs? County-administered TANF programs have a wide range of technical assistance needs, including many they share with state-administered TANF programs and some that are unique. Both state and county TANF administrators already receive federal technical assistance and federally facilitated opportunities for peer learning, for which those interviewed for this study expressed appreciation. County TANF administrators interviewed, however, expressed a need for more direct communication with federal TANF administrators and for technical assistance in implementing federal policies at the county level. Administrators of county TANF programs also strongly emphasized the value of peer learning among counties in a state or among states with county-administered TANF programs. Again, those interviewed expressed appreciation for the opportunities they already received and eagerness for more. E X E C U T I V E S U M M A R Y V I I Concluding Observations Counties in some\u2014but not all\u2014states with county-administered TANF programs have considerable authority and responsibility to develop TANF policies. The extent of county control and, by extension, the limits on state control are important for federal lawmakers and regulators to recognize. Governors and other state-level officials may not have direct authority to mandate specific actions at the county level. Though states ultimately are responsible for complying with federal laws and regulations and ensuring that their counties do also, implementing federal policies in a state with a county-administered TANF program can be complex. Further, because county administrators in some states are directly implementing federal policies, technical assistance on these matters needs to be directed to county administrators as well as state officials in these states. County flexibility to tailor TANF programs depends not only on the formal structure of state and county authority and responsibility but also on counties’ practical ability to act. When counties have fewer financial resources, such as during the recent recession, or if they lack the personnel and technical capacity to develop innovative programs, there are fewer county-by-county differences regardless of their formal authority. Although county or state TANF administration is not systematically correlated with measured outcomes for families, there are those who highlight the benefits of each. Proponents of state TANF programs highlight the consistent support low-income families receive throughout the state. Proponents of county-administered TANF programs underscore the flexibility to adjust to local circumstances, culture, priorities, and perspectives. As all states continue to implement and revise their TANF programs, whether county-administered or state-administered, they each seek their own balance between providing consistent support for low-income families and adjusting to local circumstances. V I I I E X E C U T I V E S U M M A R Y Introduction Half of all families receiving cash assistance from the Temporary Assistance for Needy Families (TANF) program receive assistance through a county-administered TANF program. How counties administer TANF, how states supervise them, and how these arrangements differ from state-administered TANF programs are important considerations for federal regulations, policies, and technical assistance. However, there is no precise definition of county administration and states do not report the details of their administrative arrangements to the federal agency that oversees TANF. This report addresses that knowledge gap by providing detailed information on how TANF is administered in four states (California, Colorado, Minnesota, and North Dakota) and selected counties within these states. The report also identifies differences between county- and state-administered TANF programs and describes county-administered programs’ technical assistance needs. Background The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), which replaced Aid to Families with Dependent Children (AFDC), authorized the TANF block grant. The four purposes of TANF are (1) to provide assistance to needy families so that children can be cared for in their own homes or homes of relatives; (2) to end the dependency of needy parents on government benefits by promoting job preparation, work, and marriage; (3) to prevent and reduce the incidence of out-of-wedlock pregnancies; and (4) to encourage the formation and maintenance of two-parent families. The structure of the block grant gives states considerable flexibility in an array of policy, financing, and operations choices, subject to a handful of federal requirements such as a 60-month time limit on federally funded assistance, work participation requirements, and maintenance of effort funding.2 Among the choices states make about their TANF programs is whether to delegate administration of at least some program elements to localities or counties much in the same way that the federal government transfers administrative responsibility to the states. PRWORA requires each state to conduct a program, designed to serve all political subdivisions in the State (not necessarily in a uniform manner) and to submit to federal authorities (the US Department of Health and Human Services, Administration for Children and Families) a state TANF plan describing how they will do so.3 The state TANF plans typically include general statements about the roles of counties in administering TANF and do not discuss the details of county roles and responsibilities or communication and oversight processes. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 Although PRWORA significantly expanded states’ role in crafting welfare policy, questions of state versus county control predate TANF. The AFDC program, like other federal-state programs under the Social Security Act of 1935, allowed states to choose between a state-administered system and one that was state supervised but county administered. States had the option to administer AFDC centrally or to pass administrative tasks to other agencies, usually local governments, operating under the supervision of a single state agency. The supervising state agency always retained the ultimate responsibility to federal authorities. Most states developed their plans over several years in the late 1930s and early 1940s. By the end of that period, 32 of 50 states had state-supervised, locally administered structures. During the next 50 years, no other states changed to a decentralized system, but many chose to centralize. By 1990, and continuing to PRWORA’s enactment in 1996, only 15 states operated state-supervised, locally administered systems; the remaining 35 had state-administered systems. Since the implementation of TANF in 1997, states have chosen a variety of approaches to administration, and thus county-administered can mean many different things. States make different choices about the level of county fiscal and policy authority and the specific roles of county and state staff. Eight states have consistently reported in their state TANF plans that they have county- administered TANF programs, though the specific state and county roles vary even among these states. They are California, Colorado, Minnesota, New Jersey, New York, North Carolina, North Dakota, and Ohio. Wisconsin also had a county-administered system until January 2013, but over the years, the state moved from a county-based service delivery structure to one in which private entities contract with the state to administer all aspects of TANF in 10 geographical areas. Other states have somewhat hybrid approaches to administration, although their state TANF plans may or may not describe their programs as county administered. Although only eight states currently describe their TANF programs as county-administered, one- half (50.3 percent) of the national TANF caseload resides in these states. California alone accounts for one-third of the national TANF caseload and two-thirds of the total TANF cases in states with county- administered TANF programs. 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Research Design and Methods With the ultimate goal of improving TANF performance, the study addresses three key research questions: 1. What do county-administered TANF programs look like? 2. How do county-administered TANF programs differ from state-administered programs in program implementation, operations, outputs, and outcomes? 3. Do county-administered TANF programs have unique technical assistance needs? To address the questions, the study team conducted site visits in four states with county- administered TANF programs, conducted phone interviews or collected surveys from 29 states with state-administered TANF programs and two additional states with county-administered TANF programs, and analyzed secondary data. The three research questions were deliberately broad to allow for a full exploration of the diversity the study team expected to find in county-administered TANF programs as well as to accommodate the broad range of topics included in the conceptual framework. Each of the research questions encompasses specific aspects of program context, implementation, operations, outputs, and outcomes. Site Visits The research team conducted site visits in three counties in California and two counties each in Colorado, North Dakota, and Minnesota. Site visits included interviews with state TANF directors, state human services directors, county TANF directors, county commissioners, associations of county human services directors, and others as relevant to the state.4 The research team, in consultation with the Administration for Children and Families (ACF), selected states that were diverse in the sizes and characteristics of their TANF caseloads, forms of county governance, geography, and other characteristics. Together, these four states include 70 percent of all TANF cases in county-administered programs. The four states span a range of financial, caseload, and program characteristics (table 1).5 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 TABLE 1 Characteristics of County-Administered TANF Programs Name of TANF in state Average monthly caseload FY 2013 Total spending FY 2013 ($) Work participation rate (all families, nonadjusted) FY 2011 (%) Maximum income for initial eligibility for a family of three July 2013 ($) Number of counties California California Work Opportunity and Responsibility to Kids (CalWORKs) 563,785 7.032 billion 27.8 1,289 58 Colorado Colorado Works 15,124 315.7 million 32.1 421 64 Minnesota Minnesota Family Investment Program (MFIP) 21,435 437.0 million 32.6 1,105 87 North Dakota TANF 1,446 33.9 million 67.6 1,169 53 Source: Huber, Erika, David Kassabian, and Elissa Cohen, The Welfare Rules Databook: State Policy as of July 2013, The Urban Institute, (2014); US Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, TANF caseload and financial data, FY 2013; and Office of Family Assistance, table 1B, Work Participation Rates Fiscal Year 2011. Note: FY = fiscal year. TANF = Temporary Assistance for Needy Families. Maximum monthly income for initial eligibility across the continental United States ranges from $269 in Alabama to $1,526 in Nevada. The average for the continental United States (excluding Wisconsin) is $771. 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S California TANF in the state is called the California Work Opportunity and Responsibility to Kids program (CalWORKs), and the work component of TANF is called Welfare-to-Work. The state implements a 48- month lifetime limit on assistance, after which point the needs of the adult in the family (also called a unit) are excluded in calculating benefits.6 Also as of July 2013, the maximum monthly benefit for a family of three with no income was $638.7 For single parents who do not comply with work requirements without good cause, California’s most severe sanction is to lower the family’s grant by the amount of the adult’s portion of the benefit, approximately $120. If the parent takes appropriate action to comply with the work requirements, the full grant is restored. Table 2 presents additional client characteristics of the state caseload. TABLE 2 Select Client Characteristics, California Caseload composition, FY 2013 No adult 46.5% One-parent 44.2% Two-parent 9.3% Race\/ethnicity, FY 2011 Hispanic 55.1% African American 18.9% White 18.0% Other or unknown 7.9% Percentage with earned income 12.2% Percentage receiving SNAP 89.5% Average monthly benefit $499.50 Sources: US Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Appendix to the Temporary Assistance for Needy Families (TANF) Program’s Tenth Annual Report to Congress, (2013); and Office of Family Assistance caseload data, 2013. Note: FY = fiscal year; SNAP = Supplemental Nutrition Assistance Program. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 Colorado The state calls its TANF program Colorado Works. Receipt is capped at a 60-month lifetime limit that applies to the entire unit. The maximum monthly benefit for a family of three with no current income was $462 as of July 2013. The most severe sanction for noncompliance with work requirements is suspension of the entire family’s benefit for three months or until the individual is back in compliance, whichever is longer. Table 3 presents additional client characteristics of the state caseload. TABLE 3 Selected Client Characteristics, Colorado Caseload composition, FY 2013 No adult 32.2% One-parent 60.4% Two-parent 7.5% Race\/ethnicity, FY 2011 Hispanic 33.3% African American 11.8% White 51.7% Other or unknown 3.3% Percentage with earned income 2.8% Percentage receiving SNAP 62.2% Average monthly benefit $366.70 Sources: US Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Appendix to the Temporary Assistance for Needy Families (TANF) Program’s Tenth Annual Report to Congress, (2013); and Office of Family Assistance caseload data, 2013. Note: FY = fiscal year; SNAP = Supplemental Nutrition Assistance Program. 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Minnesota TANF in the state is called the Minnesota Family Investment Program (MFIP). The lifetime limit for assistance is 60 months and applies to the entire unit. The maximum monthly benefit for a family of three with no current income was $532 as of July 2013. The most severe sanction for noncompliance with work requirements is case closure8 for the entire family for at least one month or until the individual is back in compliance. Table 4 presents additional client characteristics of the state caseload. TABLE 4 Selected Client Characteristics, Minnesota Caseload composition, FY 2013 No adult 50.0% One-parent 50.0% Two-parent 0.0% Race\/ethnicity, FY 2011 Hispanic 13.3% African American 34.7% White 30.9% Other or unknown 21.0% Percentage with earned income 16.8% Percentage receiving SNAP 99.6% Average monthly benefit $343.20 Sources: US Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Appendix to the Temporary Assistance for Needy Families (TANF) Program’s Tenth Annual Report to Congress, (2013); and Office of Family Assistance caseload data, 2013. Note: FY = fiscal year; SNAP = Supplemental Nutrition Assistance Program. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 North Dakota The program in North Dakota is simply called TANF. The state imposes a 60-month lifetime limit for assistance that applies to the entire unit. The maximum monthly benefit for a family of three with no current income was $477 as of July 2013. The most severe sanction for noncompliance with work requirements is case closure for the entire unit until compliance. Table 5 presents additional client characteristics of the state caseload. TABLE 5 Selected Client Characteristics, North Dakota Caseload composition, FY 2013 No adult 45.9% One-parent 54.1% Two-parent 0.0% Race\/ethnicity, FY 2011 Hispanic 3.3% African American 5.7% White 27.9% Other or unknown 63.1% Percentage with earned income 21.4% Percentage receiving SNAP 86.2% Average monthly benefit $313.80 Sources: US Department of Health and Human Services, Administration for Children and Families, Office of Family Assistance, Appendix to the Temporary Assistance for Needy Families (TANF) Program’s Tenth Annual Report to Congress, (2013); and Office of Family Assistance caseload data, 2013. Note: FY = fiscal year; SNAP = Supplemental Nutrition Assistance Program. After selecting the states to include in the study, the research team, in consultation with ACF, selected two to three counties to visit in each state. The counties varied in size of the population served, with one county being among each state’s most populous (marked with * in the list below) and another of moderate or small size. The counties included a range of TANF program approaches and caseload characteristics. The study team visited the following counties: \uf06e Los Angeles County, California* \uf06e Placer County, California 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S \uf06e Stanislaus County, California \uf06e El Paso County, Colorado* \uf06e Fremont County, Colorado \uf06e Chippewa County, Minnesota \uf06e Hennepin County, Minnesota* \uf06e Burleigh County, North Dakota* \uf06e Rolette County, North Dakota Phone Interviews To gather information about state-administered TANF programs, the research team conducted targeted phone interviews with a large sample of state TANF directors of state-administered programs. The sample included the 26 states with the largest TANF caseloads and three states neighboring North Dakota with relatively small TANF caseloads (appendix A). Each call lasted approximately 40 minutes and used a structured interview guide. A few states chose to enter responses directly into a survey form that was substantively identical to the interview questions. The state-administered TANF programs that provided information account for 82 percent of all TANF cases in state-administered programs. The study team also reached out to each of the four states with county-administered TANF programs that had not been included in the site visits to offer the opportunity to contribute in the form of similarly structured interviews. Two states, New Jersey and North Carolina, provided information. Together, the caseloads of New Jersey and North Carolina account for 7 percent of the total cases in county-administered TANF programs. Analyses of Secondary Data To more fully explore differences between county-administered and state-administered TANF programs, the study team conducted limited quantitative analyses of secondary data on state characteristics, program characteristics, and program outcomes for all 50 states and the District of Columbia. The state data included the following: A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 9 \uf06e State characteristics \u00bb Population \u00bb Population density \u00bb Unemployment rate \u00bb Poverty rate \u00bb Share of poor families receiving TANF \u00bb Number of counties \u00bb Political parties of governor, House majority, Senate majority \uf06e State TANF program characteristics \u00bb Work participation rates \u00bb Number of years meeting work participation rate \u00bb Maximum benefit levels \u00bb Maximum income for initial eligibility \u00bb State TANF time limits \u00bb Worst-case sanction \uf06e State TANF caseload characteristics \u00bb Race\/ethnicity \u00bb Percent with earned income \u00bb Average monthly benefits \u00bb Average earned income \u00bb Percentage with sanctions \u00bb Percentage receiving TANF for more than 60 months The study team also reviewed state TANF plans and other relevant documents and data for each of the four states visited. 1 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S What Do County-Administered TANF Programs Look Like? No two county-administered TANF programs look alike. Each of the study states engages its counties in some aspects of program financial management and decisionmaking around administrative processes, including how to structure processes for accepting applications and managing active TANF cases. However, across the study states, counties have vastly different degrees of autonomy in and responsibility for these aspects of TANF and for policy development. This section describes in detail the TANF programs in the four states selected for site visits. Summary information from two additional states with county-administered TANF programs, New Jersey and North Carolina, is included at the end of the section. Across the study states, Colorado counties have the most autonomy and responsibility in administering the state’s TANF program. Selected Colorado counties and community organizations serving low-income populations play a formal role in approving statewide program eligibility rules, benefit levels, and other parameters, and counties have considerable flexibility in designing county TANF programs within those parameters. Colorado counties collectively, in conjunction with state staff, are responsible for determining how federal funds are distributed to counties. County governments are responsible for contributing the full amount of the required nonfederal spending and managing these funds to meet all county-level program and administrative costs, except for major IT system costs. In California, the state and counties share considerable authority and responsibility for TANF administration. The state pays most of the costs and establishes statewide eligibility rules, benefit levels, and other program rules, but the counties have significant input into the process. Within statutory and regulatory parameters, California counties have flexibility in designing and administering an array of services that meet local needs. In stark contrast to Colorado and California, North Dakota offers its counties almost no authority to shape policy, determine employment services, or determine the allocation or use of federal and state funds. Nonetheless, North Dakota’s counties have a sizable financial responsibility: counties cover all administrative costs of the county program. Minnesota falls somewhere in the middle. Minnesota counties are financially responsible for one- half of the program’s administrative costs; funding from the state makes up the balance. Minnesota counties also have authority to decide how to spend their allotment of state and federal funds for A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 1 emergency services and whether to provide services themselves or contract with employment service providers. As a result of the greater county flexibility in Colorado, California, and to some extent Minnesota, clients in different counties in those states will have more varied experiences and opportunities than clients in different North Dakota counties. However, on the whole, a family’s TANF experience is shaped more by the state in which they live than by their county because each state has uniform eligibility rules and benefit levels. Each state with a county-administered TANF program has a unique approach to sharing responsibilities between the state and counties in terms of the bureaucratic structure, responsibility for contributing financially, authority for financial decisions, authority for making policy decisions, and mechanisms for program oversight. States also make management and implementation choices about county roles in delivering services to clients and accessing information technology. After a brief history of how the study states came to have county-administered TANF programs, this section presents details on each of these state-county relationships and service delivery dimensions. History of TANF Administrative Structure Counties have administered TANF in the four study states since each first implemented the TANF program in 1996 or 1997, and all but Colorado administered AFDC at the county level prior to TANF. In California, counties have been responsible for caring for the vulnerable and needy throughout the state’s history, though the state had a more formal role in administering AFDC. With the implementation of TANF, the state maintained responsibility for establishing program eligibility rules, but it delegated substantial discretion to the counties for designing and administering the expanded employment services of TANF. Each county was required to develop its own CalWORKs implementation plan. Since then, details of the state and county responsibilities have changed, but the basic administrative structure continues. Colorado had a standardized, statewide AFDC program, but counties, which had considerable autonomy in the state generally, were fully involved in developing the initial state TANF plan. Given the diversity of the counties, particularly in their labor markets, the committee developing the state TANF plan recognized that it would be challenging to design a single program for the entire state that would meet the federal employment requirements of TANF. Therefore, the state TANF plan provided 1 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S extensive autonomy for the counties. As one county official involved in that process said, It was a new concept for everyone to rewrite your own program. It was kind of a first! Although the formal roles of the state and the counties in administering TANF have remained consistent, the tenor of their relationship has fluctuated over the years. State and county representatives now describe a particularly positive and collaborative working relationship. Minnesota has a long tradition of local control that continues today. The specific structure of the state’s TANF program began under AFDC. Minnesota obtained a federal waiver in 1994 to create its MFIP program, which the state adopted as its TANF program in 1997 and launched in 1998. The first change to that earlier structure came three years ago when a group of 14 counties chose to work together and received state permission to administer TANF employment services under the direction of a joint powers board with representatives from each of the 14 counties; 2013 was the first year with a shared contract. In the past, the 14 counties worked cooperatively, but each had its own plan. Now, the 14 counties have permission from the state to submit a single joint plan. In North Dakota, counties have always administered social services programs. In 1935, the legislative assembly established a county welfare board (together with a public welfare board), and the assembly legislated primary responsibility for providing care for people in need upon county government. According to a county social services board member, Each county sees it as their prerogative to run their programs. This relationship has remained relatively unchanged since at least the early 1980s, state administrators said. Before then, local workers, who typically handle cases across all of the state’s public assistance programs and not just AFDC or TANF, had more discretion in making eligibility-related decisions. State administrators pointed to growth in programs such as Medicaid and food stamps coupled with new eligibility rules and concerns about federal regulations as drivers of the changes in the state-local relationship that scaled back some local decisionmaking authority. In recent years, state legislators have filed bills to end county administration of public assistance programs, though these measures have failed. Table 6 describes the history of TANF administrative structure in the four case study states. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 3 TABLE 6 History of TANF Administrative Structure in the Four Case Study States County- administered when? Changes with or after TANF? Recent changes? California Always Greater county discretion in work programs under TANF than AFDC More frequent state rule changes that counties need to implement Colorado With TANF TANF was the first time counties developed their own welfare programs Positive changes to state-county relationship (communication; collaboration) Minnesota Always MFIP began with a waiver; became foundation for TANF 14 counties jointly administer employment services North Dakota Always No changes to administrative structure No Source: Urban Institute and ICF analyses. Bureaucratic Responsibilities In every state, administering TANF is a multifaceted endeavor involving a host of actors with varying degrees of authority and responsibility. State actors include the legislature, the governor, and executive branch agencies. Within the state human services agency, one person serves as the official TANF director, though that person may have responsibility for other programs as well, and other people also have important roles related to TANF. In states with county-administered TANF programs, actors include a county TANF director, who also might have responsibility for programs other than TANF and who might have staff to assist with various aspects of TANF administration. The county TANF director is usually hired by the county board of commissioners (or board of supervisors depending on the county’s nomenclature), a body of elected officials who have oversight responsibility for the county. In addition, most states have an association of county social service directors, although the membership of the organization and the formality of its role vary by state. County employees staff the county social service offices that administer TANF. Beyond this consistent set of actors, in some states TANF administration also involves other state or county committees and decisionmaking bodies. In some states, unions may play an important part in negotiating the details of how TANF services are delivered to clients. Together, these actors develop and implement TANF legislation, rules, and policies; ensure the smooth and accountable flow of federal, state, and county TANF dollars; and ensure compliance with federal, state, and county requirements. The entity that has decisionmaking authority for a particular 1 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S aspect of TANF administration may or may not have a financial responsibility as well. In each of the states, there are some differences in the roles and responsibilities related to determining eligibility and providing TANF cash assistance, as compared with those related to developing and providing TANF employment-related services. For example, county employees might handle eligibility determination and case management while contractors provide employment-related services. Among the four county- administered TANF programs included in this study, each state’s specific approach to TANF administration is unique, as described in the following sections. State and County Roles CALIFORNIA The state law creating CalWORKs made a distinction between rules governing who is eligible for TANF and rules about the services families would receive. The state maintains statewide eligibility standards and grant levels but delegates substantial discretion to counties for service decisions. For example, the state may require that counties provide orientation to clients and assist them in a job search, but the counties develop their own specific orientation curriculum and job search programs. The state has no direct authority over the county welfare directors, who are hired by and accountable to the county boards of supervisors. However, the state does maintain the ability to take severe measures, such as halting a county’s TANF funding, in the unlikely scenario of gross county mismanagement of the program. TANF actions are governed by state statute, regulations, and state-issued All County Letters, which essentially have the force of regulations. The state requires counties to submit CalWORKs plans that broadly define the TANF program choices they have made within the state regulatory framework. In this state-supervised, county-administered system, the state interprets federal law, regulates, oversees performance, and manages the accounting and control required to comply with state and federal fiscal control agencies. Counties lease buildings, hire staff, procure computers and automated eligibility systems, receive state and federal money, contribute their own money, administer benefits and services, report to the state, and are subject to audits. COLORADO Similar to California, Colorado has consistent statewide TANF eligibility rules and benefit amounts and a statewide framework for Colorado Works included in the state TANF Plan. Within that framework, counties develop and implement individual policies that are approved by county boards of commissioners and certified by the state as compliant with state rules. However, in contrast to the A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 5 other study states, the State Board of Human Services must approve Colorado’s statewide TANF rules, within the limits of state and federal law.9 The board is composed of governor-appointed county commissioners and community stakeholders, such as representatives from Boys & Girls Clubs and United Way. CDHS may, however, initiate rule changes. In addition, a committee of county commissioners and state staff, the Works Allocation Committee, determines the formula for allocating federal TANF funds to counties. Each county human services director is hired by and accountable to the county board of commissioners. The state and county roles regarding TANF are included in a memorandum of understanding between the state and a county. Generally, each memorandum of understanding is identical except for the county name. The state provides monitoring and oversight to ensure compliance with state and federal laws and provides training to the counties. MINNESOTA In Minnesota, state statutes outline most of the bureaucratic relationships and TANF policies. As in California and Colorado, Minnesota has statewide TANF eligibility rules and benefit amounts and allows counties greater discretion in providing employment and training services. The state Department of Human Services is responsible for administering TANF policy, making recommendations to the governor and legislature regarding the implementation of TANF, and ensuring the quality and integrity of MFIP implementation throughout the state. Although the state seeks input from the counties to develop policies and legislation, it ultimately sets the policy. Within the limits of state law and policy, counties can choose whether to provide services directly or through contracts, how to administer state policies, and which performance standards to include in any contracts. Counties submit biennial plans to the state indicating how they intend to use funds allocated to them for providing employment and training services and for the state share of eligibility worker salaries, as well as whether they plan to use any of the funds for emergency cash assistance (if they do, counties set policies for this assistance). Counties also can seek state permission to collaborate with other counties to develop regional performance standards or to comingle funds. As noted, a group of 14 counties has formed this type of collaborative relationship and act as a unit for many TANF program purposes. NORTH DAKOTA In North Dakota, counties have the least autonomy of all the study states. For example, the state sets all eligibility and program rules, and counties cannot contract with private or nonprofit groups directly or adjust the programming for TANF services. For eligibility-related functions, counties have discretion only in establishing business processes, staffing levels, and other aspects of administering uniform state TANF policies, although counties do have autonomy in assessing clients’ needs and making referrals to 1 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S outside groups, state administrators said. County employees staff the county social service offices. For employment-related services, the state contracts directly with three service providers who each cover part of the state. Both counties and employment service contractors interact independently with the state through its TANF program administrator and regional representatives who also provide technical assistance and training. The state seeks input from counties and employment service contractors on some policies and administrative guidelines, but it does not allow flexibility within the established policies and guidelines. ROLES OF COUNTY ELECTED OFFICIALS The roles of the county elected officials are similar in each of the four study states. As oversight bodies responsible for protecting the counties’ legal and financial responsibilities, the county commissioners and county boards of supervisors hire the county TANF directors and approve the counties’ TANF budgets and contracts. Whether county boards also must approve county-level changes to TANF policy varies by state and county. For example, California boards mainly approve only the initial county plans, not the annual updates; boards in Minnesota and Colorado, as well as in some counties in California, must approve all county-level policy changes. The state sets all TANF policies in North Dakota. For the most part, elected officials rely on their appointed TANF directors to handle day-to-day decisions. However, some issues require board input. In the counties visited for this study, TANF directors typically keep the board informed, at least through annual reports, about the status of the program and the director’s decisions. For example, when the Los Angeles County Department of Public Social Services decided to assign dedicated case managers to homeless clients, they did not go to the board for an overt policy decision, said a county administrator, but consulted with the board’s representatives, [and] called deputies who were heavily involved in the decision. In some communities, advocates for low-income families also bring issues to elected officials’ attention. Although boards are not generally involved in day-to-day decisions, their level of involvement can vary depending on the county. According to those interviewed in Colorado, commissioners in some counties are very involved in Colorado Works and even sign off on decisions about whether to grant diversions to individual families. North Dakota county commissions appoint social services boards that meet monthly with county social services departments and handle the midlevel decisions, such as whether to hire additional staff. The county commissions in North Dakota are the ultimate approval authority and handle major decisions themselves, while the county TANF program administrators handle day-to-day administration of the program. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 7 Unique to Colorado among the study states, county commissioners play major roles in promulgating statewide rules and determining the allocation of federal TANF funds to the counties. Elected officials vary in their backgrounds and professions and hold diverse perspectives and attitudes about low-income families and social services in general, according to several TANF directors and elected officials interviewed. They often have limited knowledge of social policy or social service implementation issues. TANF issues are a small part of the overall issues county elected officials face. As one elected official in Colorado explained, You have to understand, commissioners aren’t always prioritizing TANF with roads and bridges and fires and floods. It is not a major focus. We don’t micromanage the department, but we keep accountability through the budget process. Our finance department makes sure things are operating smoothly and we are meeting regulations from the state. ROLES OF ASSOCIATIONS OF COUNTY SOCIAL SERVICE DIRECTORS Associations of county administrators play a role in the administration of TANF in each of the study states. The County Welfare Directors Association of California (CWDA) has the most extensive role of any of the associations in the study states. The CWDA is a nonprofit association representing human service directors from each of California’s 58 counties.10 It serves as a two-way conduit between the state and counties, helping the state to stay abreast of what is happening in the counties. It also analyzes county-level data for the state and helps counties understand state rules. Because county TANF directors in California do not directly report to the state TANF director, the state does not have easy access to data or other information on TANF service delivery beyond that collected in its regular fiscal and program reporting. When the state is considering a change in regulations or enacts legislation, the CWDA advises and provides assistance to agency or legislative staff, such as talking through the implications and providing data analysis and surveys. The CWDA facilitates dialogue between the state and the counties both formally and informally. The CWDA also hosts and facilitates meetings among stakeholder groups, forums, and committees, as well nearly daily informal discussions with state and county entities about funding, programming, and all other aspects of TANF implementation, according to CWDA representatives. Although the CWDA is a membership organization representing county TANF directors, professional staff overseen by a paid executive director conduct most of the CWDA work. The heads of the county social service departments serve as the board of directors for the CWDA. The Colorado Human Services Directors Association (CHSDA), like CWDA, is a nonprofit association representing the human services directors from each of Colorado’s 64 counties. However, CHSDA is primarily an association of county TANF directors and has just two staff members (a policy analyst and a coordinator). An individual county TANF director serves as the president of CHSDA. 1 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S CHSDA works under the authority and direction of the county commissioners and their formal association, Colorado Counties, Inc. CHSDA provides a collective voice for county directors to share their perspectives and recommendations with the state legislature and state agencies, and it facilitates information sharing among the counties. For example, as counties develop innovative programs, they share information through CHSDA on how other counties can develop similar programs. However, budget limitations within counties reportedly have reduced such innovative programs. The Minnesota Association of County Social Service Administrators (MACSSA) plays a large role as a workgroup and advisory group to the state. The group formed in 1946, and its 135 county public service directors and staff members represent all 87 Minnesota counties. Members of the MACSSA Self-Sufficiency Committee meet monthly with state officials to discuss MACSSA and state ideas and concerns. MACSSA employs an executive director, a lobbyist, and a small staff, who are managed by an executive committee of members. According to an active member of the association, the state uses the committee to float ideas or receive input. The state formally requests MACSSA representation on various committees and workgroups. MACSSA committee appointees, in turn, report back to the association. The self-sufficiency committee is one of several program-focused committees within the broader state association. Members of the committee are considered content experts in all income support program areas. The group is composed of county directors and senior-level managers who have responsibility for eligibility and case management in most financial programs in the county. Separate committees focus on child support and health care. Committees’ focus has shifted in different directions over the years with administrative and policy changes, an association leadership representative said. The North Dakota Association of Counties is an umbrella organization, authorized by state law, that represents not only county social service directors but also county prosecutors, clerks, sheriffs, and other county officials. The primary role of the association is to unite the groups in a common legislative agenda and to advocate for the counties. However, the association also has a fiduciary responsibility. It also provides insurance, IT support, and other programs or services for the counties. For example, some smaller counties without IT departments rely on association-provided IT services for a fee, such as setting up employees’ work stations or maintaining local computer networks. However, the association has no direct responsibility for TANF or role in TANF administration, state administrators said. The association is led by an executive director who answers to a board of directors consisting of 25 county officials. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 1 9 ROLES OF UNIONS In California, labor unions also play a role in TANF administration because most of the frontline staff are union members. State and county officials interviewed in California generally characterized their relationship with the unions as positive and collaborative. For example, TANF administrators in Stanislaus County said they often confer with union officials about potential changes to ensure they have union support. In one case, for instance, before opening a call center that would be staffed on Saturday mornings, Stanislaus County TANF administrators consulted with the union. In Los Angeles County, unions and county administrators have worked in partnership to advocate for state resources and make county-level decisions about allocating funds. Although the same union represents most eligibility workers, according to a Los Angeles County official, there is substantial local variation among the union contracts. In Minnesota, some county eligibility workers are union members, as are employment services workers in some sites. Colorado and North Dakota do not have unionized TANF workers. Union officials were not interviewed as part of this study. Financial Management and Fiscal Reporting TANF programs nationally are funded through a combination of federal and state (or local) funds. Each state receives an annual TANF block grant, the amount of which has remained constant since 1997. As a condition of receiving federal funds, each state is required to maintain a certain percentage of its historical spending on welfare programs, known as state maintenance of effort (MOE). States may use federal TANF and state MOE funds for any of the four purposes of TANF, which are (1) to provide assistance to needy families so that children can be cared for in their own homes or homes of relatives; (2) to end the dependency of needy parents on government benefits by promoting job preparation, work, and marriage; (3) to prevent and reduce the incidence of out-of-wedlock pregnancies; and (4) to encourage the formation and maintenance of two-parent families. States with county-administered TANF programs have developed their own approaches to incorporating counties into financial contributions and funding decisions. In California, the state’s general funds cover nearly all of the program costs, while Colorado dedicates no state general funds to the TANF program. In Minnesota and North Dakota, the state covers the cost of benefits to individual families and other major costs, but the counties are responsible for at least one-half of the administrative costs of the program. In North Dakota, counties pay all of the administrative costs for TANF, but the state covers all benefit expenditures. 2 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Counties have varying authority over how TANF funds are spent. Colorado counties have the most autonomy (and responsibility) for spending their federal and county funds, with individual counties making their own decisions about spending on cash assistance, program administration, supportive services for TANF clients, and even on whether and how to use funds for preventing out-of-wedlock pregnancies and encouraging two-parent families. In both California and Minnesota, counties make decisions about funding additional supports and services beyond those the state requires, and at least some aspects of program administration, though there are significant differences in the level of authority between the states. North Dakota counties have no authority over how TANF or state funds are spent; even administrative costs are based on estimates of administrative time dedicated to TANF, not proactive county decisions. State and county TANF budgets have been squeezed in recent years. The block grant has declined in real value as a result of inflation, and the recession increased demand for services while reducing state and county general funds. In addition, changes to federal TANF law as a result of the Deficit Reduction Act of 1995 created financial pressures. The American Recovery and Reinvestment Act of 2009 buffered some of the financial pressures introduced by the recession by providing the temporary Emergency Contingency Fund to support TANF expenses related to increased caseloads, short-term nonrecurring benefits, and subsidized employment. Those funds were available only through the end of fiscal year 2010. Counties in each of the study states except North Dakota reported that as a result of constrained funding, they cut TANF-related supportive services or employment services, limited program innovations, or reduced funding for TANF purposes other than cash assistance. Table 7 provides an overview of TANF financial management in the four study states. The remainder of this section describes those arrangements in detail. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 2 1 TABLE 7 Overview of TANF Financial Management in the Four Case Study States Funding sources County funding obligation Who pays MOE? Who determines allocations among counties? County spending authority California Federal, state, county 2.5% of basic cash assistance; fixed MOE share State and county Counties recommend; state decides Administration, support services Colorado Federal, county Full fixed MOE County Counties recommend; legislature decides Cash assistance, administration, support services Minnesota Federal, state, county 50% of administration costs State State Support services, including administration of support services North Dakota Federal, state, county Administration costs State State None Source: Urban Institute and ICF analyses. Note: MOE = maintenance of effort. California CalWORKs is funded through a combination of the federal TANF block grant, state general funds, and county funds. The state legislature, with input from the governor and the California Department of Finance, decides how the federal TANF block grant will be appropriated and how much of the state general fund to budget for CalWORKs. Costs for basic cash assistance are handled differently from the rest of the CalWORKs costs. Counties must contribute 2.5 percent of basic cash assistance costs and a fixed MOE amount. To cover nearly all other aspects of CalWORKs, counties receive an allocation of the combined federal and state funds. With these funds, the counties pay for both administrative and program costs, including hiring workers, leasing buildings, providing or contracting for employment and support services, and other elements. The counties are not responsible for IT costs related to CalWORKs. After the state legislature proposes and the governor approves a negotiated budget for specific categories of CalWORKs expenditures, counties play a substantial role in determining how the total funds are distributed among the counties and how the funds are spent. The CWDA helps counties and the California Department of Social Services arrive at a consensus on an allocation formula for distributing the budgeted amount among the counties. According to a California state official, the 2 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S counties definitely collaborate to redistribute resources the most effectively. If [one] county realizes it’s going to be underspending and [another] county realizes it’s overspending, they’ll try to work that out [in advance]. [The state] will put out a planning allocation but ultimately [the counties] will sit down in a room and the final allocation is really dictated by county choice. Counties may not carry allocations over into the next year. The distribution formula has evolved with time. Historically, the distribution was based primarily on county caseload and prior spending, but recently has included consideration of actual costs per case. Most of the funding allocated to counties is part of the CalWORKs single allocation, which includes four suballocations for eligibility determination, welfare-to-work services, child care subsidies for TANF recipients, and CalLearn.11 Each suballocation can have a different distribution formula. Although the amounts of the four suballocations are determined separately, the funds are fungible. In addition to the CalWORKs single allocation, the state provides supplemental funding streams, including three new allocations established since 2013 for the state health insurance exchange, family stabilization activities, and a subsidized employment program. In practice, the counties are reimbursed quarterly for costs up to the full amount of the annual allocation. Likewise, the county MOE contributions are deducted from the allocation rather than sent to the state by the county. Counties may satisfy the MOE requirement through their CalFresh (California’s implementation of the Supplemental Nutrition Assistance Program [SNAP]) spending, which most counties do, leaving them with no MOE costs for CalWORKs. At some point each fiscal year, CWDA helps counties adjust the redistribution if counties are under- or overspending their initial allocations. Because the allocation formula includes historical spending that may no longer reflect current conditions, some counties receive a lower base allocation per case than other counties and may have a greater challenge spending within their allocations. Neither state nor county officials were aware of specific mechanisms for providing additional state funds to assist counties should a natural disaster strike. Los Angeles County representatives recall the county covering the added costs associated with the Northridge earthquake in 1994. Counties have considerable flexibility in how they spend their single allocation. In Stanislaus County, TANF officials first consider staffing, support, and overhead for running the program. Then they consider how much they will use for direct support services, child care, and contracted services. Contracted services have included a literacy center, vocational training programs, and a clean and sober living program. Los Angeles County TANF staff, in contrast, first consider child care costs because CalWORKs regulations require child care subsidies for working TANF recipients. Next they A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 2 3 determine spending levels for eligibility services followed by domestic violence prevention, homeless prevention, training, and other supports. After deciding how much to spend on each component, they decide whether to provide the services themselves or contract for the services. The county boards of supervisors must approve the county TANF budgets and contracts and authorize the expenditures. Counties have the option to use county general funds to supplement the single TANF allocation. According to a representative of CWDA, it was more common before the recession for counties to do so, often to pay for elective services such as dental care or tattoo removal that may help parents be more successful finding employment but that are outside the realm of basic allowable welfare-to-work activities. The state retains a portion of the federal TANF block grant to administer CalWORKs. The legislature also appropriates some federal TANF or state MOE for efforts to prevent pregnancies among unmarried mothers and promote two-parent families (TANF purposes 3 and 4). Most notably, the state uses roughly $1 billion per year for college scholarships for low-income individuals, based on evidence that college-bound and college-educated women are less likely to become single mothers. However, the state typically does not retain funds for state-run TANF initiatives. Instead, the state can influence county-level initiatives by providing dedicated funding streams to county TANF programs. For example, since January 2014, a portion of the state and federal TANF funding has been distributed to counties for family stabilization activities, such as augmenting existing efforts to stabilize family housing or address other crises that may prevent families from securing and keeping a job and becoming self-sufficient. The state sets the spending parameters for the funds, and each county develops its own approach. Family stabilization efforts emerged after the state reduced the lifetime limit on TANF in the state from 60 months to 48 months and as new opportunities were established in 2012 to receive a wider array of welfare-to-work services. Colorado Colorado Works is funded through a combination of the federal TANF block grant and county funds. No state general funds are dedicated to the TANF program, though the state may choose to count some of its spending on related programs toward the state’s MOE requirement. The Colorado state legislature decides how much of the federal TANF block grant will be designated for counties and how much the state will receive. Typically, about 85 percent of the block grant goes to counties and about 15 percent to the state. CDHS is responsible for the state allotment and uses it for TANF services for refugees, a small contingency fund, and to oversee the integrity of the county TANF implementation, including 2 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S providing electronic reporting systems, training, and technical assistance. During better economic times, the state used some of the federal TANF funds for Statewide Strategic Use Fund grants, which funded innovative community projects responsive to the four federal purposes of TANF. The federal TANF funds designated for county use are allocated to specific counties on the basis of Works Allocation Committee (WAC) recommendations. WAC is a committee of county commissioners (or their appointed designees) from each of the 64 counties and three state CDHS staff. The committee agrees on a formula for allocating the federal TANF block grant funds among the counties. The CDHS director makes the final decision. The formula can be adjusted each year, but generally includes factors such as TANF caseload, previous spending, poverty rate, penetration rates for food assistance and Medicaid, and the number of families eligible for Medicaid, as well as minimum and maximum allocations per county. Counties are responsible for all aspects of TANF, including basic cash assistance grants, employment services, staff salaries, facilities, county IT systems, and more. In addition, counties decide whether and how much to spend on preventing births to unmarried women and promoting two-parent families (TANF purposes 3 and 4) and whether and how much to transfer to the Child Care and Development Block Grant or the Social Services Block Grant. Both El Paso and Fremont county-TANF administrators reported transferring TANF funds in the past to child care or activities related to pregnancy prevention and two-parent family promotion, but they have since reduced or eliminated these expenditures because of budget cuts. Each county is also responsible for contributing a fixed amount of county funds toward the MOE requirement. Although counties know the amount of their federal TANF fund allocation and MOE requirement at the beginning of the year, they must spend county funds to meet the MOE requirement before spending the federal TANF funds. Together, the counties’ contributions to MOE fulfill the state’s MOE requirement. However, additional state spending on preschool programs, the nurse home-visiting program, refundable state earned income tax credits, and other related programs helps the state exceed its required MOE amount. Counties are also encouraged to identify community partners’ activities that could help the state accrue more than the required MOE ( excess MOE ). Counties are allowed to save up to 40 percent of their federal TANF allocation or $100,000, whichever is greater, in reserve. (Until recently, counties could keep unlimited reserves.) Counties may also shift federal TANF funds among themselves to make midyear allocation adjustments. In small counties or counties that have budgeted conservatively, relatively small changes in the caseload or contracts during the year can make a big difference in the budget. A county can sell funds to another A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 2 5 county, in which case the receiving county also takes responsibility for contributing the MOE funds. On the other hand, a county can gift funds to another county, in which case the donating county contributes the full MOE. Gifting of funds is common after natural disasters. Selling funds is common when program circumstances change unexpectedly during the year. For example, if a county’s caseload is higher than expected and the county doesn’t have enough funds to cover basic cash assistance as well as other priorities, it would seek another county’s federal TANF funds, even though the receiving county would also need to increase the amount of its own county funds to meet the MOE requirement. Likewise, a county that either finds itself with more federal TANF funds than it needs or is having difficulty finding the county funds to pay the MOE requirement, will try to sell some of its federal TANF funds and transfer responsibility for the MOE contribution to another county to reduce its own county financial burden. WAC must approve all midyear funding shifts between counties and historically has approved all requests. In addition, without formally shifting funds, counties can pool resources to fund joint contracts or joint activities with other counties. Minnesota Minnesota’s MFIP program is funded with a combination of federal, state, and county funds. The funding mechanisms and responsibilities differ for basic cash assistance costs, administrative costs, and the costs of supportive services. For administrative costs associated with determining program eligibility, counties receive an approximately 50 percent reimbursement from the state on the basis of an electronic sampling of how caseworkers spend their time across different assistance programs (random-moment time studies). For program expenses for employment and supportive services, counties receive a Consolidated Fund allocation from the state. Counties use the Consolidated Fund for employment and training services and staff, emergency cash assistance, staffing expenses for the state’s TANF diversion program, and other supportive services such as clothing and transportation. The state caps use of the Consolidated Fund for administration at 7.5 percent of the fund. Counties receive 95 percent of their Consolidated Fund allocations automatically, and they can receive the remaining 5 percent only when they meet specific performance measures; 2.5 percent is tied to the calculated local work participation rate, and 2.5 percent is connected to the Self-Support Index. The Self-Support Index is a retrospective, statistically adjusted alternative performance measure that focuses on select client outcomes. (For more details, see Program Oversight section below.) Counties must submit biennial plans to the state indicating how they intend to use the Consolidated Fund. Counties have flexibility to decide the type of emergency cash assistance they will provide, how 2 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S to target the services, and how much to spend. They also decide how much of the fund to contract out for employment services. For example, individual county choices varied widely after a recent cut in the Consolidated Fund, with some counties cutting only employment services and others cutting other aspects of their programs. Counties also have flexibility to provide services to families whose incomes are up to 200 percent of the federal poverty guideline, although few have chosen to do so. Each of the 14 counties that are working collectively to provide employment services contributes a portion of its Consolidated Fund to a joint contract with a single employment service provider. Consolidating their efforts creates savings to each of the counties because now there is a single invoice and one fiscal agent handles the administration of the contracts. The state legislature appropriates federal TANF block grant funds, including transfers, to the Social Services Block Grant or Child Care and Development Fund and decides whether to use any TANF funds for purposes 3 and 4. For example, Minnesota has directed significant TANF funds to family planning services, the Family Home Visiting Program, and grants to reduce racial and ethnic disparities in infant mortality rates.12 In addition, since 2005 the state has set aside state and TANF dollars for an Innovation Fund. Most recently, the state set aside $3 million per year for this purpose. The state typically identifies areas for innovation and seeks proposals from the counties. In the past, Innovation Fund dollars have been targeted for transportation services and for Adult Basic Education services. Counties can apply for an Innovation Grant at any time during the year until the fund is depleted. In addition to MFIP program expenses, Minnesota uses state MOE funds for subsidized child care, a refundable tax credit for K 12 education expenses, the Minnesota Working Family Credit, Head Start, and noncitizen medical assistance. North Dakota North Dakota’s TANF program is funded with federal, state, and county funds. Counties are responsible for TANF administrative costs, while the state pays all program costs. To determine TANF administrative costs, the state conducts random-moment time studies. The state provides TANF cash benefits directly to clients, and the state contracts directly with employment service providers. The employment services contractors have a fixed budget and are reimbursed by the state for expenses within the budget. The state also uses a portion of the TANF block grant for emergency services and family preservation supports in the foster care system. The state meets its MOE requirement through spending on child care, child support, and other programs. In counties with Native American A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 2 7 reservations, the state is responsible for a percentage of administrative costs based on the size of the tribal population. When AFDC was transitioning to TANF in North Dakota, the state legislature, in consultation with the counties, enacted a sweeping change to the state-county financial relationship across a broad swath of its public assistance programs. Passed in 1997 and referred to as the swap legislation, the state assumed full program costs for nine public assistance programs including cash assistance and the complementary Job Opportunities and Basic Skills program. Also included were the state’s child care, food stamp, and medical assistance programs, among others. Before the swap, a state finance administrator said, counties were responsible for using county money for 15 percent of the nonfederal grant program costs of economic assistance programs such as Medicaid, child care, and AFDC. Those costs, and particularly financing for grant expenditures, were becoming too much to bear and deemed out of local officials’ control, especially for the Medicaid program. In response, the swap legislation transferred budgetary responsibility for 100 percent of the program expenses to the state. In return, the counties assumed responsibility for all administrative costs for the local provision of services instead of just a portion of these costs.13 One motivator for the financing change was to maximize spending efficiency, a manager with the state association of counties said. Consequently, local offices have begun seeking ways to collaborate and share staff, particularly in rural areas. Thus far, two multicounty units have combined social services offices. In North Dakota, the state makes all funding decisions beyond local administrative costs, including whether to transfer TANF block grant funds to the Social Services Block Grant or Child Care and Development Fund. Similarly, state officials determine whether to use any TANF money for family planning and promotion of two-parent families. Other than the swap legislation, the only other significant financing change was a shift in child support enforcement responsibility from the counties to the state beginning in the early 2000s, which tangentially affected TANF. Policy Authority and Development at the State and County Levels The policy authority of states and counties varies across the four study states. However, one consistent feature is that counties lack the authority to change basic TANF eligibility criteria and benefit amounts, which are uniform throughout each state. This section discusses which policies the state or county makes and the processes for arriving at those policy decisions. It also discusses how policies vary by 2 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S county. Table 8 summarizes some of the basic aspects of policy development authority in the study states. TABLE 8 Authority for TANF Policy Development in Four Case Study States Eligibility rules Benefit amounts Other policies Contracts for services California State State County flexibility within state parameters Counties Colorado County representatives approve consistent statewide rules. Counties may expand eligibility in some areas with county funds. County representatives approve consistent statewide rules. Counties may increase benefits with county funds. County representatives approve consistent statewide parameters. County flexibility within state parameters. Counties Minnesota State State Mostly state. Counties decide whether and how to provide emergency services. Counties North Dakota State State State; no county flexibility State Source: Urban Institute and ICF analyses. Statewide Policies As California developed CalWORKs, a clear consensus emerged that the state should be the entity to establish policies that affect eligibility, the amount of benefits, and due process rights, according to officials interviewed for this study. The California State TANF Plan states that CalWORKs is administered by county welfare departments in accordance with a statewide system of regulations that ensure universal access as well as consistent and uniform eligibility criteria. 14 Therefore, state statutes and regulations establish the eligibility requirements, earned income disregards, benefit levels, work requirements, sanction procedures, time limits, and family cap policy. For example, counties decide whether and for whom to grant extensions of the state’s 24-month time limit, during which clients may participate in a broad range of welfare-to-work activities. (Once clients exhaust the 24 months, they are required to participate in a narrower set of welfare-to-work activities for the remainder of the 48-month lifetime limit on assistance.) The state also imposes additional directives on the county. Typically, the state provides additional funding and mandates that county welfare A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 2 9 departments use it for targeted purposes. The counties then are required to develop specific policies and procedures for using the funds for those purposes. The most recent example is the family stabilization funds, discussed in the previous section, that counties began receiving in January 2014. In Colorado, CDHS in collaboration with the county departments develops statewide rules, which must be approved by the Board of Human Services. The board promulgates rules presented by CDHS related to basic eligibility requirements and benefit levels. CDHS outlines broadly how many other aspects of the program are to be administered, and the rules specifically identify where the counties have options. For example, although the state TANF plan establishes a statewide 60-month time limit on benefit receipt and reasons for hardship extensions, counties may define additional hardship reasons in their county TANF policies. Therefore, the time a family can receive TANF cash assistance could vary across counties. According to CDHS administrators, because CDHS has limited authority to mandate how TANF is administered at the county level, it relies on education and promoting awareness among county officials and administrators to influence county TANF programs. For example, although the state TANF plan sets a goal of reducing out-of-wedlock pregnancies, the plan states that it intends to achieve this goal by providing policy direction to counties, such as providing counties with information on evidence-based strategies and assisting counties in developing collaborations with local partners. In Minnesota, the state sets all program policies, including standardized eligibility and benefit policies. Like Colorado, however, Minnesota counties have flexibility in determining time limit exceptions and exemptions, such as the process for determining if a family is eligible for an extension beyond the state time limit. The state legislature determines Minnesota TANF policy, which is approved by the governor. In North Dakota, the state sets all policies and program requirements through a combination of changes to state law and administrative rules. The North Dakota General Assembly enacts all changes to the Century Code (the collection of all North Dakota statutes), and the Department of Human Services drafts administrative rules, which are more in-depth and detailed than the state statutes. The state must approve all exceptions and exemptions. According to the North Dakota county representatives interviewed, the state actively seeks county comments on proposed changes. The state TANF program administrator seeks county input through a TANF work group that meets at least annually. 3 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S County Policies The state of California dictates which TANF services the counties must provide. However, the counties have autonomy to decide how to provide those services. A state official explained the state essentially says, Here’s the outer boundaries. We are looking for reasonable participant results and looking for documentation of participation that meets federal standards. County perspectives and economies drive variation across counties in employment services options. Counties can choose how to organize a subsidized employment program, the eligibility criteria for the lump-sum diversion program, the structure of mental health treatment, and the extent of English as a Second Language programs or substance abuse services, for example. Likewise, the counties can choose which work-related activities their TANF clients are allowed to engage in and whether to contract with service providers or provide the services through the county. Placer County, for example, provides some types of client services through informal partnerships with community-based organizations. They have ongoing agreements with five nonprofit agencies that provide adult education, training, job preparation, internships, and unpaid work experience for participants. Stanislaus County, on the other hand, uses information on clients’ needs gathered from assessments to determine which supportive services to provide. Currently, the county contracts with another county department, the Alliance Worknet, to develop the curriculum for job clubs and to develop job leads for TANF clients. Stanislaus County also does more outreach into rural communities than would be necessary in more urban counties. Los Angeles County has opted to add staff and managers who work specifically with homeless families. Los Angeles County also developed a local program in which specialized workers conduct home visits with families as soon as the families become noncompliant with program rules as a way to preemptively address issues and bring clients back into compliance. In Colorado, individual counties establish policies within the parameters of the statewide rules. For example, consistent with federal rules, the state requires all work-eligible individuals to participate in work activities, except those with domestic violence waivers or those with children under age 6 for whom child care is unavailable. However, the counties define who is ready to work, determine the good cause reasons for work activity exemptions, and establish the detailed definitions of unavailable child care. Individuals who disagree with county decisions must begin the complaint or dispute process with the county, though appeals of those decisions may be made to the state. Counties also have the option to use county funds to expand TANF eligibility or increase benefit amounts in the form of cash assistance, lump sum payments, or payments for specific items. However, A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 1 according to Colorado administrators, counties have not recently done so. The CDHS offers a template that counties can choose to use to help define their individual policies on benefits for teen parents, individual responsibility contracts, sanctions, the period of ineligibility after receiving state diversion funds, time limit extensions, individual development accounts, and other elements. Although the state offers county TANF directors guidance on establishing policies and the state reviews policies for compliance with state and federal program rules, the county commissioners must approve the policies. Fremont County TANF administrators explained that they hold working sessions with a subset of the commissioners who provide administrators with direction on how to approach policy options. The administrators then bring the proposed policy to a formal board meeting to reach consensus. Our mission, a Fremont County administrator explained, is to figure out what people need and how to provide that and how to develop programs around that. The county started with the core policies and has added policies and programs as things have arisen. For example, in response to several natural disasters in the past few years, Fremont County recently added an enabling resolution to help in cases of natural disaster. El Paso County TANF administrators take great pride in our staff developing the policies, an administrator said. We did some innovative things as far as income disregards and those kinds of things. They sought to have neither too few nor too many policies and consciously avoided having policies set us up to be something we couldn’t live up to. Referring to the range of county approaches to TANF across the state, one state official said, We have some counties that would give the program back if they could and other counties doing outreach trying to bring people into the program. Minnesota counties have flexibility to administer MFIP within the limits of state and federal requirements. Counties have flexibility to establish specific procedural policies and to use their judgment in implementing other policies. For example, MFIP clients must begin work activities within 30 days of being determined eligible for MFIP, according to state policy, but counties have the option to require work activities sooner. Although the state sets the good cause and sanction policies for enforcing work requirements, county agencies determine whether an individual client’s circumstances warrant good cause or a sanction in accordance with the state policy. Likewise, the state has established a 60-month time limit and specified the hardship conditions that may warrant a time limit extension; county agencies determine whether hardship conditions exist on a case-by-case basis. Individuals who are denied services or disagree with county agency decisions may submit a request for a hearing to the county agency or directly to the Appeals and Regulations Division of the Department of Human Services. State human services judges conduct the hearings. Minnesota counties have the most authority in emergency assistance. Counties decide whether to offer emergency assistance to families 3 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S earning up to 200 percent of the federal poverty guideline and, if so, the amount of TANF and state funds to set aside for this purpose and the basic policies such as who is eligible for how much assistance and under what circumstances. North Dakota’s State TANF Plan establishes detailed TANF policies and does not devolve authority to the counties to establish additional policies. The counties are responsible for hiring staff and administering the program in compliance with the state policies. County administrators interviewed said, Oversight tends to be tight, and We follow very strict rules. Nonetheless, the state allows for special projects through which human service planning regions may, with state approval, provide TANF benefits and services that are not identical to benefits and services provided elsewhere in North Dakota. A key feature of any special project is closer cooperation among county social services, employment providers, the regional human service centers, and any tribal programs in the region. The special projects are recognition by the North Dakota Department of Human Services that there are diverse populations within the state and that the various human service planning regions can better meet the needs of the populations within their regions and determine methods to assist recipients in their endeavors to become self-sufficient, a state administrator said. The projects are akin to pilot projects with the overall goal of expanding successful ideas statewide, although the state has not used this arrangement since the mid-2000s, administrators said. Program Oversight All states, regardless of their administration type, are required to ensure that their TANF programs comply with federal laws and regulations, to report on TANF spending, and to meet the federal work participation rate requirement. States with county-administered TANF programs must monitor and oversee the county TANF programs to ensure that the state as a whole is in compliance. In addition, states monitor county TANF programs to ensure their compliance with state laws and regulations. States’ approaches to monitoring county TANF programs differ depending on the counties’ level of autonomy in making financial and policy decisions. At the county level, county supervisors and county commissioners have oversight responsibilities, as discussed earlier. County TANF programs, too, may have additional processes for overseeing TANF administration within the county. This section describes how the state oversees the county TANF programs, how they approach the work participation rate requirement, and any other compliance or performance measures at the state or county level. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 3 California STATE MONITORING AND OVERSIGHT In California, the first level of state oversight is review of the county TANF plans. California counties are required to submit annual updates to the plans, including any changes to county TANF policies and county decisions on how to implement new state initiatives. States review plans for compliance with statutes, regulations, and state-issued instruction, as well as alignment with program goals. State fiscal oversight is ongoing, with county and state accounting offices keeping close watch on TANF expenditures. In California, the state uses standardized financial reporting mechanisms to do the accounting and control required to comply with state and federal fiscal control agencies. As a CWDA representative put it, Fiscally, the state knows what [counties] are doing to the nickel. Tracking TANF caseloads and client activities is more complicated than tracking finances. Unique among the study states, California does not have a single automated eligibility system for the state as a whole. Rather, each county uses one of three systems. Each of the three automated eligibility systems tracks information on client cases and processing, including timeliness. The counties provide the data from their automated systems to the state in a cooperative relationship. Because the three automated systems do not allow for combined tracking of the total state caseload and client participation in activities, counties report to the state monthly using the state’s Welfare to Work 25 form, which provides point-in-time information about where people are in the process, how many are engaged in which activities, how many are sanctioned, and so on. In addition to these oversight mechanisms, the state conducts annual audits of payment accuracy and periodic audits of randomly selected cases. WORK PARTICIPATION RATE AND OTHER PERFORMANCE MEASURES California’s annual federal work participation rate is calculated using monthly samples of county CalWORKs cases. The state Department of Social Services draws a random sample of cases, and the counties provide demographic and activity information for the selected cases. In conjunction with the sample used to calculate California’s statewide federal work participation rate, the state uses an expanded sample to calculate county-specific rates. State law holds counties partially accountable for any federal penalties resulting from a failure to meet the federal work participation rate. To date, California has addressed shortfalls in the work participation rate through corrective action plans and has not received a federal financial penalty. However, if the state were to be penalized financially, counties that contributed to the penalty would pay 50 percent of the penalty unless the county could demonstrate good cause. 3 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Beyond the work participation rate, the state does not require other TANF performance measures. However, the state has developed several other performance metrics to continually monitor the efficacy of the program, such as performance measures for job retention and earnings gains. The state also uses other metrics, such as the rate recipients are sanctioned for noncompliance or are provided an exemption from work requirements, to develop and support the program. Nonetheless, one state official said, I think the biggest incentive that we’ve got is what happens if they succeed, if we get people connected to the labor market, and how well they do. I can’t think of a county where that isn’t a priority. Every county reviews several metrics, such as wages, job placement rates, caseloads, work participation, program integrity, overpayments, and fraud. Ultimately, said a representative of the CWDA, county welfare departments want people to get jobs. How are they getting employment? What kind of employment? Are they coming back? Many counties have relationships with partners or research organizations; others have in-house analysts who monitor program performance. Each of the California counties included in this study has its own systems for monitoring and improving performance. Stanislaus County TANF administrators, for example, look first at work participation: How many of our welfare-to-work clients that are to be enrolled in the program are actually participating? What types of activities are they taking part in? What is our sanction rate? We look at job placements and employment and how many individuals are leaving the program and the reasons why they’re leaving the program. Then we look at the [work participation rate] overall. Stanislaus County TANF administrators use reports from their automated systems both for day-to-day management of workload and broader assessments of where additional staff training might be needed. TANF program supervisors also review cases for compliance to supplement the state audit. When the Stanislaus County Community Services Agency contracts with other departments to provide services to TANF clients, those contracts include certain outcome-focused performance measures. For example, contractors are responsible both for the number of clients they serve and for ensuring that 80 percent of the referred clients complete the activity. Placer County TANF administrators have an internal requirement to meet at least a 50 percent work participation rate, consistent with the federal requirement. Similarly, all counties in the state are expected to process cases within regulatory time frames, but Placer County monitors timeliness to ensure the county also meets its own goal of at least 95 percent timeliness. The county has in-house data analysts, and county case supervisors conduct case reviews that go beyond the state audit. The county also conducts an annual survey of customer satisfaction that is not required by the state. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 5 The Los Angeles County Department of Public Social Services commits to specific performance targets and holds monthly meetings with all the high-level managers in the department to review the department’s performance, including the work participation rate and other measures related to CalWORKs eligibility and welfare-to-work performance. The county’s work participation rate steering committee develops the measures related to the work participation rate, but other measures go beyond the work participation rate. If the county’s performance falls short of its commitments, corrective action is taken and monitored. The county does not hold individual caseworkers responsible for meeting the work participation rate targets. Los Angeles County also evaluated the implementation of its sanction policy out of concern for the large number of people sanctioned. The evaluation involved home visits to every sanctioned family to determine whether the sanction was appropriate. According to one person interviewed, other counties followed the Los Angeles example. Colorado STATE MONITORING AND OVERSIGHT CDHS works collaboratively with counties to improve performance and ensure that programs are implemented within state rules. The state ensures that the state and county implementation of TANF complies with federal and state rules and regulations; the state also provides monitoring and oversight to ensure that the county TANF programs comply with their own individual policies. Every three years, the CDHS conducts management evaluations of the county programs. The state also provides technical assistance and works with targeted groups of counties to understand their needs and ways of approaching the program. The state monitors all TANF expenditures through the County Financial Management System (CFMS), an automated financial system that is linked to the automated eligibility system and includes many other programs in addition to TANF. Counties have the ability to pull their own reports from CFMS. The state takes several steps to ensure the accuracy of counties’ use of CFMS. A financial users group of state and county staff meets regularly to discuss correct TANF-related coding in the system, such as the differences between assistance and nonassistance expenditures. The state also includes a review of coding accuracy in the state’s management evaluation process, and state accountants meet with state TANF administrators monthly. Colorado tracks TANF eligibility and benefits determination and processing through another automated system, the Colorado Benefits Management System (CBMS), which is also used for other 3 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S programs such as SNAP and Medicaid. The state closely monitors the accuracy and timeliness of TANF processes, in part because of a court order. The department developed a performance management approach called C-STAT, in which department leaders and key staff review state and county data against specific targets and address any problems in employment entry, timeliness, and accuracy. Not only do state leaders review data reports, but they also send the reports to the counties each week. In addition, the state has a formal case review process, in which it reviews a random sample of individual TANF cases to ensure that frontline staff are collecting the correct data and making timely and accurate determinations. In addition to formal oversight and monitoring, CDHS has developed a cooperative relationship between the state and counties: the state provides upfront technical assistance and the county TANF administrators are comfortable asking the state for help. A state TANF official explained, That has really changed monitoring, because we believe in compliance, but there’s a respectful way of doing it that moves people in that direction a lot quicker. It’s relationships and being responsible for the solution as well. For example, state finance staff conduct road tours to county TANF offices to provide technical assistance on program design and to help counties understand their flexibility in spending TANF funds. As a result of this trust, a state TANF official reported, [counties] are sharing dirty laundry, because they know we can help them fix it, and we’re part of the solution\u2014not there to give a slap on the wrist. WORK PARTICIPATION RATE AND OTHER PERFORMANCE MEASURES Beyond compliance with federal and state rules and regulations, the work participation rate is the only performance measure for which Colorado counties are held accountable. The work participation rate requirement is included in the memorandum of understanding that each county has with the state. In addition to the threat of penalties for not meeting the work participation rate, counties have a financial incentive to meet it. Unlike any other study state, Colorado has chosen to impose the same MOE requirement on counties that the federal government imposes on the state. County MOE contribution requirements are based on the state maintaining 80 percent of historical spending on welfare-related programs, which is the federally required level for states that do not meet the work participation rate requirement. If counties do meet the work participation rate, they are required to maintain only 75 percent of historical spending levels, consistent with federal rules that apply to states. Colorado is currently revising the memoranda of understanding with county commissioners to add an opportunity for counties to negotiate an additional outcome based on employment. This would mean counties could choose to measure not only the work participation rate but also GED attainment, A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 7 certification attainment, completion of domestic violence training or parenting classes, or other activities and indicators of wellness. To improve capacity for measuring such outcomes, the state has augmented its computer system to capture data on activity completion; previously it captured only number of hours. In addition, according to a state official, Colorado’s Works Allocation Committee is considering revising the funding allocation formula to reflect county performance. The revision might follow the model of the child welfare program, which recently set aside a percentage of funds to be allocated on the basis of performance and outcomes. Some counties do their own monitoring and data analysis, but most do the minimum case review and required contract monitoring, according to a representative of the county TANF directors’ association. Counties have flexibility to create performance-based contracts when they outsource services. They also are able to create reports from the state automated systems, particularly if they have data analysts on staff. El Paso County TANF administrators said they monitor various aspects of program participation, as well as employment for families diverted from assistance. The county’s employment contractor, Goodwill Industries International, tracks employment outcomes and provides that data to the county. Fremont County spot-checks cases for accuracy and to identify areas where additional staff training is needed. Minnesota STATE MONITORING AND OVERSIGHT The state of Minnesota takes overall responsibility for meeting federal TANF law and regulations but also passes those expectations on to the county governments. The state trains county personnel on meeting the federal requirements and oversees the counties, including their program and financial audits, to ensure compliance and to meet federal fiscal reporting and program administrative requirements. A Minnesota Department of Human Services official noted that the department also develops risk assessments for its programs and responds to any identified risks with an audit. WORK PARTICIPATION RATE AND OTHER PERFORMANCE MEASURES The state sends the counties monthly reports on their work participation rates. However, county responsibility for meeting the work participation rate is an area of muddied waters, according to a Minnesota state TANF official. Ultimately, the state is responsible for meeting the federal work participation rate, but there is some uncertainty across the state about whether individual counties are also responsible for meeting the targets. What is clear is that counties have a financial incentive to meet 3 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S the target. State law requires counties to bear 12 percent of any cut to the TANF block grant that the federal government might impose on Minnesota for failing to meet the work participation rate. Counties can only receive their full allocation of TANF funds if they meet the work participation rate and another performance measure, the Self-Support Index. The Self-Support Index measures how many adults who receive TANF are working 30 hours or more a week at the three-year mark, and how many are no longer receiving cash assistance. Minnesota uses a regression model to calculate an expected range of values for a county’s success rate on the Self-Support Index, accounting for variation across counties in economic and demographic characteristics.15 Though the work participation rate measures processes (the number of TANF recipients engaged in federally defined work activities), the Self- Support Index is intended to measure outcomes. Counties receive 95 percent of their TANF funding allocation initially, and then 2.5 percent only when they meet the work participation rate and 2.5 percent when they meet the Self-Support Index. Effective July 1, 2015, counties will receive their full allocations automatically and will be able to earn an additional 2.5 percent if their performance is in the expected range of the Self-Support Index. Those not landing in that range will be required to institute a two-year performance improvement plan. Continued failure to meet the Self-Support Index ultimately would lead to a loss of 2.5 percent of funding. In 2016, the penalties will disappear, but counties will remain eligible for bonuses for exceeding each county’s expected performance for the Self-Support Index. Over the past few years, a Minnesota steering committee has been developing potential outcome measures for a broad set of essential services for children, the elderly, and people with disabilities; it has also been promoting economic opportunities for adults. The goal is to have a process for managing performance and continuous quality improvement. The potential changes are making their way through the state legislative process. Minnesota counties can take their own actions to promote best practices and quality assurance and to meet the expectations of their county boards of commissioners. For example, some counties conduct their own staff training or rewrite bulletins more clearly and add county-specific expectations. Hennepin County includes performance metrics in its contracts with service providers. Chippewa County, a member of the 14-county group that has consolidated its employment services, reviews its work participation rate each month and meets with caseworkers to ensure they are accurately coding work activities. The county also holds monthly coordination meetings, which include TANF staff and other public health, social services, and child support enforcement staff, to track individual cases and identify how to create the best opportunity for success for the client. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 3 9 The 14-county collective is held accountable for the work participation rate and Self-Support Index. Nonetheless, ongoing work participation rates are reported to the individual counties in the region, who compete for the highest rate. Throughout the state, the counties, not the employment contractors, are accountable for meeting the work participation rate, but the workforce center reports on performance to the joint powers board of the 14-county collective. Further, county program managers present quarterly reports to the joint powers board, whose members then share the reports with the boards for their individual counties. North Dakota STATE MONITORING AND OVERSIGHT The state of North Dakota monitors county administration of TANF through reviews of TANF data in the state’s computer system and quality reviews on randomly selected cases. The quality reviews examine timeliness and accuracy of benefit determination and other processes. Monthly, the state also assesses whether cases that have exceeded the time limit for cash assistance have been appropriately exempted. If errors are found through any of these oversight processes, the state works with the county TANF program administrator to provide guidance and take corrective action. In addition to this oversight, the state may request additional (voluntary) information from the counties. Likewise, counties may ask the state for data from the state’s computer system. According to an interview with a county-level staff member, counties also conduct their own quality reviews when notified by community stakeholders or others inquiring about a particular case. WORK PARTICIPATION RATE AND OTHER PERFORMANCE MEASURES Employment contractors, not the individual counties, are accountable for the work participation rate. Contractors may receive a financial bonus if they achieve work participation rates of at least 50 percent. The contract may also be revoked if performance is subpar. The state monitors work participation monthly and shares this information with the contractors quarterly. The state has been working actively with employment contractors in recent years to ensure they are reporting correctly on client activities. If the federal government were to penalize the state for failure to meet the federal work participation rate, the employment contractors, and not the counties, would be penalized. 4 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Service Delivery Counties in county-administered systems generally have the most local control over service delivery. County TANF administrators or county boards\u2014often with sweeping authority to determine staffing and adopt business processes\u2014enter into contracts with nonprofit organizations or private groups and integrate with other human service programs. These local choices allow for greater responsiveness to county needs, though on rare occasions at the cost of creating programs that may be inconsistent from a client perspective in services offered or quality. Variation in General Service Delivery Models across Counties CALIFORNIA Intake and case management are relatively consistent across counties, but specifics vary by county and by degree of coordination with workforce services, support services, and business processes. As a CWDA representative described the structure, There is a big continuum of how counties provide these services, but everyone has the same due process. There is a macro flow and within that there is a great deal of county-level decision making. Intake, Case Management, Employment and Training, and Supportive Services. An application for CalWORKs can be submitted online, but applicants must visit a local office for a face-to-face interview to complete the eligibility determination process. County administrators have authority to determine how workers manage the caseload: they might have a dedicated caseload assigned by client last name, or they may share cases but focus on specific tasks as part of the larger case-management process. Many counties are exploring or adopting this task-based approach to caseload management. One of the most significant areas of variation, both state and county officials said, is the local decision of how to structure client employment and training services. The fact that we administer locally, said a CWDA representative, increases our ability to tailor our program to the most effective [work arrangement] in our local circumstances\u2014the services we offer, the way we deliver, what we do ourselves, what we contract, partnerships we build, and so forth. Los Angeles County has 24 CalWORKs offices and seven regional employment services (GAIN program) locations. The county operates five of the employment programs and a private provider operates two. Overall, the county handles approximately 175,000 cases comprising 425,000 individual recipients. The county’s CalWORKs offices are uniform to a degree, although some are considered full- A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 4 1 service because they handle multiple program caseloads in the same office, not only CalWORKs cases. By and large, the basic [process] structure is the same, a county human service manager said. Do we take this piece of paper and have two people touch it or three people touch it? That would vary by office, the manager said, but the basics would be the same. All but one of the Los Angeles County welfare-to-work offices are physically separate from the CalWORKs eligibility offices. Placer County stresses employment services as early as possible in the application process. As a county human services manager said, Our employment counselors meet with that applicant to discuss and talk up the employment services program, what the benefits of the program are, and get people interested in wanting to seek out the services of the employment services. After a client is approved for benefits, he or she meets with a caseworker to develop an employment plan, including work activities and the number of hours to work, while considering federal work participation rates. The county handles all employment services in-house. Counselors have some flexibility but ultimately must follow state- and federally defined allowable work activities. As one official said, We can be creative in some ways but also have to stay within the rules. Placer County recently opened an employment services center that combines employment services and eligibility in one location, and some recipients also are able to fulfill the work experience activity there. The county conducts staff training on employment services and intake, and some other counties have sent employees to Placer County to view its operations, such as its automated system by which applicants and recipients are routed through the waiting area, its task-based case management, and its call center. Placer County also has a contract with the University of California, Davis, for specialized training. Stanislaus County adopted a hybrid case management approach, said a county administrator, when it became apparent to staff that some tasks were slipping through the cracks when the county tried a task-based approach. One person would do one piece of the puzzle and throw the case over to the next unit, who would do one piece of the puzzle, and we found that if a task wasn’t addressed for a specific thing like ‘enter customer address here,’ it wouldn’t get done, the manager said. County administrators suggested that in part, the problem lay in the computer system, which was not as accommodating as it could be to a task-based case management process. County size also affects service delivery decisions, one Stanislaus manager said. Given differing needs in rural and urban areas, such variation is preferable. Each county is a little different in the population they serve, so it gives us the opportunity to maybe set up our program a little bit different so we can work with the customers we have, the manager said. Contracts with Service Providers. Counties retain the authority to contract for services, although the state does not permit counties to contract out for eligibility functions. As noted, Placer County conducts all welfare-to-work services in-house; in Los Angeles County, those services are contracted out. Los 4 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Angeles County also contracts with community colleges to help CalWORKs students on campus secure required forms from the school and navigate the community college system. Stanislaus County contracts with an external provider in the community for some of its welfare-to-work services. The provider assists in running the county’s job clubs and helps with employment search. Integration with Other Human Service and Workforce Programs. Throughout California, TANF is highly integrated with other programs. One benefit of county administration, said a TANF official in Los Angeles County, is that it facilitates integration with SNAP, Medicaid, child welfare, and to a degree, housing authorities, local school districts, and workforce investment boards. Because most TANF recipients are eligible for SNAP or Medicaid, workers in local offices typically handle applications for all three programs, even though in many counties separate offices exist for the programs. Throughout the state, anyone who is a mandatory welfare-to-work participant is eligible for supportive services such as child care. In at least one county, Stanislaus, welfare-to-work services are integrated in the same office as Workforce Investment Act programs. We’re a one-stop shop, said a local manager. Any of our intake workers or phone workers can answer questions for any program, and they do. In Placer County, TANF and welfare-to-work programs are integrated. The office layout is open (without the traditional security features of welfare offices) and customers can use computers to search for jobs, workshops, and employment counselors or to prepare resumes. Staffing and Hiring. Counties in California determine whether caseworkers focus only on TANF or on a broader set of services. County administrators (subject to collective bargaining agreements negotiated in each county) generally have sweeping authority for staff hiring, firing, the setting of employee qualifications, and overall staffing. COLORADO Service delivery in the state varies widely across counties. Counties make diverse choices in how to manage their processes, what services to provide, whether to contract with providers, and how to staff their offices. Intake, Case Management, Employment and Training, and Supportive Services. Caseworkers’ roles vary by county in Colorado. Some counties have program-specific caseworkers; others assign staff to cover multiple assistance programs. Caseload management also varies (that is, whether to assign cases to a specific worker or distribute work by tasks). Administrators have noticed a shift toward task-based caseload management, and Colorado has contracts for technical assistance with business process redesign in the 10 largest counties. The Change and Innovation Agency, a vendor, was in the process of evaluating Colorado’s business processes during the study team’s visit. The extent to which counties A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 4 3 provide supportive services or offer diversion benefits for TANF-eligible families can vary across counties. In El Paso County, a team provides intake for those applying for Colorado Works and helps them also apply for food assistance, family medical assistance, and any other needed services. The county adopted this service integration approach many years ago to emphasize that there’s no wrong door to come in for services, a county administrator said. Initially, the county aimed to limit the number of times a family needed to visit the human services office by working with the family on a needs assessment and employment plan ( individual responsibility contract ) during the intake visit. However, the staff realized that families were so desperate to get the cash assistance that they could not fully engage in developing employment plans. A few years ago, the county changed its approach so that families could complete the eligibility process on one day and come back another day to develop their employment plans. Administrators said, We thought people wouldn’t show, but the no-show [rate] didn’t skyrocket. Local administrators in Fremont County recently changed how local staff delivers services. Previously, separate units handled intake for TANF, SNAP and Medicaid. However, the recent Medicaid expansion eliminated the need for a separate SNAP unit because anyone who is eligible for Medicaid is also eligible for SNAP. Families are now able to work with a single staff member to apply for all needed programs. Families turning in applications can choose whether they want to complete the intake process with a staff member that day or make an appointment for another day. Contracts with Service Providers. The decision whether to contract for services varies considerably, state administrators said. One county might contract with its workforce center to develop work activities, another might contract with a nonprofit organization for employment services, and a third might use its own staff. In addition, counties can create benchmarks and details in performance contracts for privatized services. According to a representative from the CHSDA, the decision to contract for services may fall along urban\/rural lines, geographically, or even by how a region’s health care or education systems are set up. Also, in some areas, there are too few nonprofit organizations or private groups to contract with. When a contractor serves multiple counties, it must adjust its services to meet the county-specific requirements. For example, in the Denver metro area, where three counties (Denver, Adams, and Arapahoe) contract with a single vendor for employment services, people could move across the street to another county and be subjected to different rules and regulations, a state administrator said. 4 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Integration with Other Human Service and Workforce Programs. In Colorado counties, connections between TANF and Department of Labor programs vary. In some counties, TANF and Labor programs are located together and have strong connections; in other counties they have no connections; and in most counties the degree of connection is somewhere in between, according to program administrators. Most counties have adopted no wrong door policies to help individuals access services. The option rests with the county whether to employ program-specific or general caseworkers. State administrators said different programs within a county could be located together or in separate offices, and relations between programs in an area could be strong or disjointed. On one hand, There’s really open and consistent communication about what is going on, what’s happening, where we are overlapping [among programs], and where are there other gaps, one state administrator said. On the other hand, Some don’t speak at all. Most of the counties, the administrator said, are in between. In El Paso County, the Pikes Peak Workforce Center is located in the same building as the county human services office, although the entities are separate and the workforce center that serves El Paso County jointly serves a neighboring county. An El Paso County TANF administrator said, They [the Workforce Center] do job fairs. We certainly encourage our clients to attend those. We do them here sometimes but we don’t have a direct relationship with Department of Labor programs, or responsibility for the oversight. It’s more of a partnership. In Fremont County, too, the human service and workforce entities are separate but do coordinate efforts. In addition, a high-level staff member of the human service agency serves on the regional workforce board. Staffing and Hiring. Staffing and hiring can vary significantly from county to county. There are no state- mandated, standardized qualifications for caseworker hiring, and it is up to county administrators to set job descriptions and qualifications, including salary and benefit levels. MINNESOTA Counties in the state may administer assistance programs however they deem best. Smaller counties often join a regional effort to share the administrative and financial tasks. Intake, Case Management, Employment and Training, and Supportive Services. Eligibility workers in the counties may be generalists or specific to a program, for example only working on TANF. Some counties divide caseloads among eligibility workers based on client characteristics, and other counties assign workers to either intake or on-going case management tasks. Both Hennepin and Chippewa counties have adopted a case-management approach (as opposed to a task-based approach), but officials said some counties in the state have transitioned to task-based systems. A county-by-county description of which models were in use was unavailable. Hennepin County was moving toward a system of area A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 4 5 service hubs within the county. In Chippewa County, local human service managers have the option to offer emergency assistance to some TANF families, typically in response to a specific need, while other counties in the same operating area do not offer additional assistance. Hennepin County offers family stabilization services, not required by the state, to a subset of TANF families. The county finances the services. Contracts with Service Providers. Counties can contract for services or not. Most contracts are for employment services, county TANF administrators said. Some counties join with other counties to collectively contract for employment services. In Hennepin County, contracted employment services staff provide employment counseling, in part because of a diverse population with unique needs, such as concentrated immigrant groups. A county human services manager said there are disparities among the population in employment, health status, education, and high school graduation rates. There is a big divide there and a continual challenge for us in providing employment services. Staffing and Hiring. Minnesota counties can use the statewide merit system for hiring or they can use hiring qualifications that are unique to their county. Individual counties, and often county boards, are responsible for determining appropriate staffing levels. Counties without the infrastructure to operate large human resources departments tend to rely on the statewide merit system, a local TANF manager said. Managers in Chippewa County, which uses the state merit system, noted that they have less flexibility in job descriptions and the state must review all postings. Larger counties are more likely to develop their own civil service processes. These counties have more flexibility to set job descriptions. Administrators said that because benefits or compensation can vary across regions, counties could be competing for the same workers. NORTH DAKOTA Of the four states the study team visited, North Dakota counties had the least flexibility in service delivery decisions. Although all counties are on the state merit system and the state sets employment service contracts for all counties, local administrators do have authority to determine how they assign cases to caseworkers and some staffing decisions. Intake, Case Management, Employment and Training, and Supportive Services. Some counties are changing how local offices handle casework, shifting from assigning caseworkers a set caseload to assigning specific tasks, which leads to a client’s needs being handled by multiple workers. Counties have the autonomy to adopt the business process model of their choosing. Counties also vary in whether they have dedicated TANF-specific workers or caseworkers who work in more than one assistance program. 4 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Contracts with Service Providers. The state contracts with three employment service contractors, with one contractor covering the large majority of localities. Authority to enter into contracts ultimately rests with state administrators, and North Dakota restricts counties from independently entering into human service contracts. The state reorganized contracts in the late 2000s, moving away from a prior, dominant contractor. The contractors provide client case management for employment services, and they work from a state-provided employment contractor handbook. The state does not set explicit performance measures for the contractors, but both state administrators and officials in the employment services organizations said there is an understanding that continued poor performance will compel the state to rebid for services. We are a private contractor for the department\u2014the competitive bid. If we do not do our job, we get fired, one contractor said. We have some integrity on the line. Some contractors said providing employment services in the current arrangement rather than as state employees allows for greater flexibility and adaptation to local circumstances. For example, the state’s largest contractor said its ability to make home visits, if needed, helps ensure client participation, especially in more rural areas. Integration with Other Human Service and Workforce Programs. One of the state’s three employment services vendors (serving only the state’s most populous county, Cass County) also administers Workforce Investment Act programs while the other two vendors do not. Although the other counties administer an array of human service programs, including TANF, only Cass County co-locates these programs in county offices. In all but the most rural or smallest county offices, where workers are more likely to handle all programs equally, TANF frontline workers concentrate on TANF but also handle all other programs a TANF client is enrolled in, a state administrator said. Staffing and Hiring. The state develops job descriptions within the merit system and, by extension, counties follow the state-established structure for employment requirements and pay scale. However, benefits such as vacation, retirement, and health insurance may differ by area. County TANF directors, under the authority of county boards, are free to determine the number of staff needed and whom to hire. Some county workers actively seek state jobs because of the potential for more generous pay and benefits, a state administrator said, making it hard to retain the best workers, particularly in counties near the state capital, which tend to be feeders for state employment. Implications for Families Moving across County Lines Given the greater flexibility in county-administered systems, clients may experience greater variation in services if they move to another county. However, county and state officials in each of the study sites A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 4 7 reported that such transitions were generally seamless. The team did not interview clients. In none of the study states are recipients required to reapply after a move. In California, the cases of families crossing counties are transferred, although state and county TANF managers reported clients could experience a delay or difference in service quality after a move. It could be smoother, but [it’s] certainly not designed to be a start-over, a state TANF official said. Clients are often required to make a new appointment in their new county, and county workers may need to communicate with each other if a recipient’s case information is not transferred as intended. In addition to different supportive services offered across counties, clients might experience different modes of accessing caseworkers, such as the availability of on-line or phone communication. In Colorado, case information of families moving across county lines is transmitted through a structured county transfer system, and benefits are not disrupted. The newly arrived family’s case must be reevaluated and it is subject to availability of resources and supportive services in the new county, which may not be the same as in the county they left. For example, some counties have wait lists for child care subsidies. In theory, although not currently the case in any county, a family’s cash benefits could increase or decrease in the new county if one of the counties decided to augment the standard grant with locally financed TANF grants. County TANF administrators said the process, at least in some areas, used to be more acrimonious. It used to be a sibling rivalry between counties, said one El Paso County official, but we’ve developed policy and procedures where when someone comes here, the case transfers from CBMS and they need to develop a new Individual Responsibility Contract. Depending on the county, things are quite different than they are here. In that county, one caseworker is dedicated to just check for transfer cases each day. Minnesota and North Dakota share similar procedures when families move. In Minnesota, families are transferred within the state’s eligibility system, MAXIS. County TANF managers said recently arrived families are connected with caseworkers in the new county; workers can communicate with a recipients’ previous county to migrate their employment services plan. It’s an extra effort on our part, a Hennepin County manager said. A TANF manager from the smaller Chippewa County said a recipient’s previous employment and training provider may have failed to close the person out of their system, and for recipients moving from some bigger areas, the cases are not closed out as quickly. Clients’ employability assessments are available through the state system. In North Dakota, the state client management system allows for a family’s file to be transferred online when initiated by a county- level worker. The originating county formally notifies the new county of the moving case with a referral, although internal processes can vary by county, local managers said. The new county then assigns the new case and makes a referral to that county’s employment or work services contractor. 4 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Engagement with Community Partners CALIFORNIA Counties in California regularly engage with local partners. Caseworkers in Los Angeles County are trained to refer clients to community-based organizations in the county that are contracted to provide services. The referrals are for services such as domestic violence, legal, and mental health and substance abuse services. In Placer County, human service managers said the county has informal relationships with community-based organizations to help clients with employment services, but the county also has established (1) ongoing agreements with five nonprofit agencies to provide unpaid work experience opportunities, (2) memoranda of understanding with adult education and local community colleges for adult education and training, and (3) contracts with both the Community College Foundation, a nonprofit education-focused organization, for paid internships and MTI College for job preparation training. Stanislaus County engages extensively with community partners, reflecting their core values, according to administrators, to maintain a community presence in every service the county offers. [Our community partners] are always at the table with us making those decisions, one Stanislaus manager said. The community plays a part, and they really do feel a sense of ownership in the programs and support We’ve been real fortunate in that. Stanislaus County staff said the county has either memoranda of understanding or formal contracts with more than 100 different partner agencies in the community. Community groups played a key role in responding to the recession that began in late 2007, county welfare staff said, when funding cuts hampered the county’s ability to fund certain services. For example, when Stanislaus County funding was eliminated for three clean-and-sober-living homes that had successfully served county TANF clients, members of the faith-based community approached the county with a plan to raise alternative funds. A financial donation from the faith-based community enabled the creation of a nonprofit that allowed the homes to continue operating. Further, the county was able to use the financial contributions as leverage to access an additional $3.5 million in child welfare dollars. When you talk about a state-run versus a county-run system, a manager in the county said, it is how the community comes forward to work with the department. So many of our families are [receiving services] through mental health and substance abuse treatment programs. COLORADO In Colorado, El Paso County has formal contracts with community partners such as Goodwill Industries International, primarily for employment services and case management. In addition, county TANF managers in both El Paso and Fremont counties said the local offices might work with community A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 4 9 groups in an effort to engage clients. One of the values and benefits of [county administration] is having a county design a TANF program specific to resources, community partners, and economic diversity, a senior state TANF official said. I think it has really helped our particular program. In El Paso County, 40 to 50 workers from outside organizations ranging from domestic violence programs to behavioral health organizations are located in the same building as the county human services office. El Paso County has convened a group of community partners to provide input on certain aspects of the county’s TANF policy where the county is afforded flexibility, such as time limit extensions. El Paso County also proactively works with its relatively conservative community to build understanding about the role of the Department of Human Services. We work hard in many different and nontraditional ways to help [the community] invest in what we’re trying to do, an El Paso County manager said. We work with nonprofits, the faith community, public-sector folks to educate them about what their local Department of Human Services does. [We have] many private citizens who think we’re giving away free money, and it’s a constant education piece. We are open and invite people to come in. In Fremont County, local officials noted that many community partner organizations are active in referring clients or potential clients to the county for services, and collaborations with faith-based groups is not uncommon. In past years, Fremont County offered TANF-funded community grants to nonprofit organizations that worked with low-income families. However, as the county depleted its TANF reserves during the recession and was limited in the amount of reserves it was allowed to maintain, those community grants ended. A county TANF administrator said some of the programs that lost county funding are no longer available, though some are going strong and continuing to help families. MINNESOTA Chippewa County refers clients to a community action agency and the Salvation Army, among others, so they can learn about other resources available to them as an emergency backup should the provision of state benefits be interrupted or otherwise prove incongruous. NORTH DAKOTA Senior state TANF administrators said counties have the ability to innovate, including collaborating with community partners and nongovernmental organizations, and most counties do collaborate with outside groups. Transportation assistance is the most common need among clients, which county partnerships with outside groups in Cass County, which includes Fargo, work to address, state administrators said. These partnerships are not common in other counties. In Cass County, county administrators have arranged with a local transportation agency to provide bus tickets for some TANF 5 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S clients to travel to and from work assignments or day care providers. Finding child care is another significant need, state administrators said. Counties may partner with groups such as the YMCA in connecting TANF recipients to child care, and county workers often go beyond their job descriptions in helping recipients find child care from community organizations. Information Technology States provide IT systems to counties for core eligibility and benefit applications processing, although the states vary in the extent to which they provide ancillary technology packages and support. Often, counties’ key IT decisions are associated with their population size or number of county employees needing access to the system. Possibly because financing of at least some IT-related costs falls to the counties in many of the study states, counties in some states frequently collaborate to stretch resources. The ability of states and counties to use the data to create reports varies widely. A package of basic, preprogrammed reports often is made available to county staff as part of the state’s eligibility system. Counties’ ability or willingness to undertake additional data analysis is at times connected to its size or metropolitan status. Counties within a state can hire dedicated data analysts, but these costs often are assumed locally. Use of Statewide and County-Specific IT Systems CALIFORNIA Rather than provide a single statewide automated system for the TANF program, California has multiple (currently three, but soon to be two) automated systems, called consortia, that groups of counties use. The three consortia each encompass approximately one-third of the state’s caseload. Collectively, the multiple systems are referred to as the Statewide Automated Welfare System (SAWS), and each individual system supports eligibility, enrollment, benefit determination, and case management. In addition to TANF, the systems also manage other assistance programs such as Medicaid (called Medi-Cal in California) and CalFresh and are required to interface with the California Healthcare Eligibility, Enrollment, and Retention System, which supports the state’s health insurance exchange. Spanning the three Statewide Automated Welfare System consortia, the Welfare Data Tracking Implementation Project, a data tracking system, allows for the California Department of Social Services A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 1 and all 58 counties to access information on how long clients have received TANF, including from counties in other consortia and other states. Counties are not responsible for the operating costs of the data system; however, other programs administered by the consortium, such as CalFresh, require a county funding share to cover costs. Counties are financially responsible, either with county dollars or the county’s single TANF allocation, for most other hardware or software to aid in service delivery. For example, if a county wanted to implement a visitor check-in system, the county would be required to cover that cost. In one of the counties the study team visited, the county was able to acquire a software program free of charge from another county that procured it to assign tasks to workers. Other managers reported similar collaborative agreements to stretch IT and technology resources. COLORADO The state provides counties access to the CBMS coupled with CFMS, both of which every county must use. CBMS administers public benefits across the state including TANF, SNAP and other nutrition programs, Medicaid, and adult financial programs. Many senior officials within CDHS said Colorado’s shift to CBMS, which began in September 2004, was associated with a host of performance issues, including slow processing, inaccurate benefit terminations, and huge backlogs that still reverberate years later. The difficult transition led to a lawsuit against the state by a nonprofit advocacy organization. The state is still under a settlement agreement for TANF, Medicaid, and food assistance programs for meeting court-ordered performance benchmarks. People are still suffering, a senior CDHS official said. It just was not ready to roll, and it rolled out with big backlogs. Governor John Hickenlooper’s election in 2011 marked a change in the state’s approach to the challenges of the CBMS system. The state moved toward greater accountability to recipients, state officials said. In response, administrators began holding meetings across multiple agencies to modernize and improve the system. The recent upgrades and increased focus on staff development have resulted in marked improvements to CBMS and ease of use in the system, staff said. Although the state provides the underlying IT system for eligibility, benefits processing, and caseload management in CBMS and CFMS, counties are responsible for providing infrastructure to support the required networks. The counties can ask a state contractor to provide all of the IT support (albeit at a higher cost to the counties). Counties that do so are known as to-the-desk counties. Counties that use their own IT staff and infrastructure are referred to as to-the-door counties. Roughly 20 of Colorado’s 64 counties are to-the-desk, and typically are small or midsized counties. As a human services manager in El Paso County described their to-the-door model, CBMS, CFMS, all those 5 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S types [of applications] come directly to the county, and the county is responsible for server lines. Security is through the county IT, and we’re responsible for making sure that new [staff] get online. Conversely, Fremont County Department of Human Services, which serves a smaller population, is a to- the-desk county with no IT staff. Fremont County relies on the state and its vendors for computers and service to the state network system. There is no cost to the counties for CBMS computers. However, if a county needs more than the number of computers provided by the state, then the county must use county funds to buy additional computers. MINNESOTA Similar to California, Minnesota provides core IT systems for administering both the cash and employment services components of TANF, and counties can supplement these systems by using county money, state officials said. Eligibility determinations for Minnesota’s TANF program, MFIP, are conducted by MAXIS, a legacy, mainframe computer system. Eighteen other human services and health care programs also use MAXIS, including SNAP, general assistance, refugee cash assistance, and medical assistance. Workforce One, itself considered dated, is the web-based client management application that counties (and their contractors, where applicable) are required to use for the employment and training component of TANF. Other programs in Minnesota using Workforce One include the state’s diversion program, SNAP, and non TANF education and training. Workforce One was in the process of being updated when the study team visited, and a new program, C\u00faram, will replace MAXIS in 2016. Senior Minnesota Department of Human Services officials reported no specific challenges with MAXIS beyond its age. The state requires all county workers to be certified in using MAXIS before being granted access to the system, and training is provided first in online modules culminating in a three-to-four-day in-person session. Counties are responsible for the travel costs of workers to attend the training. State-provided training is part of a larger set of help-desk-type services provided to the counties and county workers primarily for issues with MAXIS or Workforce One, state officials said. In the past, the Minnesota Department of Human Services managed MAXIS, but responsibility for both MAXIM and C\u00faram will migrate to the new state IT service department. Counties generally are required to procure any IT components outside of the eligibility and employment services products of MAXIS and Workforce One. Counties cited electronic document management, phone translation services, and phone interactive voice response systems as technology commonly procured (and financed) by counties outside the formal Minnesota Department of Human Services structure. Hennepin County developed its own document-imaging program in the mid-to-late 1990s that is still in use, albeit in need of updating. It also procured its own interactive voice response system. The county finances both systems. Counties both large and small reported collaborating to A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 3 stretch IT resources. Senior human services administrators in Hennepin County said they meet monthly with heads of other metropolitan counties and have provided their interactive voice response and language assistance services to other areas. Human service program leaders in Chippewa County said they have wanted to transition to a paperless case-management system using scanning technology but the financing costs have been a barrier thus far. Those efforts have to be paid for by the county, which is a lot of the reason why we’ve struggled getting there, one official from the county said. There is a lot of networking that happens; we get with other counties and learn from each other. NORTH DAKOTA The state provides a standardized eligibility system to all counties and also delivers some secondary IT applications and services, such as client tracking software and server costs. Counties are required to finance any products that the state does not provide, however, and county-level administrators said that initiatives often undertaken on a pilot-basis by individual counties are later picked up and financed by the state to the balance of counties. For example, the client tracking software in the process of being distributed statewide began as a county-funded pilot, a state human service official said. On another ancillary system, a document imaging program, the state pays for the licensing fees and monthly costs of the network, but the counties are responsible for financing the scanning hardware. Because the scanners are used across multiple programs, counties allocate the start-up costs across TANF, Medicaid, child care, and other programs, a senior North Dakota Department of Human Services official said. Employment services contractors in North Dakota are required to provide their own IT systems but also use a state-provided screening tool, the Online Work Readiness Assessment. The screening tool, a web application, began as a pilot in 2009; an employment services contractor said the program took longer than expected to be rolled out, but they were appreciative to have been given the chance to provide feedback, and the tool has been helpful overall. North Dakota’s Information Technology Department provides support to counties for interfacing with the primary eligibility system, but counties themselves are responsible for financing and obtaining other IT-related support, such as server costs beyond the eligibility system, setting up a local area network, desktop support, maintaining an email system, word processing, and other desktop applications. This arrangement often presents counties with the choice of providing IT support and server management in-house or contracting with an external provider, often through a subsidiary of the North Dakota Association of Counties, which charges a separate, negotiated fee for IT services. County size, and specifically, the number of employee workstations, often is the determining factor for counties in establishing an in-house department or engaging an IT contractor, according to a representative of the county association. Once you reach 50 or 60 desktops, it probably makes sense to have somebody 5 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S on staff. The volume makes it a little cheaper to be there. Also, the state is using 90 percent federal matching funds to help build a new eligibility system with the goal of including TANF and the state’s other human services programs in the new application along with medical assistance, a senior North Dakota Department of Human Services official said. Ability of State and Counties to Create Reports and Access Data CALIFORNIA In California, counties own the data collected by the various consortia, but the counties historically have shared data extracts with the state. County managers reported relative ease in creating and customizing reports, although there may be some minor variation among consortia and individual counties using the same system. In Los Angeles County, county managers have access to many preprogrammed reports, including detailed caseload characteristics. Data extracts can then be packaged into a data dashboard that includes employment services and caseload processing information. One downside in Los Angeles County is that the information is not real-time, although future plans are moving in that direction, one manager said. TANF managers in Placer and Stanislaus counties also said they create reports using data from the respective consortia. In Stanislaus County, local managers pull data daily so workers know which cases they will be assigned for the day, and a human services manager said they use regular reports to monitor caseload numbers. We can set any report we want, the manager said. We can also use reports to see if there’s training we need to give our staff\u2014 maybe we’re having a problem in a specific area. There is no single client database for the state as a whole. I’m not that concerned about it in as much as the three consortia that operate are fully cooperating with us, a senior state human services official said. When we want management data, they give it to us in whatever form we’re asking for. The County Welfare Directors Association of California can, and often does, act as a conduit for producing files of data, CWDA representatives said, and CWDA staff frequently perform data analysis and surveys involving the counties. Legislative staff also may approach CWDA for data collection involving the counties, although this is often done on an ad hoc basis as there are no standing data reports established between CWDA and counties, staff said. At the county level, staff rely on in-house analysts for monitoring. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 5 COLORADO In general, Colorado counties use the state’s Cognos software system for generating reports from the CBMS that county office staff frequently rely on, a senior state human services manager said. State workers pull reports weekly on whether tasks are being completed on time, among other issues, and the state tracks eligibility backlogs. Tracking backlogs is important because Colorado is under a court order to improve timeliness in processing applications for certain assistance programs, including TANF. State staff recently augmented the capacity to track work and employment services data. In a bid to overcome a self-described poor ability to track this data, Colorado recently modified the system to better capture information on employment outcomes and other work-related data. In the past, the system only tracked one measure, work hours. We’re still struggling with having good [employment] data, one senior state manager said. Gaining the information has been a huge challenge. Although all counties have access to CBMS data through Cognos, the degree to which localities use the data is often determined by population size and whether the county places IT staff in-house. You can always run reports out of Cognos, but one of the issues with counties without a robust staff is knowing which reports need to be run in Cognos and which data reports are most helpful and how those can be utilized\u2014a ‘top-10′ list hasn’t been developed, one senior state official said. Counties with larger capacity may provide their own tailored reports as well. In El Paso County, human service managers described how, in addition to the preprogrammed reports available, they can design some custom queries in the system. Obstacles to wider use of custom reports are the limited number of licenses for access to the software and the depth of local IT departments, even among the larger or more metropolitan counties. Creating reports rests with the managers. Sometimes our IT staff aren’t able to get us what we need, an El Paso County official said. In more rural Fremont County, human service managers said they can use predesigned reports from the state system, which is critical for county staff to track and balance financial data such as caseload counts and expenditures. One potential drawback to the flexibility afforded counties in deciding which technology systems to develop or use is the unavoidable disparity between counties in their IT system capabilities, El Paso County administrators said. For example, some counties have data dashboard systems, scanning or document imaging programs, or access to an external, subscription-based employment verification database, but others do not. MINNESOTA State officials in Minnesota regularly create county performance data as part of the expanded set of performance measures on the Self Support Index as well as monthly caseload reports required by state 5 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S law on 10 features of the caseload. Counties receive monthly reports on the work participation rate and caseload information and less frequent reports on the special performance measures in the Self Support Index. Chippewa County human service managers can create some reports from a special section of MAXIS, although specific measures are not always available. The county also receives some information from the state to help fill in the gaps in areas of interest to county administrators, although the data are limited to what is available from the MAXIS and Workforce One systems, a county manager said. NORTH DAKOTA North Dakota provides monthly reports to counties on the work participation rate. Beyond the required standard reporting, few staff are aware of the possibility of extracting data from the eligibility system, an administrator said. State TANF staff said North Dakota makes an effort to provide counties with any requested information from the eligibility system. The information is provided at no cost. Administrators said large counties typically are more active and interested in requesting reports. The requests typically stem from county commissioners interested in the number of clients receiving services or the distribution of TANF clients by various demographic or socioeconomic factors. Local officials sometimes request city-level information, which the department can oblige as well, although administrators said they take special care to eliminate any personally identifying information. Some counties make such requests sporadically; others request monthly reports. Conversely, if the state were interested in collecting information beyond the eligibility system, the state would issue a request to the field, although state officials said county participation to comply is voluntary. Some state administrators hope that as more counties adopt a process management business model, in which the counties assign caseworkers to specific tasks but with no set caseload, more options for generating reports would arise. Employment service contractors said staff enter information for assessments and other tasks into the state-provided system, but if a contractor wanted to review information from the system, that person would make the request directly with the state Department of Human Services. County TANF Administration in New Jersey and North Carolina Two states with county-administered TANF programs not included in the study’s site visits, New Jersey and North Carolina, provided information via brief surveys and phone interviews. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 7 New Jersey Administrators in New Jersey reported that the TANF program has always been county administered. Bureaucratic responsibilities are set by statute and regulations, and the state Department of Human Services Division of Family Development sets WorkFirst NJ (TANF) policies and procedures for New Jersey’s 21 counties. The counties have some discretion in how the program rules are carried out and interpreted, state administrators said, although service delivery mechanisms across counties are similar since the state employs a case-banking\/case-processing business process. Neither the state nor the counties use privatized services or contractors. A range of county structures\u2014a county executive in tandem with a county director of human services, citizen services, and the local welfare department\u2014 help shape local human services program delivery, including TANF, and the frontline workers in the local offices are county employees. New Jersey finances WorkFirst NJ with a combination of state and county dollars in addition to the federal block grant. The state allocates funds to the counties across multiple programs, namely, TANF, SNAP, and child care. The allocation is based on a method that incorporates prior year allocations, expenditures in the prior quarter, and caseload size. Counties’ allocations, which are determined with no county involvement, are for administrative and program costs, administrators said. Although counties are expected to fund a portion of program costs, it is not a state requirement to do so. It is also up to each individual county to determine the amount of funds to contribute, if at all. All policy decisions are made by the state without county involvement. Counties are free to fund tailored social service programs using county dollars, but no TANF funding is involved, state administrators said. Funding to the counties is not tied to performance, but individual counties are responsible for the work participation rate. The state’s Department of Labor and Workforce Development provides employment services for TANF clients at its One-Stop Career Centers as part of a consolidated approach in conjunction with social services boards, county welfare departments, and individual counties. Neither state nor county administrators use performance measures for TANF beyond the work participation rate. A statewide automated system and a team of field representatives assigned to individual counties monitor and assist with program compliance. The statewide automated system also handles fiscal and work participation reporting. 5 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S North Carolina North Carolina has had a county-administered cash assistance program for as long as state administrators can remember. We’ve always had 100 counties and county departments, and we’ve always had an AFDC and workforce program in each county, a senior state TANF administrator said. In considering changes to its cash assistance program following PRWORA, administrators pointed to the additional flexibility for services and service delivery as a primary factor in deciding to maintain county administration. None of North Carolina’s counties has full autonomy over their TANF programs, called Work First, but all counties share at least some responsibility for TANF implementation. For example, county staff help determine financial management, administrative responsibilities, performance measurement, staff hiring and training, contracting for services, and IT and data system management. The state provides specific requirements for training, monitoring, and accountability, and guidance on implementation. It is up to the counties to interpret and implement the state requirements. Counties have flexibility in local office management and authority in personnel decisions. Ultimately, they have flexibility on how to meet predesigned outcomes, a state TANF administrator said. In addition to formal reporting mechanisms, states and counties communicate through a mix of meetings, written memoranda and letters, website communication, and emails. The state writes policy for all 100 counties, and most policy decisions are exclusively determined by the state, such as setting work requirements, determining sanction procedures, setting time limits, establishing family caps, and determining the child support pass-through. However, a group of seven electing counties can design their Work First programs, including eligibility criteria and benefit levels. Nonetheless, this discretion is subject to limits and close review by the state Department of Health and Human Services and the General Assembly. The remaining 93 counties are known as standard counties and follow the rules outlined in North Carolina’s Work First policy manual. Unique among the study states detailed elsewhere in this report, North Carolina’s counties request electing status from the state and have flexibility in proposing alternative rules. State law requires the electing counties as a group to contain no more than 15.5 percent of the state’s Work First caseload as of September 1 each year, and any county seeking electing status must triennially submit to the state Department of Human Services a local block grant plan that describes its proposal. Electing counties give local residents the opportunity to review the local block grant plan before submission, and the block grant plan itself is drafted from a committee of county government and community stakeholders appointed by the County Board of Commissioners. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 5 9 In practice, the policy options of electing counties are limited to areas of eligibility determination (such as which family or household members to include, or who may be the qualified caretaker in a child-only unit) and which resources to count for the asset test. The number of electing counties has declined over the years, state administrators said, in part because electing counties are viewed as informal testing grounds for innovative policies, and standard state policy now includes demonstrated innovation and flexibility. North Carolina uses TANF administrative funds for a range of uses, including IT systems, data reporting systems, assessment and referral processes, and staff training. Funds allocated to local offices are combined in a single allocation and are not differentiated by administrative or program dollars. The allocation to local offices varies year to year, state administrators reported, and the state was obligated to reduce funding levels during the recent recession. Both the state and counties are expected to contribute to North Carolina’s MOE requirement. The state previously used performance measures in addition to the federal work participation rate for program oversight and monitoring, but North Carolina currently uses only the work participation rate, administrators said. The state requires underperforming counties to submit an improvement plan, but potential federal financial penalties would not be imposed on the county. However, the state requires counties to cover the cost of benefit overpayments or other compliance errors. The state Department of Health and Human Services is in the middle of implementing a statewide, integrated eligibility system, NC FAST, which the state funds and provides to counties. Counties may supplement state-provided hardware and software applications using local dollars, state administrators said. With the advent of the new system, TANF recipients’ cases will automatically be transferred if they move to a new county. Presently, counties are required to close families’ cases and require the family to reapply in their new county. Compared with more constrained policy and financing decisions, North Carolina counties have considerably more autonomy in the areas of service delivery and designing employment programs for TANF recipients. Local workers are county, not state, employees, and counties control how staff handle caseloads and also staff salaries and benefits, which vary from county to county. The state continues to manage retirement benefits, which are standardized. All counties have flexibility to design their employment programs to meet local needs, state administrators said, and this local control can include the decision to contract with private or community groups such as community colleges or workforce development organizations. The required hours and employment activities the state requires recipients 6 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S to be engaged in are uniform statewide, but counties can shape how each allowable work activity operates locally. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 6 1 How Do County-Administered Programs Differ from State- Administered TANF Programs? County-administered TANF programs differ from state-administered TANF programs in a few key ways. However, considerable variation exists among individual state administrative approaches. The defining, unique elements of county-administered TANF programs are the following: \uf06e TANF services are delivered in county-run local offices by county employees \uf06e County governments are at least partially responsible for funding TANF \uf06e County elected officials have a role in reviewing the local TANF budget, policy, or both Differences in program administration between state- and county-administered TANF programs are a matter of the degree of state authority. Overall, state-administered TANF programs retain greater state authority and allow less local flexibility than county-administered TANF programs. However, just as county-administered programs exhibit a range of authority and flexibility, so do state-administered programs. For example, state-administered programs retain authority for policy development, although a few state-administered programs allow local offices or regions some flexibility in implementing those policies. Table 9 displays the differences between county- and state-administered TANF programs. 6 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S TABLE 9 Differences between County- and State-Administered TANF Programs Degree of difference between county- and state-administered TANF programs Dimension of TANF administration County-administered TANF programs State-administered TANF programs Areas of distinct difference Office structure County offices State offices in localities Areas of distinct difference Frontline workers (staffing) County employees State employees or state contractors Areas of distinct difference Financial responsibility County governments have at least some responsibility to contribute funds State has full responsibility for contributing funds Less-distinct differences Policy authority Counties may have authority to establish policies such as time limit extensions and eligibility criteria for short-term, nonrecurring benefits State has ultimate policy authority but may allow flexibility in policy implementation in local offices Less-distinct differences Information technology State provides major management and reporting systems; Counties may provide office-level IT; counties may control data from systems State provides major management and reporting systems Less-distinct differences Service delivery: intake and eligibility determination County processes may vary Generally uniform throughout state, but some local office variation in work flow Less-distinct differences Service delivery: work supports and other services Considerable variation within states by county Uniform in majority of states but variation within some states Very little difference Eligibility Rules and Benefit Amounts Uniform throughout state in practice (although Colorado counties may expand eligibility and increase benefits) Uniform throughout state Source: Urban Institute and ICF analyses. Note: TANF = Temporary Assistance for Needy Families. County- and state-administered TANF programs as a whole do not differ in the program outcomes they achieve, such as the work participation rate, the percentage of poor families in the state who A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 6 3 receive TANF, or the average earned income of TANF families. They also are indistinguishable in terms of time limits and average monthly benefits. Likewise, states that choose to administer TANF at the county level are no different from other states in terms of state population, population density, and child poverty rate. The remainder of this section describes the array of choices state-administered TANF programs have made in TANF administration and service delivery. This information allows readers to compare and contrast state-administered programs with the choices of county-administered TANF programs. To examine the degree and dimensions of variation between states with county-administered and state- administered TANF programs, and to identify characteristics that apply generally to both administrative approaches, the study team collected data from 29 of the 43 state-administered programs.16 The team selected these states to include a maximum share of TANF caseload and diversity in caseload size and other program characteristics. Together, these 29 states serve 41 percent of the national TANF caseload and 82 percent of the total TANF caseload served by state-administered programs. History of TANF Administrative Structure Most states with state-administered TANF programs (21 of 29 interviewed) have maintained the same or similar structure for administering cash assistance in TANF as they did under AFDC. Among those that changed, three modified the administrative structure during the transition from AFDC to TANF, and four other states changed roles sometime after implementing the TANF program. Among this latter group, states were split between devolving and consolidating TANF responsibility. For example, from 1996 to 2005, Arkansas’s program had elements of county administration but shifted to more fully state-administered when responsibility for managing TANF operations transferred to a different state agency. Florida, Idaho, and Montana also curtailed county or regional involvement. Maryland has a hybrid administrative structure (falling between county- and state-administration), but according to state officials, the process evolved over 15 years. In Maryland, each local jurisdiction submits a plan defining the program for state approval. State employees, not county employees, carry out service delivery, except in Montgomery County, where county employees deliver services. The state has recently committed to move further toward a fully state-administered structure. Maryland state administrators believe that having the ability to customize some elements of the program’s employment services did not lead to the desired effects. Conversely, Indiana in recent years has responded to calls from a new executive administration to adopt a regional structure for operating 6 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S TANF in its hybrid administrative form. The bulk of states that enacted a change in state or county roles during the move from AFDC to TANF describe the modifications between the state and regions or counties as modest in scope, usually adding some element of local involvement without fundamentally changing the overall TANF administration structure, such as Arizona carrying over a pre-PRWORA waiver program. Like Indiana and Maryland, a few other states have hybrid administrative structures that fall between county- and state-administration of TANF. These states include the following: \uf06e Alabama has alternately reported being a state-supervised, county-administered system (i.e., it did so in the eighth Report to Congress in 2009, but not in the ninth in 2012). According to the State TANF Plan, the state will conduct the Family Assistance Program designed to serve all political subdivisions in the State (not necessarily in a uniform manner) to provide assistance and\/or services to needy families with children through County Departments of Human Resources located in Alabama’s 67 counties. \uf06e Virginia operates through a regional structure for TANF implementation and service delivery. \uf06e Georgia also operates a regional structure with a county-level service delivery system. Wisconsin had a county-administered structure since TANF’s inception, but as of January 1, 2013, the state officially identifies as state-administered. The state contracts with private entities to administer all aspects of TANF in ten areas of the state. One of the private contractors subcontracts to a county. Bureaucratic Structure and Communication Bureaucratically, 12 of 28 states report using regional or substate units to implement some aspect of TANF. Of these states, most have implemented standard processes for reporting both cash assistance and noncash expenditures. In most states, information is communicated from the centralized human services office to counties or field offices using a combination of formal and informal means, such as policy memos, executive orders, and bulletins coupled with email, conference calls, and in-person meetings. The frequency of these communications varies considerably by state and method. Several states described a centralized structure where the human services agency head or TANF administrator works with senior managers to send communications to a network of regional managers, who then distribute the message locally. For example, in Massachusetts, the Department of Human Services A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 6 5 commissioner or the TANF administrator is responsible for communicating with field offices through a network of regional directors, and officials rely on operations memos, procedural guidance, monthly meetings, and daily calls with local offices or managers, with the mode often dependent on the topic or urgency. A Florida administrator also describes an approach in which managers tailor the communication mode to the message: If it’s a policy, it’s from [the executive] level through memoranda and brief trainings. If we’re trying to communicate business matters those can be handled by conference calls. Communication is as needed. Across all areas of managing and implementing TANF, states overwhelmingly either fully retain responsibility or share limited responsibility with counties or local offices. Among the minority of states that delegate responsibility to local areas either fully or in a shared arrangement with the state, none are fully autonomous in carrying out these duties. State legislative mandates or extralegislative state policies or procedures confer responsibility for managing TANF among states (often through rule- making by a state agency). Twenty-one states report that the overall TANF governance structure resulted from some action by the state legislature, and 22 states said that state policies and procedures define the structure. County rules and regulations interact with the governance structure in Georgia and Hawaii, state officials said, and in five other states, other governing authorities or mandates, such as court orders, come into play. By a two-to-one margin (18 to 9), states said the relationship between the state and lower government entities has not changed with time. In Indiana, state officials said that prior to 2005 more control rested with the county, but since then, county directors have less control, and the program has introduced a management structure regionally with more state oversight. In Arkansas, when responsibility for operating the program shifted from one state department to another, specifics were left up to administrators, but the choice itself to switch agencies was done by legislative mandate. Florida reorganized its nonstate administrative units from districts into circuits, and administrators from Georgia said the business operations in their state have changed dramatically in the past year as counties make more operations choices independent of the state office. Figure 1 provides an overview of the extent to which these states share or delegate responsibility for various aspects of TANF administration to localities or regions. 6 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S FIGURE 1 Responsibilities of States and Local Entities in State-Administered TANF Programs Number of states Source: Urban Institute analysis of survey responses from 29 states with state-administered TANF programs, December 2013 March 2014. Note: IT = information technology; TANF = Temporary Assistance for Needy Families. 23 27 17 20 9 15 22 26 0 0 3 2 7 2 0 1 6 2 8 7 13 12 7 2 Financial management Policy Administrative responsibilities Performance measurement Staff hiring Staff training Contracting for services IT and data management State Substate\/local Both Financial Management and Fiscal Reporting Financial management is primarily a state responsibility in state-administered TANF programs, although 6 of 29 states report sharing some responsibility with local offices or regions. States that allocate TANF money to local offices or substate entities are nearly evenly split on whether they direct a proportion of funds to be spent on administration or program expenses. States are also fairly evenly split on whether program or administrative allocations vary year to year. In two states, fund allocations vary month to month. States report that allocation changes stem largely from changing local economic conditions, staffing changes, or caseload variation. Both the recession and other state budget issues A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 6 7 have affected state funding levels, and potentially county resources, in about half the states. States use administrative funds in multiple categories. The most common use of such funding is for program oversight and monitoring (27 states), but a majority also finances IT systems (24 states), data-based reporting systems (23 states), costs related to the assessment and referral process (22 states), and staff training (21 states). Other uses of administrative dollars include contracting for electronic benefits transfer services and income verification (both in Kansas) and management of fiscal reporting (Montana). In no state is any portion of the MOE requirement passed down or expected to be borne by counties or lower levels of government. However, several states use local spending to meet the requirement. For example, in Iowa, a portion of what the state counts as MOE spending includes local dollars incurred in administering the program, and in Arizona, spending by food banks and other agencies is included in a portion of that state’s accounting. Virginia also uses local expenditures to draw down the MOE total, state administrators said, and while not a requirement in Washington, the state does have agreements with some state and county nonprofit groups whose spending is included. When TANF money is used on activities other than cash assistance, such as nonmarital childbearing prevention and two-parent family programs, a majority of states said that decision rests with the state human services department. In another 13 states, the legislature makes those funding decisions. In four states, the state TANF director makes the call, and in one state (Washington) local office administrators have at least some discretion for spending the funds. Policy Authority and Development In all states, the state retains authority for policy decisions affecting eligibility requirements, work requirements, sanctioning procedures, time limits, family caps, and child support pass-through amounts. Only a few states share decisionmaking about program rules, and then only in a handful of policy areas. Several states, such as Alabama and Georgia, said that although not officially involved, state officials often solicit suggestions from counties, and local officials may be informally drawn into the process. Degrees of local policy authority can also vary within a state, usually on the basis of county size. For example, though Nevada as a whole exhibits some variation in determining eligibility requirements and setting benefits, this is especially the case in the two largest counties, which may have different processes and requirements. All told, eight states described some local variation in how policies are implemented, although this variation does not necessarily mean authority to shape policy at the substate level. 6 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S States employ a variety of modes of communicating policy decisions and program rule changes to counties and other substate areas. By far, the most popular methods are policy memos (20 states), policy manuals or directives (22 states), email or electronic bulletin boards (17 states), and statewide training (19 states). Less frequently used modes include disseminating legislative concept proposals and memos (2 states), committee reports (3 states), public speeches or testimonies (4 states), functional documents such as legislation, regulations, procedures, agreements (6 states), and newsletters (5 states). In addition, in 5 of 23 states, regional or other substate entities have the autonomy to privatize services. Six states requested technical assistance broadly in policy development. Program Oversight Performance measurement is a shared responsibility in at least 7 of the 29 state-administered programs that provided information for this study. Two states delegate certain aspects of performance measurement to substate entities. Performance measurement can take many forms. In all but one state (Michigan), state administrators monitor participation in work activities locally, across the district or county, or regionally. In some cases, this involves monitoring the performance of contractors who handle employment services. States commonly track data by a district or region, which is then reported centrally. South Dakota administrators described a process of periodically reviewing local participation rates, and at times tracking individuals. In other states, such as Montana, monitors visit each contract site twice a year to review employment and training services contracts. Several states reported that the bulk of local monitoring centers on contractor performance, usually for employment services, and in several others, another state agency outside the division handling TANF is responsible for certain monitoring, again usually on employment services. By extension, most states (20 of the 26 answering this question) do not pass down federally imposed state penalties, although a handful of states said that counties might be affected financially because of the overall reduction in available funding. TANF officials from Arkansas, Connecticut, Hawaii, Michigan, Mississippi, and West Virginia said their states would convey federal penalties to a local or county office, although the penalties would not necessarily be financial. For example, administrators from Connecticut and West Virginia said a sanction to counties would usually entail taking some form of corrective action. In almost all states (25 of 28), penalties for not meeting federal work participation rates do not flow down to substate areas, state administrators said. In Alabama, program managers said some penalties are imposed locally, but with no fiscal consequences. Arizona and Connecticut also reported penalties for subpar work participation rates, including a 25 to 35 percent reduction in funding in Connecticut. In A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 6 9 contrast to penalties, Arkansas offers rewards for exceeding performance. Rewards can include individual awards and the ability to attend conferences. Beyond the work participation rate, most states (20) hold localities accountable for additional measures. These extra measures may include timeliness and error rates in processing applications, recipient outcomes, employment and training related outcomes, and general client cooperation. In Maryland, administrators said the state implements a scorecard system that tracks job placement and wages in addition to work participation rates. Wisconsin also tracks performance measures such as job placement and retention, numbers obtaining Supplemental Security Income, among others.17 In Tennessee, the state holds contractors accountable for recipients’ GED receipt, wages, and time in certain work activities. We wanted to move away from just looking at activity, a state administrator said. We work to get [recipients] up from minimum wage. For the county offices, we look at performance, caseloads, engagement. There was a time when personnel performance was tied to work participation rate, but now we’re moving away from that. Ten states requested technical assistance broadly in data management, and nine states asked for additional technical assistance in program monitoring. Service Delivery In general, intake and access services and work supports are uniform across states. Twenty-three states have the same intake process and access to services statewide, whereas 20 and 19 states said they have uniform service delivery and work supports, respectively. Where there is variation in intake processes within a state, the difference typically depends on size of the TANF caseload in each local area or access to or availability of local funding. For example, in Tennessee, in counties with fewer clients, a worker might serve as a caseworker for programs in addition to TANF, whereas workers in larger counties focus solely on TANF, state officials said. Despite largely uniform work requirements, the client experience can differ from office to office. Employment services (such as developing employment plans), for example, will vary by locality or available resources for promoting work. For example, in Washington State the local community services offices have some ability to design life skill programs and barrier removal programs using designated TANF funds. We ask them to come up with programs that make sense for specific counties, a Washington state administrator said. In only 5 of 29 states, administrators said local or other substate offices have discretion over how nonrecurring, short-term assistance may be used, such as TANF emergency assistance. In Virginia, state officials said localities have some discretion in applying the state’s diversion assistance, and West Virginia administrators said there is some discretion for workers with regard to special assistance benefit amounts, subject to limits 7 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S set by the state. Idaho staff said the framework for this type of assistance is guided by the state, but TANF emergency assistance can be drawn down by regional workers and directed to clients in a personalized way. On staffing decisions, localities have little flexibility in most states (20), while seven states allow some discretion in hiring or caseload standards. In states that do give counties some say in hiring, discretion is usually tied to available resources: the budget, local caseloads, or both. In Kansas, officials said local offices can use discretion if they stay within budget limits. Nevada state staff adjusts staff levels on the basis of funding, but local county offices are able to suggest staffing level changes. In Wisconsin, a case-manager-to-client ratio is set at 80:1, but contractors can make adjustments within this limit. All but one (Wisconsin) of 27 states set job qualifications and descriptions, although Maryland and Virginia have at least one county that is an exception. In Virginia, counties large enough to have a self- contained personnel department may set qualifications locally, and Maryland’s Montgomery County has a different level of autonomy on staffing and salaries than the counties in the balance of the state. States are split roughly evenly in granting local areas the autonomy to make hiring decisions, but 26 of 27 states (all but Wisconsin) set worker salaries centrally. In most states, service integration and cooperation between TANF and other work support programs such as SNAP, child care, or Department of Labor sponsored training, are consistent across counties. Florida, Iowa, Kansas, Maryland, South Carolina, and Wisconsin report at least some variance by county. In 27 states (all but Kansas and Wisconsin), TANF families moving from one geographic area to another within a state will continue receiving benefits without needing to reapply. Information Technology Managing IT and data services is overwhelmingly a state responsibility, with 26 states retaining responsibility. In one state, the county is responsible and in two others that responsibility is shared between state and local administrators. All 29 states use a centralized information technology system for program eligibility functions and collecting program data. All but two states\u2014Alabama and Nevada\u2014 said the IT system handles multiple programs in addition to TANF. In states sharing the system with other programs, the most commonly paired programs are SNAP (25 states), Medicaid (19 states), and child care assistance (10 states). Other programs sharing the IT system include homeless programs, A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 1 non-TANF work programs, refugee programs, child support, and emergency assistance. Eight states requested technical assistance in IT. 7 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Implications of TANF Administrative Structure Having reviewed the details of how TANF is administered by states and counties, the questions remain whether the choice of administrative structure reflects any underlying differences in state circumstances or leads to different outcomes for TANF clients and other poor families in the state. This section of the report addresses those questions. To more fully explore differences between county-administered and state-administered TANF programs as a whole, the study team conducted limited quantitative analyses of secondary data on state characteristics, program characteristics, and program outcomes. These analyses uncovered no statistically significant correlation between type of TANF administration and any of the following characteristics: \uf06e Work participation rate (2009) \uf06e Percent of poor families with children receiving TANF (2010) \uf06e Maximum TANF benefit for a family of three with no income (2010) \uf06e Lifetime time limit (2010) \uf06e Unemployment rate (2012) \uf06e Poverty rate (2010) When the county-administered TANF programs are ranked with the other states and District of Columbia on a variety measures, states with county-administered TANF programs are among those with the highest and lowest rankings, as well as close to the median, for each of the selected measures. Tables 10 and 11 illustrate the extent of the diversity across states with county-administered TANF programs. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 3 TABLE 10 County-Administered TANF States Ranked Nationally on Select Program Characteristics Average Monthly Caseload TANF (Oct. 12 to June 13) Percent of Poverty Population Receiving TANF (2009 10, 2-yr avg.)* Percent No Adult (Oct 12 to June 13) Average Monthly Benefit (All Families) Average Earned Income of TANF Families WPR (All Families, Nonadjusted) FY 2010 No. of years meeting WPR (2007 10) US rank Families US rank % US rank % US rank $ US rank $ US rank % CA 1 566,804 CA 2 66 NC 6 71 NY 3 538.50 NJ 8 947.80 ND 1 68.7 4 NY 2 121,570 MN 9 40 OH 9 66 CA 5 499.50 CA 10 919.80 NC 21 37.1 4 OH 4 69,428 NY 17 34 MN 18 50 CO 20 366.70 NY 18 834.80 NY 23 35.0 4 NJ 12 32,461 OH 18 33 CA 20 46 OH 22 356.10 ND 20 823.60 CO 28 33.6 4 MN 18 21,602 NJ 21 30 NY 22 46 MN 23 343.20 OH 27 770.80 NJ 37 19.9 4 NC 20 20,379 ND 33 18 ND 23 45 NJ 26 315.50 MN 33 736.60 MN 41 40.2 3 CO 27 14,783 CO 40 13 CO 43 32 ND 27 313.80 NC 38 631.40 CA 48 26.2 0 ND 50 1,465 NC 45 10 NJ 47 27 NC 44 211.60 CO 43 554.40 OH 49 23.1 0 Source: Authors’ analyses based on data from Administration for Children and Families and Center for Budget and Policy Priorities. Note: FY = fiscal year; TANF = Temporary Assistance for Needy Families; WPR = work participation rate. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 4 TABLE 11 County-Administered TANF States Ranked Nationally on Selected State Context Measures Child Poverty Rate, 2012 Unemployment Rate, 2012 (Seasonally Adjusted) State Population, July 1, 2013 Population Density 2010 US rank % US rank % US rank Persons US rank Pop\/sq. mile NC 11 26.0 CA 2 10.46 CA 1 38,332,521 NJ 2 1,195.5 CA 19 23.8 NC 4 9.49 NY 3 19,651,127 NY 8 411.2 OH 20 23.8 NJ 5 9.49 OH 7 11,570,808 OH 11 282.3 NY 22 22.8 NY 14 8.49 NC 10 9,848,060 CA 12 239.1 CO 32 18.5 CO 20 8.01 NJ 11 8,899,339 NC 16 196.1 NJ 44 15.4 OH 27 7.18 MN 21 5,420,380 MN 32 66.6 MN 48 14.6 MN 43 5.64 CO 22 5,268,367 CO 38 48.5 ND 51 13.2 ND 51 3.11 ND 48 723,393 ND 48 9.7 Source: Authors’ analyses based on data from Bureau of Labor Statistics, US Census Bureau, and American Communities Survey. From a TANF recipient’s perspective, the biggest difference between state- and county- administered programs is likely different work activities or access to support services depending on where the client lives within a state with a county-administered TANF program. In practice, within a state with a county-administered program, eligibility for cash assistance, benefit levels, nuanced differences in the treatment of income, how long they may remain on assistance, exemptions from participation in a work program, and sanctions for noncompliance are, if not identical, at least substantively the same. The same holds true for recipients in states with state-administered TANF programs. However, whether the recipient will be dealing with a county worker or someone employed by a contractor can and does vary widely within states, as do the employment activities and services offered. In county systems, access to special needs allowances such as assistance for work expenses or availability of emergency assistance could vary by county. In contrast, a TANF recipient in a state- administered state is more likely to encounter the same services and work activities anywhere in the state. From an operations standpoint, especially that of local office managers or line workers, being employed in a county-administered system can mean salaries may differ across counties, as could responsibilities and even what assistance programs are covered. This includes business processes and how cases are assigned. In some states, the pay can differ markedly by county, creating financial A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 5 pressures to relocate to another area in the state. Business processes and human resources decisions also vary among state-administered states, but not as frequently as counties with local administration. Despite virtually no differences in the characteristics of states choosing county or state administration, or in the quantifiable outcomes of these programs, officials in states with county-administered TANF programs often hold strong beliefs in the value of county administration. They argue that local officials best know the needs of recipients in their communities and are better able to respond to local challenges. This is particularly true, said officials in states with county-administered programs, in states that are large or have a marked divide in the characteristics of certain counties, for example, a contrast of urban and rural counties or regions with concentrated wealth versus widespread poverty. We believe that we know our communities better, and if we have that flexibility with how we spend our dollars we can figure out what’s specific to our communities and we can partner with nonprofits, an official from Colorado’s El Paso County said. If you’re at the state level, you don’t have that understanding. Another primary benefit of county administration cited by respondents is an ability to respond to challenges and rise above what is perceived as a lumbering, inefficient central bureaucracy. It allows for local control and ownership, a Minnesota state administrator said. It is easier to move 87 small boats rather than one bigger ship. Having flexibility also means that local officials are better able to tailor how they enter into customized business relationships, such as contracting for services, based on local needs. Other benefits include insulating the program from potential changes during times of rapid state leadership changes or political gridlock, and the local accessibility of having a benefits office nearer to a recipient’s community. On the other hand, state and county officials in county-administered programs pointed to numerous challenges with county administration. Most notable, there can be, at times, a marked difference in the quality or consistency of services provided in a county system. As a TANF official in California’s Stanislaus County said, recipients are dependent on the level of support for a program in the county where they live. By extension, to make certain changes statewide, it is necessary to gain the support of as many county boards or committees as there are in the state, as opposed to typically one central authority in a state-administered structure. By adding an extra administrative layer, local TANF administrators may sometimes feel that policy or program directives from the county, state, and federal levels are at odds with each other. If I had a wish list, it would be that the state and federal rules jived a little bit more in tandem, and not necessarily working against each other, a Stanislaus County administrator said. Engaging in program monitoring and collecting and using data can also be more challenging in a county system. In addition to differences in how data are collected, data might be 7 6 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S interpreted differently. An administrator in Minnesota’s Hennepin County observed that in a county system, it may be more difficult for counties to collaborate or work together with state-provided resources, which ultimately can create policy silos from area to area. On the operations side, staffing challenges can arise from multiple directions. Counties can have a different perspective on the importance of customer service, further adding to an incongruous program experience for a TANF family from one county to another, a Minnesota state official said. Also, in a system where counties are often recruiting the same employees, competition can arise between areas for the same caseworkers, a Burleigh County, North Dakota, board members noted. Staff retention is a particular problem for some rural areas in the state or counties that might not have the same level of resources to match statewide average staff salaries. In addition, at least some county officials in North Dakota were concerned about losing their best employees to state government positions. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 7 Technical Assistance Needs of County-Administered TANF Programs County-administered TANF programs have a wide range of technical assistance needs, including many that are shared with state-administered TANF programs and some others that are unique to county- administered programs. Both state and county TANF administrators receive federal technical assistance and federally facilitated opportunities for peer learning, for which those interviewed expressed appreciation. County TANF administrators with the authority and responsibility to develop TANF policies, though, expressed a need for greater communication directly with federal TANF administrators and for technical assistance in implementing federal policies at the county level. Administrators of county TANF programs also strongly emphasized the value of peer learning among counties within a state or among states with county-administered TANF programs. Again, those interviewed expressed appreciation for the opportunities they already received as well as an eagerness for more. This section first describes the available federal technical assistance and the specific needs of county-administered TANF programs, and then describes the range of technical assistance needs identified by both state- and county-administered TANF programs. The federal government offers a range of TANF-related training and technical assistance to states and counties. This assistance is provided through contracts with the Office of Family Assistance (OFA) and the Office of Planning, Research and Evaluation (OPRE) at HHS\/ACF. Services include the following: \uf06e The Self-Sufficiency Research Clearinghouse, launched in 2012, is an OPRE-funded virtual portal of research on topics relevant to low-income and TANF families. \uf06e The Welfare Peer TA Network is an OFA-funded initiative for technical assistance and other resources for state, county, and tribal social service agencies providing TANF. \uf06e The Online Work Readiness Assessment (OWRA) Tool is an OFA initiative for providing web- based resources to help facilitate client work readiness. \uf06e The Rural Communities initiative provided ongoing technical assistance to 16 rural communities (including the state of North Dakota) between 2008 and 2011. 7 8 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S \uf06e The Urban Partnerships initiative provided ongoing technical assistance to 26 large urban areas (including Minneapolis, Denver, and three urban areas in California) between 2000 and 2007. \uf06e The Promising Pathways initiative provided technical assistance to ten sites between 2011 and 2013. \uf06e Regional Roundtables are held every year to fulfill technical assistance requests from states to their ACF Regional Program Managers. \uf06e A special Welfare Peer TA Roundtable was held in July 2012 to explore the specific challenges of the state-supervised, county-administered structure. Minnesota led the request for this event. State and county TANF administrators interviewed for this study mentioned how useful these resources are. A Colorado county TANF administrator said of the Welfare Peer TA Network’s website, That’s a great opportunity We have stuff on that website I read it all the time. Another said the Welfare Peer TA Network’s facilitation of state sharing makes, a big difference. A state TANF administrator said of the Self-Sufficiency Research Clearinghouse, I’ve seen so many examples where research is crystallized and simplified, and that’s great. Minnesota TANF officials mentioned the technical assistance they received from the Peer TA Network on teen parents. A North Dakota TANF administrator said that through the Rural Communities Initiative, North Dakota developed a car donation program they modeled on another state’s program, and it benefitted a lot of people. In addition to federally facilitated technical assistance and peer networking, counties and states with county-administered TANF programs also share information within and across their states, both formally and informally, through state associations, training, or contracts with universities. Many emphasized the need for even more information on best practices, which could be shared through websites, e-mails, magazine articles, peer-to-peer visits, or conferences. A Minnesota TANF administrator said it would be helpful to hear from other county-administered programs how they turn this rig around when trying to implement new policies or procedures. A Colorado county TANF administrator said, folks are always hungry for what is already out there and what has been developed that we can go and visit or have them come out. There is recognition, however, that it is not possible to cookie cutter many solutions across states and counties. What works in one place might not work the same way elsewhere, especially given the variation among the county-administered TANF programs. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 7 9 A number of county TANF administrators expressed an interest in receiving communication directly from federal TANF administrators, rather than depending on state administrators to convey the information. County administrators with some autonomy in implementing TANF may use information or seize federal opportunities separately from state administrators. One county TANF administrator said, What I have seen is I think the feds do a good job of reaching out to states around that, but for some states you have to reach out to the county within the state. A county TANF administrator in another state added, There’s a need to look at recognizing the role of counties maybe and in a more official way. Because we’re so much more involved. We have quite a voice in a lot of the implementation, and we have opportunities with implementation…When it comes only through the state, we may not know about opportunities for innovation, and if they’re not shared in a manner that’s well understood by a vast majority of folks, maybe we don’t get enough participation in those opportunities. Along these lines, several county TANF administrators identified a need for technical assistance in navigating federal rules, including federal reporting of work participation components, categorizing spending for activities that serve more than one purpose, and complying with the new provisions for using debit cards. County TANF directors who have some direct responsibility for developing policies could benefit from expanded direct communication with federal TANF administrators. Some county administrators also expressed interest in technical assistance in partnering and communicating with local business to boost economic development. In some smaller counties, TANF administrators are not only focused on the self-sufficiency of their clients but more broadly on the self- sufficiency of the community. One county TANF administrator noted that it was her dream that local business might choose to partner with the TANF program, and may have demand for a specifically trained workforce that the TANF program could provide. There is potential for technical assistance at the county level in engaging these local businesses as employers. Other specific technical assistance needs raised by interviewees in county-administered TANF programs include the following: \uf06e Assistance with screening tools \uf06e Random moment time studies \uf06e Staff training processes \uf06e Management training 8 0 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S \uf06e Formulas for allocating funding to counties \uf06e Business process design \uf06e Connections between business processes and technology \uf06e Data privacy \uf06e Serving tribal members and other specific populations \uf06e Integration with other social service programs \uf06e Leveraging other resources \uf06e Change management for county-administered systems The study team also examined all the technical assistance requests to the federal government (HHS\/OFA) through its training and technical assistance contracts, as well as question topics posted to the Welfare Peer TA Network from January 2011 to March 2014. Of the 17 requests, counties directly made three. In two other cases, states with county-administered TANF programs requested technical assistance on the topic of program administration, suggesting that the topic may relate directly to the program’s county-administered structure. Table 12 lists the Welfare Peer TA Network topics and technical assistance requests posed directly by states with county-administered programs. TABLE 12 Formal Technical Assistance Requests by County-Administered TANF Programs, January 2011 to March 2014 County-administered TANF states Welfare Peer TA question and answer topics Technical assistance request topics California TANF administration Colorado Case management Job development, job placement and retentiona Caseload sizesa Minnesota Compliance and sanctions Teen parents Teen parents TANF administration North Dakota Nonrecurring short-term benefits Diversion New Jersey Subsidized employment and work experience Employment and traininga New York Assessments Job development staff training Ohio Child care Compliance and sanctions Job readiness North Carolina Source: Authors’ analyses of information from the Welfare Peer TA Network. a Technical assistance requested by county. A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 8 1 The technical assistance needs raised by state-administered TANF programs also vary widely. The research team asked the directors of 29 state-administered TANF programs whether they needed technical assistance in any of several specific technical assistance areas and also asked them to identify any other technical assistance topics that would benefit their programs. Among the specific technical assistance topics, each topic was selected by, at most, about one-quarter of states as an area of need for them (see table 13). Furthermore, only six states volunteered any additional technical assistance topics beyond those in the suggested list. TABLE 13 Potential Technical Assistance Needs in 29 State-Administered Programs Technical assistance topics Number of states indicating need Financial management and fiscal reporting 5 Communication 9 Policy 6 Information technology 8 Data management 10 Program monitoring 9 Service delivery 5 Training tools 10 Staff recruitment strategies 7 Staff retention strategies 9 Effective screening and assessment protocols 7 Source: Urban Institute analysis of survey responses from 29 states with state-administered TANF programs, December 2013 March 2014. While the technical assistance needs of state-administered and county-administered TANF programs overlap considerably, in general the technical assistance needs for county administered programs focus on the strategies, tools and information needed to support program implementation, where state technical assistance needs center on systems and policy change and implementation. Both county and state administrators participate in and use technical assistance provided by federal and state providers. It is evident that continuing to further target technical assistance efforts to address the issues of county-administered systems would strengthen the implementation of these programs. 8 2 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Key Findings and Conclusions While the county-administered label reveals very little about how a TANF program is administered, a few characteristics are common to all the county-administered TANF programs included in this study and set them apart from state-administered programs. First, county employees (not state employees) are the frontline workers determining eligibility and case management. Second, the counties contribute financially to the program. Third, county elected officials play some role in reviewing the local TANF budget, policy, or both. However, in Colorado and California county administration means much more. Counties in Colorado and California have considerable authority, flexibility, and responsibility for policy decisions, spending decisions, or financial contributions. For families living in states with county-administered TANF programs, their experiences receiving TANF cash assistance depend on both their state and their county. A family’s eligibility for TANF and the amount of cash assistance they receive depends almost entirely on their state of residence, not their county. The basic rules around eligibility and benefit levels vary by state but are applied uniformly across counties within each state. County-by-county differences in other aspects of a family’s TANF experience, however, are greater in Colorado and California, which allow counties greater flexibility to shape their TANF programs, than in Minnesota and North Dakota or in states with state-administered TANF programs. In states with flexible county-administered TANF programs, a family might experience different specific work requirements or training opportunities, or even different rules for the living arrangements of teen parents, depending on the county in which they live. The positive relationships observed between some county TANF administrators and their communities suggest that family experiences in county-administered TANF programs are further shaped by the local resources that are available and by the ability of the TANF program to seize opportunities to create partnerships and provide access to community resources; however, this study did not examine the relationships that state-administered TANF programs have with their communities, for comparison. County flexibility to tailor TANF programs depends not only on the formal structure of state and county authority and responsibility but also on the practical ability of counties to act. When counties have fewer financial resources, such as during the recent recession, or if they lack the personnel and technical capacity to develop innovative programs, county-by-county differences are diminished, regardless of their formal authority. As a whole, county-administered TANF programs look no different from state-administered TANF programs on major measures. County-administered programs are among the highest, the lowest, and average ranked TANF programs on the federal work participation rate, the share of poor families A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S 8 3 receiving TANF cash assistance, average earned income, average TANF benefit amount, and other measures. In addition, states with county-administered TANF programs are not systemically different from other states in terms of population size, political party, or other state characteristics. Although county or state administration of TANF is not systematically correlated with measured outcomes for families, both structures have proponents. Proponents of state TANF programs highlight the consistent support low-income families receive throughout the state. Proponents of county-administered TANF programs underscore the flexibility to adjust to local circumstances, culture, priorities, and perspectives. As all states continue to implement and revise their TANF programs, whether county- administered or state-administered, they each seek their own balance between providing consistent support for low-income families and adjusting to local circumstances. County administration of TANF appears to matter the most to the counties themselves. Even in North Dakota counties, where TANF program flexibility is very limited and the financial contribution is relatively large, the desire for county control is strong. Regardless of the reasons for or results of county administration, the extent of county control and, by extension, the limits on state control are important for federal lawmakers and regulators to recognize. Governors and other state-level officials may not have direct authority to mandate specific actions at the county level. While states ultimately are responsible for complying with federal laws and regulations, and ensuring that their counties do also, the process of implementing federal policies in a state with a county-administered TANF program can be complex. Further, because county administrators in some states are directly implementing federal policies, technical assistance on these matters needs to be directed to county administrators as well as state officials in these states. 8 4 A D E S C R I P T I V E S T U D Y O F C O U N T Y – V E R S U S S T A T E – A D M I N I S T E R E D T A N F P R O G R A M S Appendix A. State-Administered TANF Programs Included in the Study TABLE A.1 List of State-Administered TANF Programs Included in the Study Alabama Arizona Arkansas Connecticut Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Louisiana Maryland Massachusetts Michigan Mississippi Missouri Montana Nevada Oregon Pennsylvania South Carolina South Dakota Tennessee Virginia Washington West Virginia Wisconsin A P P E N D I X A 8 5 Appendix B. Site Visit Interview Guide for State TANF Directors 8 6 A P P E N D I X B O M B A P P R O V A L N O . : 0 9 7 0 – 0 4 3 6 Expiration Date: 8\/31\/2014 STATE TANF DIRECTORS’ INTERVIEW GUIDE [Note: This guide is intended for respondents identified as State TANF Directors in County Administered\/State Supervised states. Respondents will be familiar with the issues, complexities, and realities of County administered TANF programs.] Date of Interview: Interviewer (s): State: Respondent Name: Title: Respondent Affiliation: E-Mail: Phone: Address: Fax: Introduction\/Purpose of the study Thank you for agreeing to participate in this interview today. My name is _______________ and I’m a researcher from the [Urban Institute, a nonprofit research organization OR ICF International, a consulting firm] located in the Washington, DC, metropolitan area. With me today is [name and affiliation]. The Administration for Children and Families (ACF) Office of Planning, Research, and Evaluation (ACF\/OPRE) is conducting a study of county-administered Temporary Assistance for Needy Families (TANF) programs. The study is not an audit or evaluation of any single program. Rather, the purpose A P P E N D I X B 8 7 of this study is to provide information about the way the program works; for example, we want to learn: What do county-administered TANF programs look like; How do county-administered TANF programs differ from state-administered TANF programs in terms of program implementation, operations, outputs, and outcomes; and Do county-administered TANF programs have unique technical assistance needs? Privacy Statement [Interviewer must read this]: This data collection effort is intended for the purpose of describing county-administered TANF programs’ operations and needs, and comparing these with state-administered TANF programs. We will use what we learn today and from other interviews to contribute to a report to HHS and others interested in TANF programs. Our study began in October 2012 and will end in September 2014. Your participation is voluntary and your statements are private to the extent permitted by law. This interview is not part of an audit or a compliance review. Your comments will not affect the program’s management or your involvement with the program. We know that you are busy and will try to be as brief as possible. We have many questions and are going to talk to many different people, so please do not feel as though we expect you to be able to answer every question. Again, this interview is not part of an audit or a compliance review. We are interested in learning about your ideas, experiences, and opinions about TANF program administration. There are no right or wrong answers. We want to know what you think. If there are any questions you do not wish to answer, just let us know. In addition, before we start, I want to let you know that although we will take notes during these interviews, information is never associated with your name or the name of any respondent in any report, discussions with supervisors or colleagues, or ACF\/OPRE. When we write our reports and discuss the study findings, information from all informants is compiled and presented so that no one person is identified. However, although individuals will not be cited as sources, information will be presented in our reports that may enable a user to infer the identity of the information source. [IF WE WOULD LIKE TO RECORD THIS SESSION:] We value the information you will share with us today and want to make sure we capture all of it. So, with your permission, we will be recording the session and\/or [name of person] will be taking notes on a laptop computer. However, we will destroy the recordings as soon as we have made complete notes of the meeting. Do you have an objection for us to proceed with recording? 8 8 A P P E N D I X B We have scheduled this meeting for 60 minutes. Is that still convenient? (If yes) Are you willing to participate in this interview? Do you have any questions before we begin? If you have any questions during the interview, please do not hesitate to ask– if something is not clear, just let me know. Okay? [NOTE TO INTERVIEWER: The respondent’s answers to individual questions may address subsequent questions. Subsequent questions may be skipped or probed as needed to gather complete information.] I. Background and Context 1. Please describe your position\/role in the state of _____________. (Probe: What is your job title? What are your responsibilities related to TANF? What are your overall responsibilities? How long have you held this role? In the past, did you have other positions in this department?) 2. We’ll be getting into specifics shortly, but first I wanted to ask in your view, what are the benefits of managing TANF in a county-administered system? a. (Possible responses: reductions in regulations and federal oversight; ability to redesign welfare programs in more efficient\/effective ways; counties are closer to the problems of residents; additional flexibility for service delivery; greater familiarity with capacity of local programs to serve those in need; more responsive to changing demographic trends; increased ability to innovate) 3. Conversely, are there any obstacles in your view to operating in a county-administered system? What about this arrangement is more challenging? II. History of TANF Program Administration I would like to ask some questions about the history of TANF program administration in your state. 1. From what you know, what was the historical role of county offices in providing welfare services? [NOTE TO INTERVIEWER: Probe, as needed: Is relationship a continuation of administrative practices prior to the implementation of PRWORA (i.e., AFDC)? Have there been changes over time in the relationship? Are relationships clearly defined and outlined, by state policies\/procedures? How autonomous are county offices?] 2. Did the state have approved federal waivers to administer a more localized AFDC program? Can you describe some of the specific responsibilities of the county or local governing board during AFDC? A P P E N D I X B 8 9 3. What, to the extent of your knowledge, were some of the major reasons why the state placed more functional and administrative responsibilities with the counties in the wake of PRWORA rather than maintain more state-level control? [NOTE TO INTERVIEWER: These reasons can be probed if the respondent has long term involvement with decisions regarding administering and implementing TANF: a. Reductions in regulations and federal government oversight b. Ability to redesign welfare programs in more efficient and effective ways c. Perception that counties are closer to the problems of residents d. Provide additional flexibility for services and service delivery e. Greater familiarity with capacity of local programs to serve those in need f. More responsive to changing demographic trends g. Increase ability at local level to innovate h. Greater capacity to engender public support for welfare reform III. Financial Management and Fiscal Reporting I would like to focus now on financial management and fiscal reporting responsibilities for your County administered TANF program. 1. First, could you explain broadly how your TANF program is financed, including federal TANF dollars, state dollars and county dollars? [NOTE TO INTERVIEWER: The respondent’s answer may address subsequent questions in this section. Subsequent questions may be skipped or probed, as needed to gather complete information.] 2. The TANF block grant to the state has remained consistent over the last 15 plus years. What has been the experience on the state level\u2014have funds allocated to the counties remained consistent with the 1997 levels? 3. How are funds allocated to the counties? a. Are the funding mechanisms different for administrative dollars and program dollars? If so, please explain how each type of funding is allocated to the counties. b. Does the state allocation of program or administrative funds vary year to year? Month to month? c. Are adjustments program funds based on the number of families served? d. Has there been any adjustment in county program or administrative funding levels due to the economic recession or state budget issues? e. Is funding tied to performance? If so, how? 9 0 A P P E N D I X B f. What role does a county board of supervisors have in TANF funding and other financial decisions? 4. Does the State have a standard reporting process and protocol for counties to report expenditures\u2014both cash and noncash assistance? a. How does that system work? How is the back and forth between the State and Counties handled? b. How often is data collected\u2014monthly, less frequently, more frequently? c. Has the State established reporting metrics (e.g., expenditures per participant) for the counties? d. What communication vehicles are used between the state and counties? For example, is there a monthly newsletter or funding notification provided to the counties to keep them informed of changes in procedures? 5. There is a Maintenance of Effort (MOE) requirement for the drawdown of Federal TANF funds. Can you tell me a little about how that works in your State in relationship to the Counties? a. Is the MOE requirement met only by the state or is it passed down to the county level, requiring counties to meet MOE requirements? 6. Is there a set proportion of the federal funds that are reserved by the State for their use in administrative oversight, monitoring and reporting? 7. Does your state have a Solely State-Funded program(s) related to your TANF program? If so, are State dollars allocated to the counties for these programs? a. If so, how are these State dollars allocated to the counties (e.g., by caseload)? b. Is there a County match requirement for these programs? If so, what is the source for these funds? 8. What is the level of discretion that the State has in creating state-wide initiatives that are funded from Federal TANF resources? 9. When funds are used for TANF purposes 3 and 4 (reducing nonmarital childbearing and promoting two-parent families) are those allocation decisions made only at state level or also at the county level? 10. When funds are transferred to other programs, are those allocations decisions made only at the state level or also at the county level? 11. Does the state mandate to the counties any State-specific programming and set-aside allocation of funding for specific programs? 12. From your state perspective, have there been any challenges with the cost of administering TANF at the county level, especially during the economic crisis? 13. What technical assistance is needed regarding financing and fiscal reporting for county- administered TANF programs? A P P E N D I X B 9 1 IV. State County Bureaucratic Structure and Communication Now I would like to get a general understanding of the current relationship between the state government and county governments in the administration of TANF, before we delve into the specifics. 1. Can you please give us a broad overview of how the state\/county relationship is currently structured in your state with regard to TANF? From your perspective, how has this relationship changed over the 15 year implementation of PRWORA? 2. What are the general responsibilities of each level of government for managing and implementing TANF programs? (Potential areas: financial management, policy, administrative responsibilities, performance measurement, staff hiring, contracting for services) a. State responsibilities? b. County responsibilities? (Probe: Who, what position or governmental entity, is the point of contact for county responsibilities?) 3. We are interested in how these responsibilities are governed and where these entities derive their authority\/responsibility. To what extent are responsibilities governed by: a. Federal policy? b. State legislative mandate? c. County rules\/regulations? d. Are there other governing authorities or mandates (e.g., court orders)? 4. Is there a need for technical assistance to facilitate these relationships and\/or communication? If so, please describe. V. Policy Development As we delve into more specifics, I would like to focus first on the roles of the state and counties in TANF policy development. 1. What policy decisions relating to TANF implementation are made at the state level and which are made at the county level? a. Determining eligibility requirements b. Determining asset and earned income disregards c. Setting benefit levels d. Determining appropriate work requirements e. Determining recipient sanctioning procedures and processes 9 2 A P P E N D I X B f. Determining time limits g. Establishing family caps h. Determining child support pass-through 2. To what extent have counties’ policy choices and priorities varied across the state? a. What influence do local constituencies, socioeconomic factors, metropolitan status, region, population changes, budgetary situations, demographics play on policy variations across the state? 3. How are TANF policy decisions communicated up and down the bureaucracy? In other words, how does the state communicate policy decisions to the counties and how do counties communicate policy decisions to the state? How does each entity communicate policy decisions to other stakeholders? a. Policy memos or summaries? Policy manuals or directives? Legislative concept proposals and memos? Committee reports or memos? Public speeches or public testimonies? Electronic mail or electronic bulletin boards? Executive or legislative briefings? Functional documents that require independent review, as opposed to proactive engagement (e.g., legislation, regulations, procedures, or agreements)? Regular data reports (e.g., hard copies or output to a data dashboard structure?)? b. Is there a single point of contact for communication surrounding policy? 4. At what level can decisions about privatization of services be made\u2014state or county? a. Do counties have flexibility to create performance benchmarks and performance contracts for privatized services? VI. IT and other resources available to counties I would like to focus now on your technology systems and resources. 1. To what extent do counties share IT systems throughout the state? Are the systems statewide, or unique in each county, or used by subgroups of counties? a. How are shared systems managed (mainframe, web-based)? b. Is the system TANF only or connected with other programs (e.g., SNAP, Medicaid, Child Care)? 2. To what extent do counties share data systems throughout the state? Are the data systems statewide, or unique in each county, or used by subgroups of counties? a. How are shared data systems managed (mainframe, web-based)? b. Is the data system TANF only or connected with other programs (e.g., SNAP, Medicaid, Child Care)? 3. What IT technical assistance or support is available to counties from the state? A P P E N D I X B 9 3 a. How often are these resources accessed? What works well in the system? What is challenging? What do you wish was different about the process? 4. From your perspective, do counties collaborate to stretch resources further? a. Is it a formalized or ad hoc process? What mechanisms exist for initiating or responding to a request? Is this data tracked? 5. What technical assistance needs exist at the state or county level with respect to support to mitigate challenges or problem-solving for IT solutions and more effective data management? VII. Program Oversight and Monitoring I would like to focus now on the program oversight and monitoring practices of your TANF program. 1. What performance monitoring systems are used by the state to oversee TANF? 2. What performance measures have been put into place? 3. How is program compliance ensured? a. What metrics are in place to ensure county compliance? How are those data collected? How is program quality defined and measured? b. What state supports are available to counties? How are errors addressed? What types of corrective action are used? 4. How does the state monitor participation in work activities? a. What happens in your State when a county does not meet its work participation rate? b. [For states that use performance measures beyond the WPR] Do counties monitor, or are counties held accountable, for any other measures beyond the WPR? 5. If the Federal government levies a penalty against the State, how does that penalty flow down to counties? a. Do responsible counties bear the entire penalty? How are those funds realized? What steps are taken to mitigate future errors? 6. From your perspective, what tools or resources would support improved performance for county- administered TANF programs? a. What TA efforts have been implemented in the past? What were the results? What were the lessons learned? 9 4 A P P E N D I X B VIII. Service Delivery and Staffing I would like to focus now on the service delivery practices of your program. 1. To what extent is there variation in the implementation of TANF services to clients across the state: a. In-take and access (e.g., same screening and assessment tool for determining eligibility? Making referrals? Program and service eligibility?) b. Service delivery (e.g., referral mechanisms and co-location of staff, on-site supports, job support service referrals, employment supports like child care referrals and transportation vouchers) c. Work supports (e.g., job club, job-readiness training, components of work support) i. What is the level of flexibility at the county level to define and implement work support programs d. Staffing and salaries (e.g., job descriptions and requirements, salary levels, training) i. What discretion do counties have in making staffing and caseload decisions? ii. How are caseload levels (staff: case ratios) determined? 1. State directed? 2. County directed? iii. Are qualifications and job descriptions determined at the state or county level? iv. Are hiring decisions made at the state or county level? v. Are salaries set at the state or county level? e. Generalist versus Specialist Worker (e.g., universal worker, TANF only, Medicaid only, SNAP only) 2. To what extent are service integration and cooperation between TANF and other work support programs (SNAP, child care, DOL-sponsored training) standardized across the state or unique to each county? 3. How seamless is the transition for families needing services as they move from one county to another? For example, does a family’s case close, requiring them to reapply in their new county, or are cases transferred between counties? 4. From your perspective, what is the role of the state in ensuring effective case management of TANF families? 5. What technical assistance is needed to improve service delivery for TANF programs? a. On-boarding materials? b. Training tools? c. Recruitment strategies? d. Retention strategies? A P P E N D I X B 9 5 e. Effective screening and assessment protocols? IX. Other variation or technical assistance needs 1. Are there any other differences in how TANF programs are implemented from county to county that we haven’t already discussed? 2. We have asked about specific technical assistance and support during this discussion. Are there any other types of technical assistance that that would benefit your program? a. (Recount earlier examples, probe for each area: Communication, policy, IT, monitoring, service delivery, OTHER?) ______________________________________________________________________________ Thank you so much for sharing this information with us. This has been a great discussion and we are grateful for your time. Is there anything else you would like to share with us about your program? If we have any follow-up questions as we write our report, may we contact you again? Thank you. 9 6 A P P E N D I X B Notes 1. Descriptions for these two states, New Jersey and North Carolina, are fully contained on pp. 57 61, rather than throughout the report. 2. Federal law requires states to engage at least half of all TANF families with a work-eligible individual in a specific set of work or work-related activities for at least a minimum number of hours each month, subject to adjustments based on caseload reduction and state spending. A state that does not meet this work participation rate requirement may lose part of its TANF block grant. See Hahn, Kassabian, and Zedlewski (2012). 3. In addition, PRWORA requires states to conduct a program that provides assistance to needy families with (or expecting) children and provides parents with job preparation, work and support services to enable them to leave the program and become self-sufficient (42 U.S.C. 602, Sec. 402(1)(a)(i)). 4. See appendix B for the semi-structured discussion guide used in interviews with state TANF directors, which were the most expansive discussions among the site visit interviews. 5. This report draws state TANF policy information from Huber, Kassabian, and Cohen (2014). At the time of this report, policy information as of July 2013 was the most recent available. 6. Clients are allotted 24 cumulative months to participate in the full array of CalWORKs welfare-to-work activities with no hourly core\/noncore requirement. Once clients exhaust the 24 months, they are required to meet federal TANF work participation rate requirements. The state time limit for cash assistance is 48 months. 7. Maximum benefits are calculated assuming that the unit contains one adult and no children who are subject to a family cap, have no special needs, pay for shelter, and live in a high-cost area of the state. 8. Although the immediate outcome is the same as full suspension of a recipient’s benefit, case closure adds administrative complexity once the family is again compliant because the family typically must reapply for assistance. 9. As explained in the Colorado State Board of Human Services’ Standards and Procedures Manual for Rule- Making, When the Colorado General Assembly creates a law, it may leave certain things to the Executive Branch’s discretion to establish or further define giving authority to the agency or rule-making body to further define requirements or establish more specific criteria. Through rules, agencies in the Executive Branch can elaborate on laws created by the legislature (Colorado Department of Human Services 2002, 9) CDHS programs or stakeholders also may initiate rules in response to a change in state department procedure, organization, or policy that is required or permitted by statute; or identification of a new need or previously unknown issue (9). Regardless of who initiates the rule-making, It is CDHS policy that programs identify stakeholders and involve them in the rule-making process (16). For additional information, see Colorado Department of Human Services (2002). 10. According to the CWDA website, the association was established at the 1926 annual meeting of the California Conference of Social Work. This unofficial group of public welfare organizations, with a membership of 20 people, was originally called the Association of California’s Executives of Public Welfare. The name was changed to the County Welfare Directors Association in 1943. 11. The Cal-Learn program assists pregnant and parenting teens who have not obtained a high school diploma or its equivalent to graduate and become self-sufficient. 12. According to Minnesota’s State TANF Plan, The goal of the [Family Home Visiting] program is to prevent child abuse and neglect, reduce juvenile delinquency, promote positive parenting and resiliency in children and promote family health and economic self-sufficiency (p. 8). 13. For programs that receive federal reimbursement for administrative expenses, such as SNAP, the swap legislation meant counties were required to assign any share of administrative money they would have received as a reimbursement to the state. 14. The California State TANF Plan is available at California Department of Social Services, TANF State Plan, accessed May 6, 2015, http:\/\/www.cdss.ca.gov\/cdssweb\/PG152.htm. N O T E S 9 7 15. The index’s data sources include participant-submitted paystubs, the TANF eligibility system, and the Department of Employment and Economic Development. See Hahn and Loprest (2011). 16. Most of the data were collected through phone interviews. A small number of states chose to enter responses directly into a survey form that was substantively identical to the interview questions. Not all states responded to every question. 17. For more information on outcome-based performance measures, see Hahn and Loprest (2011). 9 8 N O T E S References Colorado Department of Human Services. 2002. Standards and Procedures Manual for Rule-Making. Denver: Colorado State Board of Human Services Administrator, Boards and Commissions Division, Office of Performance Improvement. http:\/\/www.colorado.gov\/cs\/Satellite\/CDHS-ExecDir\/CBON\/1251616102645. Hahn, Heather, David Kassabian, and Sheila Zedlewski. 2012. TANF Work Requirements and State Strategies to Fulfill Them. Temporary Assistance for Needy Families\u2014Research Synthesis Brief 05. Washington, DC: US Department of Health and Human Services, Administration for Children and Families, Office of Planning, Research, and Evaluation. http:\/\/www.acf.hhs.gov\/sites\/default\/files\/opre\/work_requirements_0.pdf. Hahn, Heather, and Pamela Loprest. 2011. Improving State TANF Performance Measures. Washington, DC: Urban Institute. Huber, Erika, David Kassabian, and Elissa Cohen. 2014. Welfare Rules Databook: State TANF Policies as of July 2013. OPRE report 2014-52. Washington, DC: US Department of Health and Human Services, Administration for Children and Families, Office of Planning, Research and Evaluation. R E F E R E N C E S 9 9 About the Authors Heather McCallum Hahn is a senior fellow in the Center for Labor, Human Services, and Population at the Urban Institute. Throughout her career, Hahn has conducted nonpartisan research on the wide range of issues related to the well-being of children and families, including TANF, SNAP and other supports for low-income families, as well as education, labor and other policy issues. She received a Master of Public Policy from Duke University and a Ph.D. in Political Science from Stanford University. David Kassabian is a research associate in the Income and Benefits Policy Center at the Urban Institute, where he is involved in examining TANF policy and projects supporting and evaluating state efforts to streamline work support benefits\u2014Medicaid, the Supplemental Nutrition Assistance Program, and child care. He received a Master of Public Affairs from the University of Texas at Austin. Lina Breslav is a research assistant in the Center for Labor, Human Services, and Population at the Urban Institute. She is involved in projects related to women’s and adolescent health, the social determinants of health, and supports for low-income families. Yvette Lamb is a senior fellow in the Family Self Sufficiency Group at ICF International where she directs the research and evaluation activities of the group. Her projects cross several disciplinary boundaries including human services, workforce, health and education and target a wide range of stakeholders including TANF programs, local service providers, community based organizations and workforce development organizations. Her doctorate, in education from the University of Pittsburgh, focused on policy, planning and evaluation in the context of community driven collaborative initiatives. 1 0 0 A B O U T T H E A U T H O R S ST A T E M E N T O F I N D E P E N D E N C E The Urban Institute strives to meet the highest standards of integrity and quality in its research and analyses and in the evidence-based policy recommendations offered by its researchers and experts. We believe that operating consistent with the values of independence, rigor, and transparency is essential to maintaining those standards. As an organization, the Urban Institute does not take positions on issues, but it does empower and support its experts in sharing their own evidence-based views and policy recommendations that have been shaped by scholarship. Funders do not determine our research findings or the insights and recommendations of our experts. Urban scholars and experts are expected to be objective and follow the evidence wherever it may lead. Executive Summary What Do County-Administered TANF Programs Look Like? How Do County-Administered TANF Programs Differ from State-Administered Programs? What Are the Technical Assistance Needs of County-Administered TANF Programs? Concluding Observations Background Research Design and Methods Site Visits California Colorado Minnesota North Dakota Phone Interviews Analyses of Secondary Data History of TANF Administrative Structure Bureaucratic Responsibilities State and County Roles California Colorado Minnesota North Dakota Roles of County Elected Officials Roles of Associations of County Social Service Directors Roles of Unions Financial Management and Fiscal Reporting California Colorado Minnesota North Dakota Policy Authority and Development at the State and County Levels Statewide Policies County Policies Program Oversight California State Monitoring and Oversight Work Participation Rate and Other Performance Measures Colorado State Monitoring and Oversight Work Participation Rate and Other Performance Measures Minnesota State Monitoring and Oversight Work Participation Rate and Other Performance Measures North Dakota State Monitoring and Oversight Work Participation Rate and Other Performance Measures Service Delivery Variation in General Service Delivery Models across Counties California Colorado Minnesota North Dakota Implications for Families Moving across County Lines Engagement with Community Partners California Colorado Minnesota North Dakota Information Technology Use of Statewide and County-Specific IT Systems California Colorado Minnesota North Dakota Ability of State and Counties to Create Reports and Access Data California Colorado Minnesota North Dakota County TANF Administration in New Jersey and North Carolina New Jersey North Carolina History of TANF Administrative Structure Bureaucratic Structure and Communication Financial Management and Fiscal Reporting Policy Authority and Development Program Oversight Service Delivery Information Technology Statement of Independence ”

” C C W R O P O LI C Y B R IE FI N G – 20 15 – 0 1 Coalition of California Welfare Rights Organizations, Inc. Kevin M. Aslanian Executive Director [email protected] Grace A. Galligher Directing Attorney Steve Konnoff, Director of Development 1111 Howe Avenue, Suite 150 Sacramento, CA 95825-8551 Tel. (916) 736-0616 Fax (916) 736-2645 Cell (916) 712-0071 ccwro.org SB 1041- Impact on Sanctions WtW sanctions have been a concern since the enact- ment of the Welfare-to-Work program. In 2006, the State legislature enacted AB 1808, Chapter 75, Stat- utes of 2006. AB 1808 added another $90 million in TANF funds to the Employment Services component of the County Single Allocation to reduce WtW sanc- tions. TABLE #1 reveals that the $90 million allocated to reduce sanctions has not had the effective results as the legislature had intended. In 2008, we see only a 4% reduction in sanctions from the previous year. In 2009, we see only a 2% reduction. In 2010, sanctions rise again to 34%. On June 27, 2012, SB 1041, Chapter 47, statutes of 2012, was signed into law requiring families with chil- dren under the age of 6 to be reengaged in a WtW ac- tivity or face the WtW sanctions. CCWRO opposed this change because it meant increased sanctions imposed upon impoverished families living in toxic poverty. This policy briefing examines whether sanctions have increased in light of the enactment of SB 1041. TABLE #2 reveals that sanctions increased from 30% in 2008 up to a whopping 49% in December of 2014. This is based on the sanctions imposed on unduplicated participants in the WtW program and not the enroll- ees as preferred by the Department. The rational for using unduplicated participants is set forth below in detail. Page 1 of 4 Year\/ November Percentage of Sanctioned Unduplicated Participants 2005 48% 2006 35% 2007 34% 2008 30% 2009 32% 2010 34% 2011 38% 2012 43% 2013 45% 2014 49% TABLE # 1 – Percentage of Unduplicated Welfare-to- Work participants Sanctioned WtW sanctions are imposed upon participants . Enrollees are not sanctioned in California since the enactment of the GAIN and WtW program. In fact, enrollees have never been sanctioned in California. CDSS and others have erroneously tried to use enrollees as a numerator to calculate the sanc- tion rate to determine a lower sanction rate that is actually endured by CalWORKs recipients in the real world. The definition of enrollee includes recipients willing to participate which does not mean they are participating, thus they are not subject to sanctions. Moreover, enrollees does not include sanctioned families. Thus, using enrollees and sanctioned participants as a basis for calculating the WtW sanction rate is dishonest and misleading. Moreover, it represents an attempt to conceal the true impact that these punitive sanctions inflicted upon impoverished families, often because counties did not provide supportive services. The statute and the state regulations provide that sanctions can be imposed upon participants and not enrollees . In fact, the only place that en- rollees are mentioned in the statutes is only for the purposes of determination of eligibility for al- lowing participants to continue their self-initiated education in 11320.3 and 11325.23. Enrollees are also mentioned in the statute authorizing the Temporary Assistance Program (TAP) program. Looking at the state regulations, enrollees only appear in two places: 1. MPP 42-702 which provided that GAIN recipients must enroll in the newly enacted WtW program; and 2. MPP 42-711.54 which is the Self-Initi- ated Program (SIP) Page 2 of 4 WHO CAN BE SANCTIONED IN THE WtW PRO- GRAM? Only persons who fail to participate can be sanc- tioned. See MPP 42-721.21 below. DOES ENROLLEES INCLUDE SANCTIONED PERSONS? No. How can a sanction rate be calculated by including the persons who are not being sanctioned? The sanctioned persons cannot be in the numera- tor when that is the number for the denominator. WtW 25 Instructions and ACL 06-56 Enrollee: Is an individual who has been en- rolled or has been sent a notice that he or she was scheduled for a WTW appraisal. Count individu- als who received cash aid, who were eligible for cash aid (e.g., individuals in a zero basic grant status), or were considered CalWORKs recipi- ents in the report month. This would include adults who are in receipt of family reunification services, have had a child(ren) removed from the home, and are no longer in receipt of cash aid. An enrollee is de- fined as either (1) required to participate, or (2) willing to participate. WTW sanction: Occurs when the individual is not aided during the report month for a failure to comply with WTW program requirements with- out good cause and for whom compliance efforts have failed (MPP Section 42-721.41). MPP 42-720.21 An individual who is required to participate in program activities as a condition of receipt of aid shall be subject to sanctions specified in Section 42-721.4, when- ever: .211 He or she fails or refuses without good cause to comply with program re- quirements;… Below is the list of activities that a CalWORKs recipient can be sanctioned, if they fail to partici- pate therein without good cause, that are set forth Page 3 of 4 in the WtW 25 reporting form. Numbers 6-29 are repre- sented in cell 30 of the WtW 25. Often participants are not able to participate due to lack of supportive services as revealed in a report done by the Rand Corporation. The counties never verify that the participants adequate supportive services. 30. Number of individuals 6-29 (Unduplicated): Enter the unduplicated total number of individuals who were counted in activities 6-29 during the report month. This total is not the sum of Items 6-29. 6. Appraisal 7. Assessment 8. Reappraisal 9. Job search & job readiness assistance 10. Unsubsidized employment 11. Self-employment 12. Subsidized private sector employment 13. Subsidized public sector employment 14. On-the-job training (OJT) 15. Grant-based on-the-job training (OJT) 16. Work-study 17. Supported work or transitional employment 18. Work experience 19. Community service 20. Job skills training directly related to employment 21. Vocational education training 22. Education directly related to employment 23. Adult basic education 24. Satisfactory progress in a secondary school 25. Other activities 26. Providing childcare to community services participants 27. Mental health services 28. Substance abuse services 29. Domestic abuse services 30. Number of individuals 6-29 (Unduplicated) Ye ar \/ N ov em be r En ro lle es W tW 2 5 En ro lle es W tW 2 5A To ta l En ro lle es U nd up l. Pa rt . W tW 25 U nd up l. Pa rt . W tW 2 5A To ta l U nd up l. Pa rt . Sa nc tio ns W tW 2 5 Sa nc tio ns W tW 2 5A TO TA L Sa nc tio ns % o f U nd up l. Pa rt . Sa nc tio n % o f En ro lle e Sa nc tio n Pa rt . 20 08 13 89 61 53 97 4 19 29 35 9 8, 53 4 3 3, 77 8 1 32 ,3 12 33 31 1 61 81 39 49 2 30 % 20 % 20 09 13 78 82 63 15 2 20 10 34 1 03 ,5 23 4 1, 21 6 1 44 ,7 39 36 09 0 10 69 4 46 78 4 32 % 23 % 20 10 13 12 50 64 74 2 19 59 92 9 8, 00 5 4 1, 53 4 1 39 ,5 39 34 60 0 12 41 4 47 01 4 34 % 24 % 20 11 11 01 58 53 57 6 16 37 34 8 5, 85 0 3 6, 15 2 1 22 ,0 02 32 46 6 13 28 7 45 75 3 38 % 28 % 20 12 10 66 02 48 42 2 15 50 24 8 3, 99 8 3 2, 76 4 1 16 ,7 62 35 37 1 14 60 6 49 97 7 43 % 32 % 20 13 12 21 82 49 28 5 17 14 67 8 5, 12 0 3 0, 12 6 1 15 ,2 46 37 74 8 14 68 1 52 42 9 45 % 31 % 20 14 13 17 72 52 93 7 18 47 09 9 0, 04 4 3 1, 89 7 1 21 ,9 41 42 70 6 16 63 0 59 33 6 49 % 32 % U nd up l. Pa rt . – U nd up lic at ed W tW P ar tic ip an ts So ur se : C D SS W tW 2 5 re po rt s. Pa ge 4 o f 4 TA B LE # 2 – D et ai le d Ta bl e of C al ifo rn ia W tW Sa nc tio ns fr om 2 00 8 th ro ug h 20 14 ”

” C C W R O P O LI C Y B R IE FI N G – 20 15 – 0 2 Coalition of California Welfare Rights Organizations, Inc. Kevin M. Aslanian Executive Director [email protected] Grace A. Galligher Directing Attorney Steve Konnoff, Director of Development 1111 Howe Avenue, Suite 150 Sacramento, CA 95825-8551 Tel. (916) 736-0616 Fax (916) 736-2645 Cell (916) 712-0071 ccwro.org Page 1 of 2 Since the inception of the AFDC and CalWORKs work programs, parents trying to attain self-sufficiency through education have faced strong resistance from program administrators. SB 1041 was supposed to give partici- pants a 24-month opportunity to select a component in which they wanted to participate. Under current law, the participant meets with the WtW worker. They jointly decide which component to select. How- ever, rarely do participants have a real option because they are told that they must cooperate with the WtW worker or endures the devastating WtW sanctions. Thus, the option is usually what the WtW worker suggests which reflects the county policy. CCWRO has made several suggestions to eliminate this phenomenon but were rejected outright by counties and CDSS: 1. Mail the participant the options avail- able for him\/her to choose, before or after the assessment, and have the par- ticipant return his\/her chosen option to the WtW worker; 2. Allow the participant to make his\/her choice on-line. As evidenced in TABLE # 1 below, the percentage of unduplicated partici- pants allowed attendance in secondary education has declined. Some of the administrators allege that this decline is due to the improvement of the economy. TABLE # 1 reveals that even when the unemployment rate went down, the rate of WtW participants in secondary edu- cation did not decline, but did decline upon the enactment of the SB 1041 provisions. In 2006, the unemployment rate was 4.9% and 10% of the unduplicated par- ticipants were participating in a second- ary education\/SIP component. That 10% remained constant even when the unemployment rate doubled, until the enactment of SB 1041 in 2012. In 2013 the unemployment rate went down by 20% and in 2014, it went down by 30% Do Availability of Jobs Have an Impact on the Number of CalWORKs Recipients Attending Secondary Educational Activities? from 2012. These are significant reductions triggered by SB 1041. Moreover, the community college atten- dance rate has no correlation with the un- employment rate. When the unemployment rate was the lowest at 4.7%, there were 47,118 CalWORKs students. When the unemployment rate was 6.6% in 2003 there were 40,822 CalWORKs stu- dents. There were 40,671 CalWORKs stu- dents in 2009 when the unemployment rate was the highest at12.3%. Page 2 of 4 Year\/ December UI Rate CalWORKs Recipients in Commu- nity College Unduplicated Participants Potential Student Vulnerable to WtW Sanctions Secondary Education Self Initiated Program Participants Total Education Percentage of Unduplicated Participants in Education 2000 4.7% 47,118 138612 35,946 745 10427 11172 8% 2001 6.4% 40,822 135471 31,644 357 8821 9178 7% 2002 6.8% 43,109 116210 34,446 362 8301 8663 7% 2003 6.6% 40,822 92918 33,153 391 7278 7669 8% 2004 5.8% 39,257 76503 32,579 300 6378 6678 9% 2005 5.1% 34,028 79702 26,508 276 7244 7520 9% 2006 4.9% 27,663 84719 19,174 234 8255 8489 10% 2007 5.8% 27,522 88812 18,804 223 8495 8718 10% 2008 9.2% 37,165 100485 27,332 217 9616 9833 10% 2009 12.3% 40,671 102501 29,738 461 10472 10933 11% 2010 12.2% 39,801 95860 30,516 345 8940 9285 10% 2011 11.2% 36,097 84644 27,357 327 8413 8740 10% 2012 9.7% 31,333 82406 23,238 372 7723 8095 10% 2013 8.3% 30,913 85705 23,874 152 6887 7039 8% 2014 7.2% 89358 141 6036 6177 7% TABLE #1 – Secondary Education Attendance for CalWORKs Recipients CONCLUSION – In reality, the reason why CalWORKs recipients attend or do not attend secondary education has no relationship to the economy. The real reason has everything to do with the administrators of the program controlling who can go to college and who cannot. For all practical purposes, under the current WtW statutory scheme, participants are not given a choice as to what path to embarke on towards self-sufficiency. Putting it bluntly, welfare adminstrators have a father knows best mentality. Source: State Department of Social Services & California Commu- nity Colleges Chancellor’s Office ”

” Evaluation of the SB 1041 Reforms to California’s CalWORKs Welfare-to-Work Program Findings Regarding the Initial Policy Implementation and Outcomes RAND AUTHORS Lois M. Davis, Lynn A. Karoly, Robert Bozick, Diana Catherine Lavery, Dionne Barnes-Proby, Beverly A. Weidmer, Praise Iyiewuare, Jonathan Schweig AIR AUTHORS Gabriele Fain, Sami Kitmitto, Lori Turk-Bicakci, Cheryl Graczewski, Jennifer Anthony, Johannes M. Bos, Kaitlin Fronberg, Marina Castro, Melissa Arellanes, Andrew Horinouchi, Charles Blankenship C O R P O R A T I O N http:\/\/www.rand.org\/pubs\/research_reports\/RR1348.html http:\/\/www.rand.org\/ Limited Print and Electronic Distribution Rights This document and trademark(s) contained herein are protected by law. This representation of RAND intellectual property is provided for noncommercial use only. Unauthorized posting of this publication online is prohibited. Permission is given to duplicate this document for personal use only, as long as it is unaltered and complete. Permission is required from RAND to reproduce, or reuse in another form, any of its research documents for commercial use. For information on reprint and linking permissions, please visit www.rand.org\/pubs\/permissions. The RAND Corporation is a research organization that develops solutions to public policy challenges to help make communities throughout the world safer and more secure, healthier and more prosperous. RAND is nonprofit, nonpartisan, and committed to the public interest. RAND’s publications do not necessarily reflect the opinions of its research clients and sponsors. Support RAND Make a tax-deductible charitable contribution at www.rand.org\/giving\/contribute www.rand.org Library of Congress Cataloging-in-Publication Data ISBN: 978-0-8330-9555-8 For more information on this publication, visit www.rand.org\/t\/RR1348 Published by the RAND Corporation, Santa Monica, Calif. \u00a9 Copyright 2016 RAND Corporation R\u00ae is a registered trademark. http:\/\/www.rand.org\/t\/RR1348 http:\/\/www.rand.org\/pubs\/permissions http:\/\/www.rand.org\/giving\/contribute http:\/\/www.rand.org iii Preface In June 2012, Governor Jerry Brown signed the California Budget Act of 2012, which included a series of budget trailer bills, one of which\u2014Senate Bill (SB) 1041\u2014included significant reforms to California’s Temporary Assistance for Needy Families (TANF) program, known as CalWORKs (California Work Opportunity and Responsibility to Kids). The reforms, effective six months later (in January 2013), included changes to work requirements and the exemption for having a young child, with the goal of engaging CalWORKs participants in more-intensive work-related activities as early as possible. The reforms also provide enhanced supports to address barriers to work, offer more flexibility in work activity options, and increase incentives to work as participants move toward self-sufficiency. To fully understand whether SB 1041 is achieving its objectives and whether there are any unintended consequences, the California legislature required an independent evaluation. Following a competitive bidding process, the California Department of Social Services (CDSS) awarded the evaluation contract to the RAND Corporation, in partnership with the American Institutes for Research (AIR). As described in the evaluation background and study design report, the evaluation design includes five components: The process study addresses questions related to SB 1041 implementation over time using data from interviews with state-level key informants, from annual interviews and focus groups in six focal counties (Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus), and from an annual All-County Survey (ACS) of welfare directors. The county welfare operations impact study relies on the information gathered from the focal counties and the ACS, as well as administrative data from county welfare offices regarding program staffing, budgets, and other matters, to assess the impact of SB 1041 on multiple dimensions of county welfare office operations. The participant status study employs CDSS welfare system administrative data to provide a series of annual snapshots of indicators for the population of CalWORKs participants. The participant tracking study likewise draws on the array of state- and county-level administrative databases to provide a series of annual summaries of the dynamics of the CalWORKs caseload. The participant impact study combines administrative data with the California Socioeconomic Survey (CalSES)\u2014primary data collected over time for a sample of CalWORKs entrants\u2014to investigate the impact of SB 1041 on a range of adult and child outcomes for current and former CalWORKs participants. iv This first evaluation report, following the background and study design report, provides initial findings from the process study based on the first wave of the ACS and qualitative data from interviews and focus groups conducted in the six focal counties. Findings from the status and tracking studies are based on analysis of state administrative data. Initial insights on participant outcomes in terms of welfare use and employment are explored with state administrative data and nationally representative data from the Current Population Survey. Future reports will be based on further qualitative and quantitative data collection, including a second wave of the ACS, additional interviews and focus groups in the focal counties, both state- and county-level administrative data, and the first wave of CalSES. This evaluation report should be relevant for stakeholders in the public and private sectors interested in the CalWORKs program and in the TANF program more generally. Additional background on CalWORKs and the SB 1041 reforms, as well as the evaluation design, is available in the background and study design report: Evaluation of the SB 1041 Reforms to California’s CalWORKs Program: Background and Study Design, by Lynn A. Karoly, Robert Bozick, Lois M. Davis, Sami Kitmitto, Lori Turk-Bicakci, Johannes M. Bos, Aleksandra Holod, and Charles Blankenship, Santa Monica, Calif.: RAND Corporation, RR-919-CDSS, 2015, available at www.rand.org\/pubs\/research_reports\/RR919 The evaluation is being conducted jointly in RAND’s Education and Labor and Population units. At AIR, the study is housed in the Education program with staff from the Human and Social Development program and implemented in AIR’s San Mateo, California, office. Additional information about RAND and AIR is available at www.rand.org and www.air.org, respectively. http:\/\/www.rand.org\/pubs\/research_reports\/RR919 http:\/\/www.rand.org http:\/\/www.air.org v Table of Contents Preface …………………………………………………………………………………………………………………………. iii Figures ………………………………………………………………………………………………………………………… vii Tables …………………………………………………………………………………………………………………………… xi Summary ……………………………………………………………………………………………………………………. xvii Acknowledgments ………………………………………………………………………………………………………. xxxi Abbreviations ………………………………………………………………………………………………………….. xxxiii 1. Introduction ………………………………………………………………………………………………………………… 1 Overview of SB 1041 Policy Changes ……………………………………………………………………………. 3 Other Relevant Background for the SB 1041 Evaluation ………………………………………………… 10 Evaluation Conceptual Framework and Approach …………………………………………………………. 16 Road Map for Report …………………………………………………………………………………………………. 21 2. Sources of Data and Methods ………………………………………………………………………………………. 23 State-Level Key Informant Interviews ………………………………………………………………………….. 24 All-County Survey …………………………………………………………………………………………………….. 26 Focal County Qualitative Data …………………………………………………………………………………….. 29 State Administrative Data …………………………………………………………………………………………… 43 Nationally Representative Survey Data ………………………………………………………………………… 48 3. State-Level Perspectives on Initial Implementation of SB 1041 ……………………………………….. 53 Understanding of the Goals of SB 1041 ……………………………………………………………………….. 54 State-Level Planning Process and Communication Regarding SB 1041 ……………………………. 56 Factors Affecting the Initial Implementation of SB 1041 ………………………………………………… 56 Perceptions Regarding the Potential Long-Term Impact of SB 1041 ……………………………….. 59 4. Initial Implementation of SB 1041 at the County Level: Results from the ACS …………………. 61 Status of Implementation of SB 1041’s Components ……………………………………………………… 64 Organizational Changes Resulting from SB 1041 ………………………………………………………….. 64 Communication Regarding SB 1041 ……………………………………………………………………………. 68 Factors Affecting the Initial Implementation of SB 1041 ………………………………………………… 70 CalWORKs WTW 24-Month Time Clock ……………………………………………………………………. 75 Understanding of Other Components of SB 1041 ………………………………………………………….. 79 Early Engagement Activities ………………………………………………………………………………………. 82 Reengagement Strategies That Counties Identified as Being Effective …………………………….. 87 Counties’ Views Regarding Impact of SB 1041 on CalWORKs Program and Participant Outcomes …………………………………………………………………………………………………………… 88 vi Counties’ Views Regarding the Effectiveness of SB 1041 Reforms and Related Mandates at County Level ……………………………………………………………………………………………………… 89 Counties’ Additional Information Needs and Suggestions for Improving SB 1041 ……………. 92 5. A Six-County Perspective on Initial Implementation of SB 1041 …………………………………….. 98 Communication About and Planning for SB 1041 ……………………………………………………….. 100 Initial Implementation of SB 1041 ……………………………………………………………………………… 105 Work Participation Rate ……………………………………………………………………………………………. 118 Understanding of SB 1041 ………………………………………………………………………………………… 122 Early Engagement Activities …………………………………………………………………………………….. 128 County Perceptions of the Impact of SB 1041 ……………………………………………………………… 133 6. Initial Descriptive Analyses for Status and Tracking Studies …………………………………………. 137 CalWORKs WTW Participant Demographics ……………………………………………………………… 140 CalWORKs WTW Participant Counts for Status and Tracking Studies ………………………….. 142 Time on Aid and WTW Time Clock ………………………………………………………………………….. 143 Exemptions and Sanctions ………………………………………………………………………………………… 145 Leaving the WTW Program ………………………………………………………………………………………. 148 Employment and Earnings ………………………………………………………………………………………… 150 Reengagement …………………………………………………………………………………………………………. 153 7. Initial Descriptive Analyses for the Impact Study ………………………………………………………… 157 Analyses of State Administrative Data ……………………………………………………………………….. 159 Analyses of CPS Data ………………………………………………………………………………………………. 168 8. Conclusions and Policy Implications ………………………………………………………………………….. 177 Summary of Key Findings ………………………………………………………………………………………… 177 Implications and Issues to Examine in the Next Phase of the Evaluation ………………………… 183 Appendix A. Understanding How the CalWORKs Program Functions ………………………………. 187 Reengagement of Parents Who Had Previously Been Subject to the Young Child Exemption ………………………………………………………………………………………………………… 187 Appendix B. Additional Documentation for Primary Data Collection ………………………………… 197 Appendix C. Additional Documentation for Administrative Data ………………………………………. 247 Appendix D. Additional Results for Chapter Four ACS Analyses ……………………………………… 255 Appendix E. Additional Documentation for Chapter Six Status and Tracking Studies Analyses ……………………………………………………………………………………………………………….. 277 Appendix F. Additional Documentation for Chapter Seven Impact Study Analyses …………….. 283 References ………………………………………………………………………………………………………………….. 309 vii Figures 1.1. California Monthly Caseload and Monthly Unemployment Rate: State Fiscal Years 1995 to 2015 ………………………………………………………………………………………………………….. 12 1.2. CalWORKs Caseload by Family Type: 1999 to 2014 ………………………………………………….. 13 1.3. SB 1041 Evaluation Conceptual Framework ………………………………………………………………. 17 2.1. Map of Six Focal Counties for SB 1041 Evaluation …………………………………………………….. 29 2.2. Map of Eligible Zip Codes for Recruiting Focus Group Participants in Riverside’s Hemet Office …………………………………………………………………………………………………………. 37 4.1. Organizational or Administrative Changes in Response to SB 1041 or Related Legislation: All Counties and by County Caseload Size ………………………………………………. 66 4.2. County Communication of SB 1040’s Changes: All Counties and by County Caseload Size …………………………………………………………………………………………………………. 68 4.3. Coordination Activities County Social Services Departments Undertook to Plan for or Implement SB 1041: All Counties and by County Caseload Size …………………………………. 69 4.4. Communication of SB 1041’s Changes by Supervisors to CalWORKs Line Staff: All Counties and by County Caseload Size ……………………………………………………………………… 70 4.5. Who Is Responsible for Calculating How Much Time CalWORKs Participants Have Left on Their 24-Month Time Clock: All Counties and by County Caseload Size ………….. 77 5.1. Communication About and Planning for SB 1041 ……………………………………………………… 101 5.2. Initial Stage of SB 1041: Reengagement and Young Child Exemption ………………………… 106 5.3. Major Caseworker 24-Month Time Clock Responsibilities …………………………………………. 108 5.4. CalWORKs WTW 24-Month Time Clock Hourly Work Participations Requirements Flow Chart …………………………………………………………………………………………………………… 109 6.1. Number of CalWORKs WTW Participants and Unemployment Rate: 2006 to 2015 ……… 140 6.2. Percentage of CalWORKs WTW Participants by Gender and by Race\/Ethnicity: 2015 ….. 141 6.3. Percentage of CalWORKs WTW Participants in the Transitional Group and Post SB Group: Status Cross-Sections in March 2013, March 2014, March 2015 ………………………………… 142 6.4. Number of New CalWORKs WTW Participants: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………………………………………………… 143 6.5. Average Number of Months of Participation, Counted on the 48-Month Time-on-Aid Clock, and Counted on the 24-Month Time Clock Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………….. 145 6.6. Percentage of Participants Who Had an Exemption or Sanction that Stopped the Clock: Status Cross-Sections and Transitional and Post SB 1041 Groups in March 2013, March 2014, March 2015 ……………………………………………………………………. 147 viii 6.7. Percentage of Participants Who Had at Least One Exemption or at Least One Sanction That Stopped the Clock Within Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 ………………………………………………………………………………………………….. 148 6.8. Percentage of Participants Who Left the WTW Program One Year and Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 ……………………………………… 149 6.9. Percentage of Participants Who Were Employed: Status Cross-Sections and Transitional and Post SB 1041 Groups in March 2013, March 2014, March 2015 ……….. 151 6.10. Average Real Quarterly Earnings of All Participants Who Were Employed: Status Cross-Sections in March 2013, March 2014, March 2015 ………………………………………….. 151 6.11. Percentage of Participants Who Were Employed for at Least One Quarter in the Subsequent Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 ……. 152 6.12. Percentage of Participants Who Had Continuous Employment During the First Year and During the Second Year After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………………………………………………… 153 6.13. CalWORKs WTW Participant Status Among Those with the Short-Term WTW Exemption for Young Children in December 2012: March 2013, March 2014, March 2015 ………………………………………………………………………………………………………….. 155 7.1. Average County Unemployment Rate ………………………………………………………………………. 161 7.2. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Employed One Year After CalWORKs WTW Entry ………………………………… 162 7.3. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Participating in CalWORKs WTW One Year After CalWORKs WTW Entry …………………………………………………………………………………………………………. 163 7.4. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Employed Only (Not Participating in CalWORKs) One Year After CalWORKs Entry …………………………………………………………………………………………………. 164 7.5. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Both Employed and Participating in CalWORKs One Year After CalWORKs Entry …………………………………………………………………………………………………. 165 7.6. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Participating in CalWORKs Only (Not Employed) One Year After CalWORKs Entry …………………………………………………………………………………………………. 166 7.7. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Neither Employed Nor Participating in CalWORKs One Year After CalWORKs Entry …………………………………………………………………………………………………. 167 7.8. Change Associated with SB 1041 in Real Quarterly Earnings of CalWORKs WTW Entrants One Year After CalWORKs Entry ……………………………………………………………… 168 7.9. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Living Below the Federal Poverty Line …………………………………………………………………… 170 ix 7.10. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Living Below 125 Percent of the Federal Poverty Line ……………………………………………… 170 7.11. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Receiving Any Form of Public Assistance ………………………………………………….. 171 7.12. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Receiving TANF ……………………………………………………………………………………… 172 7.13. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Unemployed in March ……………………………………………………………………………… 173 7.14. Number of Annual Weeks Employed Full Time Among Families Potentially Eligible for the CalWORKs WTW Program ……………………………………………. 174 7.15. Percentage of Family Heads Potentially Eligible for the CalWORKs WTW Program Enrolled in School in October …………………………………………………………. 175 7.16. Percentage of Family Heads Potentially Eligible for the CalWORKs WTW Program Participating in Job Training in October …………………………………………… 176 A.1. Federal OWRA …………………………………………………………………………………………………….. 192 A.2. Assessment of WTW Participants’ Barriers and Needs (Pre AB 74) …………………………… 193 A.3. California OCAT (Post AB 74) ……………………………………………………………………………… 194 F.1. Example of Placebo Tests with Synthetic Control Group Method ……………………………….. 293 xi Tables S.1. Summary of Key Findings ………………………………………………………………………………………. xxi 1.1. Overview of Key SB 1041 Policy Changes Effective January 1, 2013 …………………………….. 4 1.2. Relationship Between Overall Study Questions and Five Study Components …………………. 20 2.1. Evaluation Components and Sources of Data ……………………………………………………………… 23 2.2. State-Level Types of Informants and Interview Topics ………………………………………………… 25 2.3. Characteristics of Focal Counties and California as a Whole ………………………………………… 31 2.4. County-Level Types of Informants and Interview Topics …………………………………………….. 32 2.5. Number of Caseworkers Who Were Contacted and Participated in the Focus Groups, by County ………………………………………………………………………………………………………………….. 35 2.6. Summary of Participant Focus Group Recruitment and Participation …………………………….. 39 2.7. Reasons Contacted CalWORKs Participants Were Not Eligible for a Focus Group …………. 40 2.8. Reasons Eligible CalWORKs Participants Were Not Scheduled for a Focus Group ………… 40 2.9. CalWORKs 2015 Focus Group Participants’ Self-Reported Characteristics, Overall and by County ………………………………………………………………………………………………………… 41 2.10. Sources of State Administrative Data ……………………………………………………………………….. 44 4.1. Status of Implementation of SB 1041 Components and Related Mandates by June 2015: All Counties and by County Caseload Size ………………………………………………………………… 65 4.2. Whether Timing of State Guidance on SB 1041 to Counties Hindered Implementation: All Counties and by County Caseload Size ………………………………………………………………… 71 4.3. Whether Complexity of SB 1041 Reforms Hindered Implementation: All Counties and by County Caseload Size …………………………………………………………………………………… 71 4.4. Whether Issues Hindered Implementation: All Counties and by County Caseload Size ……. 72 4.5. Whether Existing Relationships or Partnerships with Organizations or Providers Facilitated Implementation: All Counties and by County Caseload Size ……………………….. 74 4.6. System Used for Calculating 24-Month Time Clock: All Counties and by County Caseload Size …………………………………………………………………………………………………………. 76 4.7. Whether Lack of Automation of the CalWORKs WTW 24-Month Time Clock Hindered Implementation: All Counties and by County Caseload Size …………………………. 76 4.8. Supervisors’ Assessment of How Well WTW Caseworkers Understand Three Key SB 1041 Policy Changes: All Counties and by County Caseload Size …………………………… 78 4.9. Supervisors’ Assessment of How Well CalWORKs Participants Understand the 24-Month Time Clock: All Counties and by County Caseload Size ………………………………. 80 4.10. Supervisors’ Assessment of How Well WTW Caseworkers Understand Other SB 1041 Changes and Related Supports: All Counties ……………………………………………………………… 81 xii 4.11. Supervisors’ Assessment of How Well CalWORKs Participants Understand SB 1041 Changes: All Counties …………………………………………………………………………………………….. 82 4.12. Participation in the ESE Program: All Counties and by County Caseload Size ……………… 83 4.13. Among Counties with an ESE Program, Those That Contract Out ESE Services: Overall and by County Caseload Size ……………………………………………………………………….. 83 4.14. Among Counties with an ESE Program, Program Options Offered: Overall and by County Caseload Size ……………………………………………………………………………………………… 84 4.15. Services Currently Offered as Part of the FS Program: Overall and by County Caseload Size …………………………………………………………………………………………………………. 85 4.16. Staffing Changes Made Specifically to Accommodate the FS Program: Overall and by County Caseload Size …………………………………………………………………………………… 86 4.17. Counties’ Assessment of Effective Reengagement Strategies for Exempt Individuals: All Counties and by County Caseload Size ………………………………………………………………… 87 4.18. Counties’ Assessment of the Effect of SB 1041’s Implementation on Outcomes: All Counties …………………………………………………………………………………………………………… 89 4.19. Counties’ Assessment of How Well Aspects of SB 1041 and Related Mandates Are Working: All Counties ……………………………………………………………………………………………. 90 4.20. Counties’ Information Needs and Recommendations for Improving SB 1041: 24-Month Time Clock …………………………………………………………………………………………….. 93 4.21. Counties’ Information Needs and Recommendations for Improving SB 1041: Aligning Federal and State Requirements ………………………………………………………………….. 95 4.22. Counties’ Information Needs and Recommendations for Improving SB 1041: Early Engagement Activities …………………………………………………………………………………………….. 96 4.23. Counties’ Information Needs and Recommendations for Improving SB 1041: Pace of Implementation and Other Comments ………………………………………………………………………….. 97 5.1. CalWORKs Federal and WTW Requirements …………………………………………………………… 118 5.2. ESE Program Designs, by County ……………………………………………………………………………. 132 6.1. Research Questions Addressed by Status Study and Tracking Study ……………………………. 139 8.1. Summary of Key Findings ………………………………………………………………………………………. 178 A.1. Comparison of CalWORKs Welfare-to-Work 24-Month Time-Clock Activities and Federal Work Activities ………………………………………………………………………………………… 189 B.1. Comparison of Characteristics of CalWORKs WTW Participants Sampled for, Eligible for, and Attending Focus Groups ………………………………………………………………… 198 C.1. Summary of CalWORKs WTW Administrative Data Cohorts and Participant Groups Examined for Status, Tracking, and Impact Studies ………………………………………………….. 250 C.2. CDSS Aggregated Reports and Other Administrative Data ………………………………………… 252 C.3. Expected Sources of Data ………………………………………………………………………………………. 253 D.1. Whether Issues Hindered Implementation: All Counties and by County Caseload Size …. 256 xiii D.2. Whether Existing Relationships or Partnerships with Organizations or Providers Facilitated Implementation: All Counties and by County Caseload Size ……………………… 259 D.3. Supervisors’ Assessment of How Well WTW Caseworkers Understand Other SB 1041 Changes and Related Supports: All Counties and by County Caseload Size ……. 261 D.4. Supervisors’ Assessment of How Well CalWORKs Participants Understand SB 1041 Changes: All Counties and by County Caseload Size …………………………………… 263 D.5. Counties’ Assessment of the Effect of SB 1041’s Implementation on Outcomes: All Counties and by County Caseload Size ……………………………………………………………………… 264 D.6. Counties’ Assessment of How Well Aspects of SB 1041 and Related Mandates Are Working: All Counties and by County Caseload Size ……………………………………………….. 266 D.7. How Employment-Related Services Are Provided to CalWORKs Participants: All Counties ………………………………………………………………………………………………………………. 270 D.8. How Education- and Training-Related Services Are Provided to CalWORKs Participants: All Counties ………………………………………………………………………………………. 271 D.9. How Supportive Services Are Provided to CalWORKs Participants: All Counties ……….. 272 D.10. Assessment of Capacity Shortfalls for Provision of Employment-Related Services for CalWORKs Participants: All Counties ……………………………………………………………….. 273 D.11. Assessment of Capacity Shortfalls for Provision of Education- and Training-Related Services for CalWORKs Participants: All Counties ………………………………………………….. 274 D.12. Assessment of Capacity Shortfalls for Provision of Supportive Services for CalWORKs Participants: All Counties ……………………………………………………………………. 275 E.1. Number of CalWORKs WTW Participants and Unemployment Rate: 2006 to 2015 ……… 277 E.2.a. Number and Percentage of CalWORKs WTW Participants by Gender and by Race\/Ethnicity: 2007, 2009, 2011, 2013, 2015 …………………………………………………………. 277 E.2.b. Median Age of CalWORKs WTW Participants: 2007, 2009, 2011, 2013, 2015 …………. 278 E.3. Number and Percentage of CalWORKs WTW Participants in the Transitional Group and Post SB Group: Status Cross-Sections in March 2013, March 2014, March 2015 ….. 278 E.4. Number of New CalWORKs WTW Participants: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………………………………………………… 278 E.5. Average Number of Months of Participation, Counted on the 48-Month Time-on-Aid Clock, and Counted on the 24-Month Time Clock Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………….. 278 E.6. Number and Percentage of Participants Who Had an Exemption or Sanction That Stopped the Clock: Status Cross-Sections and Transitional and After SB 1041 Groups in March 2013, March 2014, and March 2015 ………………………………………………………….. 279 E.7. Number and Percentage of Participants Who Had at Least One Exemption and at Least One Sanction Within Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 ……………………………………………………………………………………………………………………. 279 xiv E.8. Number and Percentage of Participants Who Left the WTW Program One Year and Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………….. 280 E.9. Number and Percentage of Participants Who Were Employed: Status Cross-Sections and Transitional and After SB 1041 Groups in March 2013, March 2014, March 2015 … 280 E.10. Average Real Quarterly Earnings of All Participants Who Were Employed: Status Cross-Sections in March 2013, March 2014, March 2015 ………………………………………….. 280 E.11. Number and Percentage of Participants Who Were Employed for at Least One Quarter in the Subsequent Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 …………………………………………………………………………………………………………. 281 E.12. Number and Percentage of Participants Who Had Continuous Employment During the First Year and During the Second Year After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 ………………………………………………………………………………………………….. 281 E.13. CalWORKs Participant Status Among Those with the Short-Term WTW Exemption for Young Children in December 2012: March 2013, March 2014, March 2015 …………… 281 F.1. Employment and CalWORKs WTW Participation of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment ………………………. 283 F.2. Employment and CalWORKs WTW Participation of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment, Four Mutually Exclusive Categories …………………………………………………………………………………………….. 284 F.3. Average Unemployment Rate Across Counties of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment ………………………. 284 F.4. Percentage of First-Time CalWORKs WTW Participants Employed and Participating in CalWORKs WTW in the Fourth Quarter After CalWORKs WTW Enrollment, with Controls ……………………………………………………………………………………………………….. 286 F.5. Percentage of First-Time CalWORKs WTW Participants Employed and Participating in CalWORKs WTW in the Fourth Quarter After CalWORKs WTW Enrollment, Four Mutually Exclusive Categories, with Controls ………………………………………………….. 287 F.6. Real Quarterly Earnings for First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment …………………………………………………………… 288 F.7. Real Quarterly Earnings for First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment, with Controls ……………………………………… 289 F.8. Pretreatment Covariates Used in Synthetic Comparison Group Analyses …………………….. 295 F.9. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Living Below the Poverty Line ……………………………………………………… 296 F.10. Pre-Treatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Living Below 125 Percent of the Poverty Line …………………. 296 F.11. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Living Below the Poverty Line ……………………………………………… 297 xv F.12. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Living Below 125 Percent of the Poverty Line …………………. 297 F.13. Estimate of Differences Between California and Comparison Groups States with Corresponding 95-Percent Confidence Intervals for Poverty Outcomes ………………………. 298 F.14. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Receiving Any Form of Public Assistance ………………………. 299 F.15. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Receiving TANF ………………………………………………………….. 300 F.16. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Receiving Any Public Assistance ………………………………………….. 300 F.17. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Receiving TANF ………………………………………………………….. 301 F.18. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for Public Assistance Outcomes ……………………………………… 301 F.19. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Unemployed in March …………………………………………………… 302 F.20. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Number of Weeks Employed Full-Time ………………………………………….. 303 F.21. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Unemployed in March …………………………………………………… 304 F.22. Comparison Group States and Their Associated Weights for Comparisons with California in the Number of Weeks Employed Full-Time ………………………………………….. 304 F.23. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for Employment Outcomes ……………………………………… 305 F.24. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Enrolled in School in October ………………………………………… 306 F.25. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Participating in Job Training ………………………………………….. 306 F.26. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Enrolled in School in October ………………………………………… 307 F.27. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Participating in Job Training ………………………………………….. 307 F.28. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for School and Training Outcomes …………………………… 308 xvii Summary Senate Bill (SB) 1041, signed into law in June 2012, specified a package of policy changes for California’s Temporary Assistance for Needy Families (TANF) program\u2014known as CalWORKs (California Work Opportunity and Responsibility to Kids)\u2014which is overseen by the California Department of Social Services (CDSS) and operated by county welfare offices in the state’s 58 counties. Most of the SB 1041 provisions became effective January 1, 2013, although implementation may have started later, and the law scheduled other features to be phased in over time. As part of an independent evaluation required by the SB 1041 legislation, this report provides a first look at the process of implementing the policy changes at the state and county level, the extent to which key indicators for CalWORKs participants changed between the pre and post SB 1041 period, and initial analyses of outcomes for families and children and their association with the SB 1041 policy changes. SB 1041 Policy Changes to CalWORKs The SB 1041 reforms included changes to work requirements and the exemption for having a young child, with the goal of engaging CalWORKs participants in welfare-to-work (WTW) activities as early as possible. The reforms also aimed to provide more flexibility in work activity options and increased financial incentives as participants move toward self-sufficiency. Specifically, key features of the policy change include: New time clock. The 48-month lifetime limit for CalWORKs receipt was divided into two periods: the first 24 months, when a set of flexible CalWORKs WTW services and other supports are available, and the second 24 months, when more-restrictive CalWORKs federal standards for work activities apply. Nature of WTW services. During the first 24 months of benefit receipt, there are no required core activities\u2014those that meet federal work participation requirements, such as employment, on-the-job training, and vocational educational training\u2014a more flexible option than under prior CalWORKs rules. Work requirements for those with young children. The weekly hours of required work were reduced from 32 hours to 20 hours for those whose youngest child is below the age of six. All other single-parent cases had a small drop in the work requirement, from 32 to 30 hours. Young child exemption. The prior temporary young child exemption\u2014which excused one adult per family from WTW work participation requirements while caring for one child below the age of two years or two children below the age of six\u2014was replaced by a new once-in-a-lifetime exemption from WTW requirements to care for a child from birth to xviii age 23 months. CalWORKs participants with a young child exemption as of December 31, 2012, were not subject to the SB 1041 WTW requirements (and the time clock would not start) until the county reengaged them (required by January 1, 2015), a process that involved communicating the policy change and initiating the WTW services component if they were no longer eligible for the young child exemption. Financial work incentive. The size of the earned income disregard (the income excluded when calculating the benefit level) was increased to $225, restoring it to the level that existed prior to cuts in 2011 in response to the Great Recession. Supports for pregnant and parenting teens. The Cal-Learn program, after suspension of the case management component, was fully restored and allowed to resume its specialized services supporting pregnant and parenting teens. Together, the bundle of SB 1041 policy changes emphasized moving participants through CalWORKs by intensifying their engagement with WTW activities early on\u2014in the first two years of participation\u2014and providing flexible, meaningful work activity options and supportive services during that period designed to enhance their ability to secure stable, gainful employment. It is important to note that three other policy changes, signed into law in June 2013 under Assembly Bill (AB) 74, were intended to support the policy objectives under SB 1041 and thus are relevant for the implementation research conducted for this evaluation. In particular, the following Early Engagement strategies were instituted to identify and address barriers to employment more rapidly: Online CalWORKs Appraisal Tool (OCAT). CDSS was charged with developing a new standardized online appraisal tool for use by county welfare departments to screen new CalWORKs WTW participants and more effectively identify and address barriers to employment. Family Stabilization (FS) program. AB 74 (2013) included provisions to identify CalWORKs WTW participants in need of intensive case management and services designed to support the family in overcoming an identified situation or crisis that would interfere with participation in WTW activities and services. Expanded Subsidized Employment (ESE) program. AB 74 added funds to expand the number of subsidized employment slots available to CalWORKs WTW participants. Evaluation Objectives and Approach To fully understand whether SB 1041 is achieving its objectives and whether there are any unintended consequences, RAND and AIR are conducting a multiyear evaluation with five component studies drawing on both qualitative and quantitative data: a process study to address questions related to the implementation of SB 1041; a participant status study and a participant tracking study to examine point-in-time and dynamic indicators for the CalWORKs population xix both before and after the SB 1041 changes; a county welfare operations impact study to assess the consequences of SB 1041 for various aspects of county welfare office operations; and a participant impact study to investigate the effects of the SB 1041 policy changes on a range of adult and child outcomes for current and former CalWORKs WTW participants. The evaluation is guided by a conceptual framework that, like a logic model, shows how the implementation of the policy changes links to a set of outputs and finally an array of desired impacts on child and family well-being. The evaluation framework serves to illustrate that whether the reforms achieve their intended effect will depend on a number of factors. First, as part of implementation of SB 1041, state-level officials, county welfare office administrators, and county welfare office staff must successfully communicate the new policy internally and to prospective and current CalWORKs participants. Second, some counties may need to reorganize staff or shift resources among competing priorities to successfully implement the reforms. Further, the sequential nature of the implementation steps means that the pace at which the reforms are instituted may affect how quickly changes occur in county welfare operations or in the outcomes that participants experience. Third, the reforms are expected to affect the experience of CalWORKs applicants and participants. Individuals are expected to apply for CalWORKs and, if eligible, receive assistance, develop a WTW plan, and participate in WTW activities. All of these potential implications of the SB 1041 reforms are occurring in concert with other policy changes\u2014and many other factors, such as the state of the economy, also might affect the outcomes of interest. The analytic challenge is drawing inferences about the causal impacts of the SB 1041 reforms when these other factors are not constant. Hence, for the impact analyses conducted for this evaluation, we adopt empirical strategies to control for possible confounding factors. This report, based on data available or collected during the first year of the evaluation, addresses four of the five evaluation components (all but the county welfare operations impact study). The primary focus in this initial report is on findings from the process study, which is based on qualitative and quantitative information collected at the state level for all 58 counties plus additional information from six focal counties where more in-depth data-gathering was conducted. The data collected and examined for the process study cover the first two and a half years of the implementation of SB 1041. Together, these rich data offer a statewide perspective on the status of implementation, as well as an in-depth view of implementation in the six focal counties, which represent 64 percent of the CalWORKs caseload. This information is extremely valuable for understanding the pace of implementation, how counties have approached the policy and process changes adopted under SB 1041, and the opportunities for addressing any challenges encountered to date. In addition, this report includes analyses based on several other sources of data that contribute to other study components. Specifically, we analyze state administrative data to address questions pertaining to the status and tracking studies. The state-level data systems capture key indicators for CalWORKs WTW participants such as time clock status, exemptions and sanctions, and employment. We also employ the state administrative data, as well as xx nationally representative survey data, to conduct analyses of the patterns in the outcomes of interest, in advance of more-rigorous impact analyses that could not be conducted with the data available for this report. These initial impact study analyses provide an early assessment of the potential impact of SB 1041 on CalWORKs participants, specifically for outcomes such as CalWORKs participation, employment, and poverty status. We stress the tentative nature of these initial findings given that the data cover just one to two years of the post SB 1041 period, thus providing only a very short-term assessment of impact. Future evaluation reports will extend the administrative data we are able to examine and augment the primary data assembled for this report with additional waves of qualitative and quantitative data collection. These data will then support more-rigorous analyses of outcomes as part of the impact study. In the remainder of this summary, we highlight the key findings associated with the four component studies. Table S.1 provides a high-level summary of the findings. Experience with Implementation of SB 1041 Our findings regarding the implementation of SB 1041 are based on information gathered from the following sources: interviews with state-level key informants, such as representatives from CDSS and other relevant state agencies, legislative staff involved in the formulation of SB 1041, relevant associations, and other stakeholder groups the first wave of the All-County Survey (ACS), an online survey of the state’s 58 county welfare directors where we obtained a 100 percent response rate key informant interviews and focus groups with caseworkers and CalWORKs participants conducted in six focal counties\u2014Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus\u2014which were selected to capture variation that is potentially relevant for the implementation of SB 1041, such as the geographic region of the state, the rural-to-urban continuum, the demographic makeup of the population, measures of socioeconomic status, and the state of the economy. Triangulating across these multiple sources and perspectives, Table S.1 shows that we have findings on numerous topics related to the implementation of SB 1041. Next, we highlight the most salient findings among those listed in Table S.1. State- and county-level stakeholders had varied views regarding the goals and objectives of SB 1041. Some state-level stakeholders were concerned that many CalWORKs WTW participants would be unprepared to meet federal work requirements after exhausting their 24-month time clock. County administrative and line staff (e.g., caseworkers, employment services specialists) also said SB 1041 was a significant change to the CalWORKs WTW program that required a number of adjustments to be made. CDSS staff emphasized that the legislation is intended to offer more flexibility to clients in their progress toward self-sufficiency. xxi Table S.1. Summary of Key Findings Topic Key Findings Process Study Analyses Stakeholders’ views of SB 1041 State-level stakeholders’ perspectives regarding the goals and expected impact of SB 1041 differed, with some viewing it as well motivated with the potential for positive change, while others were more concerned about potential negative consequences. State planning for and communication regarding SB 1041 As required by the legislation, CDSS implemented a state-level workgroup process to develop implementation guidance for SB 1041, which was characterized as positive and inclusive by stakeholders. Communication of policy with the counties occurred primarily through All County Letters (ACLs). However, the intensive and lengthy planning process contributed to the slow release of guidance to the counties, creating implementation challenges at the local level. County planning for and communication regarding SB 1041 Interagency or interdepartmental meetings were the primary county vehicles for communication with other agencies. Three-quarters of all county social services departments reported reaching out to individual directors or agency representatives in other county agencies to plan for or implement support services under SB 1041. County communications with line staff occurred through memoranda and other written documents (81 percent of all counties), briefings and\/or internal staff meetings (93 percent of counties), and mandatory training sessions (83 percent of counties). County staff communicated with participants about the changes that were brought about under SB 1041 primarily through in-person discussions, phone calls, and letters. Status of SB 1041 implementation as of June 2015 Across the 58 counties, most have completed the reengagement of participants with the short- term young child exemption. Eighty-six percent reported having implemented the FS program countywide, and 69 percent reported they had implemented the ESE program countywide. To increase supportive services, up to 60 percent of all the counties reported developing new or enhanced partnerships with education providers, vocational education\/job training providers, domestic violence service providers, substance abuse treatment providers, and mental health service providers. Across the focal counties, staff did not report significant reorganization of staff structures or roles in order to implement SB 1041, although they did emphasize that the reengagement process was labor intensive and SB 1041 as a whole has required a strong focus on training and support for caseworkers. Caseworkers’ and staff understanding of SB 1041 Compared with other SB 1041 components, a higher percentage of all counties (18 percent) reported that their WTW caseworkers did not understand at all or only slightly understood the new WTW 24-month time clock; 16 percent of counties indicated their WTW caseworkers did not understand at all or only slightly understood the changes to the determination of hourly program participation. Caseworkers who participated in focal county focus groups expressed a significant amount of confusion regarding SB 1041 and identified the WTW 24-month time clock as the most challenging component of the legislation, including the way in which time elapses (when the clock should tick and untick ). CalWORKs participants’ understanding of SB 1041 According to the ACS, the WTW 24-month time clock is the SB 1041 feature that is understood the least by participants. Supervisors in 67 percent of counties reported that CalWORKs participants did not understand at all or only slightly understood the changes represented by the WTW 24-month time clock. By comparison, 71 percent of all counties rated CalWORKs participants’ understanding of the reengagement process for those who had a short-term young child exemption as moderately to very well understood. Likewise, administrators and caseworkers in all six focal counties reported that there are still many participants who do not fully understand the implications of SB 1041, including where they land within the WTW 24-month time clock period. Stakeholders’ view of factors that can support or hinder implementation According to many state-level stakeholders external to CDSS, the benefits of SB 1041 will not be fully realized until the accompanying Early Engagement reforms\u2014the OCAT, FS program, and ESE program\u2014are fully implemented on a statewide basis. Tension between promoting SB 1041 and meeting federal Work Participation Rate (WPR) requirements was viewed as another potential barrier, a theme that was also present in the focal county discussions on the topic. xxii Table S.1\u2014Continued Topic Key Findings Process Study Analyses (continued) County experiences with factors that can support or hinder implementation Focal counties reported that participation in the state-level workgroup process and discussions better positioned them to begin planning early for SB 1041. Implementation was challenging, given other concurrent policy changes (e.g., Medicaid expansion). Forty-five percent of all counties indicated that existing relationships with other county agencies facilitated implementation. Interagency committees and advisory groups were rated as helpful. Twenty-one percent of all counties reported that the timing of the release of state guidance on SB 1041 was a moderate or major hindrance to implementation; with smaller counties being more likely to provide this rating. Seventy-nine percent of counties reported that explaining the complexity of SB 1041 to participants was a moderate or major hindrance. Given the complexity of the WTW 24-month time clock, the lack of full automation of the time clock was viewed as a hindrance to implementation, especially for smaller counties. Overall, 60 percent of all counties reported that the WTW 24-month time clock is being calculated using both an automated system (e.g., for an initial calculation) and manually (e.g., to make needed adjustments), typically by caseworkers (93 percent of counties). The latter was more common for smaller counties. For 83 percent of all counties, caseworker supervisors reported that their WTW caseworkers understood the WTW 24-month time clock moderately well to very well. At the same time, many caseworkers in the six focal counties indicated a poor understanding of the WTW 24- month time clock. The lag between implementation of SB 1041 and upgrading the county-level consortia administrative data systems to meet the needs of the legislation was a source of frustration for county leaders and caseworkers in the focal counties. County perceptions of SB 1041 reforms and their impact With such aspects as communications with participants; matching participants to WTW activities; provision of support services (e.g., child care, substance abuse, mental health); and coordination with other organizations in the public and private sector (e.g., community colleges, vocational education, other service providers, employers, and job training), a majority of counties consistently rated SB 1041 implementation as working moderately well to very well. This positive view of implementation also held for reengagement, tracking WTW participation, information management, and design and implementation of the ESE and FS programs. Between 45 percent and 57 percent of all counties estimated that the implementation of SB 1041 in the early years had no effect on WPR, participation in WTW activities, compliance with CalWORKs program rules, earnings, participation in CalFresh, or the number of participants receiving sanctions. At the same time, between 36 percent and 40 percent of counties reported that participation in WTW activities and enrollment in education and training programs\/ community colleges were somewhat better under SB 1041. Coordination with other public and private service providers at county level Three-quarters of all county social services departments reported reaching out to individual directors or agency representatives in other county agencies to plan for or implement support services under SB 1041. Concerns voiced by service providers in the focal counties regarding SB 1041 were similar to those identified by caseworkers\u2014that SB 1041 was complicated and difficult to understand. Education service providers in the focal counties (e.g., CalWORKs counselors on community college campuses) also noted that they had not observed the rate of referrals to education that they had expected, given the flexibility in activities afforded by SB 1041. State-level stakeholders’ view of potential long- run impact of SB 1041 Stakeholders in CDSS and other state-level agencies and organizations expressed the potential for SB 1041 to positively change how clients experience their initial engagement with CalWORKs, the activities available to them, and their relationships with caseworkers. However, stakeholders noted that it is still too early to determine whether or not SB 1041 will have the intended effect of helping clients to overcome their unique barriers to self-sufficiency. xxiii Table S.1\u2014Continued Topic Key Findings Status and Tracking Studies Initial Descriptive Analyses Exemptions The percentage of participants who received at least one exemption during their first two years in the CalWORKs WTW program increased from the March 2007 entry cohort to the March 2013 entry cohort, from 44 percent to 56 percent. Annual snapshots of all WTW participants since SB 1041 became effective\u2014in March of 2013, 2014, and 2015\u2014showed that, at a point in time, about four out of ten participants had an exemption. Sanctions The percentage of participants who received at least one sanction during their first two years in CalWORKs stayed about the same from the March 2007 entry cohort to the March 2013 entry cohort (around 14 percent). Yearly snapshots since SB 1041 became effective showed that, in a given March, fewer than one out of ten participants were currently sanctioned. Leaving CalWORKs The percentage of participants who were not in the CalWORKs WTW program one year after entry did not change from the 2007 to 2013 entry cohorts (about 54 percent), while the percentage of participants who were not in the CalWORKs WTW program two years after entry increased from 63 percent for the 2007 entry cohort to 70 percent for the 2013 entry cohort. Employment and earnings A larger percentage of the March 2013 entry cohort was employed for at least one quarter in their first two years after entry compared with the March 2007 entry cohort (64 percent versus 52 percent). For the March 2015 cross-section, participants’ real earnings (i.e., adjusted for inflation) were about $2,300 per quarter on average, an 11-percent increase compared with the March 2013 cross-section. Reengagement Among the participants who had the short-term WTW exemption for young children in December 2012, 14 percent still had this exemption in March 2014 and almost none had it in March 2015. Impact Study Initial Descriptive Analyses CalWORKs receipt, employment, and earnings Initial estimates based on state CalWORKs administrative data that account for participant characteristics and county unemployment rates suggest that persons entering CalWORKs in the post SB 1041 period had WTW participation rates one year after enrollment about 2 percentage points higher than similar CalWORKs WTW participants who enrolled before the reforms. This rise in WTW participation was because participants were combining employment and WTW participation more often (an increase of about 2 percentage points) rather than being employed without participating (a decrease of about 2 percentage points) compared with similar participants who started before SB 1041. When we accounted for changes in the economy and in the demographics of CalWORKs WTW participants, the level of quarterly real earnings among CalWORKs WTW participants one year after enrollment was about $54 higher (4.2 percent) than predicted. These findings are consistent with the increase in the earned income disregard, which was one aspect of SB 1041 that was implemented immediately. Other outcomes Estimates based on the Current Population Survey (CPS) provide no indication that, in the first year after SB 1041 was implemented, outcomes for the population potentially eligible for the CalWORKs WTW program\u2014such as income below poverty, school enrollment, or receipt of job training\u2014have changed relative to a comparison group in other states with similar policies and demographics as California. Delays in developing and releasing implementation guidelines resulted in implementation and training issues for county-level staff. CDSS implemented a state-level workgroup process to develop implementation guidance for SB 1041; however, the intensive planning process contributed to the slow release of guidance to the counties, creating implementation challenges at the local level. Implementation policies from the state were released slowly, and\u2014according to county staff\u2014often confusing or contradictory. This led to challenges in training staff on SB 1041 and to confusion among administrative and line staff in regard to the different components of SB 1041 (particularly related to calculation of the WTW xxiv 24-month time clock). Training for caseworkers on SB 1041 was described as difficult, given the continual release of state guidance to clarify components of the reforms and evolving guidance over time. The ACS indicated that for 21 percent of counties, the timing of the release of state guidance on SB 1041 was a moderate or major hindrance with respect to implementation, with smaller counties being more likely to report it being a hindrance than medium-sized or large counties. In terms of the complexity of SB 1041 reforms, 48 percent of counties reported that it was a moderate or major hindrance with respect to implementation; again, smaller counties (65 percent) were more likely to report it being a hindrance than counties with medium to large caseloads. County administrators and caseworkers found the complexity of SB 1041 hindered its implementation. Survey results showed that 52 percent of counties reported that the complex details associated with SB 1041 were not a barrier to implementation. At the same time, 79 percent of counties reported that explaining the complexity of SB 1041 to participants posed a moderate or major hindrance. In addition, caseworkers across the focal counties described a significant amount of confusion regarding SB 1041 and identified the WTW 24-month time clock as the most challenging component of the legislation, including when the clock should tick and untick. The time involved in administering the time clock was also viewed as crowding out other services. Other hindrances cited in the ACS were those affecting CalWORKs participants, such as the availability of affordable housing, job opportunities, vocational education, transportation options or resources, and line staff. There were different views on caseworkers’ understanding of SB 1041. In our focal county focus groups, caseworkers expressed significant concerns regarding the complexity of SB 1041, with a particular focus on the WTW 24-month time clock. Staff raised concerns about the adequacy of training and their supervisors’ support to line staff. At the same time, when supervisors were asked on the ACS to indicate how well their caseworkers understood the WTW 24-month time clock, 83 percent of all counties indicated that the caseworkers understood the time clock moderately to very well. Compared with the other components of SB 1041, a higher percentage of counties (18 percent) reported that their WTW caseworkers did not understand at all or only slightly understood the WTW 24-month time clock; 16 percent of counties indicated their WTW caseworkers did not understand at all or only slightly understood the changes to the determination of hourly program participation due to the new averaging method for determining if a participant had met the minimum weekly hours under the 24-month time-clock plan. Relative to the other components of SB 1041, it was these two components that were most frequently identified by counties as aspects of SB 1041 for which their WTW caseworkers did not have at least a moderate understanding. SB 1041 appears to be difficult to explain to CalWORKs WTW participants. Administrators and caseworkers in all six focal counties reported that there are still many participants who do not fully understand the implications of SB 1041, including where they land within the WTW 24-month time clock period. In fact, caseworkers said that while it was difficult xxv for them to understand the changes brought about under the legislation, an even greater challenge was explaining it to participants. Data from the ACS reinforces this finding\u201493 percent of counties reported that explaining the complexity of SB 1041 to participants was a barrier. This gap in understanding the policy changes under SB 1041 has implications for the ability of participants to select the education and training activities and other supports that will be most beneficial for them during the first 24 months of CalWORKs participation. There were mixed views regarding the lag between implementation of SB 1041 and upgrading the county consortia administrative data systems to meet the needs of the legislation. Based on interviews and focus groups in the focal counties, this delay was a source of frustration for county leaders and caseworkers in the focal counties. At the same time, based on the ACS, county leadership in 64 percent of counties reported that lack of automation of the WTW 24-month time clock was not a hindrance in implementation. Conversely, 36 percent of counties reported that lack of automation of the WTW 24-month time clock was a minor, moderate, or major hindrance; this was especially true for smaller counties, where 50 percent indicated it was at least a minor hindrance. The role of WPR in the implementation of SB 1041 was a concern for some state-level stakeholders and many focal county staff. Perceptions that WPR and SB 1041 represent competing agendas emerged as a major theme in the interviews with state and focal county stakeholders. State-level stakeholders, external to CDSS, were particularly worried that counties felt pressured to meet WPR, influencing the extent to which caseworkers helped participants access options available under SB 1041. This concern was reinforced by comments from caseworkers in the focal county focus groups, with many caseworkers complaining about the lack of alignment between the state and federal requirements. ACS findings showed that 29 percent of counties assessed that SB 1041 resulted in somewhat or much worse workforce participation rates\u2014consistent with what we heard from the focus group discussions with caseworkers. Participant Indicators in the Post SB 1041 Period The status and tracking study components covered in this report are based on the analysis of state administrative data covering the CalWORKs WTW population. Although deeper analysis will occur in future reports when county-level administrative data can also be examined, the state data cover key indicators for CalWORKs WTW participants before and after SB 1041 became effective. In particular, for the status study, we examined the cross-section of CalWORKs WTW participants in March 2013, March 2014, and March 2015 in order to describe how key indicators measured in the state administrative data have changed in the first two years since SB 1041 took effect. For the tracking study, we use the administrative data to follow the cohorts that entered CalWORKs in March 2007, March 2009, March 2011, and March 2013 for two years in order to contrast the experiences of cohorts that only experienced the pre SB 1041 rules, xxvi those that only experienced the post SB 1041 rules, and those that transitioned through the policy change. As part of these analyses, we addressed questions related to exemptions and sanctions, leaving CalWORKs, employment and earnings, and reengagement. What percentage of WTW participants were exempt from participating in WTW requirements? The percentage of participants who received at least one exemption during their first two years in CalWORKs increased from 44 percent for the cohort that entered in March 2007 to 56 percent for the cohort that entered in March 2013. Annual snapshots of CalWORKs WTW participants in March of 2013, 2014, and 2015 show about four out of ten participants at any given time had an exemption after SB 1041 took effect. What percentage of WTW participants had a sanction? The percentage of participants who received at least one sanction during their first two years in CalWORKs remained steady at about 14 percent from the March 2007 to March 2013 entry cohorts. Yearly snapshots since SB 1041 showed that in a given March, fewer than one out of ten participants were currently sanctioned. What percentage of CalWORKs WTW participants were not participating one year after entry or two years after entry? The percentage of participants who were not in the CalWORKs WTW program one year after entry did not change from the 2007 to 2013 entry cohorts (about 54 percent), while the percentage of participants who were not in CalWORKs two years after entry increased, rising from 63 percent for the 2007 entry cohort to 70 percent for the 2013 entry cohort. What is the percentage of WTW participants who were employed? A larger percentage of the March 2013 entry cohort was employed for at least one quarter in their first two years after entry compared with the March 2007 entry cohort (64 percent versus 52 percent). In addition, the percentage of new participants who were continuously employed for their first year on WTW increased from 18 percent for the 2007 entry cohort to 21 percent for the 2013 entry cohort. Yearly snapshots after SB 1041 showed that a higher percentage of participants were employed in March 2015 compared with March 2013 (25 percent in 2013 and 31 percent in 2015). How much did WTW participants who were employed earn? For the March 2015 cross-section, employed participants earned about $2,300 per quarter on average, an 11 percent increase compared with the March 2013 cross-section. How did status change from 2013 to 2015 among WTW participants who had the short-term WTW exemption for young children in December 2012? Among the participants who had the short-term WTW exemption for young children in December xxvii 2012, 14 percent still had this exemption in March 2014 and almost none still had it in March 2015. Slightly more than half were not participating in the CalWORKs WTW program in March 2015. Initial Descriptive Analysis for the Impact Study One of the goals of the SB 1041 evaluation is to assess the impact of the legislation on outcomes for adults and children participating in CalWORKs WTW. For example, state administrative data on cohorts of first-time CalWORKs WTW entrants show an increase between 2010 and 2013 in rates of employment one year after enrollment and a corresponding increase in leaving CalWORKs WTW (not participating) one year after enrolling. Administrative data on earnings also show an increase in quarterly earnings among employed CalWORKs entrants one year after enrolling. However, such changes may reflect the improved state of the economy or changing demographic patterns of the CalWORKs WTW population. In this report, we used two strategies to control for possible confounding factors to assess potential impacts of SB 1041 on several key outcomes. In particular, the same state administrative data used for the status and tracking studies were employed in a multicohort interrupted time series design that aims to isolate changes in outcomes that can be associated with SB 1041. Given that the administrative data extend just about two years since the SB 1041 reforms became effective and because we have a limited set of control variables, these initial analyses do not support strong inferences about the impacts of the legislation. Nevertheless, they provide initial insights into the potential effects of the policy changes. Keeping in mind these limitations, these initial analyses produce the following findings using the state administrative data: When we accounted for the changing economy and demographics of CalWORKs WTW participants, we found that after SB 1041 individuals were continuing to participate in CalWORKs WTW one year after entry at higher rates (2.2 percentage points higher) because those who were employed were combining work and CalWORKs WTW at higher rates than predicted (2.1 percentage points higher) rather than being employed only (1.9 percentage points lower). Using this same approach to account for changes in the economy and in the demographics of CalWORKs WTW participants, the level of quarterly real earnings among CalWORKs WTW participants one year after enrollment was about $54 higher (4.2 percent) for those who started after SB 1041 than for similar participants who entered before SB 1041. These findings are consistent with the increase in the earnings disregard, which was one aspect of SB 1041 that was implemented immediately. xxviii Although these effects are all statistically significant, they are very small changes and suggest that the initial effects of the SB 1041 reforms have been modest and that much of the observed trends are likely the result of favorable economic and demographic trends. As a second approach, we exploited nationally representative survey data from the CPS to implement another strategy, the comparative case study method, to examine differences in outcomes for the population potentially eligible for CalWORKs participation in California with a synthetic control group based on a weighted combination of the same eligible population in other U.S. states. At this stage, our inferences were even more limited than the administrative data analyses, given that the CPS data available to us extend, for the most part, just to calendar year 2013, i.e., one year past the point when SB 1041 came into effect. The analyses based on the CPS showed very small and uniformly statistically insignificant differences in various outcomes\u2014income below poverty, employment, receipt of means-tested benefits including TANF, school enrollment, and participation in job training\u2014between the population of female-headed families with low education and dependent children in California compared with the outcomes for the same population in a synthetic control group of other U.S. states. However, with just one year of post-reform data for most outcomes in the CPS, it is not clear whether differences will emerge when a longer time series can be examined. Overall, given the findings from the process study indicating that the SB 1041 reforms have yet to be fully implemented across California’s 58 counties, we would not necessarily expect to see strong effects on family and adult outcomes until more time has elapsed. Implications and Next Steps As a multiyear evaluation, this initial report with evaluation findings was not intended to lead to specific recommendations. However, a number of the findings summarized in Table S.1 are sufficiently robust, especially those from the process study, to identify important implications of the results, as well as issues that we expect to consider in the next phase of the evaluation. WTW 24-Month Time Clock As indicated in Table S.1, one overarching theme of the process study is that implementation of the WTW 24-month time clock has been extremely challenging for everyone involved. Determining each participant’s time-clock status is currently a time-consuming combination of automated and manual processes that are difficult to implement in a consistent way, at least for caseworkers in the six focal counties, partly because caseworkers vary in their understanding of the policy changes. This means that implementation of time-clock rules may vary across counties or even across caseworkers within the same county. Although full automation may not be feasible, there may be ways to improve upon the existing automation systems in order to alleviate confusion and standardize as much of the process as possible. xxix In addition, there is scope for further training of supervisors and caseworkers to improve understanding of the rules (e.g., what stops and starts the clock) and to ensure greater consistency in their application when manual adjustments are required. The smaller counties in particular may benefit from such training. Counties may also gain from sharing information on best practices, although smaller counties may not have the resources needed to fully adopt practices that are working well in the larger counties, where more supports are available. Our in-depth data collection in the six focal counties further indicated that administrators and caseworkers are concerned that the WTW 24-month time clock is not sufficiently long for barriers to stable employment and self-sufficiency to be addressed. As the evaluation continues, we expect to determine if this concern is relevant statewide by examining state and county administrative data on CalWORKs WTW participants’ outcomes. Data from the CalSES will allow us to examine a broader set of adult and child outcomes for a sample of CalWORKs WTW participants who first enrolled in one of the six focal counties before and after the SB 1041 changes. CalWORKs WTW Participants’ Understanding of SB 1041 The ACS and focal county work underscored that the complexity of SB 1041 made it challenging for caseworkers to understand SB 1041 and to explain to participants what it was and what it meant for them. The focus groups with CalWORKs WTW participants further reinforced the point that participants themselves really do not understand SB 1041, including such key aspects as the WTW 24-month time clock, as well as what strategy they should take in terms of deciding how best to utilize core and noncore options and the one-time young child exemption. Although lack of understanding of program rules under CalWORKs or other programs is not a new phenomenon, these findings suggest that there is a need for simpler and more-detailed guidance that caseworkers and participants can follow. For CalWORKs WTW participants who are at the end of their WTW 24-month time clock, consideration could be given to adjusting or resetting their clock so that they have the opportunity to fully understand (and act upon) the implications of different options. Potential Process Improvements Recommendations offered during the focal county site visits focused on improving processes for caseworkers, which might ultimately make implementation easier and more understandable for all. In some cases, these processes were already being applied with good results in at least one of the focal counties and could therefore serve as models of best practice to test out and disseminate to other counties. In other cases, the recommended process change has yet to be implemented, so initial pilot testing of the process change may be warranted. One recommendation, for example, was improvement of the WTW 2 form. For another example, administrators and caseworkers in one county advocated a specialized unit to track and manage participants’ time on aid. xxx Work Participation Rate Our work in the focal counties identified a tension between needing to meet the WPR and allowing CalWORKs WTW participants to pursue the choices available to them under SB 1041. It is unclear the extent to which pressures felt by the counties regarding the WPR are influencing whether caseworkers encourage and support participants to take advantage of the flexibility SB 1041 offers, when those choices may not help the county meet the WPR. As part of the ongoing evaluation, we will continue to assess the extent to which concern over potential federal penalties associated with the WPR is deterring counties from fully supporting the options under SB 1041. Early Engagement Activities These initial evaluation findings also have implications for the set of Early Engagement activities associated with SB 1041. In particular, as a more comprehensive appraisal tool, OCAT may identify more barriers and service needs as it is rolled out in mid-2015 and beyond. A concern is whether the counties will have sufficient services and capacity to meet the identified needs through the FS program and how processes will need to be modified as a result. As the evaluation continues, the evaluation team will explore if referrals to FS have increased and perspectives on why that may be the case, as well as how the social service system is responding to any changes in demand. Likewise, given that the ESE program is relatively new and that there is some variation in the way it is being implemented across the counties, it may be helpful for counties to learn from one another about their program models and strategies to expand the number and range of employers participating. Ultimately, the full effect of the SB 1041 reforms may not be realized until OCAT is fully operational and the other Early Engagement activities are at scale. In other words, while January 1, 2013, was the effective date of the legislation, it is not reasonable to expect that all aspects of the SB 1041 policy changes would be in effect as of that date. This points to the value of the ongoing evaluation but also the need to acknowledge that the timing of the implementation of SB 1041 and supporting activities will not always align with the January 1, 2013, effective date of most of the legislation’s policy changes. xxxi Acknowledgments We would like to acknowledge the staff at the California Department of Social Services (CDSS) who have provided ongoing oversight and guidance of this evaluation and also supported access to state administrative data. These individuals include Will Lightbourne, CDSS director; Todd Bland, Welfare to Work (WTW) Division deputy director; Damien Ladd, WTW Employment Bureau chief; K\u00e4ren Dickerson, WTW Employment and Eligibility Branch chief; Vicky Lovell, WTW Performance Monitoring and Research Bureau chief; Webb Hester of the WTW Performance Monitoring and Research Bureau; Lori Christiansen of the Program Integrity Branch; and Michael Billingsley of the WTW Employment Bureau. In addition, we greatly appreciate the expert assistance with accessing and understanding CDSS CalWORKs administrative data provided by Dara Candy, Brittney Gossard, and Victor Simon from the Fiscal Forecasting and Policy Branch; Eveline Oyama and Moses Salgado from the Office of Systems Integrations; and Xing Shen from the Research Service Branch. We are grateful to the many individuals who participated in key informant interviews, the online All-County Survey (ACS), and focus group discussions. We greatly appreciate their time and willingness to provide input based on their expertise or experience. Their contributions have enriched our understanding of the process of implementing the SB 1041 policy changes. We also want to acknowledge support from the California Welfare Directors Association with providing access to county welfare directors for the administration of the ACS. In addition, we would like to acknowledge and thank the several individuals who served as key points of contact for and greatly facilitated our work in the six focal counties. These individuals include Endalkachew (Endy) Getaneh, program specialist for Alameda County; Rosalinda Torres Rolph, WTW program specialist for Fresno County; Michael A. Bono, Management and Research Services manager for Los Angeles County; Sheri Studebaker, deputy director of Public Social Services for Riverside County; Deborah Burch, division manager for Sacramento County; and Bergen Filgas, WTW manager III for Stanislaus County. We would also like to thank the following individuals who assisted with coordination of the county site visits: Janna de la Paz, management fellow for Los Angeles County; Ana Ontiveros, secretary for Riverside County; Brenda Griffin, Human Services program planner for Sacramento County; and Irene Lopez, manager IV, and Ed Cuellar, Family Services supervisor, for Stanislaus County. At RAND, Survey Research Group staff members Rosaelena Garcia and Nathaly Pacheco- Santivanez provide excellent support for focus group recruitment and facilitation. We also acknowledge valuable research support from Italo Gutierrez, Ashley Muchow, and Gabriel Weinberger. Judy Bearer and Pamela Thompson capably managed other project administrative support. We also thank Arwen Bicknell for editing the report, Beth Bernstein for managing the document production, and Eileen LaRusso for designing the cover. xxxii At AIR, Iris Hemmerich provided exceptional research support for focus group, interview, and survey work with counties and Gur Hoshen provided excellent programming assistance in preparing CalWORKs participant data. In addition, staff at AIR’s Center for Survey Methods, including Mariesa Hawkins, Bob McMahon, Kyosin Kang, and Mengmeng Zhang, provided invaluable support on implementing and fielding the ACS. We also benefited from expert support from Aleksandra Holod and ongoing thoughtful, critical review from senior reviewer Eboni Howard. At Stanfield Systems, Inc., Steve Hamilton and Christine Cox provided excellent research support for the ACS data and for checking integrity of the CalWORKs participant data. The RAND Labor and Population review process employs anonymous peer reviewers, including at least one reviewer who is external to RAND. We benefited from the thorough and constructive feedback provided by the two anonymous reviewers. NOT CLEARED FOR PUBLIC RELEASE. DO NOT CITE. xxxiii Abbreviations AB Assembly Bill ACIN All County Information Notices ACL All County Letter ACS All-County Survey AFDC Aid to Families with Dependent Children AIR American Institutes for Research BLS Bureau of Labor Statistics C-IV Consortium-IV CalSES California Socioeconomic Survey CalWIN Welfare Client Data System Consortia CalWORKs California Work Opportunity and Responsibility to Kids CDSS California Department of Social Services CIN Client Identification Number CPHS (California) Committee for the Protection of Human Subjects CPI Consumer Price Index CPS Current Population Survey CWD county welfare department CWDA County Welfare Directors Association DHHS U.S. Department of Health and Human Services DSS Department of Social Services EDD Employment Development Department ESE Expanded Subsidized Employment (program) FS Family Stabilization (program) GAIN Greater Avenues for Independence GEARS GAIN Employment and Reporting System GED general educational development LEADER Los Angeles Eligibility, Automated Determination, Evaluation and Reporting MEDS Medi-Cal Eligibility Data System MRC meaningful robust conversations MVL master variable list OCAT Online CalWORKs Appraisal Tool OWRA Online Work Readiness Assessment PRWORA Personal Responsibility and Work Opportunity Reconciliation Act RADEP Research and Development Enterprise Project NOT CLEARED FOR PUBLIC RELEASE. DO NOT CITE. xxxiv SAWS Statewide Automated Welfare System SB Senate Bill SRG (RAND) Survey Research Group TANF Temporary Assistance for Needy Families WDTIP Welfare Data Tracking Implementation Project WPR Work Participation Rate WTW welfare-to-work 1 1. Introduction Senate Bill (SB) 1041, enacted as part of the California Budget Act of 2012 (Chapter 47, 2012 Statutes), contained significant changes to the California Work Opportunity and Responsibility to Kids (CalWORKs) program, most of which became effective January 1, 2013. CalWORKs is California’s Temporary Assistance for Needy Families (TANF) program, a central component of the safety net that provides cash aid for low-income families with children. The California Department of Social Services (CDSS) provides oversight and administration of CalWORKs, while county welfare offices in the state’s 58 counties operate the program. The SB 1041 policy changes included modifications to the requirements for work under CalWORKs, the types of eligible work activities, the time clock that governs the work requirements, and the exemption for a young child\u2014all with the goal of engaging CalWORKs participants in welfare-to-work (WTW) activities as early as possible, while also providing enhanced supports to address barriers to work and to offer more flexibility in work activity options as well as increased incentives for work as participants move toward self-sufficiency. The California legislature included a provision in the bill for an independent evaluation to determine if SB 1041 achieves its objectives and if there are any unintended consequences. The goal of the SB 1041 evaluation is to understand how the reforms were implemented; how the changes affected the number and composition of CalWORKs participants and their experience with program services; and the effects of the reforms on families and children, as well as the operations of county welfare offices, the primary agents responsible for implementing and monitoring the program. Broadly, the multiyear SB 1041 evaluation is designed to address the following overarching questions by the completion of the study: Has SB 1041 provided greater flexibility in the services and activities available to CalWORKs participants? Has SB 1041 helped remove barriers to participants’ employment? Has SB 1041 affected participants’ transitions at the 25-month mark? Has SB 1041 accelerated participants’ paths to self-sufficiency? Has SB 1041 affected California’s TANF annual work participation rates? How have the changes affected CalWORKs and related programs at the county level? Has SB 1041 improved the well-being of participating children and their families? What improvements to the CalWORKs program are recommended? This report is the first of three annual reports that will provide findings from the evaluation components. Given the available data and the stage of evaluation, this report focuses on addressing a set of supporting questions that will contribute to our ability to answer the overarching study questions by the end of the evaluation. 2 As described later in this chapter and more fully in the evaluation background and study design report (Karoly et al., 2015), the evaluation consists of five component studies: a process study to address questions related to the implementation of SB 1041; a participant status study and a participant tracking study to examine point-in-time and dynamic indicators for the CalWORKs population both before and after the SB 1041 changes; a county welfare operations impact study to assess the consequences of SB 1041 for various aspects of county welfare office operations; and a participant impact study to investigate the effects of the SB 1041 policy changes on a range of adult and child outcomes for current and former CalWORKs WTW participants. The primary focus in this initial report is on findings from the process study, drawing on information gathered from interviews with state-level key informants; from the first wave of the All-County Survey (ACS), an online survey of the state’s 58 county welfare directors; and from interviews and focus groups conducted in six focal counties (Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus). These quantitative and qualitative data, collected and examined for the process study, cover the first two and a half years of the implementation of SB 1041. Together, these rich data offer a statewide perspective on the status of implementation, as well as an in-depth view of implementation in the six focal counties, which represent 64 percent of the CalWORKs caseload. This information is extremely valuable for understanding the pace of implementation, how counties have approached the policy and process changes adopted under SB 1041, and the opportunities for addressing any challenges encountered to date. In addition, this report includes analyses based on several additional sources of data that contribute to other study components. Specifically, we analyze state administrative data to address questions pertaining to the status and tracking studies. The state-level data systems capture key indicators for CalWORKs WTW participants such as time clock status, exemptions and sanctions, and employment. (Other aspects of program participation, such as the types of WTW activities CalWORKs participants engage in, are captured in county-level data systems that were not yet available for analysis but will be examined in future reports.) We also employ the state administrative data, as well as nationally representative survey data, to provide a first assessment of the potential impact of SB 1041 on CalWORKs WTW participants, specifically for outcomes such as CalWORKs participation, employment, and poverty status. We stress the tentative nature of the impact study findings given that the data cover just one to two years of the post SB 1041 period, thus providing only a very short-term assessment of potential impact. Future evaluation reports will extend the administrative data we are able to examine and augment the primary data assembled for this report with additional waves of qualitative and quantitative data collection. These data will then support more rigorous analyses of outcomes as part of the impact study. In the remainder of this introductory chapter, we provide relevant background information for the evaluation, specifically an overview of the SB 1041 policy changes and an overview of the evaluation framework and approach. These sections update information provided in the 3 evaluation background and study design report (Karoly et al., 2015). We conclude this chapter with a road map for the remainder of the report. Overview of SB 1041 Policy Changes Prior to the SB 1041 reforms, the CalWORKs program was subject to a number of policy reforms as a result of shifting state priorities, federal policy action, and the Great Recession of 2007 2009.1 These changes affected such features as benefit levels (which increased periodically until the Great Recession and then declined), work requirements (made stricter in 2004), the lifetime time limit for benefit receipt (reduced from 60 months to 48 months as of 2011), exemptions from work requirements for adults with a young child in the assistance unit2 (with a more generous allowance as of 2009), and the financial incentives to work (made less generous in 2011). Key Provisions of SB 1041 As summarized in Table 1.1, the SB 1041 legislation (2012) affected a number of key features of CalWORKs.3 Most provisions became effective January 1, 2013, although implementation may have started later and other features in the law were scheduled to be phased in over time. Adult Lifetime Limit and Time Clock The first two rows of Table 1.1 summarize the changes in two key CalWORKs features: the adult lifetime time limit and the initiation of the new WTW 24-month time clock. Under SB 1041, the lifetime limit for CalWORKs receipts remained at 48 months (the time limit adopted in 2011 legislation), but support was divided into two periods: the first 24 months, when a set of flexible CalWORKs WTW services and activities apply, and a second 24 months, when the more restrictive CalWORKs federal standards for work activities requirements apply. For participants who may need more time to complete educational goals or resolve barriers to employment, counties may grant a six-month extension of the CalWORKs 24-month time clock. 1 This section draws heavily on the discussion in Karoly et al. (2015) of the SB 1041 legislation and related policy changes relevant for the evaluation. Karoly et al. also provide a history of earlier reforms to the CalWORKs program. 2 The assistance unit consists of the co-residing family members who are determined to be eligible for CalWORKs. The assistance unit will not necessarily include all family members who are living together. 3 Some features of the CalWORKs program did not change under SB 1041. These include the structure of sanctions for noncompliance, the family cap (i.e., no increase in the monthly benefit when a new child is added to the assistance unit), and the provision for child-only benefits to continue after the adult or adults in the assistance unit reach their lifetime time limit. 4 Table 1.1. Overview of Key SB 1041 Policy Changes Effective January 1, 2013 Policy Pre SB 1041 Post SB 1041 Adult lifetime time limit 48 cumulative lifetime months of CalWORKs WTW assistance, services, and activities 48 months of support in two periods: 24 months of CalWORKs WTW services and activities 24 months of CalWORKs federal standards for work activities. Counties may extend the WTW 24-month time clock by up to six months for a target of 20 percent of participants between months 24 and 48 of aid. Time-clock initiation Not applicable Those starting the program on or after January 1, 2013, are subject to the SB 1041 time-clock structure. Those in the program prior to January 1, 2013, with fewer than 24 months accumulated are subject to the 24-month CalWORKs WTW time clock, followed by the CalWORKs federal standards until the 48-month lifetime limit is reached. Those in the program prior to January 1, 2013, with more than 24 months accumulated are subject to the 24-month CalWORKs WTW time clock until the 48-month lifetime limit is reached. Weekly total work requirements Single parent: 32 hours Two parent: 35 hours Single parent with child younger than age six: 20 hours. Single parent with no child younger than age six: 30 hours. Two parents: 35 hours. Weekly core work requirements 20 hours of the weekly work requirement of 32 hours (for a single parent) or 35 hours (for two parents) have to be in core activities No core requirement during the CalWORKs WTW 24- month service period. During the 24-month CalWORKs federal standards period, 20 hours of the weekly work requirement for single parents and 30 hours of the weekly work requirement for two parents have to be in core activities, which include employment, on-the-job training, and vocational educational training. Young child exemption Short-term exemption: One adult per family excused from WTW activities if caring for one child under two years of age or two children under six years of age One lifetime exemption: One adult per family excused from WTW activities if caring for child under two years of age. Adults exempt from the pre SB 1041 young child exemption rules were not required to participate until the county reengaged them. Counties had until January 1, 2015, to complete the reengagement process. Earned income deduction $112 disregard plus 50 percent of the remaining earned income Effective October 1, 2013: $225 disregard plus 50 percent of the remaining earned income. Cal-Learn Program case management component suspended Program fully restored on April 1, 2013: Pregnant\/parenting teens were no longer under WTW rules but under special Cal- Learn rules. Income verification Quarterly verification of income for eligibility Phased in from April 2013 to October 2013: New income verification system implemented with: Semiannual income verification for cases headed by an adult. Annual income verification for child only cases. SOURCE: Based on Karoly et al., 2015, Table 2.3. NOTE: All changes are effective as of January 1, 2013, except as noted. 5 This extension can be applied for a target of 20 percent of participants who have spent between 24 and 48 months on aid.4 After January 1, 2013, the WTW 24-month time clock stops for participants with any of the following conditions: a WTW exemption applies or the participant has a good-cause determination that excuses noncompliance in WTW activities (e.g., illness or disability, lack of transportation), is under sanction, is developing a WTW plan, is participating in job search, meets federal work participation requirements, is eligible for Cal-Learn, has a domestic abuse waiver, or has a prior temporary exemption for caring for a young child and has not yet been reengaged (we discuss this condition further below). The new 24-month CalWORKs WTW time clock is embedded within the preexisting CalWORKs 48-month time limit. As described more fully in Appendix A, the two clocks differ in the approved activities under each time period, in the way in which time elapses or ticks under each clock, how exemptions and extensions are handled, and when the clocks expire. Implementing the 24-month clock, in particular, involves an automated system combined with manual revision. The complexity of the time clocks, detailed in Appendix A, will be a recurring theme in this report. These provisions of SB 1041, as well as those discussed below, applied fully to those enrolling in CalWORKs for the first time after January 1, 2013, and to those transitioning from the pre SB 1041 rules. Thus, both new and continuing participants after January 1, 2013, have a 24-month period to engage in more-flexible WTW activities. However, those already enrolled in CalWORKs as of 2013 with more than 24 months of cumulative aid will likely reach their 48- month lifetime limit before exhausting the 24 months of flexible WTW activities. Requirements for Work and Related Activities CalWORKs participants subject to the work requirements are required to participate for a minimum number of hours in work or other related activities. As shown in the third row of Table 1.1, SB 1041 reduced the required hours of work from 32 hours to 20 hours for those whose youngest child is less than age six. All other single-parent cases had a small drop in the work requirement, from 32 to 30 hours. There was no change in the required hours of work for two-parent cases (35 hours). In addition to changing the hours of required work, SB 1041 modified the set of allowable activities that meet the work participation requirement (see the fourth row of Table 1.1). During the first 24 months of benefit receipt, there are no required core activities, a more flexible option 4 Beginning in 2015, on a semiannual basis, CDSS has provided counties with a targeted number of assistance units for the exemption in the upcoming six-month period based on 20 percent of the cases estimated to be potentially eligible (i.e., cases where all adult members will be subject to the WTW 24-month time clock within the six-month period and they will still have time remaining on the CalWORKs 48-month time limit during the six-month period). The targets provided in December and June cover the following January-to-June and July-to-December periods, respectively. 6 than under prior CalWORKs rules. During this initial 24-month period, allowable activities include unsubsidized employment, subsidized employment, unpaid work experience, vocational education, job search and job readiness training, mental health and substance abuse treatment, domestic violence services, adult basic education, and secondary school or a general educational development (GED) course. After the WTW 24-month time clock is reached, CalWORKs participants are subject to CalWORKs’ federal standards for work activities\u2014which are less flexible, either because of restrictions in duration for some activities (e.g., vocational education is limited to 12 months and mental health or substance abuse treatment to six weeks per year) or because of restrictions in intensity for others (e.g., attending secondary school is allowed only if at least 20 hours are spent in core activities, such as unsubsidized or subsidized employment). In particular, under federal TANF rules, the following activities are considered core : unsubsidized employment, subsidized employment, work experience, community service, vocational education (up to 12 months), on-the-job training, job search and job readiness training (six weeks per year; it may include mental health and substance abuse treatment), and providing child care to a community service program participant. The following activities are considered noncore : job skills training directly related to employment, education directly related to employment, and satisfactory attendance at a secondary school or course leading to a GED. Young Child Exemption Under SB 1041, the prior temporary young child exemption instituted as part of Assembly Bill (AB) X4 4 (2009) was replaced by a new once-in-a-lifetime exemption from WTW requirements to care for a child from birth to age 23 months (see the fifth row of Table 1.1). Months while the exemption is in effect do not count against the new WTW 24-month time clock, or against the CalWORKs 48-month time limit. This exemption is at the discretion of the participant: In other words, a participant eligible for this exemption as of January 1, 2013, may reserve the exemption for the caregiving of a future child or may exercise the exemption for the current child at a later date. In two-parent assistance units, one parent at a time is eligible for the exemption and the parents may alternate which parent is exempt. CalWORKs participants with a young child exemption as of December 31, 2012, were not subject to the SB 1041 WTW requirements (and the time clock would not start) until the county reengaged them. Reengagement involved initiating contact with CalWORKs participants who had the exemption, communicating the change in the policy, and initiating the WTW services component if they no longer remained eligible for an exemption (see Appendix A for additional detail). Counties had until January 1, 2015, to reengage participants with a pre 2013 young child exemption. This affected nearly 60,000 CalWORKs participants (about 18 percent of the caseload) as of December 2012. 7 Other Provisions SB 1041 included several other provisions that are also summarized in Table 1.1. Financial work incentive. The fixed component of the earned income disregard was restored to $225, the level that existed prior to cuts in 2011 in response to the Great Recession (see the sixth row in Table 1.1). Supports for pregnant and parenting teens. The Cal-Learn program, after a suspension of case management services, was reinstated and allowed to resume its specialized case management and support activities for pregnant and parenting teens (see the seventh row in Table 1.1). Income verification. In an effort to reduce the burden on CalWORKs participants and county welfare offices, the prior quarterly income verification system under CalWORKs (and CalFresh, the name for the Supplemental Nutrition Assistance Program in California) was replaced by a semiannual reporting system that was designated for implementation between April 1 and October 1 of 2013 (see the last row of Table 1.1). For child-only cases (exclusive of WTW-sanctioned cases), income verification shifted from quarterly to annually. Bundle of Policy Changes Together, the bundle of SB 1041 policy changes emphasized moving participants through CalWORKs by intensifying their engagement with WTW activities early on\u2014in the first two years of participation\u2014and providing flexible, meaningful work activity options and supportive services during that period designed to enhance their ability to secure stable, gainful employment. The elimination of a requirement for core activities during the first 24 months provides participants the potential to engage in a range of activities that could include human capital investments through education or training. The reduction in the weekly work requirement for single-parent participants with a child under the age of six provides additional accommodation for families with younger children. The return to the higher earned income disregard in place prior to 2011 provides a greater financial incentive to increase earnings. Finally, the full restoration of the Cal-Learn program reinstated the set of specialized and supportive services for pregnant and parenting teens. During the debate over the SB 1041 provisions, supporters viewed the package of policy changes as retaining the successful features of the CalWORKs program (including those in place prior to the cuts prompted by the budget crisis), such as relatively generous financial incentives and the range of WTW supports. Child and family advocates called attention to its more- restrictive features, such as the shift after the first 24 months of assistance to the more-limited work-related activities that qualify under federal TANF rules and the new one-time limit on the use of the young child exemption. The mandate for an evaluation of SB 1041, included in the 8 legislation, provides an opportunity to document the process of implementing the policy changes and to assess the resulting consequences in terms of both intended and unintended consequences. Other Related Policy Changes Three other policy changes, signed into law as part of the June 2013 budget bills for the 2013 2014 state fiscal year (specifically under AB 74, Chapter 21, 2013), were intended to support the policy objectives under SB 1041 and thus are referenced in the context of the research conducted for this evaluation. In particular, the following strategies were instituted to identify and address barriers to employment more rapidly and are commonly referred to as Early Engagement activities. (For more detail on each component, see Appendix A.) Online CalWORKs Appraisal Tool (OCAT). CDSS was charged with developing a new standardized online appraisal tool for use by county welfare departments to screen new CalWORKs WTW participants and to identify and address barriers to employment more effectively. The development of the tool, a modification of the federal Online Work Readiness Assessment (OWRA), was announced in May 2014 (CDSS, 2014e). The tool was tested in several counties in summer 2014 and statewide implementation was expected by fall 2015. Following the implementation of AB 74, OCAT will be used when WTW participants come in for their initial appraisals. The OCAT summary appraisal will thus be available earlier in the intake process for identifying barriers, addressing identified needs, making referrals to supportive services, and developing each client’s individualized WTW plan. Family Stabilization (FS) program. AB 74 included provisions to identify CalWORKs WTW participants in need of intensive case management and services designed to support the family in overcoming an identified situation or crisis that would interfere with participation in WTW activities and services. The destabilizing conditions include homelessness, domestic violence, and untreated or undertreated mental health or substance abuse problems. Services may be provided for up to six months; months with FS program support do not count toward the 24-month time clock. Counties were required to submit a written FS plan by March 31, 2014, to participate in the program (CDSS, 2014b). Expanded Subsidized Employment (ESE) program. AB 74 added funds for county welfare departments to expand the number of subsidized employment placements for CalWORKs WTW participants, with the expectation that the program could add 8,250 monthly placements by June 2014. Participants are eligible for a six-month ESE placement, with possible extensions in three-month increments for a total of 12 months of subsidized employment if the added time would increase the likelihood of the participant obtaining unsubsidized employment with the employer or of the participant obtaining 9 skills and experience relevant for unsubsidized employment in a specific field. As with the FS programs, counties were required to submit an ESE plan in order to access the additional funds (CDSS, 2013c). Changes to other social programs that are intertwined with CalWORKs continued as well, since SB 1041 went into effect. Two key competing priorities for counties included the rollout of provisions for subsidized health insurance coverage under the 2010 Patient Protection and Affordable Care Act and the realignment of the corrections system (AB 109), which could add to the service requirements at the local level. Such concurrent policy reforms to CalWORKs and other aspects of the safety net make it even more challenging to isolate and measure the effects of the specific SB 1041 reform. SB 1041 and the Work Participation Rate A central component of the federal TANF program is the work participation rate (WPR). Federal law requires states to meet a specific WPR or face a penalty by losing a portion of their TANF grant allocation. Specifically, the WPR requirements mandate that 50 percent of work-eligible (i.e., nonexempt) cash assistance program participants be engaged in work for a set number of hours per week (averaged monthly) depending on family type. There is a separate 90-percent WPR requirement for two-parent families, which have a 35-hour weekly requirement; single parents with children ages six and older are required to work 30 hours per week, and single parents with children under the age of six must work for 20 hours per week. WPR requirements are fulfilled by participating in federally defined core activities (e.g., subsidized or unsubsidized employment, work experience, on-the-job training) or a combination of core and noncore activities (e.g., adult basic education, job skills training, education). Participation in noncore activities is contingent upon engaging in core activities for at least 20 hours per week (30 hours for two-parent families) (Center on Budget and Policy Priorities, 2015). State TANF programs (e.g., CalWORKs federal) can reduce WPR requirements by getting a caseload reduction credit, based on the extent to which the caseload has declined relative to 2005 for reasons other than eligibility changes (Schott and Pavetti, 2013; Brown and Derr, 2015).5 If a state program is unable to meet its WPR, it may experience financial penalties equal to an initial 5-percent cut in its TANF block grant, an additional 2-percent cut for each subsequent year, and up to a maximum of 21 percent (U.S. Department of Health and Human Services [DHHS], 2013; Reed and Karpilow, 2010). Each year from 2008 to 2011, California failed to achieve its WPR, and the state entered into a corrective compliance plan for fiscal year 5 The rationale for this credit is that as more employable welfare participants leave the rolls, those who remain have a more difficult time, on average, finding and keeping employment. 10 2015 that requires the state to meet WPR to avoid a penalty (DHHS, 2013).6 The federal government approved California’s plan in June 2014 and the state will avoid losing hundreds of millions of dollars in federal penalties if the state’s WPR is at least 50 percent in federal fiscal year 2015. While California has historically not met the federal WPR and is in danger of financial sanctions if they do not meet these requirements, SB 1041 modified the CalWORKs program to allow work-eligible individuals to participate in activities that do not count toward the WPR. Specifically, SB 1041 eliminated the core\/noncore hourly requirement such that CalWORKs participants can now choose to engage in noncore activities for 100 percent of their hourly requirement for a period of 24 cumulative months. This flexibility is intended to offer participants the opportunity to address barriers to employment, and provide services and supports to facilitate entry or retention in the workforce (CDSS, 2014d). The CalWORKs participants who engage in these activities are referred to as WTW participants. Other Relevant Background for the SB 1041 Evaluation Before describing our approach to the evaluation of SB 1041, we briefly place the CalWORKs program in the context of the TANF program more generally, review CalWORKs caseload trends, and highlight relevant prior research. CalWORKs in the National Context When CalWORKs was first established following the 1996 federal reforms under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), California’s program relied more on incentives than on disincentives to comply with TANF requirements regarding eligibility, benefits levels, financial work incentives, time limits, work activities, and sanctions. As a result, California’s TANF program was one of the more generous among the states. Indeed, as discussed in more detail in Karoly et al. (2015), where a comparison of state TANF policies is provided, California continues to have one of the highest income thresholds to qualify for TANF receipt\u2014whether measured in absolute terms or relative to state median income\u2014and California maintains relatively high benefit levels, both in absolute terms and relative to state median income for families led by a single mother. With the restoration of the $225 earned income disregard in SB 1041, California also has one of the most generous financial work incentives. In terms of work requirements, SB 1041 eliminated the core requirement during the first 24 months on aid in order to give participants more flexibility to participate in noncore activities, such as education and job skills training that can contribute to achieving economic self-sufficiency. This change aligned CalWORKs policy with that of many states that do not require a minimum of 6 California was determined to be WPR noncompliant in federal fiscal year 2011 and a penalty of $246.1 million was imposed. A reasonable cause claim for penalty relief was submitted to the Administration for Children and Families in August 2014 (CDSS, 2015d). 11 participation hours to be spent on core activities (such as employment, on-the-job training, vocational educational training, and community service). Further, California is one of three states that exempt adults with a child as old as 24 months or even older; most other states allow no exemption or only until the child is 12 months old.7 California is also one of the few states where the maximum sanction affects only the aid received by the adults in the assistance unit, as compared with other states where a full-family sanction or case closure applies. However, the reforms in 2011 and 2013 placed California among the more restrictive states on the length of the time limit. Notably, the majority of states apply the full federal 60-month time limit. At 48 months, California’s time limit policy, in effect since the SB 72 reform in 2011, makes it one of the more restrictive states. At the same time, California is one of three states providing TANF benefits indefinitely for children in need after the adult participant reaches the time limit. CalWORKs Caseload Trends As background for this report, we briefly trace the trends in the CalWORKs caseload since July 1994 (the start of the state fiscal year), in the pre-TANF era. California’s caseload peaked in March 1995 at about 932,000 when the Aid to Families with Dependent Children (AFDC) program was in effect (Figure 1.1). A combination of factors\u2014earlier reforms under AFDC designed to reduce the caseload, the replacement of AFDC with TANF, a strong economy, and favorable demographic trends, among others\u2014helped drive caseloads downward to about 455,000 by July 2007, less than half the AFDC-era peak. Plotted against the state unemployment rate, there is a clear cyclical pattern in the caseload trend. Indeed, the caseload increased again with the Great Recession, reaching nearly 600,000 cases by June 2011. Since that time, the caseload has been fluctuating around a downward trajectory. When SB 1041 became effective in January 2013, the caseload stood at 564,000. As of June 2015, the caseload had fallen further, to about 515,000, consistent with the improving state economy as reflected in the declining unemployment rate, but still above the low point in 2007. 7 Vermont has an exemption for children up to 24 months; Alabama has an exemption that applies up to 36 months. See Appendix A in Karoly et al. (2015). 12 Figure 1.1. California Monthly Caseload and Monthly Unemployment Rate: State Fiscal Years 1995 to 2015 SOURCE: CDSS (2015). NOTE: Data cover July 1994 to June 2015. The CalWORKs caseload is made up of several types of assistance units (see Figure 1.2, which plots the trend in the caseload composition as of December in each year from 1999 to 2014). For purposes of this evaluation, we are primarily interested in cases headed by an adult, which excludes the child-only cases that fall into one of two categories: the Zero Parent group, (the largest) where there is no eligible parent in the assistance unit (e.g., because of immigration status or receipt of Supplemental Security Income), and the Safety Net cases, where all the adults have been removed from the assistance unit after reaching the 48-month CalWORKs time limit. Thus, our primary focus is on the All Other Families group, the Two Parent group, and the TANF Timed-Out cases (which are composed of adult members who have reached the federal TANF 60-month time limit but not the CalWORKs time limit). Together, these three subgroups have made up roughly two-thirds of the caseload since the mid-2000s. 0 2 4 6 8 10 12 14 0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000 Ju ly -9 4 Ja nu ar y- 95 Ju ly -9 5 Ja nu ar y- 96 Ju ly -9 6 Ja nu ar y- 97 Ju ly -9 7 Ja nu ar y- 98 Ju ly -9 8 Ja nu ar y- 99 Ju ly -9 9 Ja nu ar y- 00 Ju ly -0 0 Ja nu ar y- 01 Ju ly -0 1 Ja nu ar y- 02 Ju ly -0 2 Ja nu ar y- 03 Ju ly -0 3 Ja nu ar y- 04 Ju ly -0 4 Ja nu ar y- 05 Ju ly -0 5 Ja nu ar y- 06 Ju ly -0 6 Ja nu ar y- 07 Ju ly -0 7 Ja nu ar y- 08 Ju ly -0 8 Ja nu ar y- 09 Ju ly -0 9 Ja nu ar y- 10 Ju ly -1 0 Ja nu ar y- 11 Ju ly -1 1 Ja nu ar y- 12 Ju ly -1 2 Ja nu ar y- 13 Ju ly -1 3 Ja nu ar y- 14 Ju ly -1 4 Ja nu ar y- 15 U nem ploym ent rate (% ) C as el oa d Month and year Unemployment rate P R W O R A p as sa ge S B 1 10 4 ef fe ct iv e da te SB 7 2 ef fe ct iv e da te C al W O R K s ef fe ct iv e da te Caseload S B 1 04 1 ef fe ct iv e da te 13 Figure 1.2. CalWORKs Caseload by Family Type: 1999 to 2014 SOURCE: Authors’ analysis of CDSS aggregate caseload data (CDSS, 2015e). NOTE: The caseload is measured as of December each year. Insights from Prior Research on CalWORKs and TANF When California enacted CalWORKs in compliance with the federal PRWORA legislation, CDSS commissioned a comprehensive statewide evaluation to assess both the process of implementation and program impacts. Subsequent CalWORKs policy changes also received evaluation. In addition, the 1996 federal PRWORA reforms were preceded by a decade of experimentation with various policy changes to the AFDC program. Here, we briefly review insights of that body of research relevant for the evaluation of SB 1041. Research on Policy Implementation Prior research on the implementation of the initial CalWORKs program and subsequent policy changes demonstrate the importance of assessing how policy reforms are implemented at both the state and county levels, the impact on all levels of public-sector agencies directly involved in implementation and other supporting agencies, the incentives facing caseworkers and other line workers in policy implementation, and the importance of communicating policy changes to participating families. For example, the multiyear process evaluation of the transition from AFDC to CalWORKs demonstrated the complexities of implementing a major reform, including the need for time on the part of CDSS to prepare guidance in the form of All County Letters (ACLs) for counties on implementation, the need for time on the part of county welfare officials and staff to plan for the new processes and procedures required, the need for added operational 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 C as el oa d Year All Other Family Types Zero Parent Two Parent Safety Net TANF Timed Out 14 capacity in county welfare offices despite declining caseloads, and the need to coordinate with other county agencies (Zellman et al., 1999; Ebener and Klerman, 1999; Klerman and Ebener, 2001; Klerman, Zellman, et al., 2001). Data systems provide another focal point for implementation, as evidenced by evaluation research in 2003 examining the first cohorts of CalWORKs participants who were nearing their 60-month lifetime time limit (Crow et al., 2006). The complexities of tracking time on aid, accounting for exemptions and extensions, posed a challenge for state data systems and required substantial staff time and resources to verify that administrative data were accurate and make any needed adjustments. These evaluations have also served to illustrate the variation across counties in how implementation unfolds, partly because of factors such as caseload size, caseload characteristics, operational capacity, and other local conditions. Caseworkers play an important role in policy implementation, as is evident in prior evaluation research. The need for adequate training of caseworker staff to ensure understanding of the policy changes and consistent application of new policies was a concern when CalWORKs was initially rolled out (Cox, Humphrey, and Klerman, 2001). A subsequent evaluation of CalWORKs sanction policy as of 2004 determined that sanctions were less effective than intended because caseworkers were reluctant to impose them (Klerman and Burstain, 2008). Moreover, there was sizable variation across counties in sanction implementation. Finally, implementation studies also reveal the importance of understanding the process of policy reform from the perspective of program participants. For example, in the early stages of the implementation of CalWORKs, noncompliance was a major issue because half of the program participants were not showing up for such required activities as Job Club. During this phase, program components such as sanctions were not yet in place, counties had not fully ramped up supportive services to address barriers to participation in WTW activities, and CalWORKs participants did not always understand the new program requirements. Gaps in participants’ understanding of key CalWORKs features were also evident in a survey of individuals in six counties who entered CalWORKs between February 1999 and March 2000 (Reardon, DeMartini, and Klerman, 2004). Among those receiving benefits at the time of the 2000 2001 survey, just 51 percent correctly identified the adult lifetime time limit of 60 months and only 22 percent knew that there was no time limit for children under the age of 18. Fifty- eight percent understood that benefits would not increase if a woman had another child while on aid. Even more striking, in a 2004 2005 survey of CalWORKs participants in six counties who were within six months of reaching their 60-month lifetime limit, 89 percent of respondents were aware of the time limit, but only 61 percent knew it was 60 months and an even slighter majority\u201453 percent\u2014knew that the time limit did not apply to children (London and Mauldon, 2006). Forty-three percent did not know how many months of their eligibility remained and 19 percent of those who thought they knew the remaining time provided an overestimate of at least four months. 15 Research on Policy Impacts In the decade prior to the passage of PRWORA, California and other states experimented with reforms to the AFDC program as part of Section 1115 waivers from DHHS. Based on both experimental evaluations and analyses of observation data using quasiexperimental designs, researchers have estimated the effects of specific policy reforms\u2014work requirements, financial work incentives, and time limits, among others\u2014and groups of reforms bundled together on an array of outcomes, including welfare use, employment and earnings, income and poverty, fertility and marriage, and child well-being. (For a review and synthesis of that body of research, see Grogger and Karoly, 2005.) Most relevant for the evaluation of SB 1041 is prior research on the impacts of alternative approaches to work mandates and on the earned income disregard as a financial work incentive. Based on the Grogger and Karoly (2005) synthesis, the research findings show the following: Work requirements. A common feature of state reforms prior to PRWORA was the introduction of a requirement for work or related activities. A consistent research finding from experimental studies was that such work mandates, on their own, have their intended effect of increasing employment and reducing welfare use. Although earned income rises, the effect on income is ambiguous because welfare payments decline, although most studies find little change in income or poverty. Another focus of the welfare experiments was the relative effectiveness of the work first strategy (i.e., job search and employment is the primary objective of WTW services) versus the human capital investment approach (i.e., job training and education are emphasized). As part of the National Evaluation of Welfare-to-Work Strategies evaluation, 11 WTW programs using either the work-first or human-capital strategy were evaluated using an experimental design\u2014including Riverside County, which implemented both designs (Freedman, Friedlander, et al., 2000). While both approaches reduced welfare use, effects after five years show somewhat larger reductions for the work-first approach. The subsequent evaluation of the Los Angeles Count Jobs First GAIN (Greater Avenues for Independence) also provided support for the effectiveness of the work-first strategy (Freedman, Knab, et al., 2000). Financial work incentives alone or combined with work requirements. Increasing financial work incentives through a more generous earned income disregard, as a way to make work pay, was another common feature of the reforms in the 1990s and most states, including California, adopted this approach under TANF. In theory, instituting financial work incentives would be expected to increase employment and earnings, but also to prolong welfare use because the incentives allow individuals to combine work and welfare for higher earnings levels. The empirical research is consistent with this prediction. When strong financial work incentives have been combined with increased work requirements, the evaluation evidence also indicates both an increase in 16 employment and earnings, as well as welfare use. The combined effect in the available evaluations has been increases in income, albeit modest, and reductions in poverty because of the ability to combine earned income with continued welfare payments during the transition to self-sufficiency. Under SB 1041, the earned income disregard doubled from $112 per month to $225 per month, the disregard in place prior to reforms in 2011. Relative to the pre SB 1041 baseline, all else equal, we would expect an increase in employment combined with welfare use. Income may increase as well, although the effects on poverty would depend on whether any income gain was sufficient to close the gap between income in the absence of SB 1041 and the federal poverty line. However, the greater flexibility under SB 1041 in meeting work requirements during the first 24-months on aid and the reduced hours requirement for participants with a child under the age of six may introduce a countervailing effect that would serve to reduce employment. Thus, the next effect of SB 1041 on employment, earnings, income, and poverty in the first 24 months on aid is theoretically ambiguous. The research literature has also considered the effects of other factors on welfare participation and related outcomes, with the role of the economy being one key factor that can influence the size of the caseload and the transition to self-sufficiency. Investigations of the impact of welfare reforms after PRWORA have consistently found that some of the caseload decline that followed the adoption of the 1996 federal policy was the result of the improving economy during that period. For example, results from the impact analysis following the initial implementation of CalWORKs demonstrated that the introduction of TANF in California occurred during a period when caseloads had been falling (since 1993) and the employment and earnings of welfare participants had been rising. As the economy continued to improve after CalWORKs was implemented, the policy changes that accompanied the shift from AFDC to CalWORKs could not be credited with all of the continued improvements in caseload trends and other outcomes after CalWORKs implementation (Klerman, Hotz, et al., 2003). Evaluation Conceptual Framework and Approach Our overall evaluation effort is guided by the conceptual framework depicted in Figure 1.3, originally presented in Karoly et al. (2015). The framework is structured like a logic model, moving from the policy change in the left column, through the implementation stage in the second column, to the outputs from the policy change, and finally to the desired impacts on child and family well-being. The top row indicates the sequence of activities, starting with the passage of SB 1041, continuing with implementation by the counties based on communication from CDSS, then engagement by participants, and concluding with the desired outcomes for children and families. Figure 1.3. SB 1041 Evaluation Conceptual Framework 17 18 Additional details about each stage are shown in the middle blocks. For example, the legislation has components addressing eligibility requirements, services and support, and benefits. Those same domains are then the focus of implementation by counties depicted in the second column. Engagement by participants in the third column shows the steps experienced by CalWORKs WTW participants and the end result of either reaching the time limit or exiting to employment. The desired child and family outcomes are shown in the final column, including stable, gainful employment; economic self-sufficiency; healthy families and children; and academically prepared and successful children. Finally, the framework also denotes the associated study component(s) in the bottom of each stage. The evaluation framework serves to illustrate that whether the reforms achieve their intended effect will depend on a number of factors. First, as part of implementation by the counties (top box in the second column), state-level officials, county welfare office administrators, and county welfare office staff must successfully communicate the new policy internally and to prospective and current CalWORKs participants. Second, as indicated in the same box, some counties may need to reorganize staff or shift resources among competing priorities to successfully implement the reforms. Further, the sequential nature of the implementation steps means that the pace at which the reforms are instituted may also affect how quickly changes occur in county welfare operations or in the outcomes that participants experience. Third, as illustrated by the column specific to CalWORKs participants, the reforms are expected to affect the experience of an individual applicant to CalWORKs and those individuals who qualify for benefits. Participants are expected to apply for CalWORKs and, if eligible, receive assistance, develop a WTW plan, and participate in WTW activities. As shown in the bottom of Figure 1.3, the multiyear evaluation of SB 1041 is embodied in five study components, described briefly as follows: The process study addresses questions related to SB 1041 implementation over time using data from periodic interviews with state-level key informants, from annual interviews and focus groups in six focal counties, and from three waves of the ACS. Qualitative methods are used to document the practices, organizational changes, and policies undertaken to satisfy SB 1041; to examine the understanding of the reforms from the perspective of CalWORKs participants, caseworkers, and other county welfare office staff; and to identify any other factors that may affect SB 1041 implementation and its impacts. The county welfare operations impact study relies on information gathered from the focal counties and the ACS, as well as administrative data from county welfare offices regarding program staffing, budgets, and other matters, to assess the effects of SB 1041 on multiple dimensions of county welfare office operations. The approach uses multiple methods to isolate SB 1041 effects and rule out alternative explanations for the observed changes in county operations. 19 The participant status study employs CDSS and county welfare system administrative data to provide an annual series of descriptive tabulations\u2014separately for relevant participant subgroups differentially affected by SB 1041\u2014of how participants are distributed at a point in time in terms of WTW activities, exemptions, time on aid, current recipiency, and time-limit status and extensions, among other indicators. The participant tracking study likewise draws on the array of state- and county-level administrative databases to provide a series of annual summaries of the dynamics of the CalWORKs caseload. These analyses serve to document changes in the flow of participants into, through, and out of the CalWORKs program, capturing the timing and sequence of various outcomes, such as receipt of services, participation in WTW activities, exits for employment or because of time limits, and other aspects of caseload dynamics. The participant impact study combines administrative data with primary data collected over time for a sample of welfare entrants\u2014through the California Socioeconomic Survey (CalSES)\u2014to investigate the effect of SB 1041 on a range of adult and child outcomes for current and former CalWORKs WTW participants, including participation in CalWORKs and other means-tested programs, employment and earnings, income and poverty, adult and child health, and other aspects of family and child well-being. To make inferences about causal effects of the SB 1041 reforms, the study uses a multicohort interrupted time series design. Nationally representative data from the Current Population Survey (CPS) are also used to compare outcomes in California with other states using a comparative case study approach with a synthetic control group. In terms of evaluating SB 1041, it is important to recognize that other policy changes are occurring in CalWORKs as the SB 1041 reforms are implemented. There are also other factors in related policy areas and in the local economy that could influence outcomes for families and children. The analytic challenge is drawing inferences about the causal impacts of the SB 1041 reforms when these other factors are not constant. To address this challenge, as discussed in Karoly et al. (2015), the evaluation components concerned with measuring the impact of the legislation use relevant analytic and statistical techniques to control for such confounding factors. The qualitative data collection, including state- and county-level interviews, also identifies what other factors may be influencing SB 1041 implementation and impacts. Over the multiyear investigation, each of the five study components will contribute to our ability to address the overarching study questions outlined at the start of this chapter (as shown in Table 1.2). For example, our understanding of the implications of SB 1041 for the services and activities available to CalWORKs WTW participants (the first study question) will be informed through descriptive analysis of the process of SB 1041 implementation and through analyses of the impact of the policy changes on county welfare operations and the services that counties provide. It will also be informed by descriptive analysis of state and county administrative data 20 recording CalWORKs participants’ use of specific services and participation in specific activities, and by the impact estimates for SB 1041 based on analyses of state and county administrative data and the CalSES. In general, the process study is expected to provide descriptive insights for each of the study questions and collect the relevant information to address the first, fifth, and sixth questions related to the impact of the SB 1041 policy changes on county welfare operations. The combination of the status and tracking studies will contribute to our understanding of the first five questions covering key goals of SB 1041 with respect to CalWORKs WTW participants and their service utilization; education, training, and job search activities; benefit receipt; employment; and transitions to self-sufficiency. Finally, applying the analytic methods of the participant impact study to both administrative and survey data will allow us to address the sixth question related to CalWORKs participants’ experiences and outcomes. As noted earlier in this chapter, this evaluation report contains findings primarily related to the process study. In addition, we include results from our initial investigations pertaining to the status and tracking studies using state administrative data, as well as initial analyses in support of the participant impact study based on state administrative data and the CPS. For these quantitative analyses, in particular, the available data do not yet allow us to examine all of the outcomes listed above for these study components. Thus, at this stage in the evaluation, we do not seek to definitively address the overall study questions listed in Table 1.2. Rather, our aim is to begin to build an empirical basis for addressing those questions over the course of the multiyear evaluation. In reporting on each study component in the chapters that follow, we highlight the specific questions we are able to address given the available information and the elapse of time since the passage of SB 1041. Table 1.2. Relationship Between Overall Study Questions and Five Study Components Overall Study Questions Process Study County Welfare Operations Impact Study Participant Status Study Participant Tracking Study Participant Impact Study Has SB 1041 provided greater flexibility in the services and activities available to CalWORKs participants? \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc Has SB 1041 helped remove barriers to participants’ employment? \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc Has SB 1041 affected participants’ transitions at the 25-month mark? \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc Has SB 1041 accelerated participants’ paths to self-sufficiency? \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc Has SB 1041 affected California’s TANF annual work participation rates? \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc \u00fc\uf0fc How have the changes affected CalWORKs and related programs at the county level? \u00fc\uf0fc \u00fc\uf0fc Has SB 1041 improved the well-being of participating children and their families? \u00fc\uf0fc \u00fc\uf0fc 21 Road Map for Report This SB 1041 evaluation report presents analyses and findings for four of the five study components, based upon data and other information available during the first year of the evaluation. Chapter Two details the sources of primary and secondary data examined in this report and the analysis methods. This includes information on the methods for conducting research and analyzing the data used for the process study, namely state-level key informant interviews; the ACS; and the focal county data collected through key informant interviews, focus groups with caseworkers, and focus groups with participants. We also provide descriptions of the state administrative data and nationally representative survey data examined in the report and the analytic methods we employ for the status and tracking studies, as well as the initial analyses for the participant impact study. The next five chapters present evaluation findings. Chapters Three, Four, and Five cover the results of the process study, based on the analyses of the state-level key informant interviews, the tabulations from the ACS, and the additional insights from the qualitative data collected from the six focal counties, respectively. Together these data sources shed light on the pace of SB 1041 implementation, the approach counties have taken in implementing the policy changes, and the opportunities for addressing early challenges in implementation. Chapter Six presents analyses of state administrative data to address questions specific to the status and tracking studies. Although deeper analysis will occur in future reports when county- level administrative data can also be examined, the state data cover key indicators for CalWORKs WTW participants before and after SB 1041 became effective. In particular, for the status study, we examine the cross-section of CalWORKs WTW participants in March 2013, March 2014, and March 2015 in order to describe how key indicators measured in the state administrative data have changed in the first two years since SB 1041 took effect. For the tracking study, we use the administrative data to follow the cohorts that entered CalWORKs in March 2007, March 2009, March 2011, and March 2013 for two years in order to contrast the experiences of cohorts that only experienced the pre SB 1041 rules and those that only experienced the post SB 1041 rules. Chapter Seven employs the same state administrative data as Chapter Six but with the aim of measuring the changes in participant outcomes that might be associated with the SB 1041 reforms using a multicohort interrupted time series design that accounts for other factors, such as the improving economy, that might also be affecting outcomes. Given that the administrative data extend just about two years since the SB 1041 reforms became effective and because we have a limited set of control variables, these initial analyses do not support strong inferences about the impacts of the legislation. Nevertheless, they provide tentative insights into the potential effects of the policy changes. Likewise, in another initial impact analysis, we exploit nationally representative survey data to implement another strategy, the comparative case study method, to examine differences in outcomes for the population potentially eligible for 22 CalWORKs participation in California with a synthetic control group based on a weighted combination of the same eligible population in other U.S. states. At this stage, our inferences are even more limited than the administrative data analyses, given that the CPS data available to us extend, for the most part, just to calendar year 2013, i.e., one year past the point when SB 1041 came into effect. We conclude the report in Chapter Eight by drawing out the implications of our findings from this evaluation report, highlighting areas where implementation issues may be addressed and offering insights into the possible effects of the SB 1041 policy changes. A series of appendixes provide additional documentation of methods, data, and results. 23 2. Sources of Data and Methods The four study components included in this report rely on multiple sources of primary and secondary data as summarized in Table 2.1. In this chapter, we provide information on each of the data sources employed for the analyses reported in Chapters Three to Seven, as well as the associated analytic methods. As shown in Table 2.1, the process study\u2014presented in Chapters Three, Four, and Five\u2014relies on primary data collected through state-level key informant interviews and the ACS. The process study also incorporates information from the six focal counties collected through key informant interviews, as well as focus groups with caseworkers and CalWORKs participants. Various sources of CalWORKs state administrative data provide the basis for analyses related to the status and tracking studies presented in Chapter Six. In Chapter Seven, an initial analysis for the participant impact study is conducted using both state administrative data and national survey data from the CPS. In the remainder of this chapter, we discuss each of the data components and corresponding methods in turn, with additional technical details provided in Appendix B and Appendix C. The processes for collecting and analyzing the primary and secondary data sources described in this chapter were reviewed and approved by the California Committee for the Protection of Human Subjects (CPHS) and the RAND and American Institutes for Research (AIR) Institutional Review Boards. Table 2.1. Evaluation Components and Sources of Data Data Source Process Study (Chapters Three, Four, and Five) Status and Tracking Studies (Chapter Six) Impact Study for CalWORKs Participants (Chapter Seven) State-level key informant interviews \u00fc\uf0fc Survey of all county welfare directors (ACS) \u00fc\uf0fc Focal county key informant interviews \u00fc\uf0fc Focal county focus groups with caseworkers \u00fc\uf0fc Focal county focus groups with CalWORKs participants \u00fc\uf0fc State administrative data on welfare use and other outcomes \u00fc\uf0fc \u00fc\uf0fc National survey data (CPS) \u00fc\uf0fc 24 State-Level Key Informant Interviews To understand how the planning and implementation process for the SB 1041 reforms were organized and addressed, we conducted 17 state-level key informant interviews in the spring of 2015. The interviews were conducted with CDSS senior officials and staff involved in planning for and implementing SB 1041, as well as representatives from other relevant state agencies (e.g., California Department of Education and Employment Development Department [EDD]), legislative staff involved in the development of SB 1041, relevant associations (e.g., such as the County Welfare Directors Association [CWDA] and advocacy groups), and other members of the stakeholder workgroup convened by CDSS to plan for SB 1041 as detailed below. In addition, we conducted interviews with representatives from each of the three data consortia: LEADER (Los Angeles Eligibility Automated Determination, Evaluation, and Reporting), CalWIN (CalWORKs Information Network), and C-IV (Consortium-IV).8 Interview Topics Table 2.2 summarizes the interview topics covered with the different types of state-level stakeholders. Our interviews with CDSS staff explored both CDSS’s formal and informal roles, as well as the process of developing and planning for SB 1041. Formally, CDSS is responsible for writing the regulations and for distributing TANF monies and state CalWORKs dollars. It also has federal reporting requirements and is responsible for overseeing county programs. Furthermore, CDSS provides technical assistance and guidance to the counties to help them implement SB 1041, and it is the lead state agency in the interagency collaborations required by CalWORKs legislation and associated with SB 1041’s implementation. Our interviews with key informants in other organizations in the public and private sectors accounted for their roles in planning for and implementing the legislation. Our interviews with the three data consortia focused on the consortia’s role in planning and data collection related to SB 1041 and on the current status of automation of the 24-month time clock. To understand the planning process and the implementation of SB 1041 reforms, we developed semistructured interview protocols for each set of stakeholders listed in Table 2.2. 8 Welfare and Institutions Code section 10823 enabled the development of a multiple county consortium as the foundation of the Statewide Automated Welfare System (SAWS) Project. The purpose of the consortium concept was to facilitate the collaboration of counties in meeting their business needs in the areas of system planning, development, implementation, operations, and maintenance. The consortium concept was intended to provide flexibility to county welfare departments while balancing choice with funding limitations. Currently SAWS is being operated through three consortia. Data for the individual counties are managed by the three consortia that comprise SAWS: Welfare Client Data System (WCDS) Consortium (which operates CalWIN), C-IV, and LEADER (California Statewide Automated Welfare System Consortium IV, undated). In September 2015, Los Angeles County began piloting a new system that would combine the LEADER and GEARS (GAIN Employment and Reporting System) systems\u2014that system’s acronym is LRS, the LEADER Replacement System. (Interview with LEADER representatives, August 6, 2015; New Web-Based Public Assistance Eligibility System to Serve over 3.5 Million, October 7, 2015). 25 Table 2.2. State-Level Types of Informants and Interview Topics Informant Type Interview Topics CDSS senior staff Development of the SB 1041 legislation and plans for implementation How requirements were developed and transmitted to the counties Type of technical assistance and guidance provided to counties Reporting requirements associated with SB 1041 Coordination with other state agencies, the federal government, and county governments Key informants in other organizations in the public and private sectors Development of the SB 1041 legislation and plans for implementation How implementation guidance was developed and transmitted to the counties Types of technical assistance and guidance provided to counties Reporting requirements associated with SB 1041 Coordination with other state agencies and county welfare departments Data consortia representatives Consortia’s role in planning for SB 1041 or feedback requested from them from CDSS to inform the planning process State-level reporting requirements associated with SB 1041 and what changes in data collection were needed Resources, constraints, priorities, and challenges the consortia face in general and how SB 1041 fits into the overall priorities the consortia have Current status of automation of the 24-month time clock and future plans Data Collection We partnered with CDSS to develop a list of potential key informants in each of the categories listed in Table 2.2 A CDSS representative distributed an outreach email to inform the identified key informants about the SB 1041 evaluation and to encourage their participation in an interview. The evaluation team subsequently followed up with the key informants to begin scheduling interviews in person, where feasible, or by telephone. We conducted interviews from May through July 2015 with 17 key informants (see Appendix B for a list of agencies represented by the interviewees). When a key informant was unavailable (e.g., in two instances an individual no longer was in their original position), we worked with CDSS to determine an appropriate replacement. The interviews were conducted by two evaluation team members with one leading the discussion and the other taking notes. With respect to informed consent, we indicated that we would not share respondents’ individual answers with anyone outside of the research project and that we would not identify any individuals by name in study reports. Further, if we used any quotations from the interview, we would not attribute them to any individual by name. In addition, as part of the informed consent process, we asked each interviewee if we could audio- record the interview for note-taking purposes. All of the state-level interviewees agreed to have their interviews audio-recorded.9 9 Initial interviews with CDSS staff that were conducted early on were not audio-recorded. Instead, we had a list of topics we wanted to cover during the conversation and relied on notes taken during the interview. 26 Finally, we reviewed relevant policy documents at the state level, such as legislation, ACLs, and All County Information Notices (ACINs). This review helped inform state-level interview protocol development and supplemented key informant interview findings. They also helped provide context for the findings presented in this report. Methods for Analyzing State-Level Interview Data To discern broad patterns and form overall conclusions, we examined responses to individual questions across the set of state-level key informant interviews. This allowed us to identify key themes that emerged from the interviews and where there were similarities or differences in views regarding the goals of SB 1041, the planning process, the potential barriers or supports to implementation, and the expected impact on CalWORKs participants. All-County Survey In the first year of fielding, the SB 1041 ACS was designed to gather information from the 58 counties on their early experiences with implementing SB 1041. The survey gathered information on the following: status of implementation of different components of SB 1041 organizational and administrative changes to facilitate implementation the context within which implementation was occurring barriers and facilitators to implementation design and implementation of the WTW time clock communication to CalWORKs participants about the time remaining on the WTW time clock the FS program and ESE program characteristics the level of coordination between the CalWORKs program and other service providers (such as community colleges) at the county level expectations and perceived outcomes with respect to SB 1041. Survey Development and Topics To develop the ACS questionnaire, we began with the core set of evaluation questions regarding the status of implementation of the different components of SB 1041, organized around several themes. The initial draft instrument was sent to CDSS for comments. In addition, two of the focal counties\u2014Riverside and Stanislaus\u2014agreed to pilot test the initial draft. We selected these two counties in order to achieve variation in terms of size of the county and of CalWORKs caseloads, and the degree of urbanicity. The pilot test was conducted between February and March 2015. We initially sent an email request to each of the two pilot counties to participate in the test and asked that they review the 27 draft ACS within one week. The pilot counties were sent a hard copy of the draft instrument and were asked to return their completed ACS questionnaire to the evaluation team, along with detailed comments on the different items. We instructed them that, if necessary, they might want to complete it together with members of their management team who are responsible for case management, employment and training services, and participant outreach and communication. After receiving the completed questionnaires, we conducted a telephone interview with each county team to debrief about the draft questionnaire. We used a cognitive interview protocol that solicited their overall feedback on the survey, the length of time it took them to complete it, whether it required multiple individuals within their agency to complete, and detailed input on each section of the survey questionnaire (see Appendix B). The cognitive interview debrief was conducted by telephone by at least two evaluation team members, with one individual leading the discussion and the other being responsible for note-taking to capture the feedback from the pilot counties. Based on the results of the cognitive interview process, we identified questions and response options that were confusing or ambiguous, along with options that were missing from the questionnaire; these were used to inform our revision process. In addition, we utilized what we had learned from the focal county interviews to inform the revision process. Based on feedback from the two pilot counties, from CDSS, and the focal county interviews, the evaluation team revised and refined the individual items and response categories of the ACS questionnaire to minimize measurement error. The final questionnaire contains the following sections (see Appendix B): Implementation of SB 1041 Reforms to the CalWORKs Program in Your County Interagency Collaboration Organizational and Administrative Changes Questions for Supervisors About Line Staff and CalWORKs Participants Provision of Services to CalWORKs Participants in Your County Expanded Subsidized Employment and Family Stabilization Programs and the Reengagement Process Outcomes and Expectations. Fielding the ACS AIR administered the survey using Vovici, a software package used to create and administer online surveys. The survey field period began June 23, 2015, and continued through August 5, 2015. Prior to fielding the survey, CWDA and CDSS each sent a letter of support on June 2, 2015, and June 8, 2015, respectively, to the 58 county social services directors to inform them about the ACS and to encourage their participation. At the start of the field period, AIR sent all 58 county social services directors an email invitation (using email addresses provided by CWDA) to participate in the online survey. The invitation provided background on the survey and the evaluation of SB 1041, the survey web link 28 and county password, and a recommendation to work with key operations staff and supervisors to complete the survey. To help facilitate this process, the email invitation included a Microsoft Word version of the survey so that county staff could share it more easily. The survey also included a set of definitions related to the survey topics to ensure uniformity and consistency of the data collected, and a link to a set of frequently asked questions and answers hosted on the RAND SB 1041 evaluation website (RAND Corporation, undated). For the two pilot counties, we prepopulated their survey responses for those few items that had not changed from the original pilot instrument and asked them to complete the new items on the survey. With respect to informed consent, counties were told that their agency’s participation in the survey was completely voluntary\u2014that they may choose not to participate or decline to answer any question. Further, they were told that the information their agency provided would be kept confidential. The research team would not share their responses with anyone outside of the research project, including CDSS and would not identify any individuals by name in study reports. Further, we noted that we would report the survey results in the aggregate. One week following the initial email invitation, AIR sent the first set of reminder emails to the county social services directors. Two weeks after the initial invitation, AIR telephoned those directors who had not yet responded or opened the survey link. AIR continued to make personalized phone calls and send personalized reminder emails to encourage participation through the close of the survey. Ninety-one percent of counties completed the survey within the scheduled four-week time frame. We provided additional time for several counties and then closed the survey on August 5, 2015. All 58 counties participated, resulting in a 100-percent response rate. Methods for Analyzing the ACS The descriptive analysis of the ACS enabled us to summarize (1) the implementation status of key components of the legislation across the 58 counties; (2) organizational changes made to accommodate SB 1041 reforms; (3) coordination and communication at the county level; (4) factors that served as facilitators or hindrances in the implementation process and detailed discussion of the WTW 24-month time clock; (5) counties’ assessment of caseworkers’ and CalWORKs participants’ understanding of the different components of SB 1041; (6) status of the FS and ESE programs; (7) counties’ assessment of which reengagement strategies were effective; (8) counties’ views regarding how SB 1041 has affected various outcomes and how well different components are working; and (9) counties’ recommendations for improving SB 1041 and their information needs. Our descriptive analyses consist of tabulations (or charts) of the survey responses, with results presented for all 58 counties and then for counties classified into three groups according to the size of their total CalWORKs caseload as of March 2015 (CDSS, 2015e) as follows: small counties, those with a caseload up to and including 999 (20 counties) 29 medium-sized counties, those with a caseload of 1,000 to 4,999 (20 counties) large counties, those with a caseload of 5,000 or more (18 counties). Because this is a census of all 58 counties (i.e., we are surveying the entire population of counties in California), we do not calculate inferential statistics. Respondents sometimes added information to the other category that could be coded as a previously listed response. In these cases, we recoded responses for consistency. For a few items where respondents could select responses along a range, we collapsed response categories at the upper end of the scale (e.g., moderately well and very well) or lower end of the scale to present the results. In addition, for various questions, respondents were asked to provide comments to explain their selection of the other response option (e.g., other factors that hindered implementation) or to describe their response (e.g., communication strategies) in more detail. We analyzed those open-ended written comments and include representative quotes in the narrative. Focal County Qualitative Data The focal county in-depth data collection occurred in six counties: Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus. Figure 2.1 provides a map to show the geographic location of the focal counties, which were selected to capture variation that is potentially relevant for the implementation of SB 1041, such as the geographic region of the state, degree of urbanicity, demographic makeup of the population, measures of socioeconomic status, and the state of the economy. Counties were also selected such that, together, they would capture a sizable share of the CalWORKs caseload. Figure 2.1. Map of Six Focal Counties for SB 1041 Evaluation 30 This variation is illustrated in Table 2.3. Key geographic, demographic, economic, and caseload characteristics are summarized for the six focal counties and for California as a whole. Together, the counties represent medium and large urbanized counties in the northern, central, and southern parts of the state and display variation in the demographic and socioeconomic make-up of their populations. The six counties account for 64 percent of the CalWORKs caseload and participants, ranging from a low of about 11,000 assistance units in Stanislaus County to 176,300 assistance units in Los Angeles County as of January 2015. There are three components to the focal county data collection and analysis: county-level key informant interviews, focus groups with caseworkers, and focus groups with CalWORKs participants. For the focal county work, RAND took the lead in conducting the key informant interviews and caseworker focus groups in Los Angeles, Sacramento, and Riverside counties. AIR took the lead in conducting the key informant interviews and caseworker focus groups in Alameda, Stanislaus, and Fresno counties. RAND’s Survey Research Group (SRG) was responsible for recruiting and conducting the participant focus groups in all of the six focal counties. In this first wave of data collection, spanning the time from February 2015 to August 2015, the content of the interviews and focus groups focused on counties’ experiences with planning for and implementing SB 1041 within the first several years following its passage. We summarize the data collection methods used for each component, followed by a final section that describes our approach to analyze the resulting qualitative data. County-Level Key Informant Interviews The county-level key informant interviews were conducted in the six focal counties between February and June of 2015. Table 2.4 lists the different types of informants and the target number of interviewees per informant type, as well as the list of topics discussed. At county welfare offices, individuals in various positions were interviewed, including county directors or deputy directors of welfare services; administrative personnel (e.g., directors of the CalWORKs program, WTW program, and CalFresh; budget director; director of programs and services; personnel director; director of finance\/fiscal operations; and director of information technology); relevant supervisors (e.g., of eligibility staff or WTW caseworkers); and eligibility and caseworker staff, among other personnel. Interviewees also included senior officials in other affected county agencies (e.g., mental health services agencies, child welfare agencies, and education and training providers), and directors or other key staff at other service providers (e.g., community colleges, community-based organizations). 31 Table 2.3. Characteristics of Focal Counties and California as a Whole Characteristics Alameda Fresno Los Angeles Riverside Sacramento Stanislaus California Geographic region San Francisco Bay Area, East Bay Central Valley (south) Southern California, Greater Los Angeles Southern California, Inland Empire Central Valley (north) San Joaquin Valley (north) Urban-rural classification Large central metro Medium metro Large central metro Large central metro Large central metro Medium metro Percentage of population in urban areas 99.6 89.2 99.4 95.4 97.9 92.0 95.0 Population Total persons 1,594,569 972,297 10,136,559 2,308,441 1,470,912 528,157 38,714,725 Percentage of state population 4.1 2.5 26.2 6.0 3.8 1.4 100.0 Race or ethnic composition Percentage non-Hispanic white 32.6 30.6 26.6 37.1 46.3 44.1 38.3 Percentage non-Hispanic black 11.1 4.7 7.9 5.9 9.8 2.3 5.6 Percentage Asian 27.9 9.8 14.1 6.2 15.2 5.4 13.7 Percentage Hispanic\/Latino 22.7 51.9 48.4 47.4 22.5 44.1 38.6 Percentage other 5.6 3.0 2.9 3.4 6.2 4.1 3.8 Education level, persons ages 25 and older Percentage less than high school diploma 13.1 26.4 22.5 19.4 13.2 21.6 17.9 Percentage bachelor’s degree or more 42.8 19.7 30.3 20.7 28.9 17.0 31.7 Percentage of single-parent female-headed households 20.5 31.0 27.4 22.0 28.6 23.9 23.9 Median household income $77,214 $43,423 $55,746 $57,006 $55,842 $51,084 $61,933 Percentage of persons below poverty 12.5 27.7 18.7 17.1 18.2 18.0 16.4 Unemployment rate 5.9 11.6 8.3 8.2 7.3 11.2 7.5 CalWORKs caseload Total cases (assistance units) 16,886 27,338 167,276 31,826 31,362 11,028 541,366 Percentage of state caseload 3.1 5.0 42.0 5.9 5.8 2.1 100.0 Total persons on aid 35,986 70,747 394,249 79,364 76,271 27,407 1,301,288 Percentage of state participants 3.2 6.3 34.9 7.0 6.7 2.4 100.0 CalWORKs caseload composition Percentage two parent 6.2 11.1 6.5 9.9 12.8 12.2 8.8 Percentage all other families 40.1 35.1 41.0 43.5 34.6 36.8 39.4 Percentage no parent 27.7 27.3 34.2 27.9 21.8 27.6 30.7 Percentage Safety Net 20.5 20.7 13.1 13.7 24.7 15.8 15.2 Percentage TANF timed out 5.9 6.4 5.4 5.5 6.5 8.2 6.3 SOURCES: California Department of Finance, 2015; CDSS, 2015e; U.S. Bureau of Labor Statistics (BLS), undated; U.S. Census Bureau, undated. NOTE: Urban population is for 2010. Population counts and shares are for January 1, 2015. The demographic, education, income, and poverty measures are for 2014. The unemployment rate is the 2014 annual average. The CalWORKs caseload counts and characteristics are for January 2015. = not applicable. 32 Table 2.4. County-Level Types of Informants and Interview Topics Informant Type Approximate Number per County Interview Topics County directors\/deputy directors of welfare services 1 2 Informant’s overview of the key components of SB 1041 How state communicated these changes to the informant’s agency Overall status of implementation If their county changed the way it does business (including interactions with other agencies and service providers) to implement SB 1041 Type of organizational changes needed, if any Views regarding strengths and weaknesses of the SB 1041 changes to CalWORKs (what is working, what is not) Views regarding the impact on county operations and on CalWORKs participants Other major policy changes that occurred at the state level or county level during this same time period that may have had implications for SB 1041 implementation Administrative personnel and relevant supervisorsa 6 8 Informant’s understanding of the key components of SB 1041 How SB 1041 changes to CalWORKs were communicated to informant Planning undertaken and status of implementation of the different components of SB 1041 How the informant’s county changed the way it does business, if any (e.g., reorganize, create cross-functional units, create new staff positions, redefine staff roles, create internal databases or tracking systems) What policies needed to be developed or revised to implement SB 1041 Type of coordination activities undertaken with other county agencies and service providers How SB 1041 changes to CalWORKs were communicated to staff Type of training provided to supervisors, eligibility staff, and WTW caseworkers How well staff understood those changes Views regarding what is working well\/what is not Views regarding impact on county operations and CalWORKs participants Suggestions for improving SB 1041 Other major policy changes that occurred at the state level or county level during this same time period that may have had implications for SB 1041 implementation Eligibility staff, CalWORKs program specialists, WTW coordinators, and experienced caseworker staff 3 5 Informant’s understanding of the key components of SB 1041 How SB 1041 changes to CalWORKs were communicated to informant How, if at all, SB 1041 affected informant’s jobs and responsibilities Training they received; how they communicated those changes to CalWORKs participants Views regarding what is working well, what is not working well Views regarding which elements of SB 1041 CalWORKs participants understand well; what elements are confusing Views regarding impact on CalWORKs participants Suggestions for improving SB 1041 33 Table 2.4\u2014Continued Informant Type Approx. Number per County Interview Topics Staff from other county agenciesb 5 7 Role of their agency in coordinating with county welfare offices and\/or providing services to CalWORKs participants How SB 1041 changes to CalWORKs were communicated to informant What type of planning, if any, they were involved in What the SB 1041 changes to CalWORKs meant for their agency and clients Type of coordination with county welfare and among agencies needed to implement SB 1041 Views regarding impact on their services and operations and impact on their clients Staff from other service providersc 3 4 Role of organization in providing services to CalWORKs participants How SB 1041 changes to CalWORKs were communicated to informant What effect, if any, it had on their operations and services Whether they participated in planning for SB 1041’s implementation at the county or state level How well their staff and clients understand the SB 1041 changes Views regarding impact on services and CalWORKs participants a Includes directors of the CalWORKs program, WTW program, and CalFresh; budget director; director of programs and services; personnel director; director of finance\/ fiscal operations; director of information technology; and supervisors of eligibility staff or WTW caseworkers. b Includes mental health services agencies, child welfare agencies, and education and training providers. c Includes, for example, community colleges and other community-based organizations. As indicated in Table 2.4, our aim was to conduct 18 to 26 interviews per county depending on how the individual county was structured and the number of key stakeholders in each category. For the six focal counties, we conducted interviews with a total of 155 individuals, with some taking place as group interviews. In five instances, a caseworker who participated in a group interview also participated in a caseworker focus group. We created a standardized protocol to guide our interviews and to collect information on the topics listed in Table 2.4 (see Appendix B). We worked with each county’s designated contact to identify the personnel to be interviewed and to schedule the initial three-day site visit. The county-level key informant interviews were conducted in person and augmented with telephone follow-ups to clarify information or to interview welfare staff or other county agency staff and service providers who were not available at the time of each site visit. The interviews were conducted by two evaluation team members, with one serving as lead interviewer and the other as note-taker. As part of the informed consent protocol, interviewees were informed that we would use the information from the interviews for research purposes only. We would protect the confidentiality of their information and not disclose their identity, although the focal counties will be identified by name in study reports. We also noted that we would be taking detailed notes but would destroy all information that identifies the interviewees at the end of the study. We also requested 34 permission to audio-record each interview for note-taking purposes. All of the interviewees agreed to have the discussions audio-recorded. We did not transcribe these audio-recordings; instead, we listened to them to fill in any gaps in our notes or where we were uncertain as to what was said. We also conducted follow-up phone calls where necessary to fill in our understanding of an issue, to complete several interviews for which the time period allocated did not permit a full discussion, or to talk with individuals who were unable to participate in the scheduled in-person interview. For each focal county, we also gathered and reviewed relevant documentation related to the design and implementation of SB 1041, such as organizational charts, departmental plans and policies, planning documents, formal interagency agreements, progress reports, and other relevant information. Written documentation was used to augment the information gained from the interviews. Caseworker Focus Groups We conducted two caseworker focus groups per focal county to examine their understanding of the SB 1041 changes, perceptions of operational changes at the county level, and perspective on how SB 1041 affects their work and experience with CalWORKs participants. Specifically, the caseworker focus group protocol covered the following topics (see Appendix B): understanding of SB 1041 changes to the CalWORKs program how county welfare supervisors communicated these changes to caseworkers what training, if any, they received what organizational changes or redefining of staff roles occurred how SB 1041 affected caseloads and responsibilities what has changed in regard to client reporting requirements views regarding CalWORKs participants’ understanding of the new rules and what are their support needs views regarding factors that facilitated or hindered caseworkers’ implementation of these new rules views regarding what has worked well with SB 1041’s implementation and what challenges have been presented suggestions for improving SB 1041. In recruiting for the focus groups, our specific eligibility criteria were that a caseworker had a WTW caseload and had been a caseworker for one year or more to ensure at least some experience with implementing SB 1041. In a few instances, we had to relax this criterion and invite caseworkers with less than a year of experience in order to obtain a sufficient pool of caseworkers from which to recruit. We focused on WTW caseworkers rather than eligibility staff. 35 Our goal was to schedule 10 to 12 caseworkers per focus group with the expectation that eight to ten would actually participate. To schedule the 10 to 12 caseworkers per focus group, we needed a pool of approximately 35 to 40 candidates per focus group. To obtain the candidate pool, we requested from the county welfare agency the names and contact information of the caseworkers currently assigned to their two largest CalWORKs program offices. In several instances, we had to expand the list of caseworkers to other offices within a county in order to recruit a sufficient number of caseworkers for the two focus groups. We then emailed recruitment letters to the caseworkers explaining the purpose of the evaluation and the focus group and requesting that they reply to the email if interested in participating. We also emphasized that their participation was completely voluntary and that the information they and others shared during the focus group would not be shared with anyone outside of the evaluation team. The caseworker focus groups were held between February and July 2015. Table 2.5 summarizes for each focal county the number of caseworkers contacted, the number who participated, and the participation rate.10 The number of participants in the focus groups ranged from six to 15 caseworkers, with a total of 118 caseworkers participating in these discussions across the six focal counties. Each caseworker focus group session followed a written protocol and the sessions ran approximately 90 minutes. A researcher with experience in conducting focus groups facilitated Table 2.5. Number of Caseworkers Who Were Contacted and Participated in the Focus Groups, by County County Number Contacted Number Participated Percentage Participated Alameda 56 17 30 Fresno 50 23 46 Los Angeles 134 14 10 Riverside 55 23 42 Sacramento 88 23 26 Stanislaus 31 18 58 Total 414 118 29 10 The participation rate in Los Angeles County was lower than that of the other counties for several reasons. The geographic expanse of the county and the fact that the focus groups were held at a central location may have been a disincentive for caseworkers to participate in the focus group discussions due to distance they would have had to travel. (In the next round of data collection, we will aim to hold the focus groups in several locations to minimize this problem.) In addition, one of the focus groups was scheduled on the same day that OCAT training was scheduled, which also affected caseworkers’ ability to participate. Unfortunately, we did not know about this scheduling conflict in advance. Lastly, many caseworkers responded to our email invitation indicating they were not interested in participating. 36 the caseworker focus group discussions in each county, with the other evaluation team member(s) serving as note-takers.11 We did not provide an incentive payment to the caseworkers as they were participating in their official capacity as government employees. However, we did provide light refreshments to thank them for their time. With respect to informed consent, we informed the focus group participants that the information from the discussion would be used for research purposes only. We would protect the confidentiality of the information and, although the focal counties would be identified by name in the project’s reports, no information would be included that could be used to identify any of the individual participants. We also indicated that we would not share any information they provided during the focus groups with anyone outside of the research team in a way that could identify the individual caseworker. We also requested that focus group participants protect the confidentiality of others in the group. Lastly, informed consent included a statement that their participation in the focus group was completely voluntary and they could decide to stop participating at any time and for any reason. Their decision to participate in the focus group (or not) would not be shared with their employer or with CDSS and would not affect their employment in any way. Participant Focus Groups We conducted focus groups with CalWORKs participants to learn about their understanding of the SB 1041 changes, their perceptions of operational changes at the county level, and their perceptions of how SB 1041 affects their work and their CalWORKs experience with the participants. Specifically, the participant focus group protocol included the following topics (see Appendix B): overview of the benefits or services individuals are currently receiving under the CalWORKs program awareness and understanding of SB 1041 changes in WTW requirements, of differences between the CalWORKs and TANF program requirements, of the new time clocks, of the exemptions how participants learned about these changes; how the changes were communicated to them by their caseworkers of the range of activities they could participate in, which were most important to them in what areas SB 1041 affects their work requirements, status, reporting requirements views regarding overall effect of these changes on their own situation. As most of the focal counties are quite large geographically, we identified in each county the two county welfare offices with the largest CalWORKs caseloads and drew a catchment area 11 Our research protocol approved by the CPHS and the RAND and AIR Institutional Review Boards did not allow us to audio-record the caseworker focus group discussions, so we relied on our typewritten notes. 37 around those offices of 12 miles. CalWORKs participants were then sampled from the zip codes within that catchment area to minimize the travel distance for participating focus group members. Figure 2.2 shows the zip code list from Riverside’s Hemet Office as an example. If a zip code was associated with the list for both target offices within a county, we assigned that zip code to the closest office. The exception was Fresno, a rural county where the county welfare offices are located within the same zip code. CalWORKs participants for one focus group were recruited using the same method employed in the other five counties (i.e., from zip codes within 12 miles of the office). Participants for the second focus group were recruited from zip codes that were 12 to 20 miles from the office, in order to ensure we were also drawing cases from the more rural areas of the county. We referred to the first of these two groups as the inner ring and the second as the outer ring. We conducted focus groups in both English and Spanish. In this initial round of focus groups, we elected to conduct all of the focus groups in English in four of the focal counties (Alameda, Fresno, Sacramento, and Stanislaus) and to conduct one focus group in Spanish and one focus group in English in Los Angeles and Riverside counties. In this way, we could learn if there were differences between the experiences of English-speaking versus Spanish-speaking CalWORKs participants that we may want to explore further in subsequent years of data collection. Figure 2.2. Map of Eligible Zip Codes for Recruiting Focus Group Participants in Riverside’s Hemet Office NOTE: The selected county welfare office is in the unshaded zip code (92543); the additional areas within the 12-mile radius from which focus group participants were sampled are shaded in light purple and marked with their zip codes. 38 CalWORKs participants were eligible for recruitment for a focus group session if: (1) they were within the designated zip codes (or mile radius) and (2) they had at least ten months remaining in their WTW 24-month time clock as of September 2014. The second criterion ensured that the focus groups participants were still active in the CalWORKs program, as this group would have relevant experience under SB 1041.12 For the focus groups conducted in Spanish in Los Angeles and Riverside counties, we also purposefully sampled cases where Spanish was indicated as their primary language.13 Our goal was to recruit about 12 CalWORKs participants for each of two focus groups per county, with the expectation that eight to ten individuals would actually participate. Thus, initially for each county, we drew a sample of 60 participants per focus group for recruitment purposes. However, we learned that records for a number of individuals had incomplete information or missing or disconnected telephone numbers. Thus, we had to draw a larger sample of 100 participants per focus group per county in order to achieve the target number for each of the focus groups. In total, we drew a sample of 1,024 CalWORKs participants from the Welfare Data Tracking Implementation Project (WDTIP) file (described further below) from which to recruit the focus group participants (State of California, 2014). We then requested from each of the focal counties the name, address, and telephone number of the sampled CalWORKs participants who met our criteria. Table 2.6 shows the location and date for each participant focus group and the language of the session. The table also summarizes the number of participants sampled per focus group, the number in the sample that were contacted for recruitment purposes, the number contacted that met our eligibility criteria, the number of eligible participants scheduled for each focus group, and the number that actually participated. Overall, 12 focus groups were conducted (two per county) between June and August 2015, with ten focus groups conducted in English and two in Spanish. Of the 1,250 CalWORKs participants drawn from the WDTIP file, 1,176 had at least one telephone number listed that could be used to contact them. Of these individuals, 1,024 were contacted at least once to screen for eligibility using a questionnaire that determined if they met the eligibility criteria and that they would be able to attend the scheduled focus group in their county. Of those contacted, 733 were eligible for recruitment (i.e., they had an active telephone number, they had been or were receiving CalWORKs benefits, and they spoke the target language for the focus group). Of the 733 eligible individuals, 126 agreed to participate in a focus group and were scheduled for one of the focus groups in their respective counties. Of the 126 individuals who agreed to participate in a focus group, 93 attended the focus group sessions. 12 We selected September 2014 because CDSS informed us that reliability of the data increases after three months of elapsed time. Therefore, at the time of drawing the sample, we determined that the most recent month that contained reliable information about participants was September 2014. 13 Because Riverside County had drawn the initial sample for us, we were unable to go back and draw additional cases to get a target of 100 cases to recruit from. Thus, we had a smaller sample of 44 cases to recruit from for the Spanish focus groups in Riverside County. 39 Table 2.6. Summary of Participant Focus Group Recruitment and Participation County Location (Date) Focus Group Language Number of Participants Sampleda Contacted Eligible Scheduled Attended Alameda Oakland (July 2015) English 199 121 88 10 6 Alameda Hayward (July 2015) English 100 99 77 11 10 Fresno Inner Ring (July 2015) English 94 94 46 11 6 Fresno Outer Ring\/West Fresno Regional Center (July 2015) English 92 92 47 10 7 Los Angeles Region IV Central, Main Office (Los Angeles) (August 2015) Spanish 68 68 54 9 7 Los Angeles Region III San Gabriel Valley, Main Office (El Monte) (August 2015) English 100 82 71 11 8 Riverside Jurupa Office (August 2015) Spanish 31 31 19 7 6 Riverside Hemet Office (August 2015) English 79 79 66 13 10 Sacramento Bowling Green (June 2015) English 101 91 61 10 8 Sacramento North Highlands (June 2015) English 100 76 54 13 9 Stanislaus Turlock (June 2015) English 97 96 74 10 8 Stanislaus Modesto (June 2015) English 106 95 76 11 8 Total 1,167 1,024 733 126 93 a Number of CalWORKs participants sampled consists of those sampled and with at least one phone number provided. In total, 1,250 participants were sampled but 83 participants did not have a phone number in their record. Table 2.7 summarizes the reasons why the contacted participants were not eligible. In particular, of the 1,024 participants who were contacted at least once, 291 participants (28 percent) did not meet the following eligibility criteria for inclusion in the focus group: 276 participants (27 percent) did not have an active phone number (e.g., the phone number(s) on record had been disconnected or were no longer in service); 11 participants (1 percent) did not speak the language in which the focus group was being conducted; and four participants (less than 1 percent) indicated that they did not receive CalWORKs benefits. Table 2.8 summarizes the reasons why those eligible were not scheduled for a focus group. Specifically, of the 733 participants eligible for a focus group, 607 participants (83 percent) were not scheduled for one of the focus groups for the following reasons: 433 participants (59 percent) were contacted by phone (e.g., SRG left multiple telephone voice messages) but did not return the recruitment calls; 133 participants (18 percent) had listed a telephone number that did not belong to them; and 41 participants (6 percent) refused to participate because of scheduling conflicts or because they were not interested in participating. 40 Table 2.7. Reasons Contacted CalWORKs Participants Were Not Eligible for a Focus Group Reason Count Percentage of Those Contacted for a Focus Group (N=1,024) Phone numbers disconnected or not in service 276 27.0 Unable to speak focus group language 11 1.1 Reported not having received CalWORKs benefits 4 0.4 Total not eligible 291 28.4 NOTE: Percentages for the subcomponents may not add to the total because of rounding. Table 2.8. Reasons Eligible CalWORKs Participants Were Not Scheduled for a Focus Group Reason Count Percentage of Those Eligible for a Focus Group (N=733) Left telephone voice messages with no response back 433 59.1 Number did not belong to respondent 133 18.1 Refused (e.g., schedule conflicts and\/or not interested in attending) 41 5.6 Total not contacted 607 82.8 NOTE: Percentages for the subcomponents may not add to the total because of rounding. Table 2.9 summarizes the self-reported characteristics of the 93 CalWORKs participants who participated in the focus groups.14 Across the six focal counties, 83 percent of focus group participants were female. The average participant was 32 years old; ages ranged from 20 to 57 years. About 26 percent of participants were married, 11 percent were living with a partner, 25 percent were separated or divorced, and the remaining 39 percent had never been married. In terms of educational attainment, 46 percent had some college education or a two-year degree, 16 percent had a high school degree or GED, and 21 percent had some high school education but had not graduated. About 10 percent had less than a high school education, while about 6 percent had four-year college degrees or higher. Participants were diverse in terms of race or ethnicity, with 52 percent identifying as Hispanic or Latino, while 47 percent reported being white and 17 percent African American. Other groups represented included American Indian and Alaska Natives, Asians, and those in other racial groups. In terms of country of origin, 73 percent reported that they were born in the United States and 21 percent reported another country. English was the main language spoken by 75 percent of the focus group participants. The majority (61 percent) had been in the CalWORKs program for one to three years. Another 14 Appendix B compares key demographic characteristics, as recorded in WDTIP, for the 1,167 CalWORKs participants sampled for the focus groups, the 733 eligible participants, and the 93 participants who attended a focus group session. A test of the difference in the characteristics of those eligible versus those who attended showed no significant difference in the representativeness of those attending a focus group based on sex, race or ethnicity, participant age, the age of the youngest child, and two- versus one-parent case type. The share of Spanish-speaking cases among the focus group attendees was somewhat higher than the eligible group (18 percent versus 11 percent) which reflects the additional effort to recruit Spanish-speaking CalWORKs participants for the two focus groups conducted in Spanish. 41 Table 2.9. CalWORKs 2015 Focus Group Participants’ Self-Reported Characteristics, Overall and by County Participant Counts by County and Overall (Except as Noted) Percentage Distribution Characteristic Alameda Fresno Los Angeles Riverside Sacramento Stanislaus Total Sex Female 15 10 10 12 15 15 77 82.8 Male 1 3 5 4 2 1 16 17.2 Age Range (in years) 24 50 22 41 26 52 21 57 21 49 20 44 20 57 Mean (in years) 29 28 41 36 31 29 32 Marital status Married 2 5 4 7 5 1 24 25.8 Living with partner 1 3 1 1 1 3 10 10.8 Separated\/divorced 3 1 5 3 5 6 23 24.7 Never married 10 4 5 5 6 6 36 38.7 Education level 5th grade or less 1 1 2 1 0 1 6 6.5 8th grade or less 1 1 4 2 0 1 9 9.8 Some high school, but did not graduate 2 3 4 7 2 2 20 21.5 High school graduate\/GED 1 3 0 3 4 4 15 16.1 Some college or two-year degree 9 5 6 4 10 9 43 46.2 Four-year college degree or higher 3 1 1 0 1 0 6 6.4 Race Hispanic or Latino 3 6 13 12 5 9 48 51.6 American Indian or Alaska Native 0 1 2 2 1 1 7 7.5 Asian 1 0 0 0 3 0 4 4.3 Black or African American 5 4 1 1 5 0 16 17.2 White 7 6 4 10 6 11 44 47.3 Two or more races 0 1 1 0 1 1 4 4.3 Other 1 0 2 0 0 0 3 3.2 Not reported 2 1 5 3 1 3 15 16.1 Country of origin United States 12 12 9 11 13 11 68 73.1 Other 4 0 3 4 4 5 20 21.5 Not reported 0 1 3 1 0 0 5 5.4 Main language English 13 13 7 10 15 12 70 75.3 Spanish 0 0 6 5 0 0 11 11.8 Both English and Spanish 1 0 2 1 0 4 8 8.6 Other 2 0 0 0 2 0 4 4.3 Time in CalWORKs Less than one year 0 1 1 0 0 3 5 5.4 One to three years 7 8 10 13 11 8 57 61.3 More than three years 9 4 4 3 6 5 31 33.3 N 16 13 15 16 17 16 93 100.0 NOTE: Percentages may not sum to 100 because of rounding. = not applicable. 42 33 percent had participated for more than three years, while the remaining 5 percent had participated for less than a year. Except for Los Angeles County, where a location in the community was used, the focus groups were conducted in a conference room made available by the focal county welfare departments.15 The session began with a review of the consent protocol to make sure participants understood and to see if they had any questions before proceeding. The consent protocol indicated that participation in the focus group was completely voluntary and that focus group members could stop participating at any time and for any reason. There would be no penalties or loss of benefits to which they would otherwise be entitled if they chose not to participate or chose to stop their participation once they had started. In addition, we noted that neither their caseworker nor any other welfare staff nor CDSS would know if an individual decided to participate or not. We also indicated that the information from the focus group discussion was for research purposes only. We would protect the confidentiality of their information and would not share their responses with anyone else outside of the research project, nor identify any individuals by name in our study reports. Permission was also requested to audio-record the focus group discussion, and all participants in all sessions agreed. At the time of the focus group session, we asked participants to complete a brief demographic survey (the results of which are summarized in Table 2.9). The sessions, facilitated by experienced SRG staff, ran about 90 minutes on average and were conducted in English or Spanish (as noted in Table 2.6). At each focus group discussion, at least one note-taker was also present to capture the information on a laptop computer. We had the audio-recordings of the focus groups transcribed to augment the notes taken and to verify accuracy. A cash gift of $75 was provided to each focus group participant to thank them for their participation and a light lunch was also provided. Methods for Analyzing Focal County Qualitative Data As we did with the state-level key informant interviews, we examined the information gathered in the focal counties through key informant interviews and focus groups using qualitative methods to identify key themes, discern broad conclusions, and where there was variation across different stakeholders. In other words, unlike the ACS, we did not calculate summary statistics based on the interviews or focus groups. To analyze the qualitative interview data, we used NVivo software to support coding and data analysis. Data were entered by interview question into this cross-platform, qualitative data management and analysis package and then coded using key analytical categories driven by the research questions. Using the software, we generated reports that allow sorting, reducing, and indexing of the data, as well as elaborating on the nature of each coded mention. This approach allowed for a systematic process of categorizing the data through reduction, organization, and 15 In Los Angeles County, RAND’s SRG was able to identify a community location to hold the focus groups. 43 connection. The method supports exploration and the discovery of categorical relationships derived directly from the data and encourages sensitivity to emergent patterns and contrasts within (e.g., by interview respondent type) and across the focal counties. To analyze the CalWORKs caseworker and participant focus group data we: (1) identified general themes through review of notes and transcripts, highlighting relevant quotes and identified where there were differences in perspectives; and (2) summarized patterns of qualitative findings within and across counties. For CalWORKs caseworkers, themes identified were related to the training that caseworkers had received on SB 1041 changes to CalWORKs, how well they understood those changes, how SB 1041 affected their caseloads and responsibilities, how those changes were communicated to participants, how SB 1041 affected their interactions with participants, their views of how well participants understand the 24-month time clock and other related changes, their views regarding factors that facilitated or hindered their implementation of the new rules, and suggestions for improving SB 1041. For CalWORKs participants, themes identified were related to participants’ understanding of the SB 1041 changes to CalWORKs, how it affects their activities and ability to access services and to meet WTW requirements, how helpful their caseworker has been in steering them through the new requirements, and their perceptions of their likely future course. State Administrative Data The initial descriptive analyses for the status and tracking studies reported in Chapter Six and the initial descriptive analyses for the impact study reported in Chapter Seven draw from state administrative data maintained by CDSS.16 We begin with a description of the administrative data sources and how the data were prepared for analysis. We then detail how we defined the population of interest and the cohorts we analyze. A final section describes the analytic approach for findings reported in Chapters Six and Seven. Data Sources and Preparation for Analysis As summarized in Table 2.10, the individual-level databases maintained at the state level include WDTIP (referenced earlier in the context of sampling for the focal county CalWORKs participant focus groups), a statewide welfare time-on-aid tracking and reporting system; the Medi-Cal Eligibility Data System (MEDS); and the EDD Base Wage Match.17 For each data source, the table lists the population covered, the unit of analysis and frequency, and the data constructs. 16 In future reports, in addition to state administrative data, we expect to report on individual-level data from the three statewide consortia: CalWIN, C-IV, and LEADER. These data will add such information as participants’ use of services, enrollment in education programs, and reasons for discontinuing in CalWORKs. 17 We draw from restricted access state administrative data that were made available as part of the SB 1041 evaluation. In future reports, we expect to report on additional data from EDD with information on unemployment insurance. 44 Table 2.10. Sources of State Administrative Data Data Source Coverage Unit Level\/ Frequency Data Constructs Welfare Data Tracking Implementation Project (WDTIP) Adult TANF\/CalWORKs WTW participants since 1998 Individual level\/ monthly Time clock, program participation, exemptions, sanctions Medi-Cal Eligibility Data System (MEDS) Longitudinal Database and Monthly Extract Files All AFDC\/TANF\/ CalWORKs participants since 1998 Individual level\/ monthly Demographics, county codes Employment Development Department (EDD) Base Wage Match All CalWORKs adults since 2006 Individual level\/ quarterly Employment, earnings Most of the information used to address the evaluation’s research questions came from WDTIP, including information related to participating in CalWORKs, such as becoming sanctioned or exempted from participation, and exiting the program. WDTIP also tracks cumulative time toward the WTW 24-month and CalWORKs 48-month time-on-aid clocks. To form a more complete record for each CalWORKs participant, we merged information from the MEDS and EDD to WDTIP data. Data from MEDS provided information about participant sex, age, race or ethnicity, and primary language. We used these data to describe the population and to examine group differences based on demographic characteristics. Data from EDD provides information about the employment and earnings of CalWORKs participants while they are participating in CalWORKs, as well as before and after.18 We used these data to assess employment longevity and consistency and level of earnings. Appendix C contains additional information about each data source and a description of the data preparation, merging (conducted using anonymized identifiers rather than actual Social Security and Client Identification Numbers), and quality control processes. Population and Analytic Framework Our population framework for the status, tracking, and impact studies included adults who were in the CalWORKs WTW program and were eligible to work, including those who may have been sanctioned, either prior to or after SB 1041 implementation. We use the term CalWORKs WTW participant to identify this population.19 We used WDTIP to establish the main study 18 The EDD data provide information on employment and earnings for workers covered by unemployment insurance. Nationally, the unemployment insurance data system is estimated to cover about 93 percent of the wage and salary component of national income (BLS, 2015b). Uncovered sectors include self-employment, some agricultural workers, and the informal sector (i.e., individuals working for cash). Estimates suggest that unemployment insurance administrative data underreport self-reported employment among welfare leavers by 10 20 percent (Isaacs and Lyon, 2000). Other estimates for the welfare-eligible population indicate that wages, when they are reported in the unemployment insurance data, may be understated by 11 to 14 percent (Hotz and Scholz, 2001). 19 CalWORKs WTW participants are members of cases. A CalWORKs case includes all members of the same family and counts them as one unit rather than separate individuals. This report focuses on the experiences and outcomes of the adult individuals in CalWORKs cases. 45 population and added demographic information from MEDS.20 Appendix C provides more details about how we derived the study population. We analyzed different clusters of participants for the initial status, tracking, and impact studies. The status study analysis included cross-sectional snapshots of all CalWORKs WTW participants in March of 2013, 2014, and 2015, the period after SB 1041 was instituted, in order to gain perspective on a cross-section of participants at regular intervals after the policy change. As snapshots, each point-in-time cross-section included participants who started in CalWORKs before and after the policy change. Since WTW participants may experience CalWORKs differently depending on when they entered the program, we divided the snapshot population into two groups of participants, those who began participating in CalWORKs WTW before January 2013 and continued after the policy change and those who first participated in CalWORKs WTW in January 2013 or later. By examining the findings for participants who only experienced CalWORKs WTW under the SB 1041 reforms, we may gain insight to the long- term steady state outcomes of the SB 1041 reforms. The status study cross-sections combined included 958,365 participants. The status study figures in Chapter Six show the three status cross-sections defined as follows: status cross-section 2013: All CalWORKs WTW participants in March 2013 status cross-section 2014: All CalWORKs WTW participants in March 2014 status cross-section 2015: All CalWORKs WTW participants in March 2015. The status study analyses also show the following groups within each cross-section: all participants: All CalWORKs WTW participants in March of each year transitional group: CalWORKs WTW participants who started the CalWORKs WTW program before SB 1041 began and continued after January 2013 post SB group: CalWORKs WTW participants who started the CalWORKs WTW program for the first time in January 2013 or later. The tracking study analysis included four CalWORKs participant entry cohorts\u2014those who started in the CalWORKs WTW program for the first time in March of 2007, 2009, 2011, and 2013\u2014to dynamically assess groups of CalWORKs WTW participants across time.21 We followed each entering cohort for two years. The 2007, 2009, and 2011 cohorts were assessed for two-year periods before SB 1041 began, while the 2013 cohort was assessed for the two-year 20 During the planning stage for this evaluation, we expected to derive the study population from the MEDS data. However, WDTIP is the main record of participation in CalWORKs WTW and contains the majority of the information required for this report, which makes it preferable over MEDS for deriving the study population. 21 By first time, we mean that the participant was not an adult participant in the CalWORKs WTW program since January 1998 because 1998 is the earliest year for which we have reliable data. 46 period after SB 1041 began.22 We assessed, for example, whether participants received exemptions, left CalWORKs WTW, and\/or became employed during that time.23 In this analysis, we followed participants for two years because this period is the earliest that participants could reach the 24-month CalWORKs WTW time limit under SB 1041. The tracked entry cohorts combined included 38,131 participants. The tracking study figures in Chapter Six show findings for the four cohorts defined as follows: tracked entry cohort 2007: First-time CalWORKs WTW participants in March 2007 tracked entry cohort 2009: First-time CalWORKs WTW participants in March 2009 tracked entry cohort 2011: First-time CalWORKs WTW participants in March 2011 tracked entry cohort 2013: First-time CalWORKs WTW participants in March 2013 (only experienced CalWORKs WTW after SB 1041 took effect). The initial impact study analysis, presented in Chapter Seven through a series of figures, shows outcomes for 16 quarterly cohorts defined as follows: Initial impact study analysis Cohorts 2010 through 2013: First-time CalWORKs WTW participants in each of four quarters. The four 2013 cohorts only experienced CalWORKs WTW after SB 1041 took effect. These cohorts thus include first-time CalWORKs WTW participants from 2010 through 2013 who started in Quarter 1 (January through March), Quarter 2 (April through June), Quarter 3 (July through September), or Quarter 4 (October through December). Each quarter-year forms a cohort. The data analyzed included information on 416,144 participants entering CalWORKs WTW.24 In the status, tracking, and impact studies, we categorized participants and examined their outcomes based on whether they first participated in CalWORKs WTW before or after the SB 1041 reforms became effective in January 2013. This division allowed us to compare whether the outcomes of participants who experienced both old and new policies and procedures differed from those of participants who only experienced SB 1041 policies and procedures. However, an important consideration in this distinction is the pace of implementation of the reforms. The appropriateness of using January 2013 as an analytical cut point depends on the 22 We placed a participant into a cohort for the impact analysis if he or she began in the CalWORKs WTW program in March of a given year and did not participate in the program between January 1998 and February of a given year. For example, participants in Cohort 2007 started in the program in March 2007 and did not participate in the program between January 1998 and February 2007. 23 We examined time on aid, exemptions, sanctions, discontinuances, and employment for eight yearly cohorts from 2006 to 2013. We did not find notable differences across the cohorts so we show findings in this report for Cohorts 2007, 2009, 2011, and 2013. 24 The population frame for the impact analysis is based on WDTIP, but unlike the status and tracking study, it only retains individuals who also have a record in MEDS. WDTIP contained 482,177 new participants in this time frame. We matched participants in WDTIP to entries in MEDS for 416,144 (86 percent) of the participants. 47 extent to which SB 1041 was actually implemented, as intended, by that time. As will be discussed in Chapters Four and Five, the initial implementation of SB 1041 appeared to be uneven, given delays in clear, consistent implementation guidance from the state and with Early Engagement lagging behind. An alternative approach would be to separate the population at a later point of full implementation, but it may be difficult to establish that date with certainty. For future reports, we will explore to what extent the evaluation findings are sensitive to when the pre SB 1041 versus post SB 1041 periods are defined. Analytic Approach for State Administrative Data Administrative data contains information on all CalWORKs WTW participants. Since this is population data, analyses do not require tests of significance. Analyses presented in Chapter Six are descriptive. Figures are based on counts or averages, and the denominator is all cohort participants, unless otherwise noted. Analyses in Chapter Seven offer a first glimpse of the changes in participants’ participation and employment outcomes that might be associated with SB 1041. This analysis assesses the association between SB 1041 and CalWORKs WTW participants’ employment, CalWORKs participation, and other measures of economic status by comparing the outcomes of individuals who participated in CalWORKs WTW after SB 1041 went into effect with the outcomes of individuals who participated in CalWORKs WTW before SB 1041 was put into effect. Such comparisons will not necessarily provide an unbiased estimate of the effects of the policy change because demographic and economic factors other than SB 1041 may have influenced the outcomes of CalWORKs WTW participants and may also have changed who participated in CalWORKs WTW in the first place. As California’s economy and demographics change, the observed outcomes for participants will change regardless of any changes due to SB 1041. To isolate the changes in outcomes that can reasonably be associated with SB 1041, we used a statistical regression model to account for specific economic and demographic factors other than SB 1041. This analysis, known as interrupted time series analysis, used a regression model to compare the pre and post SB 1041 outcomes of different cohorts of CalWORKs WTW participants as if the observable characteristics of the participants and local economies were the same. The specific regression model used in this report accounted for: participant sex, age, race or ethnicity, and primary language; the age of the youngest child and number of children in the case at participants’ entry into CalWORKs; and, the county of participation and that county’s unemployment rate.25 Because EDD collects employment and income data quarterly, the monthly WDTIP and MEDS data for each participant were aggregated to corresponding quarters. The quarters for each participant were indexed relative to the CalWORKs enrollment quarter (e.g., first quarter 25 The regression models included county fixed effects to account for differences across counties that do not change over time and quarter fixed effects to account for seasonality in outcomes. 48 after enrollment, second quarter after enrollment). Information on these first-time participants was tracked for up to one year (four quarters) after entry. The available data allowed us to track four quarterly entry cohorts that started in 2013, after SB 1041, and to compare their first-year outcomes with those of the 12 pre SB 1041 quarterly entry cohorts that stared in 2010, 2011, and 2012. We conducted analyses on three sets of outcomes. We first analyzed whether, in the fourth quarter after entering, the participant was in CalWORKs and whether the participant was employed.26 These two categories are not mutually exclusive as many CalWORKs WTW participants are both in the program and employed at the same time. Second, to explore the results in more detail, we categorized and analyzed outcomes using four mutually exclusive indicators: whether the participant was in CalWORKs only, employed only, both in CalWORKs and employed, or neither. Third, we analyzed total real earnings in a quarter (i.e., earnings adjusted for inflation and expressed in first quarter 2013 dollars).27 In future years of the evaluation of SB 1041, we will conduct status, tracking, and impact analyses using county CalWORKs administrative data obtained from the three county consortia, which provide detailed information on outcomes and participant characteristics. Because WDTIP does not contain the full range of information that we eventually plan to use in this evaluation, the results should be viewed as tentative and interpreted with caution. For example, in the initial impact analysis, we are attempting to account for factors other than SB 1041, but we cannot yet conclude that any estimated impacts are due to SB 1041. Nationally Representative Survey Data To complement our analyses of state administrative data, we also analyzed data from the CPS to assess the impact of the SB 1041 policy change on single-parent female-headed families in California. We briefly describe the CPS and its advantages for our analysis and then detail our analytic approach. Current Population Survey Data The CPS is a nationally representative monthly survey of approximately 60,000 households in 792 sample areas across the United States that provides a wide range of information on population characteristics and the state of the U.S. labor force. The CPS is the data source used to calculate the nation’s unemployment rate; as such, it is the gold standard for collecting data on 26 Because outcomes were analyzed at the quarter level, in CalWORKs WTW in a quarter was defined as being in CalWORKs WTW in at least one month during the quarter. 27 The classification variables as well as earnings were analyzed using a linear regression model. Even though the classification variables are binary outcomes, the analysis here is descriptive and not causal so a linear regression model, also known as a linear probability model for binary outcomes, was used to generate results to ease interpretability. 49 employment\u2014a critical indicator of economic self-sufficiency for families participating in the CalWORKs program. The U.S. Census Bureau, using a scientifically selected national sample of residential housing units with coverage in all 50 states and the District of Columbia, conducts the survey for the BLS. For analyses reported in Chapter Seven, we take advantage of the national coverage in the data to make comparisons between single parents living in California and single parents living in other states that are similar to California in terms of their sociodemographic composition and TANF policies. The CPS has four features that make it valuable for assessing the effects of SB 1041. First, as a large national study intended to produce state-level estimates, it is possible to make valid comparisons of California residents with residents of other states. Second, the CPS includes measures of outcomes that are important for gauging the success of CalWORKs, including family economic resources, labor force participation, public assistance receipt, and school enrollment. Third, the CPS collects information from families in a systematic fashion over time, allowing us to track outcomes in the years prior to and following the implementation of SB 1041. Fourth, in contrast to the administrative data, which are limited to individuals who apply for and receive CalWORKs benefits, the CPS data allow us to examine outcomes for the entire population potentially eligible for CalWORKs. In this way, we capture the implications of SB 1041 for the population at risk of CalWORKs participation, which will include those who are eligible but do not enroll in the program. Analytic Approach for CPS In our analysis of the CPS, we use a comparative case study design to compare outcomes of CalWORKs WTW eligible families in California with outcomes of families in other states in the years immediately after SB 1041 was put into effect. In comparing families in California with families in other states, we are able to get a sense of how the CalWORKs WTW program stacks up against other state TANF programs. Direct comparisons with other states can be misleading, however, as California is unique in terms of its size, population, and state welfare policies. To make meaningful comparisons, we employed a synthetic comparison group methodology, which allowed us to compare families in California with families in states that are most similar to California in terms of their sociodemographic composition and the rules and benefits of their state TANF programs. Families in these similar states act as a synthetic comparison group against which we could compare specific outcomes of CalWORKs WTW-eligible families in California. To undertake this analysis, we used up to 11 years of data from the CPS. We used data spanning 2005 through 2012 to assess trends in outcomes prior to SB 1041 and data from 2013 up through early 2015 to assess trends in outcomes in the first few years following the launch of SB 1041. We measured outcomes starting in 2005 following the passage of SB 1104 (2004), which tightened the CalWORKs participation requirement to mandate 20 hours of defined core work activities out of the 32 hours required for single parents (where previously there was no 50 requirement for core activities in the first 18 to 24 months).28 Data from the March CPS (covering 2005 to 2015) are used to examine one outcome measured for the current month (unemployment status), as well as several measures collected with reference to the prior calendar year available in the March CPS annual supplement (covering 2005 to 2013), including poverty status, receipt of public assistance in general and TANF receipt in particular, and annual weeks worked full time. Data from the October CPS (covering 2005 to 2014) are used to examine current school enrollment and participation in job training. The CPS does not contain direct information on eligibility for or participation in CalWORKs, and thus can only show how those in California who are most likely to require cash assistance compare with similar individuals in other states. We selected all female-headed families in the CPS with one or more children under the age of 18 living in the state of California as our treatment group because they are the primary target population for the CalWORKs WTW program. To further limit our treatment group to those that were most likely to require financial assistance from the CalWORKs WTW program, we eliminated those where the female head had a bachelor’s degree or higher.29 Across the 11 years of our analysis, 12,876 female-headed families in California met our criteria, approximately 1,170 in each year. For ease of expression, we refer to these families as our California treatment group. Our comparison group was a purposefully selected group of states that have populations and welfare policies similar to California. For a state to be eligible for inclusion in our synthetic comparison group, it needed to be similar to California in several ways (see Table F.8 for sources): racial and ethnic composition of the population, measured by the percentage of adults who identified as Hispanic, African American, white, Asian, and other nativity, measured by the percentage of adults who are foreign-born educational attainment, measured by the percentage of adults with a bachelor’s degree age, measured by the percentage of the population under the age of 18 poverty, measured by the percentage of families living below the poverty line family structure, measured by the percentage of families led by a single parent and the percentage of births to unmarried women unemployment, measured by the unemployment rate the maximum monthly income threshold for eligibility in the state’s TANF program the maximum monthly financial benefit from the state’s TANF program the maximum number of months allowed on the state’s TANF program. 28 See Karoly et al. (2015) for additional information on the history of policy changes since CalWORKs was implemented in 1998. 29 As the CPS lacks direct measures of welfare participation, we follow the approach taken by other analysts who have used the CPS to study the effects of welfare policies by focusing on outcomes among female-headed household with children under the age 18 (Grogger, 2003; Matsudaira and Blank, 2014). 51 Using these state-level variables for each year, we selected states for inclusion in the comparison group and constructed weights for these states to maximize the comparison group’s similarity with California in terms of the pre SB 1041 outcomes of interest, as well as the population and policy measures listed above.30 Because our central interest is in assessing the effects of the implementation of SB 1041, we reviewed the states selected by our weighting algorithm to ensure that there were no major substantive changes to their policies throughout our period of observation that would contaminate our estimated differences between them and California. The result is a comparison group composed of states that can be interpreted as approximately similar to California in both population and policy environment. More-detailed information on the comparison group selection process and the accompanying weighting scheme is included in Appendix F. In our analysis, we plotted the trend line in outcomes for California and the weighted trend line in outcomes for the comparison group states. We compared the difference between California’s trend line and the comparison group’s trend line post SB 1041. To make inferences about the magnitude of the observed post SB 1041 differences between California and the comparison group, we used a placebo test approach outlined by Abadie, Diamond, and Hainmueller (2010). Specifically, we applied the synthetic comparison group approach to every state in the sample and compared the resulting differences with the observed difference between California and the comparison group. Hence, every state acted as a placebo. We considered this observed difference to be of statistical significance if it was below the 2.5th percentile or above the 97.5th percentile of the placebo comparison distribution. This is conceptually akin to a two-tailed test of significance with a threshold of p < 0.05. If California outperforms the comparison group states in the post SB 1041 years on our outcomes of interest using this placebo test, this would provide suggestive evidence that the SB 1041 policy changes may have contributed to changes in the outcomes of female-headed families in California. 30 Technically, all states were included in the comparison group, but states that were more similar to California were given more weight and states that were less similar to California in the pre SB 1041 years were given less weight. In our analyses, the majority of states were given a weight of 0 (and thus did not contribute to trends in the comparison group) as they were too different from California on our measures of sociodemographic composition and state welfare policy parameters. Note that the comparison group states change for each analysis that we present because the states are in part selected on how similar they are to California on the outcome of interest. To accommodate this variability, we use different states for the comparison group for each separate comparison. 53 3. State-Level Perspectives on Initial Implementation of SB 1041 As part of the process study, we gathered information from key informants in relevant government agencies, as well as other stakeholders with a state-level perspective to understand, at a high level, how these stakeholders viewed the context and background in which SB 1041 was developed, how the policy changes were planned and communicated, and what factors affected implementation. As detailed in Chapter Two (and summarized in the text box at right), we conducted interviews in the spring of 2015 with CDSS staff as well as representatives from key organizations involved with the planning, implementation, or both of SB 1041 for a total of 17 interviews. Our analyses aimed to address the following questions, which we have listed with a preview of our findings: How did stakeholders at the state level view the goals and objectives of SB 1041? Stakeholders' perspectives regarding the goals and expected impact of SB 1041 differed: Some viewed it as well-motivated with the potential for positive change while others were more concerned about potential negative consequences. These differing views contributed to the intense nature of the negotiations over the proposed legislation. In addition, our conversations at the state level revealed a fundamental difference in how different stakeholders understood the CalWORKs WTW 24-month time clock component of SB 1041. How did the state plan for SB 1041 and communicate the changes brought about by it? As required by the legislation, CDSS implemented a state-level workgroup process to develop implementation guidance for SB 1041, which was characterized as positive and inclusive by stakeholders. Communication of policy with the counties occurred primarily through ACLs. However, the intensive and lengthy planning process contributed to the slow release of guidance to the counties, creating implementation challenges at the local level. According to state-level stakeholders, what factors have hindered or facilitated initial implementation of SB 1041?According to many stakeholders external to CDSS, the benefits of SB 1041 will not be fully realized until the accompanying Early Engagement Chapter Three Methods Based on key informant interviews conducted with 17 state-level officials in the public and private sectors in spring 2015. Topics focused on context and background for SB 1041, how the policy changes were planned and communicated, and factors affecting implementation. Analyzed using qualitative methods. See Chapter Two for more detail on data and methods. 54 reforms\u2014the OCAT, FS program, and ESE program (discussed in Chapter One and Appendix A)\u2014are fully implemented on a statewide basis. In addition, state stakeholders described tension between promoting SB 1041 and meeting federal WPR requirements. From the perspective of state-level stakeholders, what is the potential long-term impact of SB 1041? Interview respondents (both within CDSS and external to the department) discussed the potential for SB 1041 to positively change how clients experience CalWORKs in terms of their initial engagement with the program, the activities available to them, and their relationships with caseworkers. However, respondents noted that it is still too early to determine whether SB 1041 will have the intended effect of helping clients to overcome their unique barriers to self-sufficiency. Next, we provide a detailed discussion of the interview findings organized by a series of key themes. Note that in the discussion, interview respondents from CDSS are identified as such (e.g., CDSS administrators or CDSS staff ), whereas the term state stakeholder is used to refer to representatives from statewide organizations other than CDSS (e.g., welfare advocacy groups, California Community College Chancellor's Office, Legislative Analyst's Office, and legislative staff). Understanding of the Goals of SB 1041 In the January 2012 budget proposal, the Brown administration proposed to significantly redesign the structure of CalWORKs to provide budget savings. In particular, the revised program would reduce caseloads and focus resources on those families that are meeting work requirements. Specifically, the proposal created three groups in the program: CalWORKs Basic, CalWORKs Plus, and Child Maintenance (Public Policy Institute of California, March 2012). CalWORKs Basic would provide WTW services to families for up to 24 months, rather than 48 months. The CalWORKs Plus program would include families with eligible parents who are working a substantial number of hours before they reach their 48-month limit in the program. WTW services would be focused on these two groups, and there would be a slight increase in cash assistance to families in CalWORKs Plus. All other families would be placed in the third level, the Child Maintenance program\u2014here parents would be ineligible for aid, grants to children would be reduced, and child care services would no longer be available. State stakeholders reported that many state legislators viewed these proposed changes as a reduction in the safety net available to low-income families in California in the form of reduction in grant amounts and in the time available for adult participants to receive benefits (Legislative Analyst's Office, February 22, 2012). The legislature subsequently rejected the Governor's proposed redesign and entered into an intense and rushed negotiation process with the administration and CDSS. The ultimate package of changes incorporated in SB 1041 is the result of those negotiations. A history of cuts to CalWORKs explains some of the negative reaction to 55 the administration's initial proposal to change aspects of the program. For example, in 2011, the lifetime limit on aid was reduced from 60 to 48 months. One state stakeholder noted that in response to the introduction of the CalWORKs WTW 24-month time clock, a central component of SB 1041, the legislature viewed it as a strategy to reduce the grant program yet again. While many state stakeholders we spoke with appreciated the flexibility offered to clients through SB 1041\u2014namely the elimination of core activities within the 24-month time clock period\u2014 other state stakeholders were concerned that many CalWORKs WTW participants would be unprepared to meet federal work requirements after exhausting their 24-month time clock and would fall off aid as a result. In contrast, CDSS staff with whom we spoke as part of our 2015 interviews did not consider SB 1041, in the words of one administrator, as a major sea change to the CalWORKs program. Instead, they viewed the legislation as a mechanism to more effectively help participants overcome barriers to self-sufficiency through early and intensive engagement and provision of flexible and individualized supportive services. One CDSS respondent described the general vision for the legislation: There should be a period where we say [to participants], What is it you want to do with your life and that will get you out of poverty, and how can we support you? Our hope was that that would mean . . . an increase in meaningful conversations between the workers and the clients about what they want in their lives and, very critically, about what their barriers are. Specific SB 1041 goals identified by CDSS administrators included the following: increased flexibility in the WTW flow (e.g., clients are not automatically moved into employment training and job search before assessment of their strengths and challenges) improvement in referral processes to supporting services, including reduction in wait times for clients increased use of supportive services (e.g., mental health and substance abuse) increased participation in education activities. Although CDSS administrators and some other state stakeholders with whom we spoke did not view SB 1041 as a dramatic change in the program, both groups recognized the varying opinions about the legislation. Interview respondents reported: There seems to be this feeling in the air like it's a bad thing. It's somehow a reduction of the program, and People believe that participants will be kicked off at the end of 24 months, rather than facing a change in participation requirements. The SB 1041 time clock was a topic where the perspectives of different stakeholders particularly varied. When a client exhausts his or her CalWORKs WTW 24-month time clock, some state stakeholders characterized it as an abrupt (and possibly premature) termination of services, placing the client at risk of sanction for failure to meet federal TANF requirements. For other state stakeholders, as well as CDSS staff, the end of the initial CalWORKs WTW 24- 56 month time period simply marked a return to federal TANF participation requirements that already existed prior to SB 1041. State-Level Planning Process and Communication Regarding SB 1041 CDSS staff and state stakeholders noted that CDSS supported an iterative workgroup process to craft SB 1041 guidance. There was broad agreement among respondents that CDSS's process to develop guidance for supporting implementation of SB 1041 was useful and productive. Participants in the workgroup included advocacy groups (Western Center on Law and Poverty, California Welfare Rights Organization), the County Welfare Directors Association, legislative staff, the California Community College Chancellor's Office, county representatives, and CDSS staff. As one state stakeholder noted, the people who needed to be at the table were there. The CDSS workgroup process was praised for its inclusiveness and detailed focus on implementation. Although perceptions about the impact of SB 1041 varied among those with whom we spoke at the state level, the majority of informants acknowledged that the legislation was complicated and as such, the workgroup intentionally and carefully vetted implementation guidance to get it right. As a result, state stakeholders and CDSS staff recognized that information was released slowly to counties and many issues required extended clarification. Implementation of SB 1041 began on January 1, 2013, while counties were still seeking out clarification about the details of the legislation from CDSS\u2014a cause of concern for several state- level stakeholders. Incremental changes to the regulations and data systems,31 as well as clarification on previously issued guidance, meant that county staff had to review previous cases and make corrections to WTW plans as appropriate. This theme\u2014 counties' uncertainty about initial guidance released by the state as they began to implement SB 1041 reforms\u2014was also expressed by respondents to the ACS (discussed in Chapter Four) and echoed many times by participants in the focal county interviews (discussed in Chapter Five). Factors Affecting the Initial Implementation of SB 1041 In discussing the factors that could support or hinder implementation of SB 1041, two topics received the most attention: the implementation of Early Engagement components and the WPR requirements. 31 The policy reforms created under SB 1041 required significant changes to the data systems that counties used to track CalWORKs participants. California's counties are grouped into three consortia, each of which uses a different data system\u2014LEADER, Cal-WIN, and C-IV. Representatives from all three consortia participated in the state SB 1041 workgroup process to develop guidance for counties and to change the data systems to meet the needs of the new legislation. The main challenge, as identified by staff across the three consortia, was the automation of the 24-month time clock, for a variety of reasons. 57 Implementation of Early Engagement Components SB 1041 was negotiated by legislators with the promise of several additional programs intended to support clients under the new reforms. Known as Early Engagement, this package of supports (discussed in Chapter One)\u2014 the OCAT, FS program, and ESE program\u2014was designed to identify and address individual client barriers, provide intensive services for those who need them, and support expanded employment opportunities. Many with whom we spoke\u2014both CDSS staff and other state stakeholders\u2014viewed Early Engagement as critical to the successful implementation of SB 1041. However, these programs (established under AB 74, 2013) were not implemented in the same time frame as SB 1041\u2014and, in fact, were not fully implemented in most counties until recently.32 When discussing Early Engagement, stakeholders placed the most emphasis on the importance of the OCAT, identifying it as critical to ensuring that the CalWORKs WTW 24- month time clock instituted through SB 1041 does not have a negative impact on participants. A state stakeholder characterized the OCAT as the key to knowing better than we now know what a family needs or wants, and the key to assessing in a broad and holistic way a family's strengths and needs . . . once we've done that, then we can, within 24 months, put a much better, more tailored, more family-focused package of services together. This respondent went on to say that it was difficult to imagine that we're going to see that vision of a fully actualized SB 1041 implementation at the ground level until the OCAT is at that level [fully actualized]. Other components of Early Engagement include the FS program, which as of January 1, 2014, provides intensive case management and services to a subset of CalWORKs participants with particularly challenging family situations. Family Stabilization services are designed to ensure a basic level of stability within a family prior to, or concurrent with, participation in WTW activities. State stakeholders were optimistic about the promise of the FS program, although they acknowledged it is still too early to gauge its impact. The ESE program is the third component of Early Engagement, a new CalWORKs WTW activity in which a participant's employer is partially or wholly reimbursed for wages, training costs, or both. ESE is intended to increase the number of subsidized employers and cannot be used to fund or supplement AB 98, the original Subsidized Employment program (CDSS, 2013c). Through ESE, state stakeholders hope, as reflected in the comments of one respondent, to grow a community of employers who are available and willing to help connect CalWORKs participants to the workforce. Eventually, ESE is expected to improve unsubsidized employment outcomes for clients. The lag between the implementation of Early Engagement and SB 1041 was a sore point for 32 Responses to the ACS administered in the spring of 2015 show that 69 percent of counties indicated they had an ESE program and 86 percent reported they offer Family Stabilization (see Chapter Four). 58 many state stakeholders with whom we spoke. Several expressed concern that Early Engagement was not implemented at the same time as SB 1041 and that it has not been rolled out at the same pace across all 58 counties. Given that the OCAT, FS program, and ESE program took longer to become fully operational, depending on the county,33 it was believed that many CalWORKs participants who are now close to timing out on their 24-month time clock did not receive the supports under Early Engagement that they should have had access to, or did not receive access to the supports early enough to fully benefit from the 24-month window to reach their self- sufficiency goals. WPR Requirements One of the factors that drove the development of SB 1041, according to a CDSS administrator, is the federal WPR requirement. As noted in Chapter One, a central component of the transition to TANF in 1996 was the introduction of WPR, which mandates that at least 50 percent of TANF cash assistance participants in a state must be engaged in work for 30 hours per week per month, or 20 hours for single parents with children under the age of six. State programs that are unable to meet the WPR may experience financial penalties. Each county contributes to California's overall WPR. If a federal penalty is enforced and a county is found to have contributed to the state's low WPR, they must contribute proportionally to the penalty payment from their county and general funds. California is one of 13 states and two territories that did not meet its target in 2012. To date, states have not paid their full WPR penalties, but given the financial risk, it remains a powerful motivator (Center for Law and Social Policy, 2015). Despite the fact that SB 1041 allows more CalWORKs participants to engage in noncore activities during their first 24 months on aid, most CDSS staff argue that SB 1041 will benefit the state's WPR in the long term by helping to reduce participants' barriers to employment and helping them make a more effective and lasting connection to the workforce. According to CDSS, the legislation allows CalWORKs participants to benefit from more flexibility in work requirements and access to services, so that they are better positioned in the long run to meet federal requirements sooner within their period on aid\u2014thus helping California to meet the target WPR. At the same time, the participation requirements in SB 1041 do not align with WPR. If a client chooses to meet his or her CalWORKs participation requirements with noncore activities, those activities do not contribute toward meeting the WPR. A CDSS staff member explained, There's some recognition that, perhaps in the short run, SB 1041 would maybe be a detriment to meeting WPR requirements. But over the course of time, people will be better positioned, more people will be meeting the WPR and it'll help us avoid the really significant penalties. 33 Specifically, five early user counties began using the OCAT in 2014, which was updated and then subsequently pilot-tested in five pilot counties. FS and ESE were rolled out and expected to be fully implemented statewide in state fiscal years 2014 2015 (CDSS, May 1, 2014). 59 This misalignment between federal TANF requirements and SB 1041 was of concern to state stakeholders, including welfare advocates, and also to the majority of caseworkers in the focal counties, as will be discussed in Chapter Five. Several state stakeholders reported that some counties may be encouraging participants to meet the federal TANF requirements, rather than the more-flexible requirements written into SB 1041, because they want to get their WPR rate at their county level up so that they are not liable. They're trying to help the state to [avoid] those penalties. State stakeholders noted that the perceived competition between SB 1041 and WPR is hindering implementation of SB 1041. A state-level respondent explained, The diversity and multiplicity of expectations [counties face] and the extent to which some of them work at cross purposes makes this very, very challenging. A welfare advocate said, You're dealing with a WTW program where counties are told that they have to meet the WPR, and the WPR means that 50 percent of the people would have to be meeting [and] doing core hours. And if they don't meet the WPR the counties could be penalized. The state gets penalized, the counties will be penalized . . . there's an inherent conflict over here of flexibility and meeting the Welfare-to-Work participation rates and nobody's addressed that. Discussions with state stakeholders (and county staff) suggests that the state has not clearly communicated how counties should prioritize SB 1041 versus WPR. That is, it is unclear whether counties should be working to meet federal requirements or to help clients take advantage of SB 1041 if it is in their best interest toward self-sufficiency. A state stakeholder said, I think just for counties it's that mixed message: Are we supposed to be work first ? Are we supposed to try and meet the WPR? Are we supposed to encourage people to meet federal [requirements] when they're able? Or are we supposed to say, No, you'll get a better job if you don't meet federal for a while. That's the key mixed message\u2014the county is being told, If this person could use a work plan that is not consistent with WPR to help them in the long run, give it to them. But, oh, by the way we're not meeting WPR, and you're liable if your county contributes. I think it's hard for the counties to come to terms with those messages. This issue clearly played out in our discussions with focal county caseworkers and is explored in detail in Chapter Five. Perceptions Regarding the Potential Long-Term Impact of SB 1041 Several state stakeholders and CDSS staff discussed the potential of SB 1041 to have a positive effect on how clients experience CalWORKs in terms of their initial engagement with the program, the activities available to them (including expanded educational opportunities), and their relationships with caseworkers. For example, prior to SB 1041, most clients moved first through what is known as Job Club\u2014a group setting to build the capacity of clients to search for 60 employment\u2014followed by the actual job search, and then assessment. Under SB 1041, clients do not have to participate in Job Club and job search before assessment\u2014counties can conduct a more expanded orientation with clients or refer them to Family Stabilization, as appropriate. SB 1041 provides flexibility in clients' initial engagement with the program. In addition, the state stakeholders and CDSS staff explained that OCAT is designed to provide an in-depth assessment of clients' strengths and needs and to identify appropriate services to meet those needs. To leverage the potential of the OCAT, caseworkers must engage with clients in a way that may be more intensive and meaningful than has been done previously and partner with them to develop an individualized WTW plan\u2014one that might focus on the pursuit of a degree or certification, as opposed to an immediate search for employment. This shift will require ongoing retraining to support caseworkers to help meet this new vision of CalWORKs. It is important to note that changing large public social systems such as CalWORKs takes time. In California, the welfare system is a county-administered system and implemented by staff across 58 county welfare offices, each of which maintains significant local governance authority, as well as relationships with community-based partners such as community colleges and other service providers. One state-level stakeholder said, The reality is, the culture or the infrastructure of the CalWORKs program had taken so many backward steps during the recession [reference to budget cuts to the WTW program and corresponding increase in exemptions], as did our partner agencies that are going to deliver all of these more flexible services, that the time it's going to take to really implement in terms of the broader definition\u2014 changing the culture, training your staff, integrating your services, reconnecting with and expanding the capacity of your community-based agencies and other service partners\u2014we have a ways to go. SB 1041 represents a shift toward an integrated system in which county services are integrated and responsive to the needs of clients\u2014as described by one state stakeholder, it will mean taking all of those pieces and weaving them together into a sensible, holistic whole. It's exciting. It's definitely what we need to be doing. 61 4. Initial Implementation of SB 1041 at the County Level: Results from the ACS The SB 1041 ACS was designed to gather information about the experiences of all 58 counties in planning for and implementing these reforms. More specifically, as summarized in the text box to the right (and detailed in Chapter Two), the survey obtained information about the status of implementation of different components of SB 1041, the organizational and administrative changes to facilitate implementation, the context within which implementation was occurring, barriers and facilitators to implementation, the design and implementation of the WTW time clocks, the way in which time remaining is communicated to CalWORKs participants, the FS and ESE programs, and the level of coordination between the CalWORKs program and other service providers (such as community colleges) at the county level. The survey provides information for these topics as of approximately July 2015. This chapter addresses the following questions associated with the process study. (We also preview the key findings from the survey.) What is the status of implementation of SB 1041 reforms to CalWORKs as of June 2015? Overall, most counties have completed the reengagement of participants with the short- term, young child exemption. With respect to the Early Engagement components, 86 percent of counties reported having implemented the FS program countywide and 69 percent reported they had implemented the ESE program countywide. To prepare for implementing SB 1041 support services, up to 60 percent of all the counties developed new or enhanced partnerships with education providers, vocational education\/job training providers, domestic violence service providers, substance abuse treatment providers, and mental health service providers. How did counties communicate the changes brought about by SB 1041 to other county agencies and service providers and to line staff (e.g., caseworkers, employment services specialists)? With respect to coordination activities, three-quarters of all county social services departments reported reaching out to individual directors or agency Chapter Four Methods Based on analysis of ACS administered in June July 2015; all 58 counties responded. Topics focused on aspects of planning for and implementing SB 1041. Analyzed using descriptive data methods reported in tables and charts. Results are reported in total and for counties stratified into three groups\u2014small, medium, and large\u2014based on CalWORKs caseload size: up to 999 assistance units; 1,000 to 4,999 assistance units; and 5,000 or more assistance units, respectively. See Chapter Two for more detail on data and methods. 62 representatives in other county agencies to plan for or implement support services under SB 1041. Counties communicated SB 1041's changes to the CalWORKs program to other county agencies predominantly via interagency or interdepartmental meetings. Counties communicated these changes to line staff by a variety of means, including memoranda and other written documents (81 percent), briefings and\/or internal staff meetings (93 percent), and mandatory training sessions (83 percent). How well did county staff understand those changes? Supervisors were asked to indicate how well their WTW caseworkers understood the different components of SB 1041 (e.g., determination of the CalWORKs WTW 24-month time clock, changes to required hours of participation, changes to the determination of hourly program participation). Overall, 83 percent of counties reported that their WTW caseworkers understood moderately well to very well the 24-month time clock. At the same time, 18 percent of counties reported that their WTW caseworkers did not understand at all or only slightly understood the 24- month time clock. Sixteen percent of counties indicated their WTW caseworkers did not understand at all or only slightly understood the changes to the determination of hourly program participation. Relative to the other components of SB 1041, these are the two components for which the prevalence was highest of counties indicating that their WTW caseworkers did not have as strong an understanding. How well did CalWORKs participants understand those changes? Supervisors in 67 percent of counties reported that CalWORKs participants did not understand at all or only slightly understood the changes represented by the 24-month time clock. On the other hand, they rated higher CalWORKs participants' understanding of other components of SB 1041: 66 percent of counties indicated that participants understood the new WTW participation requirements moderately to very well; 77 percent assessed that CalWORKs participants understood moderately to very well the increase in choices with respect to the activities they could participate in during the 24-month time clock period; 71 percent rated CalWORKs participants' understanding of the reengagement process for those that had short-term, young child exemptions as moderate to very well, and 48 percent rated participants' understanding of the new one-time young child exemption as moderate to very well. What factors facilitated or hindered initial implementation of SB 1041? Forty- five percent of counties reported that existing relationships with other county agencies facilitated implementation. Counties also pointed toward interagency committees and advisory groups that were very helpful in implementing reforms. Twenty-one percent of counties reported that the timing of the release of state guidance on SB 1041 was a moderate to major hindrance; smaller counties were more likely to report it being a moderate to major hindrance than medium-sized or large counties. Seventy-nine percent 63 of counties reported that explaining the complexity of SB 1041 to participants was a moderate or major hindrance. What are counties' assessment of the effects of SB 1041 on key outcomes and how well are SB 1041 reforms and related mandates working at the county level? Between 45 percent and 57 percent of counties estimated that the implementation of SB 1041 in the early years had no effect on WPR, participation in WTW activities, compliance with CalWORKs program rules, earnings, participation in CalFresh, or the number of participants receiving sanctions. At the same time, between 36 and 40 percent of counties reported that participation in WTW activities and enrollment in education and training programs\/community colleges was somewhat better under SB 1041. In addition, 78 percent of counties indicated that communication of the new rules was working moderately well to very well, despite earlier survey responses citing the challenges of communicating the new rules to CalWORKs participants. Also, 85 percent of counties indicated that matching CalWORKs participants with appropriate WTW activities was working moderately well to very well. What are the key challenges facing counties? The lack of full automation of the 24-month time clock was viewed as a minor, moderate, or major hindrance to implementation by 36 percent of counties; this was especially true for smaller counties, where 50 percent indicated this to be the case. Overall, 60 percent of all counties reported that the 24- month time clock is currently being calculated using both an automated system and manually. Counties with larger CalWORKs caseloads were more likely to use a combination of automated and manual calculation than counties with smaller or medium- sized caseloads, many of which primarily relied on manual calculation. Caseworkers play an important role in the calculation of how much time is left on the CalWORKs participants' 24-month time clock. Ninety-three percent of counties indicated WTW caseworkers were responsible for doing so on a monthly basis for their caseloads. Yet, this was the component most counties reported that their WTW caseworkers did not understand well. Thirty-seven counties provided written recommendations for improving SB 1041\u2014the majority of recommendations centered on the need for clearer guidance on and suggested improvements to the 24-month time clock. In the rest of this chapter, we detail findings specific to the research questions above. We begin with an overview of the status of implementation of SB 1041's components, including organizational changes made, communication activities, and factors affecting implementation. We then present findings specific to the 24-month time clock, including how it is being calculated, whether lack of automation of its calculation was viewed as a hindrance to implementation, who is responsible for calculating how much time a CalWORKs participant has left on the 24-month time clock, and supervisors' assessment of how well caseworkers and participants understood the 24-month time clock, to the required hours of participation, and to 64 the determination of hourly program participation. Next, we present findings on counties' assessment of caseworkers' and participants' understanding of the other components of SB 1041. We also discuss survey results related to Early Engagement activities (ESE and FS programs) and on the effectiveness of different reengagement strategies for individuals. We conclude with counties' views regarding the impact of SB 1041 on the CalWORKs program and on participant outcomes, and the effectiveness of SB 1041 reforms and related mandates at the county level. Lastly, we summarize counties' feedback on their information needs and suggestions for improving SB 1041. Appendix D presents additional survey results regarding the provision of and capacity to provide services related to employment, education and training, and supportive services. Status of Implementation of SB 1041's Components The 58 counties were asked to report on the current stage of implementation of the components of SB 1041 reforms to the CalWORKs program in their county, including the status of related programs (the FS and ESE programs). Note that status of the implementation of the 24-month time clock and related mandates is reported separately below. Fifty-six counties (97 percent) reported that they had completed the countywide reengagement of the short-term, young child exemption population (Table 4.1). With respect to the Early Engagement components, 86 percent of counties reported that they had implemented the FS program countywide and 69 percent reported they had implemented the ESE program countywide.34 With respect to developing new or enhanced partnerships, 57 percent to 60 percent of all counties reported that they had done so with education providers, vocational education\/job training providers, domestic violence service providers, substance abuse treatment providers, and mental health service providers. Large counties were more likely (72 percent to 78 percent) to develop new or enhanced partnerships with these providers than small or medium-sized counties. Organizational Changes Resulting from SB 1041 The counties were asked whether in 2013 and\/or 2014, their county's social services department had implemented any of the organizational or administrative changes shown in Figure 4.1 in response to SB 1041 or to related legislation.35 Among all counties (black bars), 55 percent indicated they created new units (e.g., specialized case management or reengagement units) (Figure 4.1). This varied by size of county: 55 percent of medium-sized and 83 percent of large 34 Note that the denominator is all 58 counties. If we use the 57 counties that reported they had an FS program as the denominator, 93 percent of counties with an FS program reported they had implemented it countywide. Likewise, if we use 43 counties that reported they had an ESE program as the denominator, 88 percent (40 out 43) of counties with an ESE program reported they had implemented it countywide. 35 Related legislation includes AB 74, which established the FS and ESE programs. 65 Table 4.1. Status of Implementation of SB 1041 Components and Related Mandates by June 2015: All Counties and by County Caseload Size Number of Responding Counties in Total County Has Program Component Implemented Program Component All Counties Small Counties Medium Counties Large Counties Reengagement of AB X4 4 short-term young child exemption population Number 58 56 19 19 18 Percentage 97% 95% 95% 100% New\/enhanced partnerships with education providers (e.g., community colleges) Number 58 35 11 11 13 Percentage 60% 55% 55% 72% New\/enhanced partnerships with vocational education\/job training providers Number 58 33 10 10 13 Percentage 57% 50% 50% 72% New\/enhanced partnerships with domestic violence service providers Number 57 33 9 10 14 Percentage 58% 45% 53% 78% New\/enhanced partnerships with substance abuse treatment providers Number 58 34 9 11 14 Percentage 59% 45% 55% 78% New\/enhanced partnerships with mental health services Number 56 33 8 11 14 Percentage 59% 42% 58% 78% ESE program Number 58 40 10 13 17 Percentage 69% 50% 65% 94% FS program Number 58 50 17 18 15 Percentage 86% 85% 90% 83% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer per program component (not shown, the other options were not planned\/designed, program planning\/design in progress, piloted in selected districts\/regional offices. We report here the results for the option program component implemented countywide by June 2015. Percentages are calculated using the number of counties responding to the question as the denominator. counties indicated they had done so, compared with only 30 percent of small counties. Forty- five percent reassigned existing units, with medium-sized and large counties more likely to have done so than small counties. 66 With respect to staffing changes, 45 percent of counties paid staff overtime to revise and\/or calculate participants' 24-month time clock status, and 36 percent paid staff overtime to implement the reengagement process (Figure 4.1). Large counties, in particular, were more likely to pay staff overtime for these two activities than medium-sized or small counties. One county reported hiring additional staff to conduct the reengagement process. Also, 31 percent of Figure 4.1. Organizational or Administrative Changes in Response to SB 1041 or Related Legislation: All Counties and by County Caseload Size 67 SOURCE: Authors' analysis of ACS data. NOTE: N=58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. counties colocated welfare staff with other county agencies to implement SB 1041 and related legislation. 55 45 31 3 21 26 22 45 36 18 30 30 25 5 11 10 25 35 35 13 55 55 30 5 25 35 25 40 20 14 83 50 39 0 28 33 17 61 56 25 0 20 40 60 80 100 Created new units (e.g., specialized management or reengagement units) Reassigned existing units Colocated welfare staff with other county agencies Opened new regional office locations Enhanced regional office locations Shifted funding from one unit or program to another Pooled funding across county agencies to provide services to CalWORKs participants Paid staff overtime to revise and\/or calculate participants' WTW 24-month time clock status Paid staff overtime to implement the reengagement process Other Percentage Ty pe o f o rg an iz at io na l o r a dm in is tr at iv e ch an ge All counties Small Medium Large 68 Only two counties (one small and one medium-sized) indicated that they opened new regional office locations, whereas 21 percent of counties indicated they enhanced regional office locations in response to SB 1041 and related legislation. With respect to funding, 26 percent of counties reported shifting funding from one unit or program to another and 22 percent reported pooling funding across county agencies to provide services to CalWORKs participants under SB 1041 and its related mandates (Figure 4.1). Large counties were more likely to shift funding from one unit or program to another but less likely than the other sized counties to pool funding from across county agencies. Communication Regarding SB 1041 We asked the counties how they communicated SB 1041's changes to the CalWORKs program to other county agencies. The predominant way was via interagency or interdepartmental meetings (Figure 4.2). Fifty-five percent of counties also reported they did so via briefings, and Figure 4.2. County Communication of SB 1040's Changes: All Counties and by County Caseload Size SOURCE: Authors' analysis of ACS data. NOTE: N=58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. 40 55 93 53 9 20 40 90 20 0 35 60 90 60 10 67 67 100 83 17 0 20 40 60 80 100 Memoranda, letters, or administrative directives Briefings Interagency or interdepartmental meetings Interagency working groups Other Percentage M et ho d of c om m un ic at io n All counties Small Medium Large 69 53 percent via interagency working groups. Forty percent of counties utilized memoranda, letters, or administrative directives to communicate about the changes to the CalWORKs program as a result of SB 1041. With respect to the use of briefings, interagency working groups, and written communication, we see a distinct difference by county size. Counties with medium- sized and large caseloads were more likely to use these mechanisms than smaller counties. We also asked what coordination activities county social services departments had undertaken since the passage of SB 1041 in June 2012 with other county agencies to plan for or to implement CalWORKs support services (e.g., housing, child care, mental health, drug treatment, domestic violence services). Three-quarters of county social services departments reported reaching out to individual directors or agency representatives in other county agencies to plan for or implement support services under SB 1041 (Figure 4.3). In addition, 45 percent convened an interagency planning meeting and 39 percent established an interagency working group. Figure 4.3. Coordination Activities County Social Services Departments Undertook to Plan for or Implement SB 1041: All Counties and by County Caseload Size SOURCE: Authors' analysis of ACS data. NOTE: N=58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. 45 39 77 18 45 21 79 0 30 45 75 31 61 50 78 19 0 20 40 60 80 100 Convened an interagency planning meeting Established an interagency working group Reached out to individual directors or agency representatives Other Percentage M et ho d of c oo rd in at io n All counties Small Medium Large 70 Several questions in the ACS were directed to supervisors of line staff. One question concerned how their department communicated SB 1041 changes to line staff in the program. Supervisors communicated these changes to line staff using a variety of means, including memoranda and other written documents (81 percent of counties), briefings and\/or internal staff meetings (93 percent of counties), and mandatory training sessions (83 percent of counties) (Figure 4.4). Counties with smaller caseloads were less likely to utilize memoranda and other written documents and mandatory training sessions than the two groups of counties with larger caseloads. Figure 4.4. Communication of SB 1041's Changes by Supervisors to CalWORKs Line Staff: All Counties and by County Caseload Size SOURCE: Authors' analysis of ACS data. NOTE: N=58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. Factors Affecting the Initial Implementation of SB 1041 As noted in Chapter Three, the guidance from CDSS evolved over time, and as will be discussed in Chapter Five, the focal counties reported that the timing of the release of state guidance made it challenging to implement the different components of SB 1041. In the ACS, we gathered information from all 58 counties about which factors affected the initial implementation of SB 1041. With respect to the 58 counties, 55 percent reported that the timing of the state's guidance was not a hindrance in terms of implementation (Table 4.2). However, 45 percent of 81 93 83 9 50 85 50 0 100 100 100 15 94 94 100 11 0 20 40 60 80 100 Memoranda and other written documents Briefings and\/or internal staff meetings Mandatory training sessions Other Percentage M et ho d of c om m un ic at io n All counties Small Medium Large 71 Table 4.2. Whether Timing of State Guidance on SB 1041 to Counties Hindered Implementation: All Counties and by County Caseload Size Group and Indicator Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Total All counties Number 32 14 5 7 58 Percentage distribution 55% 24% 9% 12% 100% Small counties Number 7 5 1 7 20 Percentage distribution 35% 25% 5% 35% 100% Medium counties Number 13 5 2 0 20 Percentage distribution 65% 25% 10% 0% 100% Large counties Number 12 4 2 0 18 Percentage distribution 67% 22% 11% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer on the Likert scale. Percentages are calculated using the number of counties responding to the question as the denominator. counties reported it was a hindrance; with smaller counties being more likely to report this than medium-sized to large counties. This result may be driven partly by the fact that smaller counties were less likely to have participated in the state workgroup planning process. In terms of the complexity of SB 1041 reforms, 52 percent of counties reported that it was not a hindrance in terms of implementation (Table 4.3). However, 48 percent of counties reported it Table 4.3. Whether Complexity of SB 1041 Reforms Hindered Implementation: All Counties and by County Caseload Size Group and Indicator Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Total All counties Number 30 21 5 2 58 Percentage distribution 52% 36% 9% 3% 100% Small counties Number 7 8 3 2 20 Percentage distribution 35% 40% 15% 10% 100% Medium-sized counties Number 11 8 1 0 20 Percentage distribution 55% 40% 5% 0% 100% Large counties Number 12 5 1 0 18 Percentage distribution 67% 28% 6% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer on the Likert scale. Percentages are calculated using the number of counties responding to the question as the denominator. 72 was at least a minor hindrance to implementation; smaller counties were more likely to report this (65 percent) than counties with medium to large caseloads (45 percent and 33 percent, respectively). Table 4.4 addresses a series of other potential implementation challenges. Among all counties, 79 percent reported that explaining the complexity of SB 1041 to participants was a moderate or major hindrance. Seventy-six percent of counties reported that availability of Table 4.4. Whether Issues Hindered Implementation: All Counties and by County Caseload Size Number of Responding Counties in Total County Rated Issue as a Moderate or Major Hindrance Issues All Counties Small Counties Medium Counties Large Counties Availability of job opportunities for CalWORKs participants Number 58 41 17 13 11 Percentage 71% 85% 65% 61% Availability of educational opportunities for CalWORKs participants Number 58 18 12 3 3 Percentage 31% 60% 15% 17% Availability of vocational education or on the job training opportunities for CalWORKs participants Number 58 22 14 5 3 Percentage 38% 70% 25% 17% Availability of financial resources for CalWORKs participants Number 58 13 5 4 4 Percentage 22% 25% 20% 22% Availability of child care services for CalWORKs participants Number 58 8 5 3 0 Percentage 14% 25% 15% 0% Availability of affordable housing for CalWORKs participants Number 58 44 17 15 12 Percentage 76% 85% 75% 67% Availability of transportation options or transportation resources for CalWORKs participants Number 58 25 12 10 3 Percentage 43% 60% 50% 17% Competition with other state\/federal mandates (e.g., Medi-Cal expansion) Number 58 26 9 10 7 Percentage 45% 45% 50% 39% Availability of line staff (e.g., caseworkers, employment services specialists) who work with and\/or counsel WTW participants Number 58 33 12 13 8 Percentage 57% 60% 65% 44% 73 Table 4.4\u2014Continued Number of Responding Counties in Total County Rated Issue as a Moderate or Major Hindrance Issues All Counties Small Counties Medium Counties Large Counties Explaining the complexity of SB 1041 to participants Number 58 46 13 16 17 Percentage 79% 65% 80% 94% Prior staff reductions\/freezes in staff and\/or funding Number 58 18 4 8 6 Percentage 31% 20% 40% 33% Other Number 40 12 2 5 5 Percentage 21% 10% 25% 28% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Percentages are calculated using the number of counties responding to the question as the denominator. Appendix Table D.1 provides results for responses across the full Likert scale. affordable housing for CalWORKs participants and 71 percent of counties reported that availability of job opportunities for CalWORKs participants was a moderate or major hindrance. Fifty-seven percent of counties reported that availability of line staff who work with and\/or counsel WTW participants was a major or moderate hindrance to implementation. Forty- three percent cited availability of transportation options or transportation resources for CalWORKs participants and 38 percent reported availability of vocational education or on-the- job training opportunities as being moderate to major hindrances. In addition, 45 percent of counties reported that competition with other state\/federal mandates (e.g., Medi-Cal expansion) was a hindrance to implementation. Fewer counties reported that availability of financial resources for CalWORKs participants (22 percent of counties) and prior staff reductions\/freezes in staff and\/or funding (31 percent of counties) were a hindrance with respect to implementation of SB 1041 reforms. Somewhat surprisingly, only 14 percent of counties reported that availability of child care services for CalWORKs participants was a moderate or major hindrance to implementation. With respect to facilitators, we asked the counties whether existing relationships or partnerships with various types of organizations facilitated or not the implementation of SB 1041 reforms in their county. Overall, 45 percent of counties indicated that existing relationships with other county agencies such as mental health, behavioral health, child support services, housing agency, etc., were a moderate or major facilitator for putting into place the changes to the CalWORKs program that SB 1041 represented (Table 4.5). Counties also pointed to interagency committees and advisory groups as being very helpful in implementing reforms. For example, one county commented that 74 Table 4.5. Whether Existing Relationships or Partnerships with Organizations or Providers Facilitated Implementation: All Counties and by County Caseload Size Number of Responding Counties in Total County Rated Partnership as a Moderate or Major Facilitator Organization or Provider All Counties Small Counties Medium Counties Large Counties Other county agencies (e.g., mental health, behavioral health, child support services, housing agency) Number 58 26 6 8 12 Percentage 45% 30% 40% 67% Educational providers (e.g., community colleges) Number 58 18 4 7 7 Percentage 31% 20% 35% 39% Vocational education or on the job training providers Number 58 16 5 4 7 Percentage 28% 25% 20% 39% Employment services or job placement providers Number 57 27 8 9 10 Percentage 47% 40% 45% 56% Community organizations and\/or welfare advocacy organizations Number 58 13 2 4 7 Percentage 22% 10% 20% 39% State organizations (e.g., CDSS, CWDA) Number 58 31 7 13 11 Percentage 53% 35% 65% 61% Other Number 38 4 1 0 3 Percentage 7% 5% 0% 16% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Percentages are calculated using the number of counties responding to the question as the denominator. Appendix Table D.2 provides results for responses across the full Likert scale. The CalWORKs County Advisory Team and CalWORKs Policy Committee were both major facilitators for the implementation of SB 1041. These groups provided a forum where counties could learn from each other and obtain critical policy and procedural clarification from CDSS. With respect to service providers, 31 percent of counties reported that existing relationships or partnerships with educational providers such as community colleges facilitated implementation of SB 1041 (Table 4.5). In addition, 47 percent of counties cited existing relationships or partnerships with employment services or job placement providers and 28 percent of counties cited relationships or partnerships with vocational education or on-the-job training providers as being facilitators; medium-sized and large counties, in particular, reported that these relationships were important facilitators. With respect to community organizations, 22 percent of counties indicated that existing relationships with community organizations, welfare advocacy 75 organizations, or both also facilitated implementation of SB 1041 reforms, with large counties particularly noting the role of these organizations. In the write-in comments for this item in the questionnaire, one large county noted, Our county has strong collaboration with internal and external community partners. Fifty-three percent of counties also reported that existing relationships with state organizations such as CDSS and the CWDA facilitated implementation of the SB 1041 reforms (Table 4.5). Thirty counties cited the CWDA in their write-in comments as playing a critical role in facilitating implementation: A small county commented, CWDA has helped [us] to understand the requirements and expectations of these changes. A large county commented, The CWDA worked as an advocate for county issues and concerns regarding implementation of SB 1041 program components. A medium-sized county commented, CWDA was instrumental in connecting our agency with others also implementing programs. They also facilitated discussions with the State and legislative analysts, and provided excellent updated information and strategy discussions at CWDA meetings. Most recently, they facilitated a webinar on WPR that included ideas for Subsidized Employment programs. In addition, the counties cited CDSS as being an important facilitator and said CDSS worked closely with CWDA in that process. As explained by one medium-sized county, CWDA and CDSS worked in partnership to provide necessary guidance to counties in the implementation of SB 1041. CalWORKs WTW 24-Month Time Clock The 58 counties were asked how the 24-month time clock is being calculated within their county. Sixty percent of all counties indicated that it was being calculated both using an automated system and manually (Table 4.6). Counties with larger CalWORKs caseloads were more likely to use a combination of automated and manual calculation than counties with smaller or medium-sized caseloads, many of which primarily relied on manual calculation. Twenty-five percent of small counties and 15 percent of medium-sized counties indicated that they relied solely on manual calculation of the 24-month time clock. Sixty-four percent of all counties reported that lack of automation of the 24-month time clock was not a hindrance in implementation (Table 4.7). Conversely, 37 percent of counties reported that lack of automation of the 24-month time clock was a minor, moderate, or major hindrance; this was especially true for smaller counties, where 50 percent indicated it was at least a minor barrier. 76 Table 4.6. System Used for Calculating 24-Month Time Clock: All Counties and by County Caseload Size Group and Indicator Manual Automated Both Total All counties Number 10 13 35 58 Percentage distribution 17% 22% 60% 100% Small counties Number 5 6 9 20 Percentage distribution 25% 30% 45% 100% Medium-sized counties Number 3 6 11 20 Percentage distribution 15% 30% 55% 100% Large counties Number 2 1 15 18 Percentage distribution 11% 6% 83% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. The caseworkers play an important role in the calculation of how much time CalWORKs participants have left on their 24-month time clocks. In terms of who is responsible for calculating the 24-month time clocks in their county, 93 percent of counties indicated WTW caseworkers were responsible for doing so on a monthly basis for their caseloads (Figure 4.5). Overall, 19 percent of counties indicated that supervisors of caseworker staff calculate or reconcile participants' time clocks on a monthly basis. Four counties (7 percent) indicated that a Table 4.7. Whether Lack of Automation of the CalWORKs WTW 24-Month Time Clock Hindered Implementation: All Counties and by County Caseload Size Group and Indicator Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Not Applicable Total All counties Number 37 9 8 4 0 58 Percentage distribution 64% 16% 14% 7% 0% 100% Small counties Number 10 3 3 4 0 20 Percentage distribution 50% 15% 15% 20% 0% 100% Medium-sized counties Number 13 3 4 0 0 20 Percentage distribution 65% 15% 20% 0% 0% 100% Large counties Number 14 3 1 0 0 18 Percentage distribution 78% 17% 6% 0% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer on the Likert scale. Percentages are calculated using the number of counties responding to the question as the denominator. 77 special group of staff was tasked with the initial calculation of participants' time clocks and 7 percent indicated that a special group of staff was tasked with ongoing calculation of participants' time clocks.36 Figure 4.5. Who Is Responsible for Calculating How Much Time CalWORKs Participants Have Left on Their 24-Month Time Clock: All Counties and by County Caseload Size SOURCE: Authors' analysis of ACS data. NOTE: N=58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Respondents were instructed to mark all that apply. 36 Three counties reported using a special group of staff for both the initial calculation of the time clock and the ongoing calculation of the time clock. One county reported using only the first approach and another county reported using only the second approach. 7 7 19 93 19 0 5 25 85 10 15 10 20 100 25 6 6 11 94 22 0 20 40 60 80 100 A special group of staff was tasked with the initial calculation of participants' time clock A special group of staff was tasked with ongoing calculation of participants' time clock Supervisors of caseworker staff calculate or reconcile participants' time clock on a monthly basis WTW caseworkers calculate participants' time clock on a monthly basis for their caseload Other Percentage W ho is re sp on si bl e All counties Small Medium Large 78 Supervisors were asked to indicate how well their WTW caseworkers understood three key features of SB 1041: determination of the WTW 24-month time clock, changes to the required hours of participation due to the SB 1041 reforms, and changes to the determination of hourly program participation due to the new averaging method.37 Among all counties, 18 percent reported that their WTW caseworkers did not understand or only slightly understood the 24- month time clock (Table 4.8). Fifteen percent of counties indicated their WTW caseworkers did not understand or only slightly understood the changes to the determination of hourly program participation due to the new averaging method. In contrast, all but one county indicated that their WTW caseworkers understood the changes to the required hours of participation at least moderately well to very well. Relative to the other components of SB 1041 reported in Tables 4.8 and 4.10 (discussed later), it was these two components\u2014the 24-month time clock and changes to the determination of hourly program participation\u2014that were most frequently identified by counties as aspects of SB 1041 for which their WTW caseworkers did not have at least a moderate understanding. Table 4.8. Supervisors' Assessment of How Well WTW Caseworkers Understand Three Key SB 1041 Policy Changes: All Counties and by County Caseload Size Policy Change Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Determination of a client's WTW 24-month time clock All counties Number 1 9 39 9 0 58 Percentage distribution 2% 16% 67% 16% 0% 100% Small counties Number 1 2 15 2 0 20 Percentage distribution 5% 10% 75% 10% 0% 100% Medium-sized counties Number 0 3 11 6 0 20 Percentage distribution 0% 15% 55% 30% 0% 100% Large counties Number 0 4 13 1 0 18 Percentage distribution 0% 22% 72% 6% 0% 100% 37 Prior to November 2014, caseworkers were instructed to simply count up the total number of noncore participation hours in CalWORKs activities that a case had completed to determine if a client had met the minimum weekly hours under the 24-month time-clock plan. If a CalWORKs participant had completed at least 20 hours each week of the month, then he or she met the requirements. Under new direction from CDSS (released in November 2014), caseworkers were to use an averaging methodology to determine if a client was meeting the minimum weekly hours under the 24-month time-clock plan. The weekly average is calculated by adding the total number of participation hours in all CalWORKs activities for the month, dividing by 4.33, then rounding to the nearest whole number (CDSS, November 14, 2014h). See Appendix A for more detail. 79 Table 4.8\u2014Continued Policy Change Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Changes to the required hours of participation All counties Number 0 1 24 33 0 58 Percentage distribution 0% 2% 41% 57% 0% 100% Small counties Number 0 0 8 12 0 20 Percentage distribution 0% 0% 40% 60% 0% 100% Medium-sized counties Number 0 0 6 14 0 20 Percentage distribution 0% 0% 30% 70% 0% 100% Large counties Number 0 1 10 7 0 18 Percentage distribution 0% 6% 56% 39% 0% 100% Changes to the determination of hourly program participation due to the new averaging method All counties Number 2 7 27 22 0 58 Percentage distribution 3% 12% 47% 38% 0% 100% Small counties Number 2 1 11 6 0 20 Percentage distribution 10% 5% 55% 30% 0% 100% Medium-sized counties Number 0 4 9 7 0 20 Percentage distribution 0% 20% 45% 35% 0% 100% Large counties Number 0 2 7 9 0 18 Percentage distribution 0% 11% 39% 50% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer on the Likert scale per policy change. Percentages are calculated using the number of counties responding to the question as the denominator. In comparison, counties indicated that CalWORKs participants' understanding of the WTW 24-month time clock was even weaker. Supervisors in 67 percent of all counties reported that CalWORKs participants did not understand at all or only slightly the changes represented by the 24-month time clock (Table 4.9), an issue that holds regardless of county size. Understanding of Other Components of SB 1041 Supervisors were asked to assess the understanding of other components of SB 1041, for both caseworkers and participants. In the tables that follow, because we report responses across the full Likert scale, we have tabulated the totals across all counties. See Appendix D for the results disaggregated by county size. 80 Table 4.9. Supervisors' Assessment of How Well CalWORKs Participants Understand the 24-Month Time Clock: All Counties and by County Caseload Size Policy Change Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total All counties Number 14 25 16 3 0 58 Percent 24% 43% 28% 5% 0% 100% Small counties Number 7 7 5 1 0 20 Percentage distribution 35% 35% 25% 5% 0% 100% Medium-sized counties Number 4 9 6 1 0 20 Percentage distribution 20% 45% 30% 5% 0% 100% Large counties Number 3 9 5 1 0 18 Percentage distribution 17% 50% 28% 6% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer on the Likert scale. Percentages are calculated using the number of counties responding to the question as the denominator. WTW Caseworkers' Understanding of Other SB 1041 Components Compared with the findings in Table 4.8, supervisors reported that WTW caseworkers have a stronger understanding of the other components of SB 1041 and related supports. Nearly all counties reported that WTW caseworkers understood moderately well or very well the enhanced educational flexibility, that there are more choices now in WTW activities, the new one-time young child exemption, and the reengagement process (Table 4.10). Similarly, most counties reported that WTW caseworkers understood the ESE and FS programs moderately to very well. WTW Participants' Understanding of Other SB 1041 Components Earlier we noted that supervisors in 67 percent of the counties reported that they believed CalWORKs participants did not understand at all or only slightly understood the changes represented by the 24-month time clock (Table 4.9). Table 4.11 records the results of supervisors' assessments of how well CalWORKs participants understand the other components of SB 1041. 81 Table 4.10. Supervisors' Assessment of How Well WTW Caseworkers Understand Other SB 1041 Changes and Related Supports: All Counties Policy Change Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Enhanced educational flexibility Number 0 1 39 18 0 58 Percentage distribution 0% 2% 67% 31% 0% 100% There are more choices now in WTW activities Number 0 1 23 33 1 58 Percentage distribution 0% 2% 40% 57% 2% 100% New one-time young child exemption Number 0 0 12 46 0 58 Percentage distribution 0% 0% 21% 79% 0% 100% Reengagement process (AB X4 4) Number 0 2 22 34 0 58 Percentage distribution 0% 3% 38% 59% 0% 100% ESE program Number 0 4 24 22 8 58 Percentage distribution 0% 7% 41% 38% 14% 100% FS program Number 0 9 28 20 1 58 Percentage distribution 0% 16% 48% 34% 2% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer on the Likert scale per policy change. Percentages are calculated using the number of counties responding to the question as the denominator. Appendix Table D.3 provides results separately for small, medium, and large counties. With respect to the new WTW participation requirements, 66 percent of counties indicated that participants understood them moderately well to very well (Table 4.11). Seventy- three percent of supervisors in counties assessed that CalWORKs participants understood moderately well to very well the increase in choices with respect to the activities they can participate in during the 24-month time-clock period. Seventy-one percent indicated that CalWORKs participants understood the reengagement process for those who had a short-term, young child exemption moderately well to very well and 83 percent suggested that participants understood the new one-time young child exemption moderately well to very well. As noted earlier, supervisors rated CalWORKs participants' understanding of the 24-month time clock far lower, with only one-third assessing that participants understood the process moderately to very well. 82 Table 4.11. Supervisors' Assessment of How Well CalWORKs Participants Understand SB 1041 Changes: All Counties SB 1041 Component Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total New WTW participation requirements Number 2 17 31 7 0 57 Percentage distribution 4% 30% 54% 12% 0% 100% Increase in choices with respect to the activities they can participate in during the 24-month time clock period Number 3 12 31 10 0 56 Percentage distribution 5% 21% 55% 18% 0% 100% Reengagement process for those who had short-term young child exemption (AB X4 4) Number 4 10 25 16 3 58 Percentage distribution 7% 17% 43% 28% 5% 100% New one-time young child exemption Number 1 9 21 27 0 58 Percentage distribution 2% 16% 36% 47% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer on the Likert scale per component. Percentages are calculated using the number of counties responding to the question as the denominator. Appendix Table D.4 provides results separately for small, medium, and large counties. Early Engagement Activities The Early Engagement activities include the ESE and FS programs, both established under AB 74 (see Chapter One). Below we present results for questions in the ACS related to both programs. Expanded Subsidized Employment (ESE) Program Seventy-four percent of all counties indicated that they were participating in the ESE program at the time of the survey (Table 4.12). Nine percent indicated that they had opted out of the program and 17 percent responded that they were planning to or were in the process of developing a program. By size of county, smaller counties were less likely to be participating in the ESE program (55 percent) compared with medium-sized or large counties where the participation rate was 75 percent and 94 percent, respectively. Among the nine counties with small caseloads and no ESE program, six reported that they were planning to or were in the process of developing a program for their county. 83 Table 4.12. Participation in the ESE Program: All Counties and by County Caseload Size Group and Indicator Yes No, Opted Out No, but Planning to Join Total All counties Number 43 5 10 58 Percentage distribution 74% 9% 17% 100% Small counties Number 11 3 6 20 Percentage distribution 55% 15% 30% 100% Medium-sized counties Number 15 2 3 20 Percentage distribution 75% 10% 15% 100% Large counties Number 17 0 1 18 Percentage distribution 94% 0% 6% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium- sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. Of the 43 counties that were participating in the ESE program at the time of the survey, 58 percent contracted out services for their ESE program, instead of having their county welfare department directly responsible for implementing those services (Table 4.13). Among the smaller counties, 36 percent contracted out services for their ESE program, a lower rate than medium-sized counties (53 percent) and large counties (76 percent). Table 4.13. Among Counties with an ESE Program, Those That Contract Out ESE Services: Overall and by County Caseload Size Group and Indicator Contracts Out ESE Program Does Not Contract Out ESE Program Total Overall Number 25 18 43 Percentage distribution 58% 42% 100% Small counties Number 4 7 11 Percentage distribution 36% 64% 100% Medium-sized counties Number 8 7 15 Percentage distribution 53% 47% 100% Large counties Number 13 4 17 Percentage distribution 76% 24% 100% SOURCE: Authors' analysis of ACS data. NOTE: Analysis is for the 43 counties that have an ESE program. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. 84 Table 4.14 reports the programs offered by the 43 counties that have an ESE program. For those counties with ESE programs, nine out of ten offered ESE participants paid work experiences with private for-profit organizations, the business sector, or private nonprofit agencies (Table 4.14). Sixty-five percent of counties offered participants exempt from WTW volunteer opportunities in the county's ESE program. Job Club was not a part of many of the ESE programs, with only 40 percent of counties indicating this was the case and the large counties, in particular, less likely to include Job Club as part of their programs. Table 4.14. Among Counties with an ESE Program, Program Options Offered: Overall and by County Caseload Size Number of Responding Counties County Has ESE Program Option Listed Program Option Offered Overall Small Counties Medium Counties Large Counties Paid work experience with county and local government agencies Number 43 30 7 13 10 Percentage 70% 64% 87% 59% Paid work experience with private for-profit organizations or the business sector Number 43 39 9 15 15 Percentage 91% 82% 100% 88% Paid work experiences with private nonprofit agencies Number 43 39 9 15 15 Percentage 91% 82% 100% 88% Job Club Number 43 17 5 7 5 Percentage 40% 45% 47% 29% Participants exempt from WTW are offered volunteer opportunities in the ESE program Number 43 28 5 10 13 Percentage 65% 45% 67% 76% Other Number 43 6 1 1 4 Percentage 14% 9% 7% 24% SOURCE: Authors' analysis of ACS data. NOTE: Analysis is for the 43 counties that have an ESE program. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. Percentages are calculated using the number of counties responding to the question as the denominator. Family Stabilization (FS) Program Overall, 57 of the 58 counties (98 percent) reported that they had an FS program at the time of our 2015 survey (results not shown). Table 4.15 shows the types of services the counties with an FS program offered. All of the counties with an FS program reported increasing the level and\/or intensity of case management and 96 percent indicated they offered treatment of family members of CalWORKs participants (Table 4.15). With respect to treatment services, 93 percent offer 85 substance abuse counseling and treatment and 70 percent offer day treatment, nonmedical outpatient drug-free treatment, or residential treatment for FS program participants. Small counties in particular seem to have more resource constraints compared to other-sized counties to successfully implement the FS program (e.g., small counties are less likely than other counties to have offered transitional housing, rehabilitative services, and intensive drug treatment as part of this program). With respect to meeting housing needs, 82 percent of counties with FS programs indicated they offered emergency shelter and 72 percent offered movement to transitional housing. Table 4.15. Services Currently Offered as Part of the FS Program: Overall and by County Caseload Size Number of Responding Counties County Has FS Program Service Program Service Offered Overall Small Counties Medium Counties Large Counties Increased level and\/or intensity of case management Number 57 57 19 20 18 Percentage 100% 100% 100% 100% Treatment of family members of CalWORKs participants Number 56 54 17 20 17 Percentage 96% 89% 100% 100% Intensive day treatment, nonmedical outpatient drug free treatment, or residential treatment Number 57 40 10 16 14 Percentage 70% 53% 80% 78% Emergency shelter Number 56 46 15 17 14 Percentage 82% 83% 85% 78% Movement to transitional housing Number 57 41 11 15 15 Percentage 72% 58% 75% 83% Rehabilitative services Number 57 35 10 12 13 Percentage 61% 53% 60% 72% Substance abuse counseling\/treatment Number 57 53 16 19 18 Percentage 93% 84% 95% 100% Other Number 42 27 5 11 11 Percentage 64% 56% 65% 69% SOURCE: Authors' analysis of ACS data. NOTE: Analysis is for the 57 counties that have an FS program. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark Yes or No or Don't Know for each program service listed. Percentages are calculated using the number of counties responding to the question as the denominator. 86 Table 4.16 tabulates the staffing changes counties reported making in order to accommodate the FS program. Among all counties, 70 percent reassigned caseworkers to the FS program, 44 percent hired additional caseworkers, and 35 percent created a new unit to manage the FS program (Table 4.16). Large and medium-sized counties were much more likely than small counties to make these changes. Forty percent of the small counties indicated they made other changes to accommodate the FS program, with the open-ended responses referencing allotting more time for intensive case management and contracting with their county's superintendent of schools office to provide FS case management through family resource centers. Twenty- three percent of medium-sized counties indicated they had made other changes to accommodate the FS program including contracting with other county agencies to provide case management services for the FS program, contracting with an outside provider to administer the program and provide intensive case management, expanding services and hiring another social worker, and hiring a social worker supervisor and manager to support intensive case manager units. Lastly, 38 percent of large counties indicated that additional changes included hiring public health staff, hiring behavioral health staff to address mental health and substance abuse treatment needs and provide coordinated case planning, and hiring social workers and social worker managers for the FS program. In general, small counties indicated a number of constraints in supporting the FS program. Table 4.16. Staffing Changes Made Specifically to Accommodate the FS Program: Overall and by County Caseload Size Number of Responding Counties County Made Staffing Change Type of Staffing Change Overall Small Counties Medium Counties Large Counties Hired additional caseworkers Number 57 25 4 11 10 Percentage 44% 21% 55% 56% Reassigned caseworkers to work with the FS program Number 57 40 9 15 16 Percentage 70% 47% 75% 89% Created a new unit to manage the FS program Number 57 20 2 5 13 Percentage 35% 11% 25% 72% Other Number 36 12 4 3 5 Percentage 33% 40% 23% 38% SOURCE: Authors' analysis of ACS data. NOTE: Analysis is for the 57 counties that have an FS program. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark Yes or No for each type of staffing change listed. Percentages are calculated using the number of counties responding to the question as the denominator. 87 Reengagement Strategies That Counties Identified as Being Effective Counties were required to complete the reengagement of exempt individuals by December 31, 2014. We asked them which of a list of strategies that their county social services department used were considered particularly effective. Overall, 97 percent of counties reported that meeting with exempt individuals by phone or in person was particularly effective in reengaging them (Table 4.17). Eighty-three percent also reported that letters sent to exempt individuals were effective. For example, a medium-sized county explained, In our county we found it most effective to make phone calls to participants to fully and slowly describe the changes and new options, and offered to come to them to explain more about the program. Another medium-sized county noted, We implemented phone call reminders to every participant prior to their reengagement appointment. A large county reported, Our county utilized a staggered sequencing process that involved collaboration between CalWORKs ETs [employment transition] and WTW caseworkers. Customers reengaged, requested the new young child exemption or met other exemption criteria. All customers were reengaged prior to the December 2014 deadline. Another large county commented, We did all of the above strategies but the initial show rate was lower compared to after beginning the noncompliance process. During the noncompliance process, clients tend to show up when informed of their grant being impacted. Table 4.17. Counties' Assessment of Effective Reengagement Strategies for Exempt Individuals: All Counties and by County Caseload Size All Counties County Rated Strategy as Effective Reengagement Strategy Overall Small Counties Medium Counties Large Counties Letters sent to the exempt individual Number 58 83% 80% 85% 83% Percentage 48 16 17 15 Meeting with exempt individuals by phone or in- person Number 58 97% 100% 100% 89% Percentage 56 20 20 16 Incentives that were offered Number 58 5% 15% 0% 0% Percentage 3 3 0 0 Other Number 58 10% 0% 15% 17% Percentage 6 0 3 3 SOURCE: Authors' analysis of ACS data. NOTE: Analysis is for all 58 counties. Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark all that apply. Percentages are calculated using the number of counties responding to the question as the denominator. 88 A third large county explained, CSA [County Self-Assessment] specialists conducted group orientations on four Saturdays to reengage our customers. Customers had a one-on-one appraisal and were informed of the 24-month time clock, CalWORKs time clock, difference between federal and state participation hours, exemptions, identifying barriers and strengths. Child care staff provided information and completed necessary paperwork needed to receive services. Those who were unable to attend the group sessions were given appointments to meet with the case manager individually. Few indicated that incentives offered were effective. Written comments by counties illustrated the types of incentives offered. A small county reported offering, help with transportation costs, child care, personalized assistance in getting a job (purchasing interview clothes, haircuts). Another small county offered . . . gift cards for attending initial orientation to the WTW program. A third small county wrote they offered education services and child care services. Counties' Views Regarding Impact of SB 1041 on CalWORKs Program and Participant Outcomes We asked counties for their assessment as to what extent implementation of SB 1041 has affected different outcomes for the CalWORKs program and for participants in their county. It is important to keep in mind that the survey was conducted in the late spring\/early summer of 2015 and that these results represent their assessments for the early years of SB 1041 implementation. Between 45 percent and 57 percent of counties estimated that the implementation of SB 1041 had no effect (i.e., they marked about the same ) on work participation rates, participation in WTW activities, compliance with CalWORKs program rules, earnings, participation in CalFresh, and the number of participants receiving sanctions (Table 4.18). At the same time, 29 percent of counties indicated that SB 1041 resulted in somewhat worse or much worse workforce participation rates\u2014consistent with what we heard from the focus group discussions with caseworkers reported in Chapter Five. Seventeen percent of counties rated compliance with CalWORKs program rules was somewhat worse under SB 1041 and 24 percent of counties rated the number of participants receiving sanctions was somewhat worse. On the positive side, 36 percent of counties recorded that participation in WTW activities under SB 1041 was somewhat better and 40 percent indicated earnings was somewhat better as well (Table 4.18). With respect to education and vocational training activities, 40 percent of counties reported that enrollment in education and training programs\/community colleges was somewhat better; 33 percent reported that the length of time CalWORKs participants spend in educational activities was also somewhat better; and 22 percent reported that persistence of CalWORKs participants in education\/training activities was somewhat better. 89 Table 4.18. Counties' Assessment of the Effect of SB 1041's Implementation on Outcomes: All Counties Outcomes Much Worse Somewhat Worse About the Same Somewhat Better Much Better Not Applicable Total WPR Number 3 14 26 14 1 0 58 Percentage distribution 5% 24% 45% 24% 2% 0% 100% Participation in WTW activities Number 0 5 30 21 2 0 58 Percentage distribution 0% 9% 52% 36% 3% 0% 100% Enrollment in education and training programs\/ community colleges Number 0 1 32 23 1 0 57 Percentage distribution 0% 2% 56% 40% 2% 0% 100% Length of time CalWORKs participants spend in educational activities Number 0 4 32 19 3 0 58 Percentage distribution 0% 7% 55% 33% 5% 0% 100% Persistence of CalWORKs participants in education\/ training activities Number 0 1 42 13 1 1 58 Percentage distribution 0% 2% 72% 22% 2% 2% 100% Compliance with CalWORKs program rules Number 0 10 32 15 1 0 58 Percentage distribution 0% 17% 55% 26% 2% 0% 100% Number of participants receiving sanctions Number 0 14 29 14 1 0 58 Percentage distribution 0% 24% 50% 24% 2% 0% 100% Participation in CalFresh Number 0 1 33 6 1 17 58 Percentage distribution 0% 2% 57% 10% 2% 29% 100% Earnings Number 0 1 31 23 2 1 58 Percentage distribution 0% 2% 53% 40% 3% 2% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer per outcome. Percentages are calculated using the number of counties responding to each outcome as the denominator. Appendix Table D.5 provides results separately for small, medium, and large counties. Counties' Views Regarding the Effectiveness of SB 1041 Reforms and Related Mandates at County Level We asked counties their opinion of how well various aspects of the SB 1041 reforms to CalWORKs and related mandates were working in their county. Note that for some aspects of 90 SB 1041, such as the FS program, it may be still too early to tell. Because we report responses across the full Likert scale, we have tabulated the totals across all counties in Table 4.19. Again, Appendix D presents the results disaggregated by county size. Somewhat surprising given counties' earlier indications of the challenges in communicating the new rules to CalWORKs participants, 78 percent of counties indicated that communication of the new rules was working moderately well to very well (Table 4.19). Also, 85 percent of counties indicated that matching CalWORKs participants with appropriate WTW activities was working moderately well to very well. With respect to coordination with community colleges and vocational education providers, the majority of counties indicated this aspect was also working moderately well to very well (Table 4.19). Two-thirds of counties indicated that coordination with other county agencies to provide supportive services was working moderately well to very well. With respect to the provision of mental health and\/or substance abuse treatment services, 85 percent of counties reported this was working moderately well to very well (Table 4.19). Eighty-six percent responded with the top two ratings for the provision of supportive services. Seventy-nine percent and 85 percent of counties, respectively, reported that working with nonprofit service providers and with employers and job training providers was going moderately well to very well. Table 4.19. Counties' Assessment of How Well Aspects of SB 1041 and Related Mandates Are Working: All Counties Aspects of SB 1041 and Related Mandates Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Communication of new CalWORKs program rules to CalWORKs participants Number 1 11 34 11 1 58 Percentage distribution 2% 19% 59% 19% 2% 100% Matching CalWORKs participants with appropriate WTW activities Number 1 7 37 12 1 58 Percentage distribution 2% 12% 64% 21% 2% 100% Provision of supportive services (e.g., child care, domestic violence, housing assistance) Number 1 5 19 31 2 58 Percentage distribution 2% 9% 33% 53% 3% 100% Provision of mental health and\/or substance abuse services Number 2 5 26 23 2 58 Percentage distribution 3% 9% 45% 40% 3% 100% Coordination with community colleges Number 0 7 28 20 3 58 Percentage distribution 0% 12% 48% 34% 5% 100% 91 Table 4.19\u2014Continued Aspects of SB 1041 and Related Mandates Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Coordination with vocational education providers Number 1 6 32 11 8 58 Percentage distribution 2% 10% 55% 19% 14% 100% Coordination with other county agencies to provide supportive services Number 0 6 18 21 13 58 Percentage distribution 0% 10% 31% 36% 22% 100% Working with nonprofit service providers Number 0 7 28 18 5 58 Percentage distribution 0% 12% 48% 31% 9% 100% Working with employers and job training providers Number 0 7 27 22 2 58 Percentage distribution 0% 12% 47% 38% 3% 100% Reengagement strategy for clients with the short-term, young child exemption (AB X4 4) Number 0 9 18 26 4 57 Percentage distribution 0% 16% 32% 46% 7% 100% Tracking WTW participation of CalWORKs participants Number 5 14 27 9 2 57 Percentage distribution 9% 25% 47% 16% 4% 100% Improving information management of the CalWORKs program Number 5 18 24 7 4 58 Percentage distribution 9% 31% 41% 12% 7% 100% Design and implementation of the ESE program Number 1 6 20 23 8 58 Percentage distribution 2% 10% 34% 40% 14% 100% Design and implementation of the FS program Number 0 4 30 23 1 58 Percentage distribution 0% 7% 52% 40% 2% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer per outcome. Percentages are calculated using the number of counties responding to the question as the denominator. Appendix Table D.6 provides results separately for small, medium, and large counties. A majority of all counties rated the design and implementation of the ESE and FS programs as working moderately well to very well (Table 4.19). Seventy-eight percent of counties also rated the reengagement of participants with the short-term young child exemption as having worked relatively well. Two areas that counties flagged as working less well were tracking WTW participation of CalWORKs participants and improving information management of the CalWORKs program. Thirty-four percent of counties reported tracking WTW participation of CalWORKs participants 92 as working not at all well or only slightly well and 40 percent reported improving information management of the CalWORKs program as working not at all well or only slightly well (Table 4.19). Counties' Additional Information Needs and Suggestions for Improving SB 1041 In a final section of the ACS, counties were asked about any information needs they had. Overall, 17 percent of counties expressed an interest in additional information, with small counties (25 percent) in particular indicating such a need (compared with 17 percent of large counties and 10 percent of medium-sized counties). Eight counties provided written comments about their information needs. In addition, counties were asked for their recommendations for improving SB 1041 and for any comments they had on different aspects of SB 1041. Thirty- seven of the counties provided written recommendations. Tables 4.20 4.23 summarize, by size of county, the feedback we received regarding counties' information needs and their recommendations for improving SB 1041. We grouped the counties' comments as follows: 24-month time clock (Table 4.20) Early Engagement activities (Table 4.21) Aligning federal TANF and state requirements (Table 4.22) Pace of implementation and other comments (Table 4.23). The majority of the comments focused on the challenges of calculating the 24-month time clock, concerns about clients' understanding of it, and aligning the 24-month and 48-month time-on-aid clocks (Table 4.20). 93 Table 4.20. Counties' Information Needs and Recommendations for Improving SB 1041: 24-Month Time Clock ACS Open-Ended Comments Small Counties The 24-month clock tracking and how it will help counties and not hinder counties from meeting WPR.* It is our hope that the county will receive more information on 24-month clock management aspect related to support service and participation.* 24-month time clock implementation and tracking in C-IV.* If the state keeps the 24-month clock there should not be various reasons to stop a clock. An exemption should be the only reason to stop someone's 24-month clock. While the increased flexibility of the 24-month clock is appreciated, allow that flexibility for all participants for the duration of their time on aid (removing both a client barrier and the administrative burden of tracking yet another clock)--remove the clock, keep the flexibility. One issue that we have not fully resolved is around 24-month tracking. There are at least three people each month ensuring each and every case is being tracked appropriately. If it were possible to develop an electronic system to tick the clock if clients are using the 24-month clock versus looking at each case and unticking the 24-month clock, that would be more efficient. The 24-month clock has proven to be counterproductive to our county moving toward meeting WPR. Remove the WTW 24-month requirements and provide WTW employment services throughout the 48 months of TANF cash assistance. SB 1041 is difficult for calculation of 24 months, based off of the one of three different types of hours a client can participate in to count or not count a month. This should be streamlined to assist clients to better understand when their month will count and when it will not. It would be nice to have received or to receive some statewide training on the 24-month clock to ensure clocks are being calculated consistently. Have counties share best practices, especially smaller counties\u2014as large counties often have best practices, however, smaller counties are unable to implement these strategies due to smaller resources. Consider reviewing the Intercounty transfer process and sharing of 24-month time clock information. Comprehensive training on the 24-month time clock for small counties is needed. Eliminate the WTW 24-month time clock. Medium-Sized Counties Clearer guidance on what flexibility counties have with the extension criteria for WTW 24 months.* Adding functionality in C-IV to track the clock so this manual task does not take away vital interaction time between case managers and participants. Eliminate the 24-month limit for WTW services. Most families only receive assistance for two to three years. Time spent on the complexities of tracking 24 months could be better spent on direct participant services. Minimize the number of time clock extensions available for the 24-month time clock and just create a generic good-cause extension criteria. Creating numerous extension criteria reduces the effectiveness of the 24-month time clock. Recommend removal of the 24-month time clock, which is confusing for staff to implement and has resulted in considerably more work required. There is little flexibility as intended in activity choices. We recommend reverting back to the 48-month time clock. Lastly, we request better tracking and guidelines in regard to 24-month time clock extensions. This population has proven very difficult to track and identify for both the state and our neighboring counties. Perhaps a CDSS\/County workgroup on WTW 24-month extension practices? There have been many issues with CalWIN in regard to the accuracy in tracking of the WTW 24-month time clock, which has resulted in workers having to manually check every case. This can delay proper notice to families to inform them that they will be exhausting their clock soon. Improved automation around the WTW 24-month would benefit caseworkers and participants. Automation of 24-month time clock tracking. 94 Table 4.20\u2014Continued ACS Open-Ended Comments Medium-Sized Counties Remove the 24-month time clock limit as it does not give all clients enough time to move through barriers. Barriers tend to repeat such as MHS [mental health services] and AODS [alcohol and other drug services], which can pose a problem in a client meeting hours after 24 months. State-participation hours need to meet federal requirements (monthly average divided by 4.33). Eliminate the 24-month clock to allow SB 1041 flexibility of CalWORKs 48-month clock. Changing 48-month clock back to 60 months would be helpful. The WTW 24-month time clock is extremely difficult. In theory it appeared to be beneficial to the client but has not proven itself as such upon implementation. Since individuals who are using their 24-month clock have the option to request extensions to the clock, it would be easier to establish parameters for being allowed not to meet core hours for the duration of an individual's 48-month time clock (once in a lifetime). Once these parameters are no longer met, the individual must meet normal participation requirement. Large Counties Our county has not received instruction on how and when to discontinue customers who have reached their 24th month and are not meeting CalWORKs federal standards. In addition, we are waiting for instruction on how to treat customers who regain eligibility when they start meeting CalWORKs federal standards after they are discontinued for not meeting CalWORKs federal standards after reaching the 24th month.* Post WTW 24-month time clock direction and clarifications.* How to equitably and efficiently reconcile the WTW 24-month clock, along with the extension of the clock, without adequate automation.* Remove the 24-month clock. The tracking of the clock is confusing, cumbersome, and labor intensive, resulting in taking the focus away from working with clients to obtain employment [and putting it on] data processing and paperwork. Create a less complex set of rules to track and tick\/untick months the WTW 24-month clock. Make the automation of the WTW 24-month clock TOP PRIORITY across all consortia. Full automation of the WTW 24-month time clock. Automation in C-IV that supports SB 1041. Simplify the 24-month time clock calculation by limiting the number of exceptions and\/or by providing a hierarchy to exceptions. Eliminate the WTW 24-month time clock created by SB 1041; with the addition of the extenders, it creates a very confusing scenario for clients when working with them to develop\/continue in WTW plans that best serve their needs. Incorporate full automation into SAWS (C-IV) of the 24-month tracking. We would seek consideration to suspend or eliminate the WTW 24-month time clock until an efficient automated system can be ensured. The lack of automation creates many problems including but not limited to confusion for participants receiving incorrect NOAs [Notices of Action] and other issues. Eliminate the WTW 24-month time clock. Align the CalWORKs 48-month time of aid clock to that of the 60-month TANF clock. Repeal the clock. Suspension of the WTW 24-month clock and bring back the core and noncore WTW activities. This will assist counties and the state to improve the WPR. The WTW time clock is still evolving, suspension of the clock until all kinks are ironed out would benefit the customer, counties, and the state. SOURCE: Authors' analysis of ACS data. NOTE: Bulleted items are recommendations unless followed by an asterisk, in which case they are an information need. 95 Table 4.21. Counties' Information Needs and Recommendations for Improving SB 1041: Aligning Federal and State Requirements ACS Open-Ended Comments Medium-Sized Counties Change WPR rules; under the 24-month time limit regulations, clients can choose activities that do not meet federal WPR. Large Counties Align with the federal regulations for WPR. Raise the number of hours clients are required to participate to assist in meeting WPR or allow credit for partial participation. The best thing that happened with the implementation of SB 1041 was the alignment of participation hours between the state and federal, ESE, and FS. Instead of having differences between federal and state participation requirements, aligning completely with the federal rule would make the requirements easier to understand for staff and customers. Aligning federal TANF and state requirements helps to reduce administrative costs and improve efficiency. To change state regulations to be in alignment with federal WPR requirements to promote a better understanding of the WTW program and how it can benefit the families that we serve in our county. Alignment of federal and state WPR rules would be an exceptional enhancement and eliminate confusion. Completely align the CalWORKs federal standards to TANF regulations. Completely align CDSS regulations with SB 1041 (W & I Code) statutory language. Align WTW participation to the federal work participation requirements, and allow an emphasis in education, on- the-job training, and employment to truly prepare participants for self-sufficiency and ultimately improve the WPR. SOURCE: Authors' analysis of ACS data. NOTES: Bulleted items are recommendations. There were no comments from small counties in this category. 96 Table 4.22. Counties' Information Needs and Recommendations for Improving SB 1041: Early Engagement Activities ACS Open-Ended Comments Small Counties It is our hope that the county will receive additional guidance on ESE, FS (including creating a whole family focus).* Future of FS and if funding will increase.* Our county was not one of the counties selected to participate in the CalWORKs Housing Support program. We have experienced a significant shortfall with respect to being able to assist families to obtain and maintain affordable housing. While we utilize some of our FS funds to assist in this area, we are quite limited in terms of being able to provide these families with long-term resolution to housing issues. It is our humble opinion that a housing component is absolutely critical, along with ESE and FS, in terms of assisting families in resolving those significant barriers toward employment. Simplify subsidized employment, making ESE the only subsidized employment program. Support housing programs and expand to all counties. Continue to FS. Medium-Sized Counties Have one subsidized employment eligibility criteria, funding, and tracking process. This will allow more staff time to focus on direct participant services. We recommend additional ESE funding and options, and housing funds. The implementation of OCAT will also need to be looked at in relation to SB 1041 and FS, and provides an opportunity to focus on a package of services to create consistency in the customer experience with WTW. It would be helpful if all ESE funding and SE funding could be calculated as one larger allocation. It would also be great if we received more funding to support the family stabilization program specifically, as our agency is not just a housing program; we have case-managed services and support staff and lack funds to provide specific services like housing, rehab, etc. Having housing funds imbedded into FS monies would be very beneficial. In 2014, 20 counties received grants for Rapid Rehousing. Many of these counties have tied the Rapid Rehousing program to the FS program. Those counties that were not funded through this grant were left to offer housing through their limited Family Stabilization allocation and the existing Homeless Assistance Program. Statewide, the income-to-rent ratio is dismal. Due to the lack of affordable housing, some counties are only able to offer occasional Band-aids to the homeless population. Large Counties Combining AB 98 and AB 74 funding for subsidized employment would help to avoid confusion in program reporting. The lack of affordable and sustainable housing has been an exceptional challenge. Need to do more for those who are on the verge of losing housing. Transportation for customers who live in rural areas is still a challenge. Clarify ESE. Eliminate the new young child exemption, and reroute these parents with young children to Family Stabilization. If additional funding for FS and ESE were available, more participants could be served, thus enabling them to better improve on the barriers that were disrupting the household and allow the participants to be successful in preparing for self-sufficiency. SOURCE: Authors' analysis of ACS data. NOTES: Bulleted items are recommendations unless followed by an asterisk, in which case they are an information need. California's subsidized employment structure was created under AB 98 (2007) and expanded by SB 72 (2011). AB 74 (2013) created the ESE program in California expanding subsidized employment opportunities for CalWORKs clients in California. 97 Table 4.23. Counties' Information Needs and Recommendations for Improving SB 1041: Pace of Implementation and Other Comments ACS Open-Ended Comments Small Counties Also, clients were not given an opportunity to fully embrace the changes. We trained the staff; however, the same attention was not made available to clients because the state wanted the program implemented by a certain time. We did change our materials and provided face-to-face opportunities for clients to be informed and ask questions. Actually, we're drowning in information; it's time and administrative resources we need. Medium-Sized Counties Most of what was problematic with SB 1041 is behind us. The 'Comprehensive Conversations' that were envisioned were unrealistic, as expecting recipients to understand what staff had difficulty understanding was unfair. State directives that came out months later, or not at all, were very frustrating, particularly when counties took steps forward, only to be directed back. Consequently, other counties were hesitant to say so. Our county would like to recommend that for policy changes as significant as SB 1041 and associated policies such as AB 74, the implementation should be better coordinated and done in collaboration with our automated systems. We found it very difficult to implement these changes when our only method of tracking was manual spreadsheets done in association with our existing practices within our automated systems. Also, due to the rushed efforts by our automated systems, many of the changes that have been implemented do not work properly. In addition, we would like to recommend the timely issuance of CDSS regulation in response to state legislation. The majority of the directions provided by CDSS in regard to SB 1041 and AB 74 were issued either close to or after the requested date of implementation. The WTW 2 has not been updated to reflect the new work participation requirements from a weekly minimum to an average, which is causing confusion to clients. There hasn't been much information regarding SIPs [System Improvement Plans] and SB 1041, and the information provided in one ACL and one Q&A on the 0 23 young child exemption was not sufficient to understand all the complexities of these regulations. Large Counties Clear explanation of vision and goals of SB 1041 reforms.* Allow counties the ability to implement each regulatory reform\/change incrementally and as automation allows. Allow enough time for implementation. SB 1041 released the initial ACL in December 2012 with an expected implementation date of January 1, 2013. This was an unrealistic expectation placed on counties and their staff and created a hardship on staff that has made it difficult to recover from. Also, ACLs should be clear in direction and released in a timely manner as close to the implementation date as possible. Receiving clarifying ACLs two years into a regulatory change created confusion for staff and clients. Change all forms from legalistic jargon to client-friendly; family strengths focused materials. Hold on additional program modifications; counties need to be given time to work out issues in the current program components before any additional regulatory changes are made. SOURCE: Authors' analysis of ACS data. NOTE: Bulleted items are recommendations unless followed by an asterisk, in which case they are an information need. 98 5. A Six-County Perspective on Initial Implementation of SB 1041 This chapter presents findings from the site visits conducted with the six focal counties\u2014Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus. The focal county findings complement the information gathered through the state-level key informant interviews and the ACS completed by all 58 counties. As described more fully in Chapter Two (and summarized in the text box to the right), the focal county key informant interviews, and the focus groups with caseworkers and CalWORKs participants, were designed to provide a more in-depth view of many of the same topics covered in Chapters Three and Four. Although the focal counties were selected to capture important variation across the counties in California, the results are not necessarily representative of the experiences across all counties. Nevertheless, the ability to explore topics related to the early implementation of SB 1041 with more specificity and for stakeholders not included in the other process study components (e.g., caseworkers and CalWORKs participants) provides a richer perspective on experiences with SB 1041 to date. In particular, we consider the following questions in this chapter and highlight the key findings from our data collection efforts in the six focal counties: How did the counties communicate the SB 1041 changes to the staff? How did county staff understand those changes? The most common method used to share SB 1041 policies on a statewide basis was the release of ACLs, including periodic clarifications to previously released ACLs. County welfare departments took the lead on training their staff to implement the new rules and regulations brought about under SB 1041, using a variety of mechanisms, such as written policy guidance, internal and external training events, supervision from managers of line staff, and internal meetings. Caseworkers who participated in our focal county focus groups described a significant amount of confusion regarding SB 1041 and identified the 24-month time clock as the most challenging component of the legislation, including when the clock should tick and untick. This finding is in contrast to the ACS results presented in Chapter Four where WTW supervisors in 83 percent of counties reported that their WTW caseworkers understood the 24-month time clock moderately well to very well. Chapter Five Methods Based on analysis of qualitative data collected for six focal counties: Alameda, Fresno, Los Angeles, Riverside, Sacramento, and Stanislaus, primarily during the spring and summer of 2015. Data collection included key informant interviews, caseworker focus groups, and participant focus groups. Analyzed using qualitative methods. See Chapter Two for more detail on data and methods. 99 Do CalWORKs participants understand the changes brought about by SB 1041? How did county staff communicate this information? County staff communicated to participants about the changes that were brought about under SB 1041 through in-person discussions, phone calls, and letters. Administrators and caseworkers in all six focal counties reported that there are still many participants who do not fully understand the implications of SB 1041, including where they land within the 24-month time clock period. How did the counties change the way they do business in order to implement SB 1041? Did they reorganize, create cross-functional units or new staff positions, or redefine staff roles? Across the focal counties, staff did not report significant reorganization of staff structures or roles in order to implement SB 1041, although they did emphasize that the reengagement process was labor intensive and SB 1041 as a whole has required a strong focus on training and support for caseworkers. In regard to factors that facilitated implementation of the legislation, focal counties reported that participation in the state- level workgroup process and discussions better positioned them to begin planning early for SB 1041. In addition, counties that maintained a dedicated workgroup to focus on clients' time on aid, within the 24-month time clock, fared better in this regard. What factors facilitated or hindered implementation, and what adjustments were made to address identified challenges? Focal county staff identified many barriers to implementation of SB 1041. For example, SB 1041 occurred at a time when counties were dealing with many other changes, namely Medicaid expansion, which limited the capacity of county welfare offices to plan, train, and implement SB 1041, including the initial intensive reengagement efforts of participants. Implementation policies from the state were released slowly, and\u2014according to county staff\u2014were often confusing or contradictory. This led to challenges in training and to confusion among staff in regard to SB 1041. Training for caseworkers on SB 1041 was described as difficult, given the continual release of state guidance to clarify components of the reforms. The lag between implementation of SB 1041 and upgrading the consortia data systems to meet the needs of the legislation was a source of frustration for county leaders and caseworkers. In addition, the perceived tension between WPR and SB 1041 appeared to be a driver in how caseworkers interacted with CalWORKs participants, influencing the extent to which participants were aware of and encouraged to take advantage of the options available to them under the new legislation. How did counties coordinate with other public and private service providers in providing necessary services to CalWORKs applicants and to current and former participants? Our focal county data collection included interviews with service providers associated with CalWORKs\u2014relationships among these organizations and county social service agencies appeared strong. Concerns voiced by service providers regarding SB 1041 were similar to those identified by caseworkers\u2014that SB 1041 was complicated and difficult to 100 understand. Education service providers (e.g., CalWORKs counselors on community college campuses) also noted that they had not observed the expected rate of referrals to education that they had expected, given the flexibility in activities afforded by SB 1041. In the remainder of this chapter, we first describe our findings regarding the initial communications about and planning for the implementation of SB 1041. We discuss dissemination of SB 1041 guidance from the state to counties, followed by county-level planning and staff training. In addition, we also describe county feedback in regard to updating data systems needed to respond to the new policy reforms. Next, we provide a snapshot of the initial implementation of SB 1041 implementation, including the reengagement of CalWORKs participants and the use of the new young child exemption. We also summarize feedback from the focal county interviewees about one of the major structural changes to CalWORKs brought about under SB 1041: namely, the implementation of the 24-month time clock. We discuss communications about the 24-month time clock, staff training, client notification and explanations about the time clock, and interviewees' perceptions regarding the challenges and benefits of the 24-month time clock. This is followed by a discussion regarding interviewee results about the WPR, including calculation of weekly participation hours, consequences of not meeting the federal WPR, perceived impact of SB 1041 on the WPR, and the tension perceived by interviewees about meeting WPR versus a work-ready approach. We also discuss welfare staff's understanding of SB 1041, as well as that of participants. We then describe feedback regarding the Early Engagement programs brought about under SB 74 that are associated with SB 1041 (the OCAT and the FS and ESE programs). We conclude by highlighting the major implementation successes and challenges, the early impacts reportedly associated with SB 1041 as reported by the focal counties, and an initial set of recommendations to improve implementation. Communication About and Planning for SB 1041 We begin with a discussion of the communications about and planning for SB 1041 reforms, including the dissemination of SB 1041 guidance from the state to counties, followed by county- level planning and staff training. While not an issue that was limited to the initial SB 1041 start- up period, we also describe county feedback in regard to updating data systems to respond to the new policy reforms. As illustrated in Figure 5.1, it is important to note that these stages are inter- related and often overlapping. 101 Figure 5.1. Communication About and Planning for SB 1041 State Communication to Counties In the first year of the evaluation, the research team focused on how information on SB 1041 was disseminated by the state to county leadership, and then to county staff and to CalWORKs participants themselves. CDSS used a range of strategies to communicate and engage counties regarding the changes brought about through SB 1041 with county-level Department of Social Services (DSS) agencies. The most common method used to share SB 1041 policies on a statewide basis was the release of ACLs, including periodic clarifications to previously released ACLs. Other written guidance provided by CDSS includes ACINs and County Fiscal Letters. CDSS also hosted conference calls and meetings with county staff to discuss the details of SB 1041. In addition, county leaders participate in the monthly meetings of the CWDA, a nonprofit association representing the human service directors from each county, during which SB 1041 has been a topic of discussion. Focal county leaders and staff articulated a number of interrelated challenges regarding how the state disseminated SB 1041 guidance\u2014most notably concerns around timing and clarity of information. SB 1041 was passed in July 2012 and counties were given only six months to prepare for implementation in January 2013. Due to the tight timeline and the intensive state- level workgroup process, delay in CDSS providing SB 1041 guidance to the counties was challenging with respect to planning and implementation at the county level. Staff from all six of the focal counties shared the difficulties inherent in receiving the information so close to SB 1041 implementation, not to mention updates well into early 2013 when changes were rolled out. In addition, county leaders described the tight time frame to train staff (and then train them on subsequent updates from the state) as a barrier to smooth rollout of the legislation. Reflecting on the speed at which SB 1041 was implemented, county administrators and staff reported they were inundated with information from CDSS, pointing to the many ACLs released within the first year of implementation. State SB 1041 guidance was widely described by county leaders and staff as unclear or as contradicting previous information issued by CDSS. One administrator stated, Overall, the complexity of it, and the late releases, and the updated State Communication n County Planning County Communication and Training Data Systems 102 Q&As . . . from a supervisor's point of view, it makes it very difficult. An administrator from another county shared, Changes in interpretation of law happened so quickly that we had to have multiple repeat trainings. Another administrator reported, There was a one-month period, during which CDSS was coming out every other week with a change in policy. An administrator from that same county shared, Every time an ACL was sent out, the language was changed just a tiny bit [so that the] person reading the ACL could misinterpret it. This ACL said this\u2014and this ACL said this . . . It sounds the same, but they added a word here, and that word changed the whole concept. County Planning for SB 1041 The evaluation team solicited feedback from county staff about the planning process for SB 1041 implementation and whether they had sufficient time to incorporate the new policies. Five of the focal counties were involved in the CDSS workgroups to develop the policy guidance for SB 1041\u2014they reported that as a result of their participation, they had an earlier jump, compared with other counties, in regard to planning for implementation. Several of the focal counties also said they convened steering committees or workgroups to plan for SB 1041 and\/or their staff participated in state-level conference calls that began before January 2013 and involved CDSS personnel, county-level DSS staff, advocates and legislative staff. Despite the reports by counties that their participation in the state workgroup process was helpful, the tight time frame in which they were required to plan for and then implement SB 1041 was characterized as challenging by county staff. County administrators and caseworkers from all six counties stated that they had insufficient time to plan for and implement all of the various changes and programs required by SB 1041. As an administrator from one county explained, It really was the time. We are a big ship. We couldn't turn real quickly. So having more time from the state would have made it easier. In another county, an administrator said, Everything was pushed out late or with a very short time frame. This was definitely an issue. County Communication and Training County welfare departments took the lead on training their staff to implement the new rules and regulations brought about under SB 1041. Trainers used a variety of mechanisms, such as written policy guidance, internal training (tailored to caseworkers and supervisors, as well as departmentwide events), external training, supervision from managers of line staff, and internal meetings. Focal counties described their efforts to prepare staff, inform external providers, offer training, and draft county-level policy documents as they received guidance from CDSS. The initial training of staff occurred late in 2012 and into 2013 on the various elements of the legislation. Three of the focal counties reported that they had a dedicated staff person or workgroup tasked with interpreting SB 1041 guidance from the state and sharing it with the county welfare department staff. For example, one of these counties maintained a special projects team that 103 included supervisors, a manager, and line staff who worked on implementation of SB 1041; they also convened a task team devoted to training, asking members to make a commitment to several days of overtime so that they were delivering a consistent message to trainees. In three of the focal counties, staff could also learn about SB 1041 components through distance learning and online tools. Supervisors also were responsible for communicating SB 1041 to line staff, monitoring the development of WTW plans, and the calculation of the 24-month time clock. In the focal counties, supervisors described working with line staff to review and analyze real or mock cases, as well as hold clinics at which caseworkers could ask questions. In addition to a variety of written resources, caseworkers from several counties indicated they had developed individualized cheat sheets and other mnemonic tools to help them understand the details of SB 1041, particularly in regard to the 24-month time clock. These line staff also remarked on the value of informal support from peers and on-the-job training. Building on in-house training efforts, several external organizations have provided professional development to staff on SB 1041. For example, one county referenced the CalWORKs Academy Training, which provides information on recent program changes, a review of program fundamentals, and a variety of training opportunities, including content on SB 1041. However, according to one administrator, the Academy did not have the lead time it needed to develop a curriculum and prepare training in advance of the initial roll out because detailed guidance on SB 1041 was not available before the measure was implemented. Other SB 1041 training has been provided through the University of California Davis's Northern California Training Academy and the California Community Colleges CalWORKs Association Training Institute. When asked to reflect on the communication and training they received regarding SB 1041, some administrators provided more positive feedback on training or reported greater levels of understanding of SB 1041 than did line staff. For example, caseworkers often appeared to be frustrated with their supervisors about the supports and resources available to them to implement the changes brought about under SB 1041 and pointed to inconsistency among supervisors regarding their own knowledge and comfort with SB 1041. The evaluation team heard complaints from caseworkers about supervisors who shared guidance on a piecemeal basis\u2014 consistent with comments by county leadership about the flow of information from the state. Professional development efforts typically provided by in-house training staff were also hampered, according to focal county staff, by evolving state guidance that made it difficult to create detailed training content. A caseworker stated that the guidance they received changed so fast that what people learned in the first training versus the last training wasn't the same thing . . . To this day, we still don't have one complete policy. . . . It's 'mix and match.' Caseworkers expressed frustration with training in which the trainer was unable to answer their questions and with the fact that content offered conflicted with previous guidance they had received. For example, one caseworker commented, 104 So those trained initially were trained differently from the next group [of caseworkers]. Policies didn't have clarification on how all the time was to be accounted for\u2014so being trained with some vagueness and you have to [then] present it to your clients. Data System Changes The policy reforms created under SB 1041required significant changes to the data systems that counties used to track CalWORKs participants. California's counties are grouped into three consortia, each of which uses a different data system\u2014LEADER, Cal-WIN, and C-IV (in addition, counties also utilize various other data systems to manage aspects of their programs; however, the primary focus of SB 1041 in this phase of the evaluation was on the systems being used to implement the 24-month time clock). Representatives from all three consortia participated in the state SB 1041 workgroup process to develop guidance for counties\u2014their role was (and continues to be) to change the data systems to meet the needs of the new legislation. Reflecting on their initial work to upgrade systems to align with SB 1041, consortia staff reported that some of the fixes were done relatively quickly, such as adjustments regarding the new earned income disregard. The main challenge, as identified by staff across the three consortia, was the automation of the 24-month time clock, for a variety of reasons. In general, consortia representatives emphasized that there was a limit to the level of automation that could be achieved given all the ways that participants can meet the requirements of SB 1041. Cases ultimately require some level of caseworker review and determination. One consortia staff member explained there are multiple ways to meet the program requirements, stating, It could be a combination of working and studying and doing community service. For a system to account for so many possible combinations of weekly hours is very difficult. Some of the exemptions require a person to really go and analyze hourly or weekly [participation] and they cannot be automated. The other challenges to automation were the quick pace from planning to implementation, and the complexity of the reforms and a reported lack of clear guidance from the state. As one consortium representative said, The state requires reports on the months based on Welfare-to-Work participation to determine which months could count toward the 24 [24-month time clock] and which months should be exempted or could be qualified for not counting . . . one of the challenges we received [faced] is because even though the regulation was effective January 2013, way after January 2013 we didn't have a clear description of how to determine these exemptions in Welfare-to-Work participation . . . the clarifications came months after the regulation was in place. So one of the bigger challenges for us in calculating these months was to have a clear interpretation of each exemption, how to apply the exemption, and how to calculate that and implement that retroactively for the months already gone. So that was an extra challenge. Another consortium representative said, 105 I think at this point of time we are pretty much clear, but back in 2013 we didn't have many answers that we need to being able to determine these exemptions accurately for our participants. So if I remember correctly . . . it took us almost a year to implement the time clock, not just from the technical standpoint but also to being able to determine the correct exemptions for our participants. At the county level, administrators echoed the comments made by consortia staff, reporting that changes to data systems were made incrementally and continued well past the initial implementation period. Counties reported using their own internal tracking systems to generate reports. For example, an administrator stated, We always have some kind of workaround that we are using to process the work. A lot of it is manual. The workers really do have to keep on top of things to make sure that they do the entries correctly. County staff also referenced maintaining their own internal tracking systems to generate reports, which were separate from the consortia databases. During one of our winter 2015 site visits, two years into implementation, one county reported that they had just recently received a system update that enabled staff to record the core and noncore hours. They had to manually 'untick' clocks and remind staff to do it. The administrator added, Now, we have to figure out how to use it. It's there . . . but how are we going to get this out? It's a lot of that. We are always working way behind the system. Another administrator shared, It's also difficult, from an automation standpoint, to program something so complex and to alleviate some of the workload for line staff . . . and the state was providing clarification the last couple of years. We keep getting clarification. That makes it very difficult to program, because when you don't have the full story, you can't really program correctly or fully\u2014and sometimes you just stop. According to another county administrator, the state guidance was gray, and CalWIN was grayer still. Initial Implementation of SB 1041 As illustrated in Figure 5.2, initial implementation of SB 1041 began with reengagement of parents who had been previously subject to the young child exemption that was changed as a result of the new legislation.38 (See Appendix A for a detailed overview of the reengagement legislation and process.) Here, we summarize the perspectives of county staff regarding the reengagement process and present their perspectives on the new exemption. 38 Pursuant to AB X4 4, any individual with one child 12 to 23 months of age, or two or more children under the age of six, was exempt from WTW requirements. In addition, months when an individual qualified for this exemption did not count against the CalWORKs 48-month time limit. These short-term exemptions ended on December 31, 2012, and counties were given until January 1, 2015, to reengage those individuals exempt as of December 31, 2012 (CDSS, ACL 13-01, 2012). 106 Figure 5.2. Initial Stage of SB 1041: Reengagement and Young Child Exemption Reengagement Reengagement of participants was rolled out incrementally in counties. In our interviews, some of the focal counties referred to reengagement sequencing that involved phasing in outreach efforts with specific groups of clients\u2014for example, first meeting with CalWORKs participants who had children that were going to age out the soonest (e.g., 0 6 months left before reaching their age limits), followed by participants with more time left. Reflecting on the reengagement process, focal counties reported mixed reviews of their experiences. In one of the six focal counties, an administrator said, the reengagement process was probably one of the smoothest processes [they had] had as far as SB 1041. In order to have the appropriate staff and resources available for reengagement, two of the focal counties reported arranging to bring participants in for reengagement on Saturdays. Other counties provided supportive services on-site (e.g., child care) to encourage participants to enroll in WTW activities. However, reengagement was not without its challenges and many staff described it as an intensive effort. One focal county reported that they had high no-show rates when they attempted to reengage participants. Another county reported that identifying the participants who needed to be reengaged was especially difficult because their data system was having problems automating the information they needed. In this county, one leader said I think generally we did it effectively but it took a lot of organizational attention. One-Time Young Child Exemption Staff from three of the six focal counties characterized the one-time young child exemption as somewhat challenging to know when clients should use it. One county leader expressed concern that, in the early stages of SB 1041 implementation, caseworkers would apply the exemption without considering the longer-term implications for individual participants. Similarly, a leader in another county recounted cases where the exemption probably should not have been taken, given participants' indications that they may have more children in the future. Although Reengagement Young Child Exemption 107 caseworkers are to inform clients of their options and explain the ramifications of choosing one option over another, caseworkers shared similar views\u2014that understanding when to encourage clients to consider the exemption was not as clear as it could be. In five of the six focal counties, interview respondents reported that many CalWORKs participants did not understand the implications of using the exemption but still chose to take it. For example, caseworkers in two counties said participants often took the exemption immediately, without considering longer-term plans. Caseworkers and supervisors from two of the six counties noted that the one-time young child exemption was particularly challenging in complicated cases\u2014for example, cases where a participant had one or more sanctions in the past or present, had members in the assistance unit with different statuses in the program, or had been on and off the program one or more times. In two of the focal counties, another concern among county leaders and caseworkers was how the new one-time young child exemption may decrease the county's WPR. The one-time young child exemption is a state exemption, meaning that participants who take it are still considered work-eligible individuals according to federal requirements, and thus are counted against a county's WPR. One leader expressed that this is a frustration for me, because for WPR, it counts against us . . . we have a ton of participants who supposedly request [the exemption] for the 0 23 months and that dings us. Similarly, a caseworker in another county said the one-time young child exemption is yet again putting the county in peril . . . The federal guidelines say this population is work eligible. As noted elsewhere in this report, the one-time young child exemption represents another point where counties felt tension around priorities\u2014 meeting WPR or working with clients to help them benefit from exemptions included in the CalWORKs program. Implementation of the WTW Time-Clock As noted in Chapter One, SB 1041established the CalWORKs WTW 24-month time clock that allotted up to 24 months for participants to engage in a variety of activities that would prepare them to become or remain employed (CDSS, 2005). Although the lifetime limit for CalWORKs receipts remained at 48 months (the limit adopted in 2011 legislation), the support was divided into two periods: the first 24 months, when a set of flexible CalWORKs WTW services and other supports are available (e.g., subsidized child care, reimbursement for transportation and other work-related expenses), and a second 24 months, when the more restrictive federal TANF work activities apply. (See Appendix A for a comparison of the CalWORKs federal and WTW time clocks). County caseworkers have six broad responsibilities related to the 24-month time clock. Figure 5.3 summarizes the main six caseworker tasks. 108 Figure 5.3. Major Caseworker 24-Month Time Clock Responsibilities First, caseworkers must determine the number of nonexempt adults in the family in order to assign the required number of work participation hours. Second, the ages of children in the family is another factor that informs assignment of participation hours. Participants can be scheduled to meet the CalWORKs minimum requirements under either the 24-month time clock or the CalWORKs federal standard participation requirement. Figure 5.4 details the minimum hourly participation requirements for participants based on the number of adults and ages of children in the family. Third, after the caseworker determines participation hours for a family, the WTW plan is developed. The caseworker and participant work collaboratively to complete the WTW 2 form,39 which offers two options: Participants adhere to either the CalWORKs WTW participation requirements or the CalWORKs federal standards for work participation requirements. Based on their selection between these choices, participants are placed into two categories: (1) WTW participants are those whose WTW plan assigns them to a mix of activities and\/or hours that do not meet the CalWORKs federal requirements, and (2) CalWORKs federal program participants are those whose plan indicates that they will meet the CalWORKs federal work requirements (CDSS, 2012a). Fourth, the caseworker must verify participant compliance with the WTW plan. Fifth, in addition, caseworkers are responsible for adjusting the time clocks and WTW plans as necessary and periodically notifying participants of the status of their 24-month time clock. The 24-month time clock is designed to start and stop each month depending on the participant's participation level and WTW plan (CDSS, 2012a). For WTW participants, the 24-month clock ticks until the caseworker unticks it for an approved reason. For CalWORKs federal program participants, the 24-month clock does not tick unless it is determined that they no longer meet the work requirements. Sixth, caseworkers must notify participants that their 24-month time clock is close to ending at least once between months 18 and 21 on this clock (CDSS, September 26, 2014). Caseworkers are also responsible for conducting case reviews to assess for time clock accuracy prior to sending the Notice of Your WTW 24-Month Time Clock Ending Soon (CDSS, 2014g). 39 The WTW-2 form is a four-page document that lists CalWORKs WTW 24-month time-clock activities on the left side and CalWORKs federal work activities on the right side of the first page. In addition, the total number of required work participation hours is included one this form. Pages 2 3 include the details on the specific program assignment\/s and service\/s to which the participant has agreed. The final page is for participant acknowledgment. Each participant in the family signs his or her own form and has his or her own 24-month time clock (CDSS, undated-c). 109 Figure 5.4. CalWORKs WTW 24-Month Time Clock Hourly Work Participations Requirements Flow Chart SOURCE: CDSS, 2014h, Attachment A. 110 The 24-month time clock was a major component of SB 1041. As a result, its implementation had a significant impact on administrators, staff, and participants alike. During the site visits, interview respondents described communication efforts around the 24-month time clock, explained challenges with implementation of this policy change, and offered lessons learned from the implementation process. Perspectives on these topics are provided below. Communication About the 24-Month Time Clock Training sessions were the primary mechanism used to introduce the 24-month time clock to staff. Administrative staff workers were tasked with developing departmentwide training sessions at regional offices. Caseworkers received training on how to calculate the 24-month time clock, how to determine which activities count, and how to choose exemptions. While some caseworkers reported receiving time-clock training from the staff development unit, others received in-house training from county administrators. Training was staggered; as such, some of the caseworkers who completed the training during the early SB 1041 implementation stages had a different understanding of the time clock from those who completed it later. Others still reported receiving trainings through self-taught, self-paced, web-based platforms. Specifics about the new time clock were explained to participants through mailed notices, as well as during in-person meetings with the caseworkers. Staff Training on the 24-Month Time Clock Caseworkers and county administrators in all six focal counties spoke of the training they received on the 24-month time clock as inconsistent, inadequate, and disjointed\u2014echoing themes described earlier in this report. The speed of SB 1041 implementation meant that county leaders were asked to create training sessions with incomplete information and had to constantly update the training based on evolving guidance from the state. One county administrator referenced the frustrations in preparing for the 24-time clock implementation: People want to know everything they are supposed to do when they sit in on a training: How do I put appropriate information in the system? How do I tick the clock? Because we couldn't do this upfront, it made training complicated. Caseworkers commented on the inadequacy of the training sessions, saying that trainers were unable to answer their questions at times, and that the training caseworkers received varied. One caseworker stated, We could have used more training and information. A lot of it was trial and error . . . Caseworkers also felt their supervisors were not familiar with the 24-month time clock. One said, I was referred to my supervisor [for questions about the 24-month time clock], and even my supervisors were confused. When I asked my supervisor, my supervisor said look at the PowerPoint presentation\u2014if you have questions, we can learn at the same time. 111 Because the various components of SB 1041 were not implemented simultaneously, training on the legislation's multiple components (including the 24-month time clock) was often ineffective and unclear. Given that CDSS regularly communicated revisions to the implementation guidance, training had to be updated frequently. As noted earlier, CDSS usually uses ACLs to communicate with counties. Through these letters, the state can introduce new legislation, alert counties to modifications in existing laws, and answer county workers' frequently asked questions. Of the 25 ACLs released between October 2012 and April 2015, 18 concerned updates to or explanations of the 24-month time clock. According to caseworkers in our focus groups, the rules from CDSS were constantly changing, which made training staff cumbersome and inconsistent. The piecemeal implementation of SB 1041 made training on the 24-month time clock challenging. When asked how training was managed, one administrator noted, We've done multiple trainings. We're doing a follow-up time-clock training since the pieces with the time clock have come out recently. Going to refresh on the original (because staff have struggled on this) and training on who will hit the clock. There are some simple cases, but then there are some messy ones where it will take a day or two to do it. A caseworker reflected on the training received on the 24-month time clock: When we finally got our time clock training\u2014no counselor did the same thing as anyone else. None of us were on the same page. There was no consistency. Client Notification and Explanation Counties were required to send advance notices about the new WTW rules, including the new CalWORKs WTW 24-month time clock, to all existing nonexempt participants by December 1, 2012 (CDSS, 2012a).40 In addition, participants were informed of the 24-month time clock when they applied for the CalWORKs program or during their annual redetermination (CDSS, undated-b). County welfare staff were also trained to conduct comprehensive discussions with all participants to notify them of the new WTW rules. Staff from four of the six focal counties mentioned having these conversations with participants. Some staff referred to this as meaningful robust conversations (MRCs) or meaningful conversations, in which they explained the various changes to the CalWORKs program (including the 24-month time clock) and completed the WTW plan. Helping participants understand their options so they could decide what was best for their families was a common theme during discussions with administrators and caseworkers. One administrator noted that the point of these conversations 40 Counties were to send the CW 2205 informing notice to clients by December 1, 2012. The CW 2205 must be sent to all nonexcluded WTW-eligible adults that receive cash aid on behalf of or with a child, including sanctioned adults. The notice included a summary of the new WTW rules, including the new CalWORKs WTW 24-month time clock, hours of participation, the fact that clients would have more choices in the activities they could participate in during the 24-month time clock, and what type of conditions would stop the 24-month time clock. 112 was to inform participants of the various activities available to them to prevent them from losing the opportunity to receive WTW benefits. Per one caseworker, staff were instructed to, explain all . . . options to the clients\/customers and let them make the decision as to what they wanted, during the MRCs. An administrator in another county commented that the caseworkers were coached to have appropriate conversations with participants, so a client can make the best decision for their situation. MRCs appeared to have been dually focused on educating participants about the new WTW options and helping participants decide between WTW or CalWORKs federal program activities. Challenges with the 24-Month Time Clock In each of the six focal counties, county administrators, caseworkers, and service providers cited multiple challenges with the 24-month time clock. One clear concern, across all six focal counties, was a lack of understanding about the clock. County administrators and caseworkers noted confusion on the county level on multiple fronts, including (1) perceived impact of the conflict between the WTW 24-month and 48-month time-on-aid clocks, (2) calculation of the 24-month time clock, (3) explanation of the 24-month time clock to CalWORKs participants, (4) manual revisions of the time clock, and (5) concerns about participants' 24-month time clock expiring (i.e., timing out ). The following section details the challenges reported involving calculation and understanding of the 24-month time clock, and outlines the impact of these difficulties on caseworkers and CalWORKs participants. Perceived Impact of Conflict Between WTW 24-Month and 48-Month Time-on-Aid Clocks The many differences between the CalWORKs WTW 24-month time clock and the federal 48-month time-on-aid clock introduced earlier were a source of significant confusion for everyone involved in calculating and implementing these clocks. Specifically, in all six focal counties, concerns were expressed about caseworkers and participants' understanding of how to track time on aid. One administrator from a large county stated, . . . the challenge [is that] we hope that the participants as well as the staff really understand that they have to look at both [time clocks] and see that they [participants] have time available. Another commented, [during case reviews] you have to look at both clocks together . . . because we have had cases fall off the 48-[month time-limit] who should have had adjustments . . . Yet another administrator from a different county said, I'm an educated woman and it's hard for me to keep track of . . . it's tough! Given that participation in services is contingent upon available time on aid, it is important that all parties are clear on the elapsed months. Differences between the WTW and CalWORKs federal program's guidelines on service provision was another perceived challenge cited by interviewees in each of the six focal counties. One caseworker in a focus group commented that the federal government is not thinking barriers, [t]he state is thinking barrier removal. Another caseworker in the same focus group said, . . . the federal and state sides don't match up [regarding addressing barriers]. 113 Additionally, a supervisor argued that some participants have a more limited window within which they can receive WTW services that would support engagement in employment; since they have less than 24 months left on their 48-month time-on-aid clock. Finally, some interviewees expressed concerns over the consequences imposed on the caseworkers, counties, and state for providing services (e.g., noncore activities) that do not comply with federal work requirements. One caseworker illuminated this point, stating, The state regulations for the 24- month does not have core hours\u2014but the federal requirements expect core hours, and without that, the state and county stand to be losing a lot of money. Incongruence between the foci of the two programs thus presented challenges at multiple levels. Calculation of the 24-Month Time Clock As indicated above, calculation of the 24- month time clock, also known as determining whether the clock should tick or if the caseworker should untick it for approved reasons, is an important task of the caseworker. (See Appendix A for an overview of the calculation of the 24-month time clock.) Many caseworkers found the task of calculating the WTW time clock particularly challenging and confusing, in part because CDSS frequently changed the guidance on regulations for calculating the 24-month time clock. For example, under new direction from CDSS (released in November 2014), caseworkers were to use an averaging methodology to determine if a client was meeting the minimum weekly hours under the 24-month time-clock plan. The weekly average is calculated by adding the total number of participation hours in all CalWORKs activities for the month, dividing by 4.33, then rounding to the nearest whole number (CDSS, 2014h). However, depending on the number of working days in a month, averaging in this way may mean that participants technically had to have more hours than detailed on the WTW form in order to meet WPR. (See the text box for further detail.) Consider the following scenario: a CalWORKs participant's WTW plan indicates that she is to complete 20 hours a week or an average of four hours per day. Prior to the November 2014 change in calculating the 24- month time clock, there was no averaging involved: If she completed at least 20 hours each week of the month, she met the requirements. Using the averaging method, hours are first added up over the calendar month. Calendar months may have from 20 to 23 working days (weekdays). With 22 or 23 working days in a month, a participant working four hours per day and 20 hours per week would then have 88 or 92 hours in a month. When divided by 4.33, the average exceeds 20 hours per week. In a month with 20 or 21 working days, the average after rounding will just fall short of 20 hours per week (e.g., 84\/4.33=19.4). Thus, although the averaging method potentially provides a participant with flexibility in shifting hours across weeks in the same month, she may technically not meet the WPR in some months, even though she completed the 20 minimum hours as listed on her WTW form. 114 Respondents from five of the six counties expressed frustration over the change instructions from the state regarding the methodology for calculating the hours. This was particularly frustrating for county administrators and caseworkers, because previous directions from CDSS instructed them not to use this averaging methodology. One county administrator explained: . . . we did get [new] rules on ACL regarding how hours are calculated. Before that, the hours were straight hours, 20, 30, or 35 for a household. That was the minimum to be met weekly. No averaging. So if you were supposed to do 20 hours, and you only did 18 one week, then you didn't meet the requirements for that month. In November, the ACL retroactively changed the rule going back to July and said . . . now you have to use a 4.33 divisor to determine if [the minimum monthly hours] are met or not met . . . That's in line with the federal rule, they've always had a 4.33 divisor so now the state has gone that way. In theory, if you are averaging out and you want to meet 20 hours [per month], you have to do at least 22 hours per week. Averaging that by 4.33, that'll get you to 20 . . . It's just been a slow burn with staff . . . [they must be sure to] convey this to their customers. The new averaging instructions led to further difficulty for both participants and caseworkers. Since the actual hours that participants had to complete were higher than was stated on their WTW forms, they were at increased risk for noncompliance with WTW or CalWORKs federal regulations, and thus, sanctions. For caseworkers, the new regulations meant more data entry, record keeping, and calculations. Caseworkers in all six focal counties expressed their frustrations with the number of changes to the CDSS instructions on the 24-month time clock. When asked about how the ACLs from the state affected the methods used to calculate the 24- month time clock, one caseworker explained, [There was a] one month period where CDSS was coming out every other week with a change in policy. It changed so fast that what people learned in the first training versus the last training wasn't the same thing . . . So we still don't [calculate the 24-month time clock] the same way. We have already gone back and recalculated them all, and we don't have time to go back and redo them all again. Because multiple exemptions can apply to the same individuals, caseworkers were often confused about how to apply the exemptions. One caseworker stated, If it was black and white, it would be easier to get though. The state has given so many exemptions that you have to go back every single month and recheck everything. There are so many different variances in [the 24-month time clock rules] that it's unrealistic. A county administrator in a different focal county spoke of this confusion among the staff regarding this issue in terms of the overall complexity of calculating the time clock, saying WTW is not one size fits all . . . there would still have to be a manual or a workaround because everyone's needs are different . . . Staff have to manually enter data into the system . . . It's almost like [the caseworkers are] working in reverse. The clock always ticks, unless they stop it . . . Some staff have 115 challenges selecting from multiple exemptions. The caseworker needs to understand how the clock applies, and needs to know all the regulations . . . so there's lots of room for human error. The difficulties of calculating the 24-month time clock\u2014which included the challenge of applying multiple exemptions and keeping up with evolving instructions from CDSS\u2014led to concerns about time-clock accuracy. Despite counties' efforts to standardize and clarify time- clock calculations, many caseworkers remained unclear about the process. Caseworkers in each of the six focal counties acknowledged inconsistencies in time-clock calculations. As one respondent stated . . . The general consensus across the board is that no one knows for sure how to do it [the 24-month time clock] or calculate it. You could sit down and watch all of us do it and I bet you would see a dozen different ways to get to the same end result. You may even get half a dozen different results at the end. There is no right or wrong, and nobody is really sure. It's kind of an, Okay, that sounds right . . . Explaining the 24-Month Time Clock to CalWORKs Participants County administrators and caseworkers alike noted how widespread confusion about calculating and implementing the 24-month time clock translated into difficulties discussing the time clock with participants. In one caseworker focus group, respondents spoke of the confusion on completion of the WTW 2 form. One caseworker commented that she tells participants, Don't worry about core or noncore\u2014just do your hours! Her coworker, a caseworker in the same county, admitted, Sometimes we don't even understand\u2014we just pretend. A county-level administrator commented, It was very confusing . . . a lot of times you have to work it out and walk it through with your staff for them to understand it. Imagine, if you have to do that with your staff, what they have to do with the customers to get [them] to understand. Some customers still don't understand it. When asked how well line staff understood the changes associated with SB 1041, one county administrator said bluntly, [Staff comprehension of the 24-month] time clock is a little sketchy. Earned income disregard, they are okay with that. But the [24-month] time clock, everyone is a little sketchy on. Another administrator from a different county commented on how caseworker confusion about the 24-month time clock impacted the caseworker-participant relationship, saying, The [core and noncore] activities are on the same page. They [caseworkers] don't know where they should put the information. We shouldn't have to figure that out in front of the client. They lose credibility with the customer that way. Caseworkers and county administrators in five of the six focal counties expressed concerns that CalWORKs participants did not fully comprehend what the 24-month time clock meant for them. As mentioned previously, the clock featured multiple exemptions, fewer required hours, and numerous clock stoppers, all of which were designed to help participants address barriers to self-sufficiency. Caseworkers worried that participants would instead understand this time as a 116 way to continue receiving cash aid for less effort, and would not use the 24 months effectively. One caseworker noted For the majority of clients I saw, once you tell them that they have reduced hours, that's all they heard. I tried to explain to explain the difference of the [WTW 24-month] plan . . . once you finish that 24th month you are going to have to go to the CalWORKs federal plan and that is going to be absolutely mandatory . . . but they would just nod their head and sign off on [the plan]. Others thought clients perceived the CalWORKs federal 48-month time limit to be more important than the 24-month time clock, and as such were not fully cognizant of the consequences associated with timing out of the 24-month clock. One county administrator said Clients are still focused about the 48-month [time clock], not the 24-month [time clock] . . . the participants [don't] recognize how crucial it is to stop the 24- month clock. Even though we tell them and we review the [24-month] time clock, it hasn't sunk in. They are concerned about the 48 months. Overall, caseworkers had difficulty explaining the 24-month time clock to participants, and were worried that participants did not truly understand what the time clock meant for their paths to self-sufficiency and their time on aid. Impact of 24-Month Time Clock on the Role of the CalWORKs Caseworker Caseworkers felt their primary role within the county had shifted from counseling to data entry. According to caseworkers in the focal counties, prior to SB 1041 and the 24-month time clock, they spent their time talking with participants, assessing barriers to self-sufficiency, and collaborating with clients to determine the best options. Now, they indicated that they spent more time calculating and generating reports than talking with their customers. One caseworker discussed how the calculation and data entry of the 24-month time clock, particularly as it pertained to reviewing cases, changed her work, stating: It's taking forever to get cases done\u2014 we were doing overtime to get it done. It was taking away from the clients and our services to the clients to get it done manually. The increase in reporting and data collection also changed the nature of the conversation between the caseworker and the participant. As one caseworker noted Talking [with participants] about the [24-month] time clock takes the focus off counseling. It takes the time [away] from talking to them about education, how they did on their interviews, etc. Instead [the caseworker has to] explain 'you need to meet [these WTW requirements].' So, it is about the numbers, not the customer. 117 Determining Extensions of Participants' 24-Month Time-Clock At the time of the focal county site visits, guidance to counties on addressing participants who were or had exhausted their 24-month time clock was at varying stages of implementation.41 An administrator in one county commented, we recently got an ACL from the state, as I said it [ACLs] always comes after the fact, now you [counties] can go back and give them [participants] some more time . . . Delayed guidance from the state had a negative effect on staff, as notification letters to the participants regarding the expiring WTW time clock needed to be generated manually. One county commented that they were . . . in the planning stages to do the training to the staff on what to do . . . once somebody's hit their 24-month clock. While just beginning to experience time-clock expiration for some of their participants, one administrator said we are having a lot of people file for extensions. It has become very popular. However, administrators and other service providers in three counties highlighted that there are a number of exceptions available that allow participants to extend their 24-month time clock. The administrators in two of these counties added that, I would be surprised if we ended up with really large number of people at the end of the 24-month time-clock and there are so many [exceptions], that they [the state] don't seem to want the clock to stop ticking. Perceived Benefits of 24-Month Time Clock From the perspective of the administrators, supervisors, and caseworkers, the 24-month time clock provides CalWORKs participants the flexibility to participate in noncore activities that address barriers to employment and self-sufficiency. As noted earlier, the noncore activities include education related directly to employment, job skills training related directly to employment, and satisfactory attendance in English as a Second Language or GED courses (CDSS, undated-b). All staff groups in the six focal counties commented that the new time clock provided greater flexibility and breadth of options to participants. However, some caseworkers and administrators worried that increased flexibility might cause participants to lose sight of the fact that WTW benefits are time limited. They encouraged participants to keep the long-term plan in mind. Specifically, administrators and service providers in four counties noted that elimination of core requirements allowed participants to focus on to education, part-time employment, and treatment without the pressure of supplementing their required participation hours with core activities. This point is well stated by one administrator: 41 Initial guidance on extending the 24-month time clock was issued by the state on February 5, 2014, in ACL No. 14-09. Since then, five additional ACLs handling expiring time clocks were released (ACLs 14-48, 15-01, 15-02, 15-03, and 15-59) that provided instructions on calculating and tracking extensions, explained the methodology for determining the target number of extensions, described the process for transitioning participants to post 24-month time-clock federal standards, and outlined the target number of extensions estimated for July 2015 through December 2015 (CDSS, 2014f; CDSS, 2015a; CDSS, 2015b; CDSS, 2015c; CDSS, 2015d). 118 If someone wanted to focus more on training versus having to do multiple activities\u2014such as having to do like community service just to meet a core requirement, or [work] experience, or trying to focus on getting a part-time job\u2014 and having more time to just solely focus on finishing up their training, they might be able to finish faster, take more courses, rather than trying to balance it with multiple activities. While the flexibility offered through SB 1041 was seen as a potential benefit for clients, the overarching take-away from our discussions with staff in the focal counties was that the actual implementation of the 24-month time clock was challenging to implement, particularly for the caseworkers. Work Participation Rate As noted in Chapter One, a central component of the federal TANF program is the WPR.42 Federal law requires states to meet a specific WPR or face a penalty by losing a portion of their TANF grant allocation. At the same time, SB 1041 modified the CalWORKs program to allow work-eligible individuals to participate in activities that do not count toward the WPR. Table 5.1 illustrates the difference between the CalWORKs federal and CalWORKs WTW work requirements and notes compliance with the federal WPR. Calculating Weekly Participation Hours The weekly work participation hours required for the WTW program are aligned with federal requirements. However, the methodology for calculating participation hours differs for the programs. Caseworkers spend an extensive amount of time calculating work participation hours, which significantly affects their workload. For WTW, this process consists of calculating a weekly average by adding the total number of hours of participation in CalWORKs activities for the month and dividing it by 4.33, then rounding to the nearest whole number (CDSS, 2014h). Table 5.1. CalWORKs Federal and WTW Requirements Hourly Work Requirements (hours per week) Case Type CalWORKs Federal Requirements (up to 48 months) CalWORKs WTW Requirements (for 24 months) Single parent with child younger than age six 20 core 20 noncore Single parent with no child younger than age six 20 core\/10 noncore 30 noncore Two-parent family 30 core\/5 noncore 35 noncore Meets federal WPR? Yes No 42 The WPR is determined by dividing the number of cases meeting the federal work requirements (the numerator) by the number of cases subject to the requirements (the denominator). 119 The averaging methodology for the CalWORKs federal WPR requires calculating a weekly average for each activity type (core and noncore) for the month and dividing each sum by 4.33, then rounding the quotients to the nearest whole number and adding the results. Veracity of these calculations is extremely important, especially for the CalWORKs federal WPR. Unfortunately, caseworkers in half of the focal counties reported confusion on calculating the hours for activities that meet WPR requirements. However, due to the criticality of meeting the WPR, three of the six counties indicated that they established specialized units to collect, verify, and report hours to the state. Consequences of Not Meeting the CalWORKs Federal WPR During the site visits, administrative and caseworker staff in five out of the six counties expressed serious concerns over the possibility of state- and county-level sanctions for not meeting the CalWORKs federal WPR. However, trepidation over the potential negative impact of not meeting WPR extends beyond state- and county-level penalties. Administrators and caseworkers in all focal counties felt that they were subject to consequences for falling short on the CalWORKs federal work requirements. Caseworkers in a focus group in one county shared that, in addition to the county sanctions, caseworkers are penalized in the form of Corrective Action Plans when their cases don't meet WPR. Caseworkers in another county discussed indirect effects of county noncompliance with WPR, including possible job loss if the county was sanctioned. Embarrassment for not meeting WPR during audits was another negative outcome cited by caseworkers in one of the counties. Another county's caseworkers affirmed this sentiment by noting that caseworkers feel like they are failing if they do not meet their performance standards. Administrators in another county commented that two consequences experienced by caseworkers include increased workload to assist participants with meeting WPR requirements, and poor performance reviews if they fail to do so. Perceived Impact of SB 1041 on WPR One of the most common concerns voiced by county staff was the tension they felt between supporting clients' participation in SB 1041 while feeling pressure to help the county meet WPR. Administrators in five of the six counties felt that the incentives or rules of SB 1041 were in conflict with the goal of meeting WPR and that SB 1041 directly contributed to a low WPR. One county administrator commented that SB 1041 takes them further away from meeting WPR. When asked about the impact of this legislation on WPR, one county caseworker responded, It's a detriment to state and federal WPR numbers. Administrators, caseworkers, and service providers in all focal counties cited an apparent conflict between the WPR (CalWORKs federal) requirements and SB 1041 (WTW) requirements. All staff across the focal counties argued that WPR and SB 1041 differ in terms of philosophy, types of approved activities or exemptions, and the level of flexibility offered to participants. In addition, administrators and caseworkers across 120 the six counties stated that incongruence between the CalWORKs federal and SB 1041 policies contribute to staff confusion and high workload. The primary recommendation offered by most of the counties was alignment of the CalWORKs federal and SB 1041 requirements. Administrators in one county asked, When is the state going to go back to the table and see if they can align [SB 1041 requirements] with the Feds? An administrator in another county said, If I had one wish, I wish everything was synced up . . . Caseworkers in the same county said, We should mirror what the federal does [to meet the WPR]. In sum, while many counties recognize the benefits that SB 1041 affords CalWORKs participants, fear of not meeting WPR appears to outweigh the perceived advantages of SB 1041. Philosophical Differences: Work-First vs. Work-Ready Approach The WPR requirements are heavily work-focused with limited opportunity for participants to engage in non work-related activities. Conversely, SB 1041 emphasizes the importance of mitigating the impact of potential barriers to employment through a variety of supportive services and options to participate in non job-related activities. Administrators and caseworkers reported challenges reconciling these work-first versus work-ready philosophies. Some characterized the work-first approach as doing what is best to meet WPR, and the work-ready strategy as doing what is best for participants. Caseworkers in one county highlighted this point by saying, you either help the participant or take the hit [on their performance for not meeting WPR]. Out of concern for the WPR, caseworkers in three focal counties indicated that they strongly encourage CalWORKs participants to engage in activities that meet the CalWORKs federal requirements. However, five out of six focal counties suggest that the work-ready activities offered under SB 1041 (e.g., education) may offer better opportunities for achieving self-sufficiency; thus are in the best interest of the participants. Balancing the competing values of WPR and SB 1041 is an ongoing struggle for the counties. Approved Activities or Exemptions Administrators and caseworkers in five of the focal counties referenced the inconsistency between the types of activities that participants can engage in under the CalWORKs federal and WTW policies. In order for participants to meet the CalWORKs federal WPR requirements, they must spend the requisite number of hours doing job-related core activities. However, SB 1041 allows participants to spend all of their required hours engaged in noncore activities that do not have to be directly associated with getting a job. An administrator in one county commented that the biggest problem with SB 1041 is that noncore activities are not compliant with the CalWORKs federal requirements. Caseworkers in another county indicated that the state's WPR review only looks at the core hours, not the SB 1041 noncore hours. They added that this is a disservice to the participants who opt into noncore activities and the caseworkers who work with those participants to select appropriate activities. 121 Caseworkers in one county agreed with the statement of their colleague: The state understands barriers, we understand them, [t]he federal government doesn't. SB 1041 permits participants who experience barriers to employment to defer or limit engagement in any activities while they receive desired supportive services. Additionally, time-limited, intensive case management is available in most counties through the FS program. While participation in these activities is considered acceptable under SB 1041, it does not exclude participants from the CalWORKs federal WPR sample. One administrator said, We have a ton of participants [who requested the state-only young child exemption (for individuals with a child under two years old)]. That dings us for our [CalWORKs federal work participation] rates. Another administrator lamented the conflict between the CalWORKs federal and SB 1041's handling of struggling participants this way: I understand that they're [the state] trying to do good things, but you [the state] hold us accountable for WPR . . . Level of Flexibility From the perspective of caseworkers in the focal counties, SB 1041 afforded participants unprecedented freedom to choose their own activities. As previously noted, participants can completely opt out of core activities for 24 months. During this time, these cases are noncompliant with the CalWORKs federal WPR regulations. Administrators and caseworkers in half of the focal counties suggested that SB 1041, vis-\u00e0-vis participant choice, disincentivizes engagement in federally approved activities. Caseworkers reported being discouraged in some instances from counseling participants to choose noncore activities because it was detrimental to meeting the CalWORKs federal WPR. Caseworkers in one county said, We are being held accountable for their [participants'] choices . . . so [we] try to encourage them to do things that meet WPR. Given the cost of participant flexibility, some counties feel compelled to limit participants' freedoms for the sake of the CalWORKs federal WPR. Staff Confusion and Workload Misalignment of the CalWORKs federal and WTW requirements contributes to confusion at all levels, including administrators, caseworkers, and participants. Administrators in one county noted that it is hard for caseworkers to explain the difference between the rules and their impacts to the participants. Specifically, one administrator shared that the WTW form that differentiates between activities that are allowable for the WTW and CalWORKs federal programs, [is] very confusing, [and] cumbersome. Caseworkers in another county said the following regarding the confusion between the two different requirements: Because they are in conflict with one another; [we] communicate to them [CalWORKs participants] the goals [of] both. Staff confusion about the difference between the rules and the calculation of the WTW time clock contributes to an increase in work volume. A county administrator explained this point by stating, The time clock piece of WPR [is] really messy, [s]o it adds to [caseworker] workload time for every single case. 122 Understanding of SB 1041 In our work in the focal counties, we explored the extent to which caseworkers and participants (based on the perspective of staff and the participants themselves) understood the changes to the CalWORKs program. Counties' Perspective on CalWORKs Participants' Understanding of SB 1041 Across the focal counties, leadership and caseworkers described a varied and multipronged effort to communicate the SB 1041 changes to participants, including holding weekend reengagement sessions for participants, sending mailers, having MRCs with participants, explaining the changes when caseworkers met with individual participants, and using a customer service helpline. Caseworkers in three of these counties said that they were instructed to meet with participants in person rather than sending out contracts so the participants would better understand the changes. Leaders and caseworkers identified several aspects of SB 1041 that have been difficult to explain to participants\u2014these include the two different time clocks (the 24-month time clock and the 48-month limit on cash assistance) and the differences in how they tick, along with the number of hours of participation each requires. While some participants may grasp the time clocks, they may not understand how the flexibility offered under the 24-month time clock could benefit them. Caseworkers reported that they spend a good deal of time talking with participants about time limits, but, as one caseworker pointed out, some participants do not understand the foundational concept that their time on aid is cumulative over the participant's lifetime. Another particularly onerous task, as described by caseworkers, is explaining to participants how the new 4.33 divisor (explained in detail in the section on the 24-month time clock) is used to calculate participation hours. Caseworkers also noted that explaining the difference between core and noncore activities (e.g., vocational training versus Job Club) to participants can be difficult. In addition, several leaders highlighted that communicating the urgency of becoming self- sufficient to participants is not always easy\u2014a challenge that existed prior to SB 1041. Leaders and caseworkers noted that some participants focused primarily on the fact that they now had fewer required hours rather than how to make the best use of the flexibility. Some participants are in survival mode, explained one leader, and can only focus on what they need to do to get through their situation. Similarly, a caseworker in a different county said participants are focused just on the present and cannot look two or three months down the road. Caseworkers in two other counties voiced that some participants do not want to take the time to understand or only focus on certain aspects of SB 1041, such as increased choice in program activities. Lastly, leaders in two counties pointed out that during the early implementation stages, the staff might not have fully have understood the new program and thus might not have explained it clearly to participants. Staff echoed this concern that participants cannot be expected to understand SB 1041 if their caseworker does not understand it. When asked about client understanding of 123 legislation, caseworkers noted there is still a range in the level of understanding both at the caseworker and participant level, echoing what was stated earlier. Leaders in all six focal counties reported that while there are still many participants who do not fully understand the implications of SB 1041, there is much less confusion now compared with two years ago, when the legislation was implemented. Caseworkers shared a somewhat similar perspective on the extent to which participants understand SB 1041, noting that staff are getting better at explaining the program, but it is still difficult for many participants to fully understand the changes brought about through the new legislation. CalWORKs Program Participants' Perspectives of SB 1041 Across the 12 focus groups, participants reported that their primary sources of information about services and benefits available to CalWORKs participants were friends, family members, or other participants. From the participants' perspective, caseworkers did not provide consistent information about access to benefits and services, unevenly applied program rules, and inconsistently offered program, services of benefits. Across focus groups, participants indicated that they also received information from the CalWORKs program by mail but many reported that they do not always pay attention to the letters unless they are being informed that their benefits are going to be reduced, citing concerns that the information is often confusing and difficult to understand. The majority of focus group participants stated that they did not feel like they had a strong understanding of the benefits or services for which they might be eligible and stated that they had a very basic understanding of how the CalWORKs program works. For example, they understood that they have a limited amount of time during which they can receive cash assistance and food stamps and that there are certain activities and paperwork that they have to complete in order to continue to receive benefits. However, they did not have a clear understanding of how the amount of their cash assistance and food stamps is determined and often did not understand why the amount of assistance they received goes up or down (or why their cash assistance goes down but their food stamps go up). In addition, participants had an uneven understanding of other benefits or services for which they may be eligible (for example, many participants did not know they could receive assistance to secure stable housing), or when or how their clock started or stopped. In fact, several participants reported that they did not know how much time they had left in the program. Participants reported that if they had questions or concerns regarding the services of benefits they are or are not receiving, they would typically contact their caseworker. However, they also expressed frustration at their inability to get a satisfactory or timely response from their caseworkers. Across focus groups, participants complained that getting in touch with their caseworkers by phone was difficult and in some cases impossible, and that it could take several days and sometimes even weeks for a caseworker to respond. Participants were asked to give their perspective on the impact of participation in the CalWORKs program. With one exception, participants across the 12 focus groups reported that 124 CalWORKs had definitely helped them and their family. Participants identified cash assistance and food stamps as the most important aspects of the program, with someone noting that without them, they would be homeless or unable to feed their children. Although two of the participants reported that receiving assistance with child care had been the most useful service because it had allowed them to go back to school or to start working, some other participants voiced concerns about the burdensome requirements and process for accessing child care (and how long it took for the program to reimburse child care providers). Participants were asked to identify the services that they had found the most helpful or important in helping them find a job or go to school. Most participants reported that the cash aid and food stamps had been the most helpful, but several participants reported that help with transportation and child care had also been extremely useful. Participants that had been going to school also mentioned the assistance they receive in paying for schoolbooks and fees as being very useful. Across focus groups, only three participants reported receiving help with housing (although it is important to note that housing was identified by staff across all of the focal counties as a significant need among participants). None of the participants reported receiving counseling or services for help with alcohol or drugs, and only a few of the focus group participants said they received mental health services or domestic violence services. Participants discussed if, and how, the CalWORKs program supported their growth toward self-sufficiency. Across the focus groups, participants stated that they needed more options, particularly in terms of the educational options that the CalWORKs program was willing to accept,43 help in finding a job, better volunteer opportunities that could turn into paying jobs, and more counseling services for issues related to mental health or domestic violence.44 CalWORKs Participants' Feedback on SB 1041 Across all 12 focus groups, the majority of CalWORKs participants reported they were unaware of the changes to the CalWORKs program as a result of SB 1041, which became effective in 43 In three of the focal counties, six participants commented that CalWORKs will provide support (e.g., help with books, etc.) if one is enrolled in a trade school or a community college, but not if one is attending a four-year college. Several also commented that their caseworker limited their choices of what schools to attend\u2014this likely was in part due to concerns we heard from caseworkers of CalWORKs participants signing up for for-profit schools or training programs where there was not a demand for those job skills in the local market. Another individual wanted flexibility in selecting which adult school to attend for GED preparation. 44 With respect to an interest in more counseling services for issues related to mental health, alcohol or drug treatment, or domestic violence, several participants in five of the six focal counties expressed the need for better information on what services were available to them. Some found out about the availability of mental health services, for example, from other participants and others researched online what services were offered by CalWORKs. They noted that caseworkers varied in terms of what services they would offer a participant or inform them about. Several domestic violence victims indicated they were told about domestic violence counseling service but did not receive a referral to them. Another individual said she was embarrassed to ask her caseworker about drug counseling services and said it would be useful if there were written materials she could have used to find out this information. In general, several participants per county indicated that having better information about what counseling services were available would have been helpful. 125 January 2013 and that affected the benefits and services that participants could receive under the program. Consistent with earlier findings, participants who had enrolled in the program after 2013 were not aware of changes to the CalWORKs program, but even participants who were in the program prior to 2013 either were not aware or had limited understanding of the policy reforms and the effects they could have. Drilling down into the specific components of SB 1041, almost none of the participants said they knew that SB 1041 provided more flexibility in selecting activities they might want to pursue to help them achieve self-sufficiency, that changes had been made to the weekly core requirements, or that the short-term young child exemption had been eliminated. Some participants were aware that there had been adjustments to the numbers of participation hours required for single-adult families, although they did not know why these changes were made. Participants were asked if they were familiar with the 24-month time clock, including whether they understood what it meant or how it worked. While several participants had heard the term, the vast majority across focus groups did not understand how it worked. Among those who were aware of the 24-month time clock, some reported having received a letter from CalWORKs on this aspect of SB 1041 while others indicated that this had been explained by caseworkers. At the same time, many participants did not know how much time they had left on their 24-month time clock (while much more aware of how much longer they were eligible for cash aid, based on the 48-month limit). In addition, all participants reported that at some point, a caseworker had talked to them about the types of activities they could participate in, but they didn't specifically link these activities to the 24-month time clock and in some cases, participants reported that they had been told about various activities only when they first enrolled in the program. A recurring theme across the 12 focus groups was lack of information on activities they could participate in and services they could receive, along with the sense that caseworkers did not provide information on services and activities unless the participant specifically asked about them. A recurring complaint among participants across the focus groups was that caseworkers provided inconsistent information about and access to benefits or services and that there was a great deal of inconsistency in terms of the information caseworkers provided, how strictly they applied the program rules, and what programs, services, or benefits were offered to participants. When asked about educational opportunities that were available to them, participants' comments were mixed. Some participants reported that their initial caseworker (when they first enrolled in the CalWORKs program) had talked to them about continuing their education and had discussed specific options. Others reported that they had looked into education programs themselves and reported back to their caseworker. Most of the participants were aware that they could complete their GED, attend some college courses, or could pursue vocational or technical training\u2014but only at approved institutions. Some participants reported that they could continue to receive assistance from CalWORKs if they were attending a community college, but that they had been told that their assistance would stop once they transferred to a four-year university. 126 Others reported having been told that their assistance would continue even after they transferred to a four-year university. In each of the six focal counties, two or three participants per focus group on average reported participating in educational activities while in CalWORKs, including GED programs, vocational training programs, or community college classes. Some indicated they had returned to school to complete their GED, while others were pursuing technical training as a nursing assistant or medical technician. A few said they were pursuing a university degree or had plans to go to a university; one participant reported that she had completed a university nursing degree as a result of the assistance she received from the CalWORKs program (that included cash assistance, food stamps, transportation, help with books and school fees, and child care). At least one participant per focus group mentioned receiving assistance from the CalWORKs program (e.g., aid for books, transportation, uniforms, etc.) to attend school. Many of the participants who were pursuing an educational option reported that CalWORKs program support was crucial in becoming self-sufficient and would allow them to get a better-paying job so that they could get off public assistance. Among participants who were not pursuing an educational option, some reported that they had not discussed it with their caseworker or did not seem particularly interested, while others stated that there were barriers that made it difficult to pursue or continue their education. This included not having adequate child care or transportation, having to work to support their child or children, and not being able to afford fees or supplies that CalWORKs would not cover. CalWORKs Participants' Reported Experiences with Caseworkers Interactions between caseworkers and participants were a focus of discussion during the focus groups\u2014an issue that affects the CalWORKs program as a whole and is particularly relevant to SB 1041, given the detailed changes that were brought about under the new legislation. First, participants described a high level of turnover among caseworkers (with participants commonly reporting between five and six caseworker changes\u2014and, in a few extreme cases, as many as 20 to 25 caseworker changes) and in some cases, without participants' knowledge. This appeared to be very frustrating for participants as they were forced to explain their circumstances and needs to each new caseworker, in some cases, experiencing delays in getting assistance as a result. Second, in each of the six focal counties, participants mentioned difficulty in contacting their caseworker and that, in some instances, it took the caseworker a long time to return messages. Several participants commented that the caseworker never called them back or responded to email or text messages. These individuals indicated that when they needed to see their caseworker, they would go to the CalWORKs offices in person, sometimes waiting several hours to see their caseworker. On the other hand, some participants reported positive experiences with their current or a previous caseworker, noting that the caseworker had been very responsive to their requests, was knowledgeable about what services and benefits they were eligible for, and had encouraged them to go to school. 127 Several participants in four of the six focal counties also expressed the view that caseworkers have such large caseloads that they often do not have enough time to talk to participants about their plan for getting off assistance or to discuss different options for doing so. In one instance, a participant was told by a supervisor that their caseworker's large caseload was the reason for the delay in the caseworker getting back to the client. Some focus group participants commented that time with caseworkers was spent primarily on completing and signing forms or on resolving sanctions or other issues with their aid, rather than discussing options for getting off aid. In each of the six focal counties, several focus group participants reported that some caseworkers appeared overwhelmed and uninformed and that new caseworkers did not seem to be appropriately trained and were themselves unsure about different aspects of the CalWORKs program or the different options available to participants. In five of the six focal counties, several participants per county reported that they felt like they themselves had to research different options, services, or benefits and bring these to the attention of their caseworker. Others reported that caseworkers were careless with their paperwork, for example, losing forms they turned in or taking a long time to process their forms, resulting in sanctions or delays in reimbursement for services such as transportation or child care. Some of these participants indicated that they had learned to make copies of all the paperwork they turned in and to keep detailed records of their activities, dates they turned in the forms, and interactions with their caseworker in order to be able to prove that they fulfilled program requirements when their paperwork was lost or misplaced. Finally, several participants in each of the six focal counties commented that some of the caseworkers were unprofessional in dealing with them and that they felt they had to avoid getting the caseworker upset for fear of reprisals or repercussions that may affect their aid or services they receive. Others said they had reported a caseworker to a supervisor in order to get assistance with a problem. At the end of each focus group, the moderator asked participants to provide recommendations for improving the CalWORKs program. Recommendations provided by participants included the following: Create more time for caseworkers to spend with clients by hiring more caseworkers and reducing their caseload. Improve caseworkers' customer service as well as their knowledge about aspects of program requirements. Provide more information (e.g., written materials, website) that describes all the programs, services, and assistance available to them. Standardize access to programs, services, and assistance for all participants. Provide more information about options and modify the CalWORKs database\/information system so that the system can generate a list of services, programs, 128 and types of aid for which the participant is eligible (rather than leaving this up to the discretion of the caseworker). Expand child care options and streamline the process for getting reimbursed for child care and transportation. Improve access to counseling services and housing, as well as enhanced job search supports. Improve access to educational opportunities, particularly for non native English speakers. Early Engagement Activities At the state level, SB 1041 was negotiated within the context of new or expanded programs intended to maximize the promise of the 24-month time clock. Under AB 74, those programs, known collectively as Early Engagement, include the OCAT, FS program, and ESE program. We gathered information from both county leaders and caseworkers regarding the components of AB 74, given their relationship with SB 1041. OCAT As noted earlier, state-level interview respondents characterized the OCAT as a key component that would support the implementation of SB 1041. In addition to standardizing the assessment process across all counties in the state, the OCAT was designed to provide a more in-depth assessment of clients' barriers and needs than what was typically done prior to SB 1041. As detailed in Appendix A, the OCAT is based on the federal TANF OWRA. A workgroup process modified the OWRA to produce the draft OCAT, which was initially tested with five early user counties and then customized based on the feedback. Subsequent piloting occurred with five counties (some overlapping) starting in mid-2014. Statewide training and implementation occurred in spring 2015 with a projected August 2015 time frame for statewide implementation. Two of the six focal counties included in this study\u2014Los Angeles and Sacramento\u2014were pilot-testing the OCAT at the time of our 2015 site visits, with the other counties aware of the tool and awaiting training. The majority of focal county staff\u2014leadership and caseworkers alike\u2014across the counties described the OCAT as a vehicle to conduct a more comprehensive appraisal of an individual's needs and develop a tailored WTW plan to address their barriers. According to both leadership and caseworkers, the OCAT will likely lead to more effective and early identification of client barriers, improve the referral process to appropriate services, and increase referrals to the FS program. As one caseworker commented, Once we start, using it will give us a clear direction on how to help our clients. Caseworkers also noted that, over time, their appraisal forms had been shortened considerably and the more comprehensive OCAT was seen as a positive step. In particular, leadership and administrators from one county emphasized 129 that the OCAT can serve as a vehicle to increase rapport and deepen a relationship between caseworkers and participants. While county administrators and caseworkers across the two focal counties generally were positive about the potential of the OCAT, they identified a common set of concerns: The OCAT is time-consuming, affecting scheduling procedures with clients and caseloads. The most common concern\u2014voiced by administrators and caseworkers in both focal counties\u2014was the length of time it takes to use the OCAT, with some interview respondents stating it can require two to four hours to complete. Counties that were early implementers or piloted the OCAT reported that some CalWORKs participants found the assessment process long and burdensome and were unable to complete it in one sitting. Staff also commented that the amount of time needed to complete an OCAT for a client also affected the number of appraisals that a caseworker could conduct in a single day. This raised concerns about scheduling clients and potentially slowing down the process by which clients had their initial assessment done. Caseworkers were also worried about the impact of the OCAT on their caseloads. The OCAT and other data systems are not currently compatible, resulting in duplication of data entry. Administrators and caseworkers in both counties voiced concerns about duplication of data entry and concerns given that the OCAT did not interface with existing data collection systems, including the statewide automated welfare reporting systems (e.g., C-IV, CalWIN) or county-level systems (e.g., GEARS). The OCAT may result in increased referrals to appropriate services; however, timely access to those services may remain a barrier. Administrators and caseworkers from the focal counties expect to see an increase in referrals to appropriate services as a result of use of the tool. Even with the potential of the OCAT to increase referrals to appropriate services and to identify barriers up front, a concern was whether timely access to services would become an issue. One caseworker speculated that moving the assessment up front still does not address the problem of the length of time it takes to get access to services: Even for the clients, the process it takes for them to get the referral and appointment gets pushed out by a month for mental health; to get to Job Club, they still have to find child care, etc., which pushes them out to the next class. Caseworkers pointed to finite resources to address needs newly identified through the OCAT. Community resources are limited, though. Networking more with the community so we don't feel limited is important. We can't identify barriers in the OCAT and not address them . . . it would be unethical. The sensitive nature of the questions included in the OCAT were a concern for both caseworkers and clients. Staff from both counties that had piloted the OCAT or were early implementers expressed concerns about the sensitive nature of some of the questions being asked on the OCAT. The tool includes items focused on drug use, 130 domestic violence, and mental health issues\u2014many caseworkers, for example, were worried about broaching these topics, particularly as they were at the beginning of their relationship with the client. On the other hand, several interview respondents noted that the OCAT can serve as a vehicle by which line staff can establish a strong relationship with clients. Family Stabilization Program AB 74 called for counties to create a Family Stabilization program, effective as of January 1, 2014. The goal of the FS program is to increase client success through more intensive case management and the assignment of clients to the additional activities or barrier removal services necessary to ultimately achieve self-sufficiency. The FS program is meant to support families as a whole and could include mental health treatment for families, substance abuse counseling, and transitory housing, to name a few supportive services. (See Appendix A for a detailed overview of the FS program.) At the time of this report, all but one of the six focal counties had implemented an FS program. Two of the six counties reported being in the early stages of implementation and were in the process of establishing their programs and determining how to structure staffing. Two other focal counties appeared to be farther along in regard to FS implementation, due to existing social service systems they had in place. For example, one county reported having a robust preexisting infrastructure for domestic violence, mental health, and substance abuse services\u2014 with the introduction of FS, they are now focused on providing new behavioral health supports for children, as well as extended rental subsidies, which are services that were not offered previously. Three counties indicated they had hired new staff to support their respective programs. Based on feedback from county leaders, the startup phase of FS was challenging for three of the five focal counties because it was an entirely new program and necessitated new budgeting processes and the development of partnerships with external social service providers. One county reported that it took six months after initially implementing their FS program to introduce housing services (in the interim, staff referred participants to homeless shelters). Within a month of rolling out the housing component of the FS program, it was put on hold for about two and a half months as an influx of housing referrals overwhelmed the system. The county then reopened the housing program after hiring more staff, although caseworkers are still restricted in the number of FS referrals they can make on a weekly basis, and the county further restricts the total number of referrals that are accepted each week. In general, county leaders across the five focal counties that have implemented FS characterized the program as an effective strategy to support clients with significant needs and barriers. One county leader stated, 131 It's an important piece to have [as part of] CalWORKs . . . up until this point, it was a referral-based [program] instead of case manage[ment]. I think it is real important to keep this program. Another leader stated, the Family Stabilization worker's job is to think outside the box and get those resources. Compared with the comments of county leaders, perspectives on the FS program among county caseworkers were somewhat more mixed across the five implementing counties. Caseworkers in two counties were mostly positive about the program. In the others, some caseworkers shared either neutral or positive opinions of the new program. Caseworkers pointed to significant needs among clients that would require long-term support, particularly those with chronic issues around mental health or housing. One of the most significant client needs identified by focal county staff was housing. In three of the six focal counties, staff reported that the majority of referrals relate to homelessness or that homelessness was considered a significant barrier for families. A fourth county, which claimed child mental health concerns as its primary reason for referrals, also indicated that housing was a great need among families. Caseworkers also identified several implementation issues related to the FS program. For example, in one county, the primary concern was that communication between the FS program and other caseworker staff needs improvement. Two other counties reported that their data system did not include FS information for clients, creating challenges with tracking information. Given that the program is relatively new, these initial implementation challenges are perhaps to be expected. Expanded Subsidized Employment Program The ESE is another part of the Early Engagement strategies. As noted in Chapter One, the program includes funds that counties may use to expand the number of subsidized employment slots available to CalWORKs participants. (See Appendix A for an overview of the ESE Program.) Feedback from focal county staff regarding the ESE program was generally positive (with just one county leader sharing his opinion that subsidized employment does not typically lead to long-term employment for clients). One focal county leader explained how their ESE program is focused on developing a trained workforce, with the hope that it will, in turn, help attract new employers to the county, which are needed in their community. In another focal county, staff described their efforts to strengthen external partnerships to train participants and help them to secure employment (e.g., collaborative efforts between trade unions and community colleges to ensure new vocational classes are accredited). Technology was an integrated aspect in ESE programs in two of the focal counties (e.g., the development of a website to match job-ready individuals with potential employers). Caseworkers in the majority of focal counties referenced positive experiences with the ESE program for their clients, pointing to many who have been 132 motivated by the prospect of a permanent job, hired through the program, and, as a result, have been able to go off cash assistance. Three of the six focal counties provided detailed information about their ESE program, revealing variation in the types of employer agreements and reimbursement rates. For example, in one county, a leader described a wide range of employers with ESE contracts, including preschools, tax credit agencies, restaurants, medical centers, law firms, public agencies, and nonprofits (such as Habitat for Humanity). Table 5.2 displays examples from three of the focal counties of county ESE program requirements. County leadership in three of the six focal counties also shared information regarding ESE eligibility criteria. For example, participants can be identified during orientation, Job Club, or community work experience as a possible candidate for the ESE program. Leadership staff in one county explained that a participant must complete 30 days of WTW activities such as Job Club and an additional 30 days of community work experience (unpaid) before they can be referred to the ESE program. This process helps ensure that the participant is able to address any challenges related to employment (e.g., child care, transportation) before entering the ESE program. A service provider from one of these three counties noted that part of the referral process includes an intensive one-on-one interview with the prospective employee to ensure they are job ready. Ensuring clients are a good fit for ESE was reported to be a key factor that contributed to the success of the program. Caseworkers in four of the six focal counties explained that it can be challenging to encourage participants who would likely benefit from the program to enroll, and conversely, to guide other participants to explore more-appropriate options. For example, caseworkers in one county explained that some participants have a lot of doubt about their employment opportunities and self-worth and may not pursue the ESE program. ESE may not be the best program for all participants, explained a caseworker, and it can be difficult to get participants to understand that completing their GED might be better for them in the long term Table 5.2. ESE Program Designs, by County County A County B County C Employer must agree to hire participants if they successfully complete the program. 100% reimbursement of wages; no cap on wages (industry standard) Employer commits to keep employee for additional six months of unsubsidized employment. Employer must hire for a job that is a minimum of 32 hours a week. Necessary training is also subsidized prior to six months of work. Employer asked to consider each participant as a potential permanent employee. Months 1 3: 75% of gross wage (up to $1500) is subsidized. Months 3 4: 50% of gross wage is subsidized. Months 5 6: 25% of gross wage is subsidized. Necessary training paid for by county (outside of subsidy). Months 1 3: 100% reimbursement of wages. Months 3 6: tiered step down of reimbursement. Subsidy percentage depends on the type of work. 133 than working in a low-wage job. In addition, according to caseworkers, participants who are receiving other benefits, such as subsidized housing, do not always see the value of employment when it may mean reduction of or loss of their cash grant. Noncompliance with employment requirements can be a challenge if the fit is not right\u2014for example, a caseworker estimated a 20- to 30-percent attrition rate from their ESE program due to lack of compliance with the program requirements. Although the majority of focal county staff agreed with the vision of ESE and shared some of the positive perceived impacts of the program during our site visits, leaders and caseworkers in all six counties described a variety of ESE administrative challenges. These included the requirements to spend out other subsidized employment funds prior to using ESE resources, as well as to use ESE resources within a one-year period. ESE is also restricted by the time a participant has left on assistance\u2014once a participant reaches his or her 48-month time limit, he or she is not allowed to remain in an ESE placement in most cases. Finally, participants who transition off of cash-aid, but remain in an ESE placement, do not count toward a county's WPR, a concern cited by one county staff member. Caseworkers in two counties also described administrative barriers in getting timely information about participant placements (e.g., caseworkers' frustration regarding a lack of information about when their participant entered the ESE program and only finding out about it from the participant directly). Staff from four of the six counties also described external factors that were considered barriers to program implementation\u2014namely, identifying and recruiting employers to participate in the program. First, employers must be willing to commit to hiring the participant as a full-time employee after the six months of subsidized employment. Second, it is difficult to find employers who are willing to hire participants with little work experience or who may have a criminal record. Third, the employment sites need to be available within the county. Leaders in two counties explained that the ESE program is focused on placing, in the words of one county administrator, the cream of the crop in employment and will have little impact on other, more- vulnerable participants, such as those without high school diplomas, with criminal records, or who are homeless. County Perceptions of the Impact of SB 1041 The evaluation was designed to gather feedback from county staff about perceived impacts of SB 1041 on the lives of CalWORKs participants. In general, most county administrators and caseworkers indicated that the expanded set of options afforded under SB 1041 within the 24- month time clock was a positive change to the program and increased engagement among participants. However, some staff expressed concern that SB 1041 was detrimental to participants' progress toward self-sufficiency and may have had a negative impact on the caseworker-participant relationship. Education service providers also shared their enthusiasm 134 about the educational prospects that the legislation afforded participants. These issues are explored in detail in the following section. Perspectives of County Administrators When asked how they thought SB 1041 had affected participants, if at all, administrators in all six focal counties emphasized both the positive and negative consequences of the added flexibility that SB 1041 afforded participants with the 24-month time-clock period. Many talked about how participants were now in the driver's seat \u2014they had the choice to decide how to use their time on assistance productively. Some administrators viewed the increased flexibility within SB 1041 as a benefit to participants, noting that their engagement in the program had increased. For example, one administrator said: In some aspects, participation is up, because clients are doing what they want instead of what the county is making them do. In addition, administrators in four of the six focal counties specifically discussed how SB 1041 would allow participants more freedom to pursue their educational goals (e.g., completing a GED, taking English as a Second Language courses, or earning a higher-level degree), and perceived this to be one of the most beneficial effects of this legislation. As one respondent stated, the option of school has always been available, but now they have two years with SB 1041, and the possibility of another year on the federal side . . . before they only had 12 months lifetime in education or vocational training . . . [having more time] takes off a lot of pressure. Some administrators noted the downside of SB 1041's emphasis on flexibility and specifically voiced concerns around what they viewed as a lack of urgency among participants, particularly those with the young child exemption: They don't have to report, and they still get aid . . . we're enabling to do nothing and get the extra two years. Another administrator spoke about how the legislation did not do enough to motivate participants toward self-sufficiency, as the consequences for noncompliance were not strict enough. We have a lot of carrots out there, without any sticks . . . The noncompliance process has to be fixed with more teeth. Telling someone they aren't engaged isn't enough\u2014they're still fine because their kids are getting money. Although in the minority, these administrators worried that the lack of structure within those two years guided participants away from the ultimate goal: getting off aid and becoming self- sufficient. Perspectives of Caseworkers Similar to county administrators, caseworkers in the focal counties also emphasized the increased flexibility within the 24-month time clock. In five of the six focal counties, caseworkers described their views on how the expanded options under SB 1041 encouraged some participants to become more engaged with CalWORKs and reach their educational goals. 135 In multiple counties, however, some caseworkers spoke of how the expanded flexibility under SB 1041 came at the price of hindering clients on the path to self-sufficiency, as the legislation removed participants' focus from the 48-month time-on-aid clock and placed it on the 24-month one. While caseworkers recognized that SB 1041 was intended to address barriers to participants' self-sufficiency (e.g., mental health issues, unstable housing, substance abuse issues, etc.), many believed that certain aspects of the 24-month time clock\u2014such as the multiple exemptions that could be granted and the reduced hours for engagement\u2014did not put the participants on the path to self-sufficiency. In addition, caseworkers in four of the six focal counties specifically discussed how the changes that were brought about under the legislation altered their interactions and conversations with participants. Due to the perceived increase in the level of reporting and data entry that accompanied the implementation of SB 1041, caseworkers reported that they have much less time to spend with participants during the initial assessment meeting and subsequent check-ins. Furthermore, conversations with clients often were spent explaining the rules of the 24-month time clock and other components of SB 1041. One caseworker expressed her frustration, saying, We lost a human connection there because we were so worried about these lists and reports. Before [SB 1041], you could pick up on a client who had an issue that they weren't asking you about. We don't have time for that now. For several caseworkers, the increased focus on data entry and reporting (especially as it pertained to the manual calculation and start\/stop of the 24-month time clock) detracted from their primary role\u2014counseling, encouraging, and monitoring participants throughout their time in the CalWORKs program. It is important to note that these caseworkers had yet to implement the OCAT. Perspectives of Education Service Providers Education service providers also shared their perspectives regarding the impact of SB 1041 on CalWORKs participants. Community colleges were excited about the educational prospects that the legislation afforded participants. The decreased number of required hours (from 35 to 20 hours per week) meant that participants could concentrate fully on their coursework without the added stressor of a job search. Providers also mentioned the increased opportunity for participants to take general education classes, earn an associate degree, or transfer to a four-year college. From the providers' standpoint, these options are more beneficial for participants, as opposed to certificates, as they were believed to be more likely to lead to sustained employment and eventual self-sufficiency. While these providers commended SB 1041 for its efforts to expand educational options, they also noted logistical issues that hampered participants' ability to maximize these opportunities. Some education providers reported that their respective counties did not engage participants early enough during their time on aid: The county isn't engaging them right away, [and] all the while, the clock is still ticking . . . The recipient could have been receiving free tuition, books and supplies, and transportation during that time. Given 136 that participants' time on aid is limited, education providers viewed it as a disservice to not engage participants in educational activities as soon as possible. Other providers discussed how some participants attempted to complete their educational goals but were stymied by bureaucratic delays with their ancillary supports (e.g., uniforms and textbooks). Despite these logistical issues, on the whole, educational service providers were enthusiastic about the changes implemented through SB 1041, and believed the legislation to have a positive impact on CalWORKs participants\u2014although not yet fully realized after two years into implementation. For example, many community college representatives we interviewed commented they expected an increase in referrals to their education programs, since SB 1041 afforded more participants the opportunity to attend school. However, these representatives said they had not observed an increase in CalWORKs' participant referrals since the implementation of SB 1041. One community college representative spoke specifically to her county, noting: SB 1041 is so complex\u2014it allows more opportunity to clients, but at the same time the county is understaffed and overworked, so it seems like the focus is not on education. 137 6. Initial Descriptive Analyses for Status and Tracking Studies Based on the intent of the legislation, SB 1041 is expected to change certain outcomes for WTW participants but may also have led to other, unintended or unforeseen, changes. Hence, it is an important part of this evaluation to examine and track a variety of key indicators of CalWORKs WTW participation. In this chapter, we offer a descriptive, statewide perspective of the CalWORKs WTW program at a point in time and over time. Using the state administrative data and methods described in Chapter Two (and summarized in the text box to the right), we examined the status of all CalWORKs WTW participants at specific points in time (status study) as well as outcomes over one- and two- year periods for cohorts of participants entering the program in the years leading up to and after the change on January 1, 2013 (tracking study). In Chapter Seven, we offer an initial look at how participant outcomes (program participation and employment) might be associated with the passage of SB 1041, rather than other factors such as the changing economy. We consider the findings here and in Chapter Seven tentative because implementation of SB 1041 is ongoing and there is insufficient post SB 1041 data for a robust examination of findings. We expect to supplement the data that informs findings from additional sources for future reports. The initial descriptive analyses in this chapter addressed the following research questions, which are listed below with a brief summary of findings. In the first two years after entry, how much of the 48-month time-on-aid limit did WTW participants use? How much of the WTW 24-month time clock did they use? After two Chapter Six Methods Based on analysis of state administrative data from WDTIP, MEDS, and EDD wage data. Analyses conducted for adults who were in the CalWORKs WTW program and were eligible to work, including those who may have been sanctioned, either prior to or after SB 1041 implementation. Status study examines the cross-section of all CalWORKs WTW participants in March 2013, March 2014, and March 2015; two subgroups are examined: Transitional group: Started CalWORKs WTW before SB 1041 became effective and continued past January 2013. Post SB 1041 group: Started CalWORKs WTW in January 2013 or later. Tracking study examines four CalWORKs WTW entry cohorts: those who entered in March 2007, March 2009, March 2011, and March 2013; outcomes for each cohort are measured one or two years after entry. Indicators examined include time on aid, exemptions, sanctions, leaving the WTW program, employment, and earnings. A final analysis examines the pace of reengagement for the population with a short-term young child WTW exemption as of December 2012. See Chapter Two for more detail on data and methods. 138 years, participants who started in the CalWORKs WTW program in March 2013 had used about nine months on average of the 48-month time limit and about two months of the WTW 24-month time clock. What percentage of WTW participants were exempt from participating in WTW requirements? The percentage of participants who received at least one exemption during their first two years in the CalWORKs WTW program increased from the March 2007 entry cohort to the March 2013 entry cohort (from 44 percent to 56 percent). Annual snapshots of all WTW participants since SB 1041\u2014in March of 2013, 2014, and 2015\u2014 showed that, at a point in time, about four out of ten participants had an exemption. What percentage of WTW participants received a sanction? The percentage of participants who received at least one sanction during their first two years in the CalWORKs WTW program remained steady at about 14 percent from the 2007 to 2013 cohorts. Yearly snapshots since SB 1041 showed that, in a given month, fewer than one out of ten participants were currently sanctioned. What percentage of CalWORKs WTW participants were not participating one year after entry? What percentage were not participating two years after entry? The percentage of participants who were not in the CalWORKs WTW program one year after entry did not change from the March 2007 to March 2013 entry cohorts (about 54 percent), while the percentage of participants who were not in the CalWORKs WTW program two years after entry increased, rising from 63 percent for the 2007 entry cohort to 70 percent for the 2013 entry cohort. What percentage of WTW participants were employed? A larger percentage of the March 2013 entry cohort was employed for at least one quarter in the cohort's first two years after entry compared with the March 2007 entry cohort (64 percent versus 52 percent). In addition, the percentage of new participants who were continuously employed for their first year on WTW increased from 18 percent for the 2007 entry cohort to 21 percent for the 2013 entry cohort. Yearly snapshots after SB 1041 showed that a higher percentage of participants were employed in March 2015 compared with March 2013 (25 percent in 2013 and 31 percent in 2015). How much did WTW participants who were employed earn? For the March 2015 cross- section, employed participants earned about $2,300 per quarter on average, an 11 percent increase compared with the March 2013 cross-section. How did status change from 2013 to 2015 among WTW participants who had the short-term WTW exemption for young children in December 2012? Among the participants who had the short-term WTW exemption for young children in December 2012, 14 percent still had this exemption in March 2014 and almost none still had it in March 2015. Slightly more than half were not participating in the CalWORKs WTW program in March 2015. 139 In considering these findings, it is important to keep in mind that these comparisons over time\u2014 capturing indicators before and after SB 1041 became effective for either cross-sections of CalWORKs WTW participants or for CalWORKs WTW entry cohorts\u2014do not necessarily mean that the changes are attributable to the SB 1041 policy changes. First, as discussed in Chapters Four and Five, although most provisions of SB 1041 became effective as of January 2013, the pace of implementation within the counties means that the policy changes had yet to be fully implemented by the end of the time period we examined. Thus, our analyses provide only an initial look at very short-term outcomes following the effective date of SB 1041. Second, changes in the composition of the CalWORKs WTW caseload, as well as the improving economy, are just two potential confounding factors that could also be contributing to the patterns we describe in this chapter. The analytic approach employed in Chapter Seven is designed to control for such factors, although those analyses must also be viewed as a first look given the limited data in the post SB 1041 period available for analysis. The rest of this chapter first describes the status and tracking studies' population and time frame, then presents results for the various indicators of participant status through one-month snapshots and participant experiences over time. For both the status and tracking studies, we examined information about time on aid, exemptions, sanctions, leaving the WTW program, employment, and earnings. Each of these studies provides a different perspective on these same topics. As a guide to the remainder of the chapter, Table 6.1 identifies which of the two studies (the status or tracking study or both) addressed each research question. In general, the status study addressed questions about participation at a point in time and the tracking study addressed patterns of participation over time. Table 6.1. Research Questions Addressed by Status Study and Tracking Study Research Question Status Study Tracking Study In the first two years after entry, how much of the 48-month time-on-aid limit did WTW participants use? How much of the WTW 24-month time clock did they use? X What percentage of WTW participants were exempt from participating in WTW requirements? X X What percentage of WTW participants received a sanction? X X What percentage of WTW participants were no longer participating one\/two years after entry? X What percentage of WTW participants were employed? X X How much did WTW participants who were employed earn?a X How did status change from 2013 to 2015 among WTW participants who had the short-term WTW exemption for young children in December 2012?b Not applicable Not applicable a Average real earnings were assessed for status study cross-section members who were employed. b This research question does not use status study cross-sections or tracking study entry cohorts. Rather, it uses a group of participants who had the short-term WTW exemption for young children in December 2012. 140 All analyses in this chapter are descriptive and are limited to the data available at the time of writing this report.45 Unless otherwise stated, all percentages shown in the figures in this chapter are based on the total number of participants within each cross-section, cohort, or subgroup. Tables that underlie all the figures in this chapter are located in Appendix E. CalWORKs WTW Participant Demographics This section describes the size and demographic composition of the CalWORKs WTW adult work- eligible participants from 2006 through 2015 who were included in the analyses presented in this chapter. The number of adult CalWORKs WTW participants rose steadily from 2006 through 2011, from 317,751 to 389,047 participants (Figure 6.1, measured on the left vertical axis). After peaking in 2011, the number of adult participants declined to 297,325 in 2015. Unemployment (superimposed on Figure 6.1, measured on the right vertical axis) peaked in 2010, one year before participation Figure 6.1. Number of CalWORKs WTW Participants and Unemployment Rate: 2006 to 2015 SOURCES: WDTIP, 2006 to 2015; EDD unemployment data. NOTES: Participation is measured in March of each year. CalWORKs WTW participants are defined as adults who were in the CalWORKs WTW program and were eligible to work, including those who may have been sanctioned. 45 For future reports, we expect to receive additional data on a wider range of topics from county consortia. Appendix B provides additional information about expectations for future reporting. 0 5 10 15 20 25 30 0 100000 200000 300000 400000 500000 600000 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 U nem ploym ent rate (percent) N um be r o f p ar tic ip an ts Year S B 1 04 1 CalWORKs participants (left axis) Unemployment rate (right axis) 141 Hispanic 42% White 24% African American 16% Asian\/ Pacific Islander 6% Native American 1% Other 4% Not reported 6% Male 22% Female 76% Not reported 1% peaked, and both have declined since those peaks. It is important to note that other factors in addition to the economy may influence CalWORKs WTW participation, such as grant reductions and changes in the young child exemption (see Chapter One for additional discussion of caseload trends). In 2015, more than three-quarters of adult CalWORKs WTW participants were female (76 percent) and 42 percent were Hispanic (Figure 6.2).46 Compared with the demographic breakdown of the California labor force as a whole, there were more CalWORKs WTW participants who identified as Hispanic (42 percent compared with 36 percent). Also, more participants were African American (16 percent compared with 6 percent) and fewer were white (24 percent compared with 74 percent). A small percentage of CalWORKs WTW participants were Asian\/Pacific Islander (6 percent) or Native Americans (1 percent).47 In March 2015, the median age of CalWORKs WTW participants was 29 years old.48 Figure 6.2. Percentage of CalWORKs WTW Participants by Gender and by Race\/Ethnicity: 2015 SOURCES: WDTIP and MEDS files. NOTES: Gender and race or ethnicity are measured in March 2015. Numbers may not add to 100 because of rounding. 46 We examined the percentage of females and the racial or ethnic distribution each year from 2006 to 2015; however, earlier periods have higher missing rates (up to 23 percent missing for sex; up to 26 percent missing for race or ethnicity). Figure 6.2 displays the percentage of females and males and the percentage of distribution by race or ethnicity for the latest year only, March 2015, where the missing rate is lower (1 percent for sex; 6 percent for race or ethnicity). There was little change in the distribution across the years. See Appendix E for distributions prior to 2015. 47 The source of the California population demographics is the California Demographic Labor Force Summary Tables\u2014 August 2015 (California Employment Development Department, 2015). The definition of the civilian labor force includes people ages 16 years and older; not members of the armed services; and not in institutions such as prisons, mental hospitals, or nursing homes. Persons whose ethnicity is identified as Hispanic or Latino may be of any race. 48 We examined the median age of CalWORKs participants each year from 2006 to 2015. There was little change in the distribution across the years. See Appendix E for the distribution prior to 2015. 142 CalWORKs WTW Participant Counts for Status and Tracking Studies From 2013 to 2015, the number of adult CalWORKs WTW participants declined by 11 percent (see the last three periods in Figure 6.1). The 2013 status cross-section had 332,186 participants compared with 328,854 for the 2014 status cross-section and 297,325 for the 2015 status cross- section. Moreover, the percentage of CalWORKs WTW participants who were subject to the SB 1041 rules for their entire time on assistance (the post SB 1041 group) increased substantially as existing cases closed and new ones opened. In March 2013, only 7 percent of all participants entered the CalWORKs WTW program for the first time after SB 1041, a share that increased to 26 percent and 39 percent in 2014 and 2015, respectively (Figure 6.3). As time progresses, a larger share of participants will have only experienced CalWORKs WTW under SB 1041 rules and procedures. The counts for the status study included all adult CalWORKs WTW participants in a given month, whereas the counts for the tracking study included only new participants in a given month. These cohorts of new participants allowed us to track participation and employment outcomes from a common starting point (i.e., controlling for differences in the program tenure of subsequent cross-sectional participant samples). In March of 2007, 2009, and 2011, there were 7,867, 11,804, and 10,597 new participants, respectively (Figure 6.4). In March 2013, three months after SB 1041 started, there were 7,863 new participants. Figure 6.3. Percentage of CalWORKs WTW Participants in the Transitional Group and Post SB Group: Status Cross-Sections in March 2013, March 2014, March 2015 SOURCE: WDTIP files. COUNTS: 2013: 332,186; 2014: 328,854; 2015: 297,325. 61 74 93 39 26 7 0 20 40 60 80 100 2015 2014 2013 Percentage of participants St at us c oh or t Transitional group Post SB 1041 group 143 Figure 6.4. Number of New CalWORKs WTW Participants: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCE: WDTIP files. Time on Aid and WTW Time Clock In the First Two Years After Entry, How Much of the 48-Month Time-on-Aid Limit Did WTW Participants Use? How Much of the WTW 24-Month Time Clock Did They Use? As discussed in Chapter Five and Appendix A, CalWORKs WTW participants' time on aid under SB 1041 is monitored by time clocks. As part of the SB 1041 reforms, the CalWORKs WTW program established a new WTW 24-month time clock that counts months concurrently with the 48-month time-on-aid clock. Once those 24 months have been exhausted, participants are subject to the stricter work requirements of the federal TANF program. If, however, the participant meets the more stringent federal TANF requirements, months on the 24-month clock are not counted. As before SB 1041, the second clock counts the total time that the adult has been on aid, which is limited to 48 months. Additionally, some CalWORKs WTW participants may receive an exemption, which allows them to continue receiving aid without counting the time against their 24-month time clock or 48-month time-on-aid clock. Therefore, we also examined months of participation (i.e., months of receiving aid) in contrast to months counted against their time clocks. In our evaluation, we focus on both the WTW 24-month clock that emerged as a result of SB 1041 and the overall 48-month time-on-aid clock. As of March 2015, few participants were at the WTW 24-month time limit, so it is premature to assess how many participants are reaching this limit and what is happening to them when they do. In addition, WDTIP is limited in 7,863 10,597 11,804 7,867 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 2013 2011 2009 2007 Number of participants Tr ac ke d en tr y co ho rt 144 providing the factors that influence time on aid. For future reports, we expect to draw on data from county consortia to have a fuller understanding of time spent on the 24-month time clock. For the participants in the 2007, 2009, 2011, and 2013 tracked entry cohorts, we calculated the cumulative number of months of participation and the cumulative number of months counted on the 24-month and 48-month time clocks within two years after entry. Since the 24-month time clock did not exist before 2013, we examined the 48-month time-on-aid clock to offer an historical perspective. We examined how the gap between participation and counted months differed among the cohorts. Participants in all cohorts participated in the CalWORKs WTW program for 13 months, on average, during the two years following entry ((). The 2011 cohort had the fewest months counted on the 48-month time-on-aid clock (seven out of 24 months counted on average), and the 2007 cohort had the most months counted on the 48-month time-on-aid clock (nearly ten out of 24 months counted on average).49 In addition, we examined how many months were counted on the 24-month clock for the 2013 entry cohort (the post SB 1041 cohort) and compared it with the count on the 48-month time-on-aid clock. As of February 2015, the 2013 cohort had on average slightly less than two months counted on the 24-month clock and slightly more than nine months counted on the 48- month time-on-aid clock (Figure 6.5). The fact that the average 24-month clock number is so small may suggest a number of different possibilities: (1) few were approaching their 24-month time limit in 2015, (2) some counties were not able to implement the 24-month clock rules until well after SB 1041 took effect, (3) some CalWORKs WTW participants met federal work participation requirements, causing their 24-month clock not to move forward, and (4) some participants have exemptions or sanctions that caused both clocks to stop. Another factor is the number of months of CalWORKs WTW participation compared with the number of months counted on the time clocks. The gap is greatest between the months counted on the 24-month time clock and participation months for the 2013 entry cohort (a gap of about 11 months; Figure 6.5). The next largest gap, between the 48-month time-on-aid clock and participation, is nearly six months for the 2011 cohort. The 2007 cohort, on the other hand, had the smallest gap, at three months. 49 For the tracking study, months of participation and time counted on clocks were measured for the 24 months after entry, including the entry month. For example, for the 2013 cohort, the entry month was March 2013, and we counted the 24 months from March 2013 to February 2015. For the 2013 tracking entry cohort, months of participation ranged from one to 24 months, months counted on the 48-month time-on-aid clock ranged from zero to 24 months, and months counted on the WTW 24-month clock ranged from zero to 23 months. 145 Figure 6.5. Average Number of Months of Participation, Counted on the 48-Month Time-on-Aid Clock, and Counted on the 24-Month Time Clock Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCE: WDTIP files. COUNTS: 2007: 7,867; 2009: 11,804; 2011: 10,597; 2013: 7,863. Exemptions and Sanctions What Percentage of WTW Participants Were Exempt from Participating in WTW Requirements? What Percentage of WTW Participants Received a Sanction? Exemptions and sanctions are two major reasons for stopping the 24-month time clock. Participants may be exempted from WTW activity requirements if they meet certain criteria, such as caring for an ill family member or having a medical disability. SB 1041 also introduced new exemptions in January 2013 particular to the 24-month time clock. Furthermore, participants may be sanctioned for noncompliance with WTW activity requirements. Across the 2013, 2014, and 2015 status cohorts, the proportion of participants who had exemptions in a given month decreased by 11 percentage points or 34 percent (Figure 6.6).50 In 50 The exemptions and sanctions shown in Figures 6.6 and 6.7 stop the WTW 24-month time clock and\/or the 48- month time-on-aid clock. The exemption and sanction categories are not mutually exclusive. The Exemption category includes Exemption Codes 300-310, 313-322, 376, and 377, while the WTW 24-MTC Exemption 1.9 9.1 7.4 8.5 9.8 13.1 13.1 13.3 13.0 0 6 12 18 24 2013 2011 2009 2007 Number of months Tr ac ki ng c oh or t Months of participation Months counted on 48-month time-on-aid clock Months counted on 24-month time clock 146 March 2013, 40 percent of participants had an exemption, compared with 32 percent in March 2014 and 29 percent in March 2015. In March 2013, a smaller proportion of the post SB 1041 group had an exemption compared with the transitional group (29 percent compared with 41 percent), but in 2014, the gap between the two groups had narrowed and reversed (31 and 34 percent for the transitional and post SB 1041 groups, respectively) and in 2015, the gap was somewhat wider (27 percent and 32 percent for the same groups, respectively). The proportion of participants who had exemptions specific to the new WTW 24-month time clock increased over time (Figure 6.6). In March 2013, 3 percent of participants had at least one of these exemptions, which increased to 8 percent in 2014 and 9 percent in 2015. Both the transitional group and the post SB 1041 group exhibited a similar pattern to the overall pattern. Three percent of the transitional group had at least one of the new WTW 24-month time clock exemptions, which increased to 9 percent in 2014 and 2015; 1 percent of the post SB 1041 group had this type of exemption in 2013, which increased to 7 percent in 2014 and 8 percent in 2015. Sanctions were much less prevalent than exemptions (Figure 6.6). Across all participants in all three years, the proportion of participants who had a sanction stayed nearly the same (13 percent in 2013 and 2014; 12 percent in 2015). In all three years, a higher percentage of the transitional group had sanctions compared with the post SB 1041 group. Between 14 and 16 percent of the transitional group had sanctions in March 2013, 2014, and 2015, compared with 0 to 6 percent of the post SB 1041 group. Furthermore, a smaller percentage of the post SB 1041 group had at least one sanction compared with the transitional group. Though the difference between the groups shrank from 2013 to 2015, there remained a difference of 9 percentage points between participants with sanctions in the transitional and post SB 1041 groups in 2015. This difference in sanctions between the two groups may reflect the longer period of time that the transitional group had been in the CalWORKs WTW program at the point of assessing their status in March of each year. However, while the post SB 1041 group was less likely to be sanctioned in March of each year compared with the transitional group, they were almost as likely to be exempted. category includes only the four exemptions that started January 1, 2013 (Exemption Codes 319-322). The sanction category includes three WTW noncompliance sanctions, Exemption Codes 200-202. 147 Figure 6.6. Percentage of Participants Who Had an Exemption or Sanction that Stopped the Clock: Status Cross-Sections and Transitional and Post SB 1041 Groups in March 2013, March 2014, March 2015 SOURCE: WDTIP files. COUNTS: 2013: 332,186; 2014: 328,854; 2015: 297,325. Analysis based on the tracked entry cohorts yielded similar findings as with status cross- sectional snapshots and adds a prepolicy trend. For each tracked entry cohort, the percentage of participants who received at least one exemption within two years was substantially greater than the percentage receiving at least one sanction (Figure 6.7).51 However, the percentage of participants who received a sanction within two years remained between 12 and 14 percent across the years, whereas the percentage receiving exemptions within two years increased from 2007 to 2011 (44 percent of the 2007 cohort, 48 percent of the 2009 cohort, 58 percent of the 2011 cohort) then decreased (49 percent of the 2013 cohort). The 2013 tracked entry cohort is the first to have WTW 24-month time clock exemptions, and 16 percent of participants had one of these exemptions within two years after entry. 51 For the tracking study, the presence of exemptions and sanctions were measured for the 24 months after entry including the entry month. For example, for the 2013 cohort, the entry month was March 2013, and we counted months from March 2013 to February 2015. 6 8 32 5 7 34 0 1 29 15 9 27 16 9 31 14 3 41 12 9 29 13 8 32 13 3 40 0 20 40 60 80 100 Sanction WTW 24-MTC Exemption Exemption Sanction WTW 24-MTC Exemption Exemption Sanction WTW 24-MTC Exemption Exemption 2 01 5 2 01 4 2 01 3 Percentage of participants St at us c oh or t All participants Transitional group Post SB 1041 group 148 Figure 6.7. Percentage of Participants Who Had at Least One Exemption or at Least One Sanction That Stopped the Clock Within Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCE: WDTIP files. COUNTS: 2007: 7,867; 2009: 11,804; 2011: 10,597; 2013: 7,863. Leaving the WTW Program What Percentage of WTW Were Not Participating One Year After Entry? What Percentage of WTW Participants Were Not Participating Two Years After Entry? Leaving the CalWORKs WTW program describes participants' exits from the program. Leaving the CalWORKs WTW program is a fluid concept because participants sometimes leave the program for a period of time and may return months or years later. To create a comparable measure across time for assessing program exits, we defined participants as having left the program if they were not observed as a participant in the program at given points in time after entry. We measured leaving at two points in time: the percentage of participants in a given entry cohort who were not in the program one year after first entry and two years after first entry.52 52 We measured leaving the WTW program after one year as a participant who was not in the program during the last month of their first year of participation after beginning the program. For the 2013 cohort who started in March 2013, participants who were not present in the program in February 2014 were counted as leaving the program. We measured leaving the WTW program after two years as participants who were not in the CalWORKs program during the last month of their second year of participation after beginning the program. For the 2013 cohort who started in March 2013, those not present in the program in February 2015 were counted as leaving the program. 14 14 13 12 16 49 58 48 44 0 20 40 60 80 100 2013 2011 2009 2007 Percentage of participants Tr ac ke d en tr y co ho rt Exemption WTW 24-month time-clock exemption Sanction 149 For the four tracked entry cohorts, the percentage of participants absent from the CalWORKs WTW program (i.e., not participating) at the one-year mark is consistent across time, about 50 percent (Figure 6.8). Absence at the second-year mark fluctuated across the years, from 64 percent and 61 percent in 2007 and 2009, respectively, to 66 percent and 67 percent in 2011 and 2013, respectively. Figure 6.8. Percentage of Participants Who Left the WTW Program One Year and Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCE: WDTIP files. COUNTS: 2007: 7,867; 2009: 11,804; 2011: 10,597; 2013: 7,863. Participants who were sanctioned at those points in time were considered participants and, hence, not considered to have left the program. 67 66 61 64 49 50 50 50 0 20 40 60 80 100 2013 2011 2009 2007 Percentage of participants Tr ac ke d en tr y co ho rt Leaving one year after entry Leaving two years after entry 150 Employment and Earnings What Percentage of WTW Participants Were Employed? How Much Did WTW Participants Who Were Employed Earn? One of the SB 1041 policy goals is improved long-term employment and earnings. This section offers an initial examination of employment patterns because only about two years had elapsed since the policy change at the time of the analysis in this report.53 By several measures, CalWORKs WTW participants increased their workforce participation over time. First, we examined the percentage of participants who were employed in the status cross-sections as of March 2013, 2014, and 2015. Next, we compared employment across the tracked entry cohorts during their first and second years of participation.54 Status snapshots in 2013, 2014, and 2015 indicate that a larger percentage of participants in March of each year were employed across time (Figure 6.9). The percentage of all participants who were employed increased from 25 percent in 2013 to 31 percent in 2015. (In relative terms, this represents an increase of 10 percent from 2013 to 2015.) The percentage employed increased among both the transitional group and post SB 1041 group. The percentage among the transitional group increased from 25 percent to 32 percent from 2013 to 2015, while among the post SB 1041 group there was a more modest increase from 27 percent to 29 percent. We examined quarterly earnings among all participants in the annual snapshots who were employed.55 Among the employed participants in March 2013, 2014, and 2015, quarterly earnings increased across the years after adjusting for inflation (Figure 6.10).56 In March 2013, all employed participants with earnings earned an average of $2,062 per quarter, which increased to $2,289 by 2015, an 11-percent increase. 53 In addition to improved long-term employment and earnings, another SB 1041 policy goal is for participants to have increased access to services and educational opportunities in the first 24 months of participation compared with the past. Participation in services may influence employment rates. In future reports, we expect to use county consortia data to examine participation in services and educational activities along with employment rates. 54 We measured continuous employment in the first year after entry as participants who were employed in the four quarters following, but not including, the entry month because employment data were measured in calendar quarters (i.e., the first quarter of the calendar year is January, February, and March). For example, for March 2013 entrants, we determine whether they were employed in the four quarters covering the months April 2013 to March 2014. We measure continuous employment in the second year after entry as participants who were employed in the four quarters following the first year after entry. For example, for March 2013 entrants, we determine whether they were employed in the four quarters covering the months from April 2014 to March 2015. Employment was measured regardless of participation in CalWORKs. 55 The transitional and post SB 1041 groups had very similar earnings in March 2013, 2014, and 2015 (within $26.00) and are not shown in Figure 6.10. See Appendix D for average earnings by group. 56 We used the Consumer Price Index (CPI) for all urban consumers (BLS, 2015a) to adjust earnings to 2013 first- quarter dollars. The average is based on participants who earned more than $0. 151 Figure 6.9. Percentage of Participants Who Were Employed: Status Cross-Sections and Transitional and Post SB 1041 Groups in March 2013, March 2014, March 2015 SOURCES: WDTIP and EDD files. COUNTS: 2013: 332,186; 2014: 328,854; 2015: 297,325. Figure 6.10. Average Real Quarterly Earnings of All Participants Who Were Employed: Status Cross-Sections in March 2013, March 2014, March 2015 SOURCES: WDTIP and EDD files. COUNTS: 2013, 83,152; 2014, 95,846; 2015, 91,665. NOTE: Quarterly earnings are measured in 2013 first-quarter dollars using the CPI (BLS, 2015a) to adjust for inflation. 29 28 26 32 29 25 31 29 25 0 20 40 60 80 100 2015 2014 2013 Percentage of participants St at us c oh or t All participants Transitional group Post SB 1041 group $2,289 $2,181 $2,062 0 500 1,000 1,500 2,000 2,500 3,000 2015 2014 2013 Quarterly earnings (2013 dollars) St at us c oh or t All employed participants 152 Next, we examined employment patterns for the tracked entry cohorts to assess the level of employment and found that later cohorts had higher employment rates than earlier cohorts (Figure 6.11). We assessed what percentage of each cohort was employed for at least one quarter during the first two years after entering the CalWORKs WTW program. The rate of employment was lowest for the earlier time periods (49 percent and 46 percent) and highest for the latest cohort (61 percent). Our final look at employment was to examine employment continuity. For each tracked entry cohort, we compared the percentage of participants who were continuously employed during their first year of CalWORKs WTW participation with the percentage who were continuously employed during their second year. For all cohorts, a larger portion of participants were continuously employed during their second year after starting the CalWORKs WTW program compared with their first year (Figure 6.12). However, the 2013 cohort stands out from the other cohorts with a higher percentage of participants continuously employed during their first and second years of participation compared with other cohorts. The percentage of continuously employed participants during the first year of participation was 14, 12, and 13 percent, respectively, for the 2007, 2009, and 2011 cohorts compared with 17 percent for the 2013 cohort. Similarly, the percentage continuously employed during the second year of participation was 18, 17, and 21 percent, respectively, for the 2007, 2009, and 2011 cohorts compared with 27 percent Figure 6.11. Percentage of Participants Who Were Employed for at Least One Quarter in the Subsequent Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCES: WDTIP and EDD files. COUNTS: 2007: 7,867; 2009: 11,804; 2011: 10,597; 2013: 7,863. 61 51 46 49 0 20 40 60 80 100 2013 2011 2009 2007 Percentage of participants Tr ac ke d en tr y co ho rt 153 Figure 6.12. Percentage of Participants Who Had Continuous Employment During the First Year and During the Second Year After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 SOURCES: WDTIP and EDD files. COUNTS: 2007: 7,867; 2009: 11,804; 2011: 10,597; 2013: 7,863. for the 2013 cohort. Furthermore, the 2013 cohort had a larger percentage-point increase in continuous employment from the first year to the second year of participation (difference of 4, 5, 8, and 10 percentage points for the 2007, 2009, 2011, and 2013 cohorts, respectively). Reengagement How Did Status Change from 2013 to 2015 Among WTW Participants Who Had the Short-Term WTW Exemption for Young Children in December 2012? This section uses neither the status cross-sections nor tracking study cohorts; rather, it highlights a specific population among WTW participants: those who had the short-term WTW exemption for young children just before SB 1041 took effect.57 We isolated the group of participants who 57 Participants with the short-term WTW exemption for young children refers to those who were exempt pursuant AB X4 4 and were subject to reengagement (see Chapter Five for further discussion). This short-term exemption 27 21 17 18 17 13 12 14 0 20 40 60 80 100 2013 2011 2009 2007 Percentage of participants Tr ac ke d en tr y co ho rt Continuous employment in first year after entry Continuous employment in second year after entry 154 had the short-term WTW exemption for young children in December 2012 to examine their trajectory during the reengagement process over the next few years. We examined this group of WTW participants, which we refer to as the young child exemption reengagement group, at three intervals: March 2013, March 2014, and March 2015. At each period, we determined the percentage of the young child exemption reengagement group that: (1) had the new young child exemption that was established in January 2013; (2) had the short-term young children exemption and did not have the new young child exemption; (3) had a sanction and did not have either young children exemption; (4) had an exemption for another reason and did not have either young children exemption or sanctions; (5) was in the CalWORKs WTW program with no exemption or sanction; and (6) was not in the CalWORKs WTW program.58 Participants who were in the program without an exemption or sanction may be considered as reengaged. For the 59,876 participants in the young child exemption reengagement group (participants who had a short-term young child exemption in December 2012), 72 percent still had the same exemption in March 2013, but the percentage dropped rapidly to less than 0.1 percent two years later (Figure 6.13). Some in the young child exemption reengagement group switched to using the new young child exemption: 8 percent of the young child exemption reengagement group was using the revised young child exemption in 2014 and 5 percent in 2015. In 2013, few of the young child exemption reengagement group had a sanction (0.5 percent) or another type of exemption besides the short-term exemption for young children (5 percent). In 2014 and 2015, the percentage of the young child exemption reengagement group with a sanction continued to be low (6 and 8 percent, respectively). Compared with sanctions, nearly the same portion had exemptions other than the short-term young children exemption (10 and 9 percent in 2014 and 2015, respectively). By 2015, a quarter of those in the young child exemption reengagement group were reengaged, and more than half were not in the CalWORKs WTW program (reengaged: 11 percent in 2013, 27 percent in 2014, 25 percent in 2015; not in program: 11 percent in 2013, 35 percent in 2014, 52 percent in 2015). expired on December 31, 2012. Of the 327,693 participants in December 2012, 18.3 percent had a short-term exemption for young children. 58 The category other exemption included exemptions such as for participation in the Cal-Learn program. It also included a small number of exceptions such as penalty, good cause, extender, and repayment. The category not in CalWORKs was measured as a participant not present in the WDTIP data system in March of the given year. 155 Figure 6.13. CalWORKs WTW Participant Status Among Those with the Short-Term WTW Exemption for Young Children in December 2012: March 2013, March 2014, March 2015 SOURCE: WDTIP files. COUNTS: 2013: 59,876; 2014: 59,876; 2015: 59,876. 5 8 1 0 14 72 8 6 0 9 10 5 25 27 11 52 35 11 0 20 40 60 80 100 2015 2014 2013 Percentage of participants with young child exemption in December 2012 Ye ar (M ar ch ) New WTW exemption for young children Short-term young children exemption Sanction Other exemption In CalWORKs WTW with no exemption or sanction Not in CalWORKs WTW 157 7. Initial Descriptive Analyses for the Impact Study In this section, we examine questions related to employment, CalWORKs participation, and earnings, among other outcomes. As indicated in Chapter Two (and summarized in the text box to the right), the analyses presented in this chapter use state administrative data and nationally representative survey data to examine the association between the implementation of SB 1041 and various adult and family outcomes. In the case of the analyses of state administrative data, these outcomes are measured for specific cohorts of new CalWORKs WTW participants who entered the program before and after SB 1041 became effective.59 The national survey data allow us to examine differences before and after SB 1041 for an important population: those potentially eligible for CalWORKs WTW participation, which we define to be female-headed households with dependent children where the female head has low education. For both types of analyses, we employ strategies to control for other confounding factors that may have affected the outcomes of interest. Given the potential for unobserved factors that we cannot 59 A participant was considered new if he or she had not previously appeared in the WDTIP database as a WTW participant. Chapter Seven Methods Methods for the first analytic approach in support of the impact study: Based on analysis of state administrative data from WDTIP, MEDS, and EDD wage data from 2010 to 2015. Analyses conducted for adults who were in the CalWORKs WTW program and were eligible to work, including those who may have been sanctioned, either prior to or after implementation of SB 1041. Conducted initial analyses using an interrupted time series design to compare outcomes for entry WTW cohorts pre and post SB 1041, controlling for observable participant characteristics and the local economy. Outcomes examined include CalWORKs WTW participation, employment, and earnings. Methods for the second analytic approach in support of the impact study: Based on analysis of nationally representative CPS data from March 2005 to 2015 and October 2005 to 2014. Focus on population at risk of CalWORKs participation: female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. Conduct initial analyses using a comparative case study design with a synthetic comparison group methodology to compare California with a group of control states possessing similar sociodemographic characteristics and TANF policies. Outcomes examined include poverty status, unemployment status, receipt of public assistance, annual weeks worked full time, school enrollment, and participation in job training. See Chapter Two for more detail on data and methods. 158 control for, as well as the relatively short time period for examining outcomes in the post SB 1041 period, we view these analyses as a first look at findings using these methods, findings that may or may not be robust to using more data. Additionally, while some aspects of SB 1041 may affect participants immediately (particularly the increased earnings disregard), other aspects may take time to implement (e.g., making greater use of the 24-month clock and linking participants to services) and we may not see the impact of those changes in the short time period under examination here. Indeed, the results in Chapters Four and Five suggest that implementation of the SB 1041 provisions and related supports were still under way during the time period covered by the data we have available for analysis. In future work, we will employ more-rigorous methods with data for additional time periods to strengthen our ability to interpret any effects we see as attributable to (or caused by) the SB 1041 policy changes. Using data from WDTIP\u2014California's welfare time-on-aid tracking and reporting system\u2014 we made regression-adjusted pre and post SB 1041 comparisons of outcomes related to employment and welfare participation. Due to the limited amount of time after the passage of SB 1041, the outcomes were measured one year after participants entered the CalWORKs WTW program, at which time participants theoretically would still be in the middle of using their 24 months of increased flexibility in meeting participation requirements. With this limitation in mind, the research questions for our use of WDTIP data and a summary of key findings for each are as follows: One year after enrollment, were rates of employment and rates of participation different for cohorts of CalWORKs WTW participants enrolling after SB 1041? When we accounted for the changing economy and demographics of CalWORKs WTW participants, we found that, after SB 1041, individuals were continuing to participate in CalWORKs WTW one year after entry at higher rates (2.2 percentage points higher) because those who were employed were combining work and CalWORKs WTW at higher rates than predicted (2.1 percentage points higher) rather than being employed only (1.9 percentage points lower). One year after enrollment, was the level of earnings different for cohorts of CalWORKs WTW participants enrolling after SB 1041? When we accounted for changes in the economy and in the demographics of CalWORKs WTW participants, the level of quarterly real earnings among CalWORKs WTW participants one year after enrollment was about $54 higher (4.2 percent) than predicted. In addition, we addressed four other questions using data from the nationally representative CPS to compare the experiences of families in California who are potentially eligible for CalWORKs WTW with a synthetic comparison group of families in certain other states. Again, keeping in mind that these data cover just one year of experience after SB 1041 became effective, the specific questions and the associated findings are as follows: 159 Are families that are potentially eligible for the CalWORKs WTW program less likely to be in poverty than similar families in similar states across the country during the first year of SB 1041's implementation? With one year of data covering the post SB 1041 period, there is no indication to date that families potentially eligible to participate in the CalWORKs WTW program are less likely to have income below poverty or below 125 percent of poverty compared with the same demographic group living in comparable states. Are families that are potentially eligible for the CalWORKs WTW program less likely to receive public assistance than similar families in similar states across the country during the first year of SB 1041's implementation? Again, with just one year of data for the post SB 1041 period, our analysis of the receipt of public assistance more generally and TANF receipt in particular shows that families potentially eligible for CalWORKs WTW were no more or less likely to make use of these components of the safety net than similar families in our comparison states. Are heads of families that are potentially eligible for the CalWORKs WTW program more likely to be employed than heads of households in similar families in similar states across the country during the first years of SB 1041's implementation? We find no statistically significant differences between families potentially eligible for the CalWORKs WTW program in California versus the comparison states in either the unemployment rate (measured two years after the SB 1041 policy changes) or the number of full-time weeks worked in the prior year (measured for just one year post SB 1041 implementation). Are heads of families that are potentially eligible for the CalWORKs WTW program more likely to be enrolled in school or job training than heads of households in similar families in similar states across the country during the first years of SB 1041's implementation? Although we have two years of data beyond the effective date for SB 1041, we do not find any significant difference between California and comparison states in the rates of school enrollment (defined to include training) or rates of job training for families potentially eligible for CalWORKs. The remainder of this chapter provides results for each research question in turn. Additional discussion of the methods employed in this chapter, as well as supporting documentation of the results, is provided in Appendix F. Analyses of State Administrative Data We begin with findings from the administrative data, first examining results for the first question concerning employment and CalWORKs WTW participation and then the second question pertaining to earnings. 160 One Year After Enrollment, Were Rates of Employment and Rates of CalWORKs WTW Participation Different for Cohorts of CalWORKs WTW Participants Enrolling After SB 1041? Looking at trends over the years just prior to implementation and just after it without any adjustments, one would observe that the post SB 1041 cohorts had higher rates of employment (employed only and both employed and in the CalWORKs WTW program) and lower rates of CalWORKs WTW participation one year after enrollment. (See Appendix F for details.) These differences cannot be immediately attributed to SB 1041, however, because we know that there were other changes in the state and its economy in addition to SB 1041 that likely affected observed outcomes. In particular, the improving economy\u2014measured by an average county unemployment rate that was 3 percentage points lower for the cohorts starting after the passage of SB 1041\u2014could be a key driver for improving the outcomes of CalWORKs WTW participants (Figure 7.1). On the one hand, the improving economy could allow some people who might have otherwise entered the CalWORKs WTW program to not enter the program in the first place, while on the other hand, the improving economy would allow people who do enter the program to find work and potentially exit the program more rapidly. The question, then, is whether the differences for post SB 1041 cohorts would remain if one were to account for those other factors. Our analysis examined the association of SB 1041 with changes in participants' one-year outcomes using a regression model to account for differences in the types of people entering the CalWORKs WTW program and the economic conditions at the time. 161 Figure 7.1. Average County Unemployment Rate SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTE: The average unemployment rate reported here is measured in the fourth quarter after the cohort enters CalWORKs and is weighted by the number of CalWORKs WTW participants in each county. In our analyses that controlled for the unemployment rate and the changing characteristic of participants, the differences between the regression-adjusted trends post SB 1041 and the projected outcome in the absence of the legislation were smaller in some cases and in a different direction in other cases, compared with findings based on analysis without these controls. For any given outcome in the pre SB 1041 period, the regression analyses are reported as the outcome for each cohort, adjusted for differences\u2014that is, as if they all had the same county unemployment rate and participant demographics. For the post SB 1041 cohorts, two outcomes are reported: one that shows what the outcome would hypothetically be, as if SB 1041 had not been implemented (red dotted line), and a second (green solid line) that adds (or subtracts) a constant percentage to each cohort that represents the change in percentage for post SB 1041 cohorts that is associated with the policy change. As a reminder, these results should not be interpreted as causal because there may be additional factors other than SB 1041 that our model does not take into account. 13.4 7.8 0 5 10 15 20 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Average unemployment rate 162 When we controlled for the county unemployment rate and participant characteristics, we found that SB 1041 was not associated with a change in the percentage of CalWORKs WTW participants employed one year after enrollment (Figure 7.2), but was associated with an increase in the percentage still participating in CalWORKs WTW (Figure 7.3).60 With SB 1041, the percentage still participating in CalWORKs WTW one year after entering was 2.2 percentage points higher with SB 1041 cohorts than would have been predicted without SB 1041 (where the predictions are based on the trends of the pre SB 1041 cohorts; Figure 7.3). Figure 7.2. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Employed One Year After CalWORKs WTW Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). 60 In the remainder of this chapter, outcomes measured in percentages are plotted on a scale that has a fixed percentage-point range (20 percentage points), although the starting and ending point on the scale may vary with the range of the outcome measure that is plotted. 30 35 40 45 50 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 + 0.2 163 Figure 7.3. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Participating in CalWORKs WTW One Year After CalWORKs WTW Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). When outcomes were analyzed using the four mutually exclusive categories (Figures 7.4 7.7), we obtain a more nuanced view of these results: The higher rates of CalWORKs WTW participation that analysis associated with SB 1041 (Figure 7.3) was composed of those who were able to find jobs remaining on CalWORKs WTW rather than leaving. Controlling for county unemployment rates and participant characteristics, we see that the percentage of participants employed only (and not participating in CalWORKs WTW) one year after enrollment was 1.9 percentage points lower with SB 1041 than without (Figure 7.4), while the percentage of those employed and still participating in CalWORKs WTW was 2.1 percentage points higher (Figure 7.5). In other words, post SB 1041 participants who were employed were more often staying on CalWORKs rather than leaving. Theoretically, this is a result one might expect because of the increase in the earnings disregard, one of the more-immediate aspects of SB 1041 to take effect. The percentages in the other two categories, participating in CalWORKs WTW only (Figure 7.6) and neither employed nor participating (Figure 7.7), had no significant change associated with SB 1041. 50 55 60 65 70 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 + 2.2* 164 Figure 7.4. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Employed Only (Not Participating in CalWORKs) One Year After CalWORKs Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). 10 15 20 25 30 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 1.9* 165 Figure 7.5. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Both Employed and Participating in CalWORKs One Year After CalWORKs Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). 10 15 20 25 30 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 + 2.1* 166 Figure 7.6. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Participating in CalWORKs Only (Not Employed) One Year After CalWORKs Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). 30 35 40 45 50 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 + 0.1 167 Figure 7.7. Change Associated with SB 1041 in the Percentage of CalWORKs WTW Entrants Who Were Neither Employed Nor Participating in CalWORKs One Year After CalWORKs Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Outcome is measured in fourth quarter after enrollment in CalWORKs WTW. Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). One Year After Enrollment, Was the Level of Earnings Different for Cohorts of CalWORKs WTW Participants Enrolling After SB 1041? As one might expect given the improving economy over the period analyzed, real earnings for participants (measured in 2013 first quarter dollars) one year after starting the CalWORKs WTW program was higher for cohorts starting after SB 1041 than before (see Appendix F).61 This trend is consistent with the falling unemployment rates reported above (Figure 7.1). When we controlled for the economic and demographic factors in our regression model, the results for earnings show an increase in earnings associated with SB 1041 (Figure 7.8). After we accounted 61 Average earnings are calculated across all participants whether or not they worked. In other words, participants who were not employed had earnings of $0. 10 15 20 25 30 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Pe rc en ta ge Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 0.2 168 Figure 7.8. Change Associated with SB 1041 in Real Quarterly Earnings of CalWORKs WTW Entrants One Year After CalWORKs Entry SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Quarterly earnings are measured in fourth quarter after enrollment in CalWORKs WTW are expressed in constant 2013 first quarter dollars using the CPI (BLS, 2015a) to adjust for inflation. Controls include the county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). for participant characteristics and county unemployment rates, the increase in quarterly real earnings associated with SB 1041 was $54, or 4.2 percent.62 Analyses of CPS Data Analyses of the CPS data were used to answer four questions pertaining to the patterns in poverty, receipt of public assistance, employment, and enrollment in school or job training after SB 1041 became effective in 2013, comparing results for the treatment population in California\u2014female-headed families with children under the age of 18 where the female head has less than a bachelor's degree\u2014against the same population in a comparable group of states. We 62 The average adjusted earnings without SB 1041 across the four 2014 cohorts was $1,286. The $54 increase in earnings is 4.2 percent of $1,286. 1,000 1,100 1,200 1,300 1,400 1,500 1,600 1,700 1,800 1,900 2,000 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2010 2011 2012 2013 Q ua rt er ly e ar ni ng s (2 01 3 do lla rs ) Entry cohort S B 1 04 1 Pre SB 1041 Post SB 1041, without SB 1041 Post SB 1041, with SB 1041 + $54* 169 refer to this treatment population as families potentially eligible for the CalWORKs program or, alternatively, as families at risk for CalWORKs participation. To aid in interpretation, we note whether differences observed post SB 1041 are statistically significant in each of the figures. Are Families That Are Potentially Eligible for the CalWORKs WTW Program Less Likely to Be in Poverty Than Similar Families in Similar States Across the Country During the First Year of SB 1041's Implementation? To answer this question, we analyzed two outcomes from the annual March supplement to the CPS that collects detail on the household's income and income components for the prior calendar year. The first measure is an indicator of whether the family is living below the federal poverty line (based on the size of the family, the number of children in the family, and the age of the head of household). For example, in 2013, the first year of SB 1041, the federal poverty line for a three-person family where two members are under the age of 18 was an annual income of $18,769. To circumvent the common criticism that the poverty line only captures extreme economic deprivation, we used a second measure that indicates whether the family is living below 125 percent of the federal poverty line. The March 2014 supplement was the most current wave of data available; thus, we can assess differences in rates of poverty only through 2013 (based on income reported retrospectively in March 2014). We plotted the trend line for California and the weighted trend line for the comparison group states in the percentage of the treatment population with income below the federal poverty line (Figure 7.9) and the percentage with income below 125 percent of the federal poverty line (Figure 7.10). Twenty-four percent of families in the California treatment group and in the comparison group were living below the federal poverty line in 2005 (Figure 7.9). This increased to about 30 percent in 2009 2012, the years immediately following the Great Recession. In 2013, the first year following the passage of SB 1041, 31 percent of families in the California treatment group were living below the poverty line and 28 percent of the families in the comparison group were living below the poverty line. This difference of almost 3 percentage points does not meet our threshold for statistical significance. The trends in poverty when using the threshold of 125 percent of the federal poverty line (Figure 7.10) are similar to those using the official poverty line (Figure 7.9). There was an increase of at-risk families in both California and the comparison states living below 125 percent of the poverty line following the Great Recession. In 2013, the first year of SB 1041, 40 percent of families in both the California treatment group and in the comparison group of states were living below 125 percent of the federal poverty line. Although the data cover only one year of the post SB 1041 era, there are no indications to date that families in California at risk for participating in CalWORKs are less likely to be in poverty compared with similar families in similar states across the country. 170 Figure 7.9. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Living Below the Federal Poverty Line SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). Figure 7.10. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Living Below 125 Percent of the Federal Poverty Line SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 20 25 30 35 40 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 10 41 + 2.6 Not significantly different 30 35 40 45 50 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 10 41 + 0.1 Not significantly different 171 Are Families That Are Potentially Eligible for the CalWORKs WTW Program Less Likely to Receive Public Assistance Than Similar Families in Similar States Across the Country During the First Year of SB 1041's Implementation? As part of the March supplement to the CPS, sample members were asked to report income in the previous calendar year from several sources of public assistance, including TANF payments from state or local welfare offices. Using this information, we examine trends in any public assistance receipt and trends in TANF receipt in particular (Figures 7.11 and 7.12, respectively).63 As with our analysis of poverty, we can assess differences in rates of self- reported public assistance only through 2013 (reported retrospectively in March of 2014). Figure 7.11. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Receiving Any Form of Public Assistance SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 63 Our results are not sensitive to potential underreporting of public assistance in the CPS but are potentially sensitive to differential changes in underreporting over our period of observation (should such changes exist). 0 5 10 15 20 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 1 04 1 + 6.8 Not significantly different 172 Figure 7.12. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Receiving TANF SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). In terms of any public assistance receipt during the year, approximately 10 percent of at-risk families in our California treatment group and in our comparison group reported receiving public assistance in 2005 (Figure 7.11). As of 2013, the first year following the SB 1041 reforms, 12 percent of the California treatment group reported received public assistance, compared with 5 percent of the comparison group states. Although sizable, this difference does not meet our threshold for statistical significance. For TANF receipt in particular, approximately 9 percent of families in both our California treatment group and in our comparison group reported receiving TANF in 2005 (Figure 7.12). In 2013, rates of TANF receipt were only 2 percentage points apart: 10 percent of families in the California treatment group received TANF compared with 8 percent of families in the comparison group. This difference, however, does not meet our threshold for statistical significance. Taken together, our results suggest that families potentially eligible for CalWORKs were no more or less likely to make use of public assistance than similar families in similar states across the country. 0 5 10 15 20 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 1 04 1 + 2.5 Not significantly different 173 Are Heads of Families That Are Potentially Eligible for the CalWORKs WTW Program More Likely to Be Employed Than Heads of Households in Similar Families in Similar States Across the Country During the First Years of SB 1041's Implementation? We assessed possible SB 1041 effects on employment using two measures: a binary measure indicating whether the sample member was unemployed at the time of the March survey (available through 2015) and a continuous measure indicating the number of weeks worked full time in the calendar year (available through 2013). The former measure (shown in Figure 7.13) is a point-in-time status indicator that is used to contribute to the calculation of the monthly unemployment rate, while the latter measure (shown in Figure 7.14) captures intensity of employment across the calendar year. In March 2005, the unemployment rate for female heads of household in both the treatment and comparison group was approximately 5 percent (Figure 7.13). Unemployment peaked for both groups in March of 2010: 10.2 percent for California and 10.8 percent for the comparison group. Following that peak, rates declined for both groups, with a somewhat larger decline for Figure 7.13. Percentage of Families Potentially Eligible for the CalWORKs WTW Program Unemployed in March SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 0 5 10 15 20 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 1 04 1 + 2.9 Not significantly different 174 the comparison group. In March 2015, three years after SB 1041 was launched, 9.0 percent of female heads of household in the California treatment group and 6.1 percent of female heads of household in the comparison group were unemployed. This difference does not meet our threshold for significance. Next we examined the average number of weeks worked full time (Figure 7.14). In 2005, female heads of household in the California treatment group and in the comparison group both worked full time an average of 24 weeks in the calendar year. This level of participation in the labor force declined steadily over the next eight years for both groups such that by 2013, the first year of the implementation of SB 1041, at-risk female heads of household in both groups worked full time an average of only 20 weeks in the calendar year. Taken together, the trends indicate that heads of families potentially eligible for the CalWORKs WTW program were no more or less likely to be employed than heads of households in similar families in similar states across the country during the first year of SB 1041's implementation. Figure 7.14. Number of Annual Weeks Employed Full Time Among Families Potentially Eligible for the CalWORKs WTW Program SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 0 5 10 15 20 25 30 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 A nn ua l w ee ks w or ke d fu ll tim e Year California Comparison group states S B 1 04 1 0.7 Not significantly different 175 Are Heads of Families That Are Potentially Eligible for the CalWORKs WTW Program More Likely to Be Enrolled in School or Enrolled in Job Training Than Heads of Households in Similar Families in Similar States Across the Country During the First Year of SB 1041's Implementation? Lastly, we examine trends in schooling and job training, which we measured using information collected in the October supplement to the CPS. This is particularly of interest in the early years of SB 1041 as the policy emphasizes immediate participation in schooling or job training within the 24-month time clock as key facilitators of employment and economic self-sufficiency. The CPS uses October to inquire about school enrollment as it is soon after the start of most academic calendar years. Using information from this supplement, we examined trends in two measures: a binary indicator of any school enrollment (including job training) (Figure 7.15) and a binary indicator of enrollment in a job-training program (Figure 7.16). Figure 7.15. Percentage of Family Heads Potentially Eligible for the CalWORKs WTW Program Enrolled in School in October SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 0 5 10 15 20 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 1 04 1 + 0.6 Not significantly different 176 From 2005 to 2014, school enrollment (including training) among heads of families in the California treatment group and the comparison group held relatively steady\u2014hovering around 10 percent (Figure 7.15). As of 2014, the second year in which SB 1041 was in effect, there was no difference between California and the comparison group states: 8 percent of heads of families in both groups were enrolled in school of some sort. The trends in job training mirror those for the trends in school enrollment overall (Figure 7.16). Across the ten years that we observe, rates of participation in job training held relatively steady at around 3 percent, with the at-risk heads of families in the California treatment and in the comparison group states participating in job training at the same rates. These two figures show that families potentially eligible for the CalWORKs WTW program are no more or less likely to be enrolled in school and job training or job training alone than heads of households in similar families in similar states across the country during the first two years of SB 1041's implementation. Figure 7.16. Percentage of Family Heads Potentially Eligible for the CalWORKs WTW Program Participating in Job Training in October SOURCE: Authors' analysis of 2005 2014 March CPS. NOTES: Families potentially eligible for the CalWORKs WTW program are defined as female-headed families with one or more children under the age of 18 where the female head has less than a bachelor's degree. An asterisk indicates that the difference is statistically significant (p < 0.05). 0 5 10 15 20 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Pe rc en ta ge Year California Comparison group states S B 1 04 1 + 1.1 Not significantly different 177 8. Conclusions and Policy Implications The first report with findings from the evaluation of the SB 1041 reforms to the CalWORKs WTW program has provided a first look at the status of policy implementation, initial outcomes, and potential impacts from the vantage of approximately two and a half years since SB 1041 became effective on January 1, 2013. The combination of mixed methods applied to qualitative and quantitative data has served to generate a state-level perspective of the policy changes; the view from all 58 counties with respect to implementation; the experience of six focal counties with implementation and perceived impact that is likely to capture the range of experiences across the state; a set of indicators capturing participant status at a point in time and over time; and quantitative assessments of potential impact on a range of participant outcomes. In this final chapter, we first summarize the key findings across the study components, integrating findings on a given topic across the study components where possible. Because these are early results, we are not yet able to delineate recommendations based on the findings. However, we conclude the chapter by drawing out implications for policy based on the early evidence. Summary of Key Findings Table 8.1 integrates and compiles our findings across the process study, status and tracking studies, and participant impact study presented in Chapters Three through Seven. Across the study components, we have identified a set of higher-level findings regarding the initial experiences with SB 1041 implementation and the associated outcomes and early impacts. State- and county-level stakeholders had varied views regarding the goals and objectives of SB 1041. Some state-level stakeholders were concerned that many CalWORKs WTW participants would be unprepared to meet federal work requirements after exhausting their 24-month time clock. County administrative and line staff also said SB 1041 was a significant change to the CalWORKs WTW program that required a number of adjustments to be made. CDSS staff emphasized that the legislation is intended to offer more flexibility to clients in their progress toward self-sufficiency. Delays in developing and releasing implementation guidelines resulted in implementation and training issues for county-level staff. CDSS implemented a state-level workgroup process to develop implementation guidance for SB 1041; however, the intensive planning process contributed to the slow release of guidance to the counties, creating implementation challenges at the local level. Implementation policies from the state were 178 Table 8.1. Summary of Key Findings Topic Key Findings Process Study Analyses Stakeholders' views of SB 1041 State-level stakeholders' perspectives regarding the goals and expected impact of SB 1041 differed, with some viewing it as well motivated with the potential for positive change, while others were more concerned about potential negative consequences. State planning for and communication regarding SB 1041 As required by the legislation, CDSS implemented a state-level workgroup process to develop implementation guidance for SB 1041, which was characterized as positive and inclusive by stakeholders. Communication of policy with the counties occurred primarily through ACLs. However, the intensive and lengthy planning process contributed to the slow release of guidance to the counties, creating implementation challenges at the local level. County planning for and communication regarding SB 1041 Interagency or interdepartmental meetings were the primary county vehicles for communication with other agencies. Three-quarters of all county social services departments reported reaching out to individual directors or agency representatives in other county agencies to plan for or implement support services under SB 1041. County communications with line staff occurred through memoranda and other written documents (81 percent of all counties), briefings and\/or internal staff meetings (93 percent of counties), and mandatory training sessions (83 percent of counties). County staff communicated with participants about the changes that were brought about under SB 1041 primarily through in-person discussions, phone calls, and letters. Status of SB 1041 implementation as of June 2015 Across the 58 counties, most have completed the reengagement of participants with the short- term young child exemption. Eighty-six percent reported having implemented the FS program countywide and 69 percent reported they had implemented the ESE program countywide. To increase supportive services, up to 60 percent of all the counties reported developing new or enhanced partnerships with education providers, vocational education\/job training providers, domestic violence service providers, substance abuse treatment providers, and mental health service providers. Across the focal counties, staff did not report significant reorganization of staff structures or roles to implement SB 1041, although they did emphasize that the reengagement process was labor-intensive and SB 1041 as a whole has required a strong focus on training and support for caseworkers. Caseworkers and staff understanding of SB 1041 Compared with other SB 1041 components, a higher percentage of all counties (18 percent) reported that their WTW caseworkers did not understand at all or only slightly understood the new WTW 24-month time clock; 16 percent of counties indicated their WTW caseworkers did not understand at all or only slightly understood the changes to the determination of hourly program participation. Caseworkers who participated in focal county focus groups expressed a significant amount of confusion regarding SB 1041 and identified the WTW 24-month time clock as the most challenging component of the legislation, including the way in which time elapses (when the clock should tick and untick ). CalWORKs participants' understanding of SB 1041 According to the ACS, the WTW 24-month time clock is the SB 1041 feature understood the least by participants. Supervisors in 67 percent of counties reported that CalWORKs participants did not understand at all or only slightly understood the changes represented by the WTW 24-month time clock. By comparison, 71 percent of all counties rated CalWORKs participants' understanding of the reengagement process for those who had a short-term young child exemption as moderately to very well understood. Likewise, administrators and caseworkers in all six focal counties reported that there are still many participants who do not fully understand the implications of SB 1041, including where they land within the 24-month time clock period. Stakeholders' view of factors that can support or hinder implementation According to many state-level stakeholders external to CDSS, the benefits of SB 1041 will not be fully realized until the accompanying Early Engagement reforms\u2014the OCAT, FS program, and ESE program\u2014are fully implemented on a statewide basis. Tension between promoting SB 1041 and meeting federal WPR requirements was viewed as another potential barrier, a theme that was also present in the focal county discussions on the topic. 179 Table 8.1\u2014Continued Topic Key Findings County experiences with factors that can support or hinder implementation Focal counties reported that participation in the state-level workgroup process and discussions better positioned them to begin planning early for SB 1041. Implementation was challenging given other concurrent policy changes (e.g., Medicaid expansion). Forty-five percent of all counties indicated that existing relationships with other county agencies facilitated implementation. Interagency committees and advisory groups were rated as helpful. Twenty-one percent of all counties reported that the timing of the release of state guidance on SB 1041 was a moderate or major hindrance to implementation, with smaller counties being more likely to provide this rating. Seventy-nine percent of counties reported that explaining the complexity of SB 1041 to participants was a moderate or major hindrance. Given the complexity of the WTW 24-month time clock, the lack of full automation of the time clock was viewed as a hindrance to implementation, especially for smaller counties. Overall, 60 percent of all counties reported that the WTW 24-month time clock is being calculated using both an automated system (e.g., for an initial calculation) and manually (e.g., to make needed adjustments), typically by caseworkers (93 percent of counties). The latter was more common for smaller counties. For 83 percent of all counties, caseworker supervisors reported that their WTW caseworkers understood the WTW 24-month time clock moderately to very well. At the same time, many caseworkers in the six focal counties indicated a poor understanding of the new time clock. The lag between implementation of SB 1041 and upgrading the county-level consortia administrative data systems to meet the needs of the legislation was a source of frustration for county leaders and caseworkers in the focal counties. County perceptions of SB 1041 reforms and their impact With such aspects as communications with participants; matching participants to WTW activities; provision of support services (e.g., child care, substance abuse, mental health); and coordination with other organizations in the public and private sector (e.g., community colleges, vocational education, other service providers, employers, and job training), a majority of counties consistently rated SB 1041 implementation as working moderately well to very well. This positive view of implementation also held for reengagement, tracking WTW participation, information management, and design and implementation of the ESE and FS programs. Between 45 percent and 57 percent of all counties estimated that the implementation of SB 1041 in the early years had no effect on WPR, participation in WTW activities, compliance with CalWORKs program rules, earnings, participation in CalFresh, or the number of participants receiving sanctions. At the same time, between 36 percent and 40 percent of counties reported that participation in WTW activities and enrollment in education and training programs\/ community colleges was somewhat better under SB 1041. Coordination with other public and private service providers at county level Three-quarters of all county social services departments reported reaching out to individual directors or agency representatives in other county agencies to plan for or implement support services under SB 1041. Concerns voiced by service providers in the focal counties regarding SB 1041 were similar to those identified by caseworkers\u2014that SB 1041 was complicated and difficult to understand. Education service providers in the focal counties (e.g., CalWORKs counselors on community college campuses) also noted that they had not observed the rate of referrals to education that they had expected, given the flexibility in activities afforded by SB 1041. State-level stakeholders' view of potential long-run impact of SB 1041 Stakeholders in CDSS and other state-level agencies and organizations expressed the potential for SB 1041 to have a positive effect on how clients experience their initial engagement with CalWORKs, the activities available to them, and their relationships with caseworkers. However, stakeholders noted that it is still too early to determine whether or not SB 1041 will have the intended effect of helping clients to overcome their unique barriers to self-sufficiency. 180 Table 8.1\u2014Continued Topic Key Findings Status and Tracking Studies Initial Descriptive Analyses Exemptions The percentage of participants who received at least one exemption during their first two years in the CalWORKs WTW program increased from the March 2007 entry cohort to the March 2013 entry cohort, from 44 percent to 56 percent. Annual snapshots of all WTW participants since SB 1041 became effective\u2014in March of 2013, 2014, and 2015\u2014showed that, at a point in time, about four out of ten participants had an exemption. Sanctions The percentage of participants who received at least one sanction during their first two years in CalWORKs stayed about the same from the March 2007 entry cohort to the March 2013 entry cohort (around 14 percent). Yearly snapshots since SB 1041 became effective showed that, in a given March, fewer than one out of ten participants were currently sanctioned. Leaving CalWORKs The percentage of participants who were not in the CalWORKs WTW program one year after entry did not change from the 2007 to 2013 entry cohorts (about 54 percent), while the percentage of participants who were not in the CalWORKs WTW program two years after entry increased from 63 percent for the 2007 entry cohort to 70 percent for the 2013 entry cohort. Employment and earnings A larger percentage of the March 2013 entry cohort was employed for at least one quarter in their first two years after entry compared with the March 2007 entry cohort (64 percent versus 52 percent). For the March 2015 cross-section, participants' real earnings (i.e., adjusted for inflation) were about $2,300 per quarter on average, an 11-percent increase compared with the March 2013 cross-section. Reengagement Among the participants who had the short-term WTW exemption for young children in December 2012, 14 percent still had this exemption in March 2014 and almost none had it in March 2015. Impact Study Initial Descriptive Analyses CalWORKs receipt, employment, and earnings Initial estimates based on state CalWORKs administrative data that account for participant characteristics and county unemployment rates suggest that persons entering CalWORKs in the post SB 1041 period had WTW participation rates one year after enrollment about 2 percentage points higher compared with similar CalWORKs WTW participants who enrolled before the reforms. This rise in WTW participation was because participants were combining employment and WTW participation more often (an increase of about 2 percentage points) rather than being employed without participating (a decrease of about 2 percentage points) compared with similar participants who started before SB 1041. When we accounted for changes in the economy and in the demographics of CalWORKs WTW participants, the level of quarterly real earnings among CalWORKs WTW participants one year after enrollment was about $54 higher (4.2 percent) than predicted. These findings are consistent with the increase in the earned income disregard, which was one aspect of SB 1041 that was implemented immediately. Other outcomes Estimates based on the CPS provide no indication that, in the first year after SB 1041 was implemented, outcomes for the population potentially eligible for the CalWORKs WTW program\u2014such as income below poverty, school enrollment, or receipt of job training\u2014have changed relative to a comparison group in other states with similar policies and demographics as California. released slowly, and\u2014according to county staff\u2014often confusing or contradictory. This led to challenges in training staff on SB 1041 and to confusion among administrative and line staff in regard to the different components of SB 1041 (particularly related to calculation of the WTW 24-month time clock). Training for caseworkers on SB 1041 was described as difficult, given the continual release of state guidance to clarify components of the reforms and evolving guidance over time. The ACS survey indicated that, for 21 percent of counties, the timing of the release of state guidance on SB 1041 was a moderate or major hindrance with respect to implementation, with smaller counties more likely to report it being a hindrance than medium-sized to large 181 counties. In terms of the complexity of SB 1041 reforms, 79 percent of counties reported that it was a moderate or major hindrance with respect to implementation; again, smaller counties (65 percent) were more likely to report it being a hindrance than counties with medium to large caseloads. County administrators and caseworkers found the complexity of SB 1041 hindered its implementation. Survey results showed that 52 percent of counties reported that the complex details associated with SB 1041 were not a barrier to implementation. At the same time, 79 percent of counties reported that explaining the complexity of SB 1041 to participants posted a moderate or major hindrance. In addition, caseworkers across the focal counties identified the WTW 24-month time clock as the most challenging component of the legislation, including when the clock should tick and untick. The time involved in administering the time clock was also viewed as crowding out time to provide other services. Other hindrances cited in the ACS were those affecting CalWORKs participants, such as availability of affordable housing, job opportunities, vocational education, transportation options or resources, and line staff. There were different views on caseworkers' understanding of SB 1041. In our focal county focus groups, caseworkers expressed significant concerns regarding the complexity of SB 1041, with a particular focus on the WTW 24-month time clock. Staff raised concerns about the adequacy of training and their supervisors' support to line staff. At the same time, when supervisors were asked on the ACS to indicate how well their caseworkers understood the changes to the WTW 24-month time clock, 83 percent of all counties indicated that the caseworkers understood the changes to the time clock moderately to very well. Compared with the other components of SB 1041, a higher percentage of counties (18 percent) reported that their WTW caseworkers did not understand at all or only slightly understood the changes to the WTW 24-month time clock; 15 percent of counties indicated their WTW caseworkers did not understand at all or only slightly understood the changes to the determination of hourly program participation due to the new averaging method for determining if a participant had met the minimum weekly hours under the 24-month time-clock plan. Relative to the other components of SB 1041, it was these two components that were most frequently identified by counties as aspects of SB 1041 for which their WTW caseworkers did not have at least a moderate understanding. SB 1041 appears to be difficult to explain to CalWORKs WTW participants. Administrators and caseworkers in all six focal counties reported that there are still many participants who do not fully understand the implications of SB 1041, including where they land within the WTW 24-month time clock period. In fact, caseworkers said that while it was difficult for them to understand the changes brought about under the legislation, an even greater challenge was explaining it to participants. Data from the ACS reinforce this finding\u201493 percent of counties reported that explaining the complexity of SB 1041 to participants was a barrier. This gap in understanding the policy changes under SB 1041 has implications for the ability of 182 participants to select the education and training activities and other supports that will be most beneficial for them during the first 24 months of CalWORKs participation. There were mixed views regarding the lag between implementation of SB 1041 and upgrading the county consortia administrative data systems to meet the needs of the legislation. Based on interviews and focus groups in the focal counties, this delay was a source of frustration for county leaders and caseworkers in the focal counties. At the same time, based on the ACS, county leadership in 64 percent of counties reported that lack of automation of the WTW 24-month time clock was not a hindrance in implementation. Conversely, 36 percent of counties reported that lack of automation of the WTW 24-month time clock was a minor, moderate, or major hindrance; this was especially true for smaller counties, where 50 percent indicated it was at least a minor hindrance. The role of WPR in the implementation of SB 1041 was a concern for some state-level stakeholders and many focal county staff. Perceptions that WPR and SB 1041 represent competing agendas emerged as a major theme in the interviews with state and focal county stakeholders. State-level stakeholders, external to CDSS, were particularly worried that counties felt pressured to meet WPR, influencing the extent to which caseworkers helped participants access options available under SB 1041. This concern was reinforced by comments from caseworkers in the focal county focus groups, with many caseworkers complaining about the lack of alignment between the state and federal requirements. ACS findings showed that 29 percent of counties assessed that SB 1041 resulted in somewhat or much worse workforce participation rates\u2014consistent with what we heard from the focus group discussions with caseworkers. Given that the process study shows the provisions of SB 1041 and related Early Engagement activities have yet to reach full implementation, it may be premature to expect substantial changes in CalWORKs WTW participant outcomes or in measured impacts. The initial analyses for the status, tracking, and impact studies demonstrate the feasibility of examining participant outcomes using state administrative data, as well as such external data as the CPS. There is some indication from the status and tracking studies that participant outcomes have been changing over time, but given the improving economy, it is important to account for other factors that may be affecting participation in the CalWORKs WTW program, labor market behavior, and other aspects of family well-being. The initial impact study findings are based on data with one to two years of post SB 1041 measures, which means we can only capture very early impacts. The pace of implementation for the reforms may explain the relatively modest effects demonstrated in the analyses that control for potential confounding factors. As the evaluation continues, we will be able to employ data covering a longer period of time after SB 1041 became effective and for a more extensive set of indicators available from county CalWORKs WTW administrative data. 183 Implications and Issues to Examine in the Next Phase of the Evaluation As a multiyear evaluation, this initial report with evaluation findings was not intended to lead to specific recommendations, although Chapters Four and Five identified a number of policy changes recommended by the counties as part of the ACS and on the part of the stakeholders who contributed to the focal county interviews and focus groups. However, a number of the findings summarized in Table 8.1 are sufficiently robust, especially those from the process study, to identify important implications of the results, as well as issues that we expect to consider in the next phase of the evaluation. In this final section, we highlight these implications and issues for further exploration. WTW 24-Month Time Clock As indicated in Table 8.1, one overarching theme of the focal county component of the process study is that implementation of the WTW 24-month time clock has been extremely challenging for everyone involved. Determining each participant's time-clock status is a time-consuming combination of automated and manual processes that are difficult to implement in a consistent way, at least for caseworkers in the six focal counties, in part because caseworkers do not have a uniformly complete understanding of the policy changes. This means that implementation of time-clock rules may vary across counties or even across caseworkers within the same county, such that two CalWORKs WTW participants with otherwise similar circumstances and histories may realize a different accounting of their time-clock status. Under the current SB 1041 policy, administrators in the six focal counties recognize that it is unrealistic to expect to be able to achieve consistency by fully automating the time clock; there are too many judgment calls required to determine what count as core versus noncore activities, when to tick or untick the clock, and so on. Although full automation may not be feasible, there may be ways to improve upon the existing automation systems to alleviate confusion and standardize as much of the process as possible. In addition, there is scope for further training of supervisors and caseworkers to improve understanding of the rules (e.g., what stops and starts the clock) and to ensure greater consistency in their application when manual adjustments are required. The smaller counties in particular may benefit from comprehensive training on the 24- month time clock. Counties may also gain from sharing information on best practices, although smaller counties may not have the resources needed to fully adopt practices that are working well in the larger counties, where more supports are available. Our in-depth data collection in the six focal counties further indicated that administrators and caseworkers are concerned that the WTW 24-month time clock is not sufficiently long for barriers to stable employment and self-sufficiency to be addressed. As the evaluation continues, we expect to determine if this concern is relevant statewide by examining state and county administrative data on CalWORKs WTW participants' outcomes. Data from the CalSES will allow us to examine a broader set of adult and child outcomes for a sample of CalWORKs WTW 184 participants who first enrolled in one of the six focal counties before and after the SB 1041 changes. CalWORKs WTW Participants' Understanding of SB 1041 The ACS and focal county work underscored that the complexity of SB 1041 made it challenging for caseworkers to understand and to explain to participants what SB 1041 is and what it means for them. The focus groups with CalWORKs WTW participants further reinforced the point that participants themselves really do not understand SB 1041, including such key aspects as the 24-month time clock, as well as what strategy they should take in terms of deciding how best to utilize core and noncore options and the one-time young child exemption. Although gaps in understanding program rules under CalWORKs or other programs is not a new phenomenon, these findings suggest that there is a need for simpler and more-detailed guidance that caseworkers and participants can follow. For CalWORKs WTW participants who are at the end of their 24-month time clock, consideration could be given to resetting their clock so that they have the opportunity to fully understand the implications of different options. Potential Process Improvements Recommendations offered during the focal county site visits focused on improving processes for caseworkers, which might ultimately make implementation easier and more understandable for all. In some cases, these processes were already being applied with good results in at least one of the focal counties and could therefore serve as models of best practice to test out and disseminate to other counties. In other cases, the recommended process change has yet to be implemented, so initial pilot testing of the process change may be warranted. For example, one recommendation was improvement of the WTW 2 form. Commenting on the complexity of the WTW 2 form, one administrator indicated that staff have gotten to the point where they describe the differences between the WTW and CalWORKs federal programs by what ticks and doesn't tick your clock, rather than try to fully go right side\/left side. A caseworker in another county noted that updating the WTW 2 form every time there's a change in activities between the WTW and CalWORKs sides of the form is challenging. The administrator said the form could be cleaner. For another example, administrators and caseworkers in one county advocated a specialized unit to track and manage participants' time on aid. This county developed such a unit during the planning stages of implementing SB 1041. They said, we really saw we needed to have one [a unit]. Time on aid was very time- intensive and the line staff really didn't have the time to do it. This [was] a big burden off of them [caseworkers]. We developed a system for all of the cases that came to our unit and how they were corrected. It would seem that a specialized time on aid unit would improve time-clock accuracy and reduce caseworkers' workload. 185 WPR Our work in the focal counties identified a tension between needing to meet the WPR and allowing CalWORKs WTW participants to pursue the choices available to them under SB 1041. This issue was also echoed by interviews with state (non-CDSS) stakeholders. It is unclear the extent to which pressures felt by the counties regarding the WPR are influencing caseworker behavior: Caseworkers might hesitate to encourage and support participants to take advantage of the flexibility SB 1041 offers when those choices may not help the county meet the WPR. As part of the ongoing evaluation, we will continue to assess the extent to which concern over potential federal penalties associated with the WPR is deterring counties from fully supporting the options under SB 1041. At the state level, for example, key informants indicated that the expected influx of CalWORKs WTW participants in community colleges had yet to materialize, which might reflect county concerns with meeting the WPR, the state of the economy, or other barriers to education participation. Nevertheless, as the evaluation continues, we can monitor community college participation as one indicator of whether CalWORKs WTW participants are engaging in further education and training as intended with the SB 1041 policy changes. Early Engagement Activities These initial evaluation findings also have implications for the set of Early Engagement activities associated with SB 1041: the OCAT, FS program, and ESE program. There are also related issues to explore as the evaluation continues. OCAT Rollout of the OCAT across the 58 counties began in the late summer of 2015. One question it raises is that this more comprehensive appraisal tool may identify more barriers and service needs than previous appraisals have done and identify them earlier in the process when an individual comes in for an initial appraisal. One of the questions moving forward is whether the counties will have sufficient services and capacity to meet those newly identified needs. Another issue is how counties will need to modify their processes to accommodate the OCAT. The guidance from CDSS focuses on the actual administration of the OCAT, but not guidance or training on how counties should modify their processes to move the appraisal process up earlier at intake and then change how a WTW participant is diverted to different programs and services to meet those needs. We will be focusing in the next round of focal county data collection on how counties have modified their processes to accommodate the OCAT and their experiences with it. Given the sensitive nature of some of the OCAT items (e.g., questions related to domestic violence, drug use, mental health issues) and the fact that these questions may be asked in front of WTW participants' children, it may be that these items will be underreported because of WTW participants' reluctance to answer such questions affirmatively. Further, the fact that these questions are being asked at the very initial intake step (before a caseworker has had a chance to 186 establish a rapport with a client) also may make it challenging to obtain accurate answers to these more-sensitive questions. This suggests it would be valuable to analyze the data and assess whether there is potential for underreporting to occur for some of the OCAT items. A final implication, given that the OCAT is still in the process of being implemented, is that the full SB 1041 treatment may not be realized until the OCAT is fully operational. Thus it may be several years before the full impact of SB 1041 can be assessed. This points to the value of the ongoing evaluation but also the need to acknowledge that the timing of the implementation of SB 1041 and supporting activities will not always align with the January 1, 2013, effective date of most of the legislation's policy changes. FS Program As suggested by several focal county leaders, the OCAT rollout in summer 2015 may have a strong impact on the FS program, driving increased referrals to the program, given the new expanded and comprehensive assessment process. In the next year of the study, the evaluation team will explore if referrals to FS have increased and perspectives on why that may be the case, as well as how the social service system is responding to any changes in demand. ESE Program The ESE program is relatively new and there is some variation in the way counties are implementing it. Therefore, it may be helpful for counties to learn from one another about their program models and strategies to expand the number and range of employers participating. Another issue that may warrant further exploration is the ESE program fund structure and allocation methods. 187 Appendix A. Understanding How the CalWORKs Program Functions This appendix provides a summary of how key components of the CalWORKs program operate under SB 1041, namely the reengagement of parents who had previously been subject to the young child exemption and the CalWORKs federal and WTW time clocks. We also provide details on the set of Early Engagement activities: the OCAT, FS program, and ESE program. Together, these aspects of CalWORKs provide important context for understanding the implementation of SB 1041 and the report findings. Reengagement of Parents Who Had Previously Been Subject to the Young Child Exemption Initial implementation of SB 1041 began with reengagement of parents who had previously been subject to the young child exemption that was changed as a result of the new legislation. Specifically, SB 1041 included the introduction of a new one-time exemption for parents of young children, ending the temporary young child exemption enacted by AB X4 4, for which parents or other primary caretakers were eligible if either one child they cared for was between 12 and 23 months of age or at least two children were under six years of age. Clients could take this temporary young child exemption as many times as needed, as long as they remained eligible. SB 1041 created a new exemption for a parent or primary caretaker of a child between 0 and 23 months of age. One key difference between the new exemption and the previous one was that the new young child exemption is a one-time exemption: It can only be taken once in a participant's lifetime regardless of how many times a client leaves and reenters the CalWORKs program (CDSS, 2012b; CDSS, 2013a). The previous exemption ended December 31, 2012. As a result, counties were required to initiate contact and communicate with participants who were no longer eligible for this exemption and reengage them into the WTW program. Counties were required to complete their reengagement processes by January 1, 2015 (CDSS, 2012d; CDSS, 2013b). CalWORKs Federal and Welfare-to-Work Time Clocks Enactment of SB 1041 modified the CalWORKs program to include a new method of providing WTW activities to nonexempt participants. As of January 1, 2013, a WTW 24-month time clock was established for the CalWORKs program that allotted up to 24 months for participants to engage in a variety of activities to prepare them to become or remain employed (CDSS, 2012a). The new time clock is embedded within the preexisting CalWORKs 48-month time limit, which 188 determines how long nonexempt participants are eligible to receive cash assistance contingent upon compliance with the federal work participation requirement. Months in the new clock accrue prospectively and cumulatively, but not necessarily consecutively (CDSS, 2012a). After the WTW 24-month time clock expires, participants are obligated to meet the CalWORKs federal standards for work participation requirements for the remainder of their 48 months on aid.64 In addition, participants with fewer than 24 months left on their 48-month time-on-aid clock are only permitted to participate in WTW activities for the time remaining on their clock (CDSS, 2012c). Comparison of Time Clocks While similar in some respects (e.g., number of required work participation hours), the time clocks are distinct in several ways. The first and most significant difference between the clocks is the approved activities. SB 1041 eliminated the WTW core and noncore hourly requirements, with the CalWORKs WTW 24-month time clock activities being more varied and extensive than the federal work activities (see Table A.1). All the activities listed under the CalWORKs WTW 24-month time-clock column (first column in Table A.1) are allowed, and participation in these activities, in any combination that satisfies the participant's hourly requirements, maintains him or her in good standing in the program (CDSS, 2012c). The increased flexibility resulting from the elimination of the core and noncore hourly requirements during the 24-month period was intended to support participants' opportunities to reach self-sufficiency. In addition, the number of hours that clients are required to participate in WTW have been aligned with the federal hourly requirements, which reduces the weekly participation requirements for single-parent families. When clients have used up, or exhausted, their WTW 24-month time clock, they are subject to CalWORKs federal standards. CalWORKs federal standards hourly requirements must then be satisfied through a combination of more restrictive work-like activities, listed on the second column of Table A.1. Although there is some overlap in the approved activities, the requirements for participation in these activities differ. For example, participation in vocational education under the CalWORKs federal standards is limited to 12 months for the participant's lifetime. However, participants can engage in vocational education for the entire 24 months of the WTW time period. The second major distinction between the two time clocks is the way in which time elapses, or ticks. The 48-month time-on-aid clock begins as soon as the nonexempt participant is approved for the CalWORKs program. However, the CalWORKs WTW 24-month time clock is triggered by the participant signing the WTW 2 form, or if the participant does not meet the CalWORKs federal requirements.65 Specifically, the CalWORKs WTW 24-month time clock 64 Participants began timing out of the WTW time clock in January 2015. 65 The WTW 2 form is a four-page document that lists CalWORKs WTW 24-month time-clock activities on the left side and CalWORKs federal work activities on the right side of the first page. In addition, the total number of 189 Table A.1. Comparison of CalWORKs Welfare-to-Work 24-Month Time-Clock Activities and Federal Work Activities CalWORKs Welfare-to-Work 24-Month Time Clock Federal Work Activities (No Core Activity Requirements) Unsubsidized employment Self-employment Subsidized private or public sector Grant-based on-the-job training Work study Work experience Community service Vocational education On-the-job training Job search and job readiness Mental health services Substance abuse services Domestic abuse services Supported work and transitional employment Job skills training directly related to employment Satisfactory attendance in a secondary school or in a course leading to certificate of general educational development Education directly related to employment Adult basic education Participation required by school to ensure child's attendance Other activities necessary to assist in obtaining employment Core Activities Unsubsidized employment Self-employment Subsidized private or public sector Grant-based on-the-job training Work study Work experience Community service Vocational education (12-month lifetime limit) On-the-job training Job search and job readiness (per established time limits) Mental health services Substance abuse services Domestic abuse services Providing child care to a community service program participant Noncore Activities Job skills training directly related to employment Satisfactory attendance in a secondary school or in a course leading to certificate of general educational development Education directly related to employment Activities Not Meeting Federal Other activities necessary to assist in obtaining employment SOURCE: CDSS, undated-c. ticks on the first month following signing the WTW 2 form or after determination that CalWORKs federal work requirements were not met. In the event that a participant meets the CalWORKs federal work requirements after the WTW 24-month time clock starts, the caseworker can go back retroactively and untick the 24-month time clock for the relevant months. Conversely, if a participant met the CalWORKs federal work requirements but was determined to be noncompliant later, the caseworker would start the CalWORKs WTW 24- month time clock at the beginning of the following month. The 24-month time clock would continue to tick until the participant began meeting the CalWORKs federal work requirements or meets one of the other criteria for stopping the clock (e.g., WTW exemption, in the process of developing a WTW plan, good cause, domestic abuse waiver, etc.) (CDSS, 2012a; CDSS, required work participation hours is included one this form. Pages 2 3 include the details on the specific program assignment\/s and service\/s to which the participant has agreed. The final page is for participant acknowledgment. Each participant in the family signs his or her own form and has his or her own 24-month time clock (CDSS, undated-c). 190 2012c). In general, the 48-month time-on-aid clock continues to tick each month while the nonexempt participant remains eligible for the CalWORKs program. Third, the two time clocks also vary in terms of clock expiration. Given that the 48-month time-on-aid clock supersedes the WTW 24-month time clock, if an individual has timed out on the 48-month time-on-aid clock, he or she is not granted any additional time on the 24-month time clock (CDSS, 2012). However, if the WTW 24-month time clock expires during the 48- month time-on-aid period, a target of 20 percent of participants in each county can be approved for a six-month extension of the 24-month time clock if the participant is likely to secure employment within six months has encountered unique labor market barriers temporarily preventing employment, and therefore needs additional time to obtain employment is close to completing an educational or treatment program needs an additional period of time to complete a WTW activity specified in his or her WTW case plan due to a diagnosed learning disability or other disability has an application for Social Security's Supplemental Security Income (SSI) under review is a second adult in the family who hasn't exhausted the CalWORKs WTW 24-month time clock faces other circumstances as determined by the CDSS (CDSS, 2014c; CDSS, 2015a). Calculation of the 24-Month Time Clock Calculating the WTW 24-month time clock, also known as determining whether the clock should tick (and therefore the month should count as time used on the clock), is a complicated process that involves automated systems and manual revision. The automatic interface ticks the 24- month time clock automatically. Los Angeles uses the automatic LEADER system. CalWIN handles this automatic process for 18 counties in California, while C-IV manages this process for the remaining 39 counties (Legislative Analyst's Office, 2012). The automatic systems tick the 24-month time clock each month, and it is up to caseworkers to review the cases monthly and untick any clocks where necessary. The action of unticking a clock takes place in a manual system that communicates with the automatic system to send time-clock information to the state and federal welfare programs. As mentioned earlier, the 24-month time clock is unticked if a caseworker finds that certain exemptions can be applied or if the CalWORKs federal requirements are met. In Los Angeles, caseworkers use the manual GEARS system to untick the clock. This data interface is also used to determine if participants met their monthly WTW hours. CalWIN and C-IV also provide subsystems that allow caseworkers to untick the clock if necessary. Caseworkers use a manual calculation process to determine if participants have met their monthly WTW hours. 191 There are several exemptions that can stop the CalWORKs WTW 24-month time clock, some of which also stop the 48-month time-on-aid clock. The one-time young child exemption, for example, exempts a CalWORKs participant from WTW and CalWORKs federal requirements provided that he or she is the primary caretaker of a child younger than 24 months of age (CDSS, 2012c). The exemption for adults caring for young children six months of age or younger, however, exempted clients caring for a child younger than six months from WTW participation, but not the CalWORKs 48-month time limit (CDSS, 2012c). Other exemptions, such as the domestic abuse exemption, excuse participants from both programs. For a complete list of exemptions see ACL 12-67 (CDSS, 2012). Under new direction from CDSS (released in November 2014), caseworkers are to use an averaging methodology to determine if a client meets the minimum weekly hours under the 24- month time-clock plan. The weekly average is calculated by adding the total number of participation hours in all CalWORKs activities for the month, dividing by 4.33, then rounding to the nearest whole number (CDSS, November 14, 2014h). Determining Extensions of Participants' 24-Month Time Clock Initial guidance on extending the 24-month time clock was issued by the state in ACL No. 14-09 (CDSS, 2014c). Since then, five additional ACLs handling expiring time clocks were released (CDSS 2014f; 2015a; 2015b; 2015c; 2015h) that provided instructions on calculating and tracking extensions, explained the methodology for determining the target number of extensions, described the process for transitioning participants to post 24-month time-clock federal standards, and outlined the target number of extensions estimated for July 2015 through December 2015. Early Engagement Activities At the state level, SB 1041 was negotiated within the context of new or expanded programs intended to maximize the promise of the CalWORKs WTW 24-month time clock. Under AB 74, those programs, known collectively as Early Engagement, include the OCAT, FS program, and ESE program. We summarize each of these components in turn. The Online CalWORKs Appraisal Tool As described in ACL 15-43, the WTW appraisal is intended to evaluate a client's employment and education history, and identify any barriers to self-sufficiency that can be addressed through WTW activities and supportive services (CDSS, 2015f) The OCAT is based on the federal OWRA tool for TANF. Through a workgroup process, CDSS modified the OWRA and 192 customized it to produce the OCAT. 66 In March 2014, CDSS contracted with ICF International to develop the web-based appraisal tool. CDSS also asked five counties to serve as early users of the uncustomized version of the OWRA tool in order to gather their initial reactions and ideas for customization.67 In the summer of 2014, CDSS began piloting the OCAT in a select number of counties,68 and statewide training and implementation began in the spring of 2015 through a series of regional train-the-trainer sessions (CDSS, 2015g). Completion of the statewide training was scheduled for July 2015 with the 58 counties expected to begin using the OCAT in August 2015. Figures A.1 and A.2 illustrate how the federal OWRA tool is used in appraising TANF participants and how the appraisal process will be altered from pre AB 74 to post AB 74 when the OCAT is fully implemented. Importantly, the OCAT appraisal form is intended for use earlier in the process\u2014that is, during a WTW participant's initial appraisal. Prior to the implementation of the OCAT, an assessment of barriers is typically done within the six focal counties only after an individual has participated in Job Club and been unsuccessful in finding employment (Figure A.1). This is consistent with a work-first approach, where job search activities are required immediately upon receipt of assistance\u2014typically for four weeks\u2014and followed by a more thorough assessment of skills and barriers if employment is not found. Following the implementation of AB 74, which established the OCAT, the appraisal was moved up earlier in the process so that it occurs when a WTW participant comes in for his or her initial appraisal (Figure A.2). This change means that counties will need to not only train their line staff in implementing the OCAT but also revise their flow and Early Engagement processes by which WTW participants are assessed and WTW plans developed. Figure A.1. Federal OWRA 66 CDSS engaged its stakeholder partners\u2014including CWDA, county welfare departments (CWDs), welfare advocacy groups, community college representatives, and legislative staff\u2014to conduct an extensive review of the federal OWRA tool and to make recommendations for modifying it to create the OCAT (CDSS, 2014e). 67 The five early-user counties were Fresno, Los Angeles, San Bernardino, Sonoma, and Tulare (CDSS, 2014e). 68 The pilot counties were Lassen, Los Angeles, Sacramento, San Bernardino, and San Francisco (CDSS, 2014e). Orientation Job club Assessment (OWRA) WTW plan 193 Figure A.2. Assessment of WTW Participants' Barriers and Needs (Pre AB 74) The OCAT generates a summary of the WTW participant's appraisal and produces a set of recommendations for addressing identified needs and barriers that includes appropriate supportive services. As Figure A.3 illustrates, this may include evaluation for the FS program, WTW exemptions, job search, assessment for education and\/or training, and Self-Initiated Programs. This information is used to develop each client's individualized WTW plan. Family Stabilization Program AB 74 called for counties to create an FS program, effective January 1, 2014. As described in ACL 14-12 (CDSS, 2014a), the program is designed to ensure a basic level of stability within a family prior to, or concurrently with, participation in Welfare-to-Work (WTW) activities. The goal of FS is to increase client success in light of the flexible WTW 24-month time clock through more intensive case management and the assignment of clients to the additional activities or barrier removal services necessary to ultimately achieve self-sufficiency. Families are required to already be participating in the WTW program to be eligible for FS. Additionally, at least one adult in the family must not yet have exhausted his or her 24-month time clock or 48- month cash-aid time clock to participate. Participation in the FS program will stop a participant's WTW 24-month time clock for up to six cumulative months. However, the length of time a participant remains in FS is dependent on the circumstance of each family. FS program participation is determined when a county identifies a family in crisis (e.g., homelessness, domestic violence, behavioral\/mental health issues, or substance abuse related needs) that would prevent adult WTW participants in that family from engaging in the program and attaining self- sufficiency. FS is meant to support families as a whole and could include mental health treatment for families, substance abuse counseling, and transitory housing, to name a few supportive services. FS is intended to be responsive to the participants and allow various degrees of flexibility to ameliorate and build family capacity to respond to their crises. Orientation and appraisal Job search Full-time employment Full-time employment not found Assessment and development of WTW plan 194 Figure A.3. California OCAT (Post AB 74) In addition, under SB 855 (2013), which modified Welfare and Institutions Code Section 11325.24(e), counties can offer housing and other needed services for any month in which a family is participating in the FS program. SB 855 also confirmed that FS is a voluntary program that aid recipients must agree to participate in; otherwise, they remain in the regular CalWORKs WTW system. Expanded Subsidized Employment Program The ESE program is another part of the Early Engagement strategy. It includes funds that counties may use to expand their current subsidized employment program. ACL 13-81 describes the ESE program as one part of Early Engagement strategies being implemented as a result of the passage of AB 74. Other Early Engagement strategies include robust appraisal and family stabilization . . . (CDSS, 2013c). The ACL states that in addition to wage and nonwage costs for the job placements, ESE funds may be used to cover all operational costs of the ESE program, including the cost of overseeing the program, developing work sites, and providing training to participants. Although CWDs will have flexibility to utilize these funds as described Orienta(on and in-\u00ad\u2010depth appraisal (OCAT) Job search Full-\u00ad\u2010(me employment (development of WTW plan) Full-\u00ad\u2010(me employment not found Barrier evalua(on FS program evalua(on (if barrier evalua(on reveals immediate crisis) Self-\u00ad\u2010ini(ated program (SIP) evalua(on WTW exemp(on determina(on Assessment for educa(on\/training (development of WTW plan) WTW 24-\u00ad\u2010month clock begins once a WTW plan is established Imme diate 195 above, CDSS will also work with CWDA to determine the proportion of ESE funding that may be used for operational costs. . . . Funds allocated for ESE shall be in addition to, and independent of, the CWDs' Single Allocation and cannot be used by CWDs to fund or supplement the AB 98 Subsidized Employment program (AB 98 program). 197 Appendix B. Additional Documentation for Primary Data Collection This appendix provides further details regarding the primary data collection components: state- level key informant interviews, ACS, and focal county data collection. For the state-level key informant interviews, we provide a list of the agencies with which our interviewees were associated. We also provide the interview protocol. For the ACS, we present the online survey instrument, formatted as a paper survey. For the focal county data collection, we include the protocols for the key informant interviews, focus groups with caseworkers, and focus groups with CalWORKs WTW participants. We also provide tabulations that compare the characteristics of the CalWORKs WTW participants who attended a focus group session with those of the sample participants who were eligible for recruitment. State-Level Key Informants The state-level key informant interviews were conducted with individuals from the following agencies and organizations: CDSS, including the WTW Division, Child Care Bureau, and CalFresh Branch CWDA Legislative Analyst's Office Senate Standing Committee on Budget and Fiscal Review Assembly Committee on Budget Office of the Chancellor, California Community Colleges California Commission of Welfare Rights Organizations Western Center for Law and Poverty Data consortia specifically LEADER, CalWIN, and C-IV. The protocol for these interviews is on the following pages. All-County Survey The ACS instrument follows the state-level key informant interview protocol. Focal Counties Data Collection This section includes the protocols for the key informant interviews, focus groups with caseworkers, and focus groups with CalWORKs WTW participants conducted in the six focal counties. We also assessed the representativeness of the CalWORKs WTW participants who attended a focus group session. 198 Representativeness of CalWORKs WTW Participant Focus Group Attendees Table B.1 compares the mean values along several characteristics for individuals who were initially sampled for the focus group, were contacted and determined to be eligible, and attended a focus group. The last three columns of Table B.1 show the difference between the mean values for individuals determined eligible and for individuals who attended the focus groups and the statistical significance of those differences. The characteristics included in Table B.1 were obtained from WDTIP, which provided the sample frame for the initial sampling of individuals. Thus, we have these characteristics for CalWORKs WTW participants sampled for the focus group and specifically for those who attended. We observe from Table B.1 that individuals who participated in the focus group are very similar in terms of sex, age, age of the youngest child, and composition of the household (whether a two-parent case or not) to the group of individuals deemed eligible and to those who were initially sampled. Regarding the race or ethnicity of the participants, we observe that black or African Americans were less likely to agree to participate and less likely to attend a focus group, while we observe the opposite for individuals in the other ethnicity category. However, these differences by race or ethnicity were not statistically significant. Another salient observation from Table B.1 is that CalWORKs WTW participants whose case language was Spanish were significantly more likely to agree to participate and attend a focus group than individuals whose primary language was English or some other language. This could be the result of conducting focus groups specifically targeted for Spanish-speaking individuals. Table B.1. Comparison of Characteristics of CalWORKs WTW Participants Sampled for, Eligible for, and Attending Focus Groups CalWORKs WTW Participants Characteristic Sampled for Focus Groups Eligible for Focus Groups Attended Focus Groups Female (percent) 85.1 83.7 82.8 Age (in years) 31.6 32.0 32.1 Age of youngest child (in years) 6.2 6.2 6.2 Race or ethnicity (percentage distribution) Hispanic or Latino 40.6 41.9 44.1 White 21.8 23.0 22.6 Black or African American 24.7 22.8 16.1 Asian 2.3 1.7 0.0 Other 10.5 10.7 17.2 Case language (percentage distribution) English 85.5 85.8 80.6 Spanish 10.5 11.2 18.3 Other 4.0 3.0 1.1 Two-parent case (percent) 20.0 21.2 18.3 N 1,167 733 93 SOURCE: CalWORKs WTW participants' characteristics as reported in WDTIP database. NOTE: Percentages may not sum to 100 because of rounding. Differences between second and third column is statistically significant at the 5-percent level only for the percentage with a case language of Spanish. 199 Evaluation of SB 1041 Reforms to California's CalWORKs Program State-Level Key Informant Interview Protocol October 2014 I. Informed Consent I work for RAND, which is a private, nonprofit, public policy research organization. [OR I work for the American Institutes for Research (AIR).] We've been contracted by the California Department of Social Services (CDSS) to conduct an independent evaluation of SB 1041, which is intended to provide a more flexible approach to supporting CalWORKs participants toward self-sufficiency. Today I am hoping to hear about your views on this subject. The interview will take approximately 45-60 minutes. Your confidential input about the development and implementation of SB 1041 is valuable to us. We will not share your individual responses with anyone else outside of the research project. And we will not identify any individuals by name in our study reports. If we use any quotations from these interviews, we will not attribute them to any individual by name. Although we won't be identifying you by name, it is possible that someone might be able to identify you by the information you give us. So we recommend that you don't tell us anything that you would not be comfortable with other people reading. Your participation in this interview is voluntary. You may choose not to participate, decline to answer any question, or stop the interview at any time. I plan to audio record it, solely for our note taking purposes. The audio recording will only be used by project staff, and we'll destroy it when the project is done. Do I have your permission to proceed with the interview? [IF NO:] Thank you anyway. [IF YES:] Do I also have your permission to audio record the interview? II. Interview Questions 1. Role. What was your role and your organization's role in regard to the development and\/or the implementation of SB 1041? 2. Development and Scope of SB 1041. [If relevant, based on Question #1] This question is about the process of developing SB 1041 legislation and plans for implementation. a. From your perspective, what was the impetus behind the development of SB 1041? What factors drove the legislation? b. How did CDSS coordinate with other state agencies, the federal government, organizations such as the County Welfare Directors Association (CWDA), and with counties in developing SB 1041 legislation and plans for implementation? c. Were any other agencies involved in the development of SB 1041 that you have not mentioned? d. Can you describe CDSS' role in writing the regulations and also distributing TANF monies and state CalWORKs funds? 3. Broader policy context. At the state-level, what other major policy changes occurred during this same time period (2011-2013) that may have had implications for SB 1041 implementation? 200 a. Did these other policy changes have any effects on the approach adopted for SB 1041 or on the timing of its implementation? b. Did these other policy changes hinder or facilitate SB 1041 implementation? 4. Reporting Requirements. In what way, if any, has the implementation of SB 1041 changed the way California reports to the federal government? a. In terms of state reporting requirements, what specifically has changed since SB 1041 was implemented? b. What are the reporting requirements for the counties? What has specifically changed since SB 1041 was implemented in regard to reporting? 5. Status\/Pace of Implementation. From the state perspective, what has been the pace of implementing SB 1041 among the counties for example, has it been a slow process or implemented all at once? a. Are there changes associated with SB 1041 that have yet to take effect? 6. Communication to Counties. How did CDSS inform counties about SB 1041 requirements? In addition to the All County Letters (ACLs) that were sent out to county welfare directors, were there other ways in which CDSS communicated implementation information with counties (e.g., webinars, meetings)? 7. Communication to CalWORKs Participants. From the state perspective, to what extent do participants understand the changes brought about by SB 1041? 8. Technical Assistance. What types of technical assistance and guidance has been provided by the state to counties? 9. State Monitoring. What types of monitoring activities are being undertaken by CDSS? a. CDSS has conducted field visits to a number of counties from your perspective, what are the key challenges facing counties? b. Are there any innovative or successful implementation examples you would like to share, based on those visits? 10. Variation in Implementation. To what extent is there variation in program services and administration across counties and how do these relate to the differences in the delivery and coverage of services? 11. Impact on County Welfare Organizational Infrastructure. To your knowledge, what is the impact of SB 1041 on county welfare operations? a. Specifically, what has changed about county welfare staffing levels, if any? b. What has changed about the level of resources allocated to counties, if any? 12. Impact on County Welfare Services. What has changed in regard to services to CalWORKs participants, as a result of SB 1041? a. How has SB 1041 impacted, if at all, child care, transportation, and other supportive services? b. How has SB 1041 impacted, if at all, welfare to work activities? 201 c. What impact are the new time limits, the revised work hour requirements, and the new clocks expected to have on county staff and CalWORKs participants? E.g., in terms of understanding and tracking. d. Are there other major changes that have impacted counties, as a result of SB 1041? 13. Impact on CalWORKs Participants. From the state perspective, what is the impact of SB 1041on CalWORKs participants? a. Is there any particular component of SB 1041 that you believe has had the strongest impact on CalWORKs participants? If so, why? 14. Implementation Successes. From your perspective, what has worked well with SB 1041? 15. Implementation Challenges. From your perspective, what have been the implementation challenges associated with SB 1041? a. What strategies have been effective, if any, in overcoming these challenges? b. Is there anything you'd change about SB 1041? Why or why not? 16. Coordination across Programs and Systems. From the state perspective, how effective is coordination among state welfare programs and other systems, in providing services to CalWORKs applicants and to current and former participants? These systems may include school districts, mental health programs, transportation providers, child care providers, community colleges, community-based organizations, the private sector, alcohol and drug programs, local planning councils, and other organizations. a. Beyond coordination, are any of these systems engaged in more intensive collaboration to serve CalWORKs participants? 17. Data Systems. How well do the current data systems support state and county needs related to implementation of SB 1041? 18. Next Steps. What does your agency see as being the next steps with respect to SB1041 implementation? For CDSS? For the counties? 19. What policy hurdles does your agency\/CDSS see going forward and what steps may be needed to address them? 20. (For CDSS and other agencies): How has SB 1041 affected your organization? a. In terms of staffing levels or structures? b. Reporting relationships? c. Your organization's relationships with other departments or agencies: at the state-level? At the county-level? d. Other impacts? 202 Evaluation of SB 1041 Reforms to California's CalWORKs Program All County Survey Instrument 2015 Dear Human Services\/Social Services Director: We would like to request your participation in a Web-based survey that is part of the state- mandated evaluation of the SB 1041 reforms to the CalWORKs Program. These reforms, which officially took effect in January 2013, are expected to impact county CalWORKs operations, CalWORKs participants' interactions with county staff, and a range of outcomes for participants and their families. The purpose of this survey (and the ones that will follow in future years) is to learn how your county has implemented the SB 1041 reforms and related legislation (including AB 74, which established the Family Stabilization Program and the Expanded Subsidized Employment Program) and how the operation of your county CalWORKs Program has changed as a result of SB 1041. The survey will ask about implementation activities going back to January 2013 when SB 1041 went into effect. This evaluation, commissioned by the California Department of Social Services (CDSS), is being conducted by the RAND Corporation and American Institutes for Research (AIR). RAND and AIR are asking the Human Services\/Social Services Directors in all 58 California counties to take part in this Web survey. Participation in the survey is completely voluntary, but we hope you will agree to participate. The amount of time needed to complete the survey will vary depending on the size and complexity of your CalWORKs Program. All information you provide will be held in confidence by RAND and AIR. This means that the information you provide will not be shared with anyone other than persons authorized by RAND and AIR. Survey responses will be analyzed and included in a report to be released in late 2015. All responses will be kept confidential; report(s) will include survey results in aggregate form only and may include representative unidentified quotes, which therefore will not be attributable to any county individually. We recommend that you print a Word document version of the survey (attached to the e- mail invitation you received) and complete it together with the members of your management team who are responsible for case management, employment and training services, and participant outreach and communication because many of the survey questions pertain to these specific program functions and activities. We also have a section that would be relevant for supervisors of Welfare to Work (WTW) line staff to complete. Once you complete the hard copy of the survey, please submit your responses online by entering the password provided in the e- mail you received with the survey link. Please submit your on-line survey responses by July 17, 2015. If you have any questions about this survey, please contact Cheryl Graczewski at AIR at [email protected] or 650-843-8238. This frequently asked questions (FAQ) document also may help to answer your questions. Thank you for your participation! \u2014The RAND\/AIR CalWORKs Evaluation Team mailto:[email protected] 203 Directions to Complete the All-County Survey The 2015 SB 1041 All-County Survey includes the seven sections outlined below. We encourage you to work through each section, answering all questions, after consulting with your colleagues using the Word copy of the survey. After completing the Word copy of the survey, enter your county's responses in the online survey. In the online survey, if you wish to return to a previous section, please use the back button on each page to move backwards, or exit and reenter the survey to return to the beginning. Your responses are saved as you proceed through the survey. Before closing your browser, please be sure to save your responses by clicking the save and exit button. Please complete all sections before submitting the survey at the end of Section VII. To review definitions related to the SB 1041 reforms, please see the last two pages of the survey. We encourage you to print out the definitions document and refer to it as needed while completing the survey. Section I. Implementation of SB 1041 Reforms to the CalWORKs Program in Your County Section II. Interagency Collaboration Section III. Organizational and Administrative Changes Section IV. Questions for Supervisors About Line Staff and CalWORKs Participants Section V. Provision of Services for CalWORKs Participants in Your County Section VI. Expanded Subsidized Employment and Family Stabilization Programs and the Reengagement Process Section VII. Outcomes and Expectations 204 I. Implementation of SB 1041 Reforms to the CalWORKs Program in Your County We are interested in the status of implementation of the SB 1041 reforms to the CalWORKs Program including facilitators and barriers to implementation. 1. Please indicate the current stage of implementation of each of the following components of SB 1041 reforms to the CalWORKs Program in your county. In addition, we also ask about the status of related programs (the Family Stabilization [FS] Program and the Expanded Subsidized Employment [ESE] Program). (Mark one circle on each line.) Program components Not planned\/ designed Program planning\/ design in progress Piloted in selected districts\/ regional offices Implemented countywide by june 2015 Not applicable a) The 24-month time clock and related mandates \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Reengagement of AB X4 4 short- term young child exemption population \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) New\/enhanced partnerships with education providers (e.g., community colleges) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) New\/enhanced partnerships with vocational education\/job training providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) New\/enhanced partnerships with domestic violence service providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) New\/enhanced partnerships with substance abuse treatment services \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) New\/enhanced partnerships with mental health services \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Expanded Subsidized Employment (ESE) Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 i) Family Stabilization (FS) Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 205 2. Please provide additional comments on the status of implementation of the components listed in the previous question that you think are pertinent. ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ 3. Please indicate the extent to which the following issues were or were not hindrances in the implementation of SB 1041 reforms (including related programs: family stabilization and expanded subsidized employment) in your county. (Mark one circle on each line.) Issue Did not hinder Minor hindrance Moderate hindrance Major hindrance Not applicable a) Timing of state guidance on SB 1041 to the counties \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Lack of automation of WTW 24-month time clock \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Availability of job opportunities for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Availability of educational opportunities for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Availability of vocational education or on-the-job training opportunities for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) Availability of financial resources for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Availability of child care services for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Availability of affordable housing for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 206 Issue Did not hinder Minor hindrance Moderate hindrance Major hindrance Not applicable i) Availability of transportation options or resources for CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 j) Competition with other state\/ federal mandates (e.g., Medi-Cal expansion) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 k) Availability of line staff (e.g., caseworkers, employment services specialists) who work with and\/or counsel WTW participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 l) Complexity of SB 1041 reforms to CalWORKs \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 m) Explaining the complexity of SB 1041 to participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 n) Prior reductions\/freezes in staff and\/or funding \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 o) Other \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 If you selected Minor Hindrance, Moderate Hindrance, or Major Hindrance for Other, please answer Question 3a. If not, please continue on to Question 4. 3a. In Question 3, you selected Other. Please specify below what other issue(s) have hindered the implementation of SB 1041 reforms and related mandates (family stabilization and expanded subsidized employment) in your county: _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ 207 4. Please indicate the extent to which existing relationships or partnerships with the following types of organizations were or were not facilitators for the implementation of SB 1041 reforms in your county. (Mark one circle on each line.) Existing relationships or partnerships with: Did not facilitate Minor facilitator Moderate facilitator Major facilitator Not applicable a) Other county agencies (e.g., mental health, behavioral health, child support services, housing agency) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Education providers (e.g., community colleges) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Vocational education or on the job training providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Employment services or job placement providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Community organizations and\/or welfare advocacy organizations \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) State organizations (e.g., CWDA) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Other \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 If you selected not applicable for 4f and 4g above, skip Questions 4a and 4b below, and go to Question 5. 4a. In Question 4, you selected a response for state organizations that have or have not facilitated the implementation of SB 1041 reforms in your county. Please specify the state organization below: ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ 4b. In Question 4, you selected Other existing relationships or partnerships that have or have not facilitated the implementation of SB 1041 reforms in your county. Please specify the type or name of the other organization below: ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 208 You have reached the end of Section I: Implementation of SB 1041 Reforms to the CalWORKs Program in Your County. Please continue to the next section. To return to a page in this section, please click Back.\" To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit.\" 209 II. Interagency Collaboration Now, we would like to ask you about the type of interagency coordination your county social services department undertook to plan for or implement SB 1041. 5. How did your county social services department communicate SB 1041's changes to the CalWORKs Program to other county agencies? (Please mark all that apply.) Memoranda, letters, or Administrative Directives Briefings Interagency or interdepartmental meetings Interagency working groups Other If you selected Other, please go to Question 5a. If not, please proceed to Question 6. 5a. Please briefly describe \"Other\" from Question 5. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 6. Since the passage of SB 1041 in July 2012, did your county social services department undertake any of the following coordination activities with other county agencies specifically to plan for or implement CalWORKs support services (e.g., housing, child care, mental health, drug treatment, domestic violence services)? Yes No a) Convened an interagency planning meeting r\uf072 r\uf072 b) Established an interagency working group r\uf072 r\uf072 c) Reached out to individual directors or agency representatives r\uf072 r\uf072 d) Other r\uf072 r\uf072 If you selected Yes for Other, please go to Question 6a. Otherwise, go to Question 7. 210 6a. Please briefly describe \"Other\" from Question 6. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 7. Please provide a brief description of the coordination activities you noted in question 6 that your department undertook with other county agencies specifically to plan for or implement the new CalWORKs support service requirements (e.g., housing, child care, mental health, drug treatment, domestic violence services)? ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ You have reached the end of Section II: Interagency Collaboration. Please continue to the next section. To return to a page in this section, please click Back.\" To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit.\" 211 III. Organizational and Administrative Changes Now, we would like to ask you about what organizational or administrative changes your county social services department may have made in order to facilitate implementation of the SB 1041 reforms to the CalWORKs Program and related mandates (i.e., Family Stabilization Program, Expanded Subsidized Employment Program). 8. In 2013 and\/or 2014, did your county social services department implement any of the following organizational or administrative changes in response to SB 1041 or to related legislation (AB 74 which established the Family Stabilization and Expanded Subsidized Employment programs)? (Mark one circle on each line.) Yes No Don't know a) Created new units (e.g., specialized case management or reengagement units) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Reassigned existing units \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Co-located welfare staff with other county agencies \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Opened new regional office locations \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Enhanced regional office locations f) Shifted funding from one unit or program to another \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Pooled funding across county agencies to provide services to CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Paid staff overtime to revise and\/or calculate participants' WTW 24-month time clock status \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 i) Paid staff overtime to implement the reengagement process \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 j) Other \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 If you selected Other, please go to Question 8a. If not, please proceed to Question 9. 8a. In Question 8, you selected Other. Please briefly describe the other organizational or administrative changes your county social services department implemented in direct response to SB 1041 or to related legislation below: ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ If you selected Yes for any of the items in Question 8, please go to Question 9. If not, please proceed to Question 10. 212 9. In Question 8, you answered Yes to organizational or administrative changes your county social services department implemented in direct response to SB 1041 or to related legislation. Please elaborate on the changes you made: ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ 10. Did your county social services department make any of the following changes to staffing in order to accommodate the implementation of SB 1041 or related legislation (e.g., to revise or calculate the WTW 24-month time clock, to support the reengagement process, to implement the Family Stabilization or Expanded Subsidized Employment programs)? (Mark one circle on each line.) Yes No Don't know a) Hired new eligibility staff \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Hired new WTW caseworkers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Hired new administrative staff \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Reassigned existing administrative or line staff, or redefined existing staff's roles \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Created new staff position(s) or function(s) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) Filled existing staff vacancies \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Other \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 If you selected Other, please go to Question 10a. If not, please proceed to Question 11. 10a. In Question 10, you selected Other. Please briefly describe the other changes to staffing made in order to accommodate the implementation of SB 1041 or related legislation below: ______________________________________________________________________________ ______________________________________________________________________________ 11. If you answered Yes to any of the items in the question above (question 10), please elaborate on the changes you made: ______________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ 213 12. Did your county social services department set up an internal tracking system (manual or electronic) or database(s) to help monitor implementation of SB 1041 reforms (e.g., the robust conversation completion, the reengagement process)? r\uf072 Yes \u00e8\uf0e8\u00e8\uf0e8 Go to Question 13 r\uf072 No \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 14 Don't know \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 14 13. If you answered Yes, briefly describe what kind of system or database(s) your department has implemented. ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ ______________________________________________________________________________________________________________________ You have reached the end of Section III: Organizational and Administrative Changes. Please continue to the next section. To return to a page in this section, please click Back.\" To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit.\" 214 IV. Questions for Supervisors About Line Staff and CalWORKs Participants Below are questions about SB 1041 that would be best answered by line staff supervisors. 14. How did your department communicate SB 1041 changes to the CalWORKs Program (e.g., to the WTW 24-hour time clock, WTW activity options, Cal-Learn, reengagement process) to your staff? (Please mark all that apply.) r\uf072 Memoranda and other written documents r\uf072 Briefings and\/or internal staff meetings r\uf072 Mandatory training sessions r\uf072 Other If you selected Other, please go to Question 14a. If not, please proceed to Question 15. 14a. Please briefly describe Other from Question 14. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 15. How well do you think your WTW Caseworkers understand the following changes SB 1041 and related mandates brought about to the CalWORKs Program? (Mark one circle on each line.) Not at all well Slightly well Moderately well Very well Not applicable a) Determination of a client's 24-month time clock \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Changes to the required hours of participation due to the SB 1041 reforms \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Changes to the determination of hourly program participation due to the new averaging method \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Enhanced educational flexibility \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) That there are now more choices in WTW activities (e.g., activities can include work, education, training, and mental health, substance abuse, and\/or domestic abuse services) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) New one-time young child exemption \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Reengagement process for clients who previously had the short-term young child exemption (AB X4 4) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Expanded subsidized employment (ESE) program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 i) Family Stabilization (FS) Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 215 15a. Are WTW Caseworkers and Eligibility Staff the same staff in your county? Yes \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 17 No \u00e8\uf0e8\u00e8\uf0e8 Go to Question 16 16. How well do you think your Eligibility staff understand the following changes SB 1041 and related mandates brought about to the CalWORKs Program? (Mark one circle on each line.) Not at all well Slightly well Moderately well Very well Not applicable a) Determination of a client's 24-month time clock \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Changes to the required hours of participation due to SB 1041 reforms \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Changes to the determination of hourly program participation due to the new averaging method \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) New one-time young child exemption \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 17. How well do you think CalWORKs participants understand the following program changes brought about by SB 1041? (Mark one circle on each line.) Not at all well Slightly well Moderately well Very well Not applicable a) The WTW 24-month time clock \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) The new WTW participation requirements \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) The increase of choices for participants with respect to the activities that they can participate in during the WTW 24-month time clock period \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) The reengagement process for those who had the short-term young child exemption (AB X4 4) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) The new one-time young child exemption \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 216 The following questions are about implementation of the 24-month time clock and Stage One child care services. 18. In your county, who is responsible for calculating how much time a CalWORKs participant has left on the 24-month time clock? (Please mark all that apply.) r\uf072 A special group of staff was tasked with the initial calculation of participants' 24-month time clock status. r\uf072 A special group of staff has ongoing responsibility for calculating participants' 24-month time clock status on a monthly basis. r\uf072 Supervisors of case worker staff calculate or reconcile participants' 24- month time clock status on a monthly basis. r\uf072 WTW caseworkers calculate participants' 24-month time clock on a monthly basis for their caseload. r\uf072 Other If you selected Other, please go to Question 18a. If not, please proceed to Question 19. 18a. Please briefly describe Other from Question 18. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 19. How is the 24-month time clock currently being calculated in your county? (Please mark one answer.) r\uf072 On a manual basis r\uf072 On an automated basis r\uf072 Both manually and using an automated system 20. In your county, how did you inform clients of their eligibility for Stage One Child Care services? ______________________________________________________________________________ ______________________________________________________________________________ You have reached the end of Section IV. Questions for Supervisors About Line Staff and CalWORKs Participants. Please continue to the next section. To return to a page in this section, please click Back.\" To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit.\" 217 V. Provision of Services to CalWORKs Participants in Your County Some services are directly provided by your county's social services department, by service providers contracted by your county, or by other county agencies or service providers to whom you refer CalWORKs participants as needed. We are interested in learning how the following activities and services listed below are provided to CalWORKs participants in your county. 21a. Please indicate how your department currently undertakes or provides the following Employment and\/or job-training to CalWORKs participants in your county. (Please mark all that apply.) Directly by County Social Services Department By local service providers contracted by the County Social Services Department By referrals to other county agencies By referrals to local service providers Don't know a) Assistance with finding unsubsidized employment r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Assistance with finding subsidized employment (public or private sector) r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) Assistance with placement in on-the-job training r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) Assistance with finding volunteer or community service opportunities r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 e) Assistance with job search and job readiness r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 f) Other activities necessary to assist with employment placement or readiness r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 If you selected Other, please go to Question 21a.f. below. If not, please proceed to Question 21b. 218 21a.f. In Question 21a, you selected Other. Please specify or elaborate on the other activities your department currently undertakes or provides for employment and\/or job-training to CalWORKs participants in your county. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 21b. Please indicate how your department currently undertakes or provides the following Educational and\/or Vocational Education\/Training to CalWORKs participants in your county. (Please mark all that apply.) Directly by County Social Services Dept. By local service providers contracted by the County Social Services Dept. By referrals to other county agencies By referrals to local service providers Don't know a) Vocational education\/training r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Adult basic education r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) GED r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) College or postsecondary education r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 21c. Please indicate how your department currently undertakes or provides the following Supportive Services to CalWORKs participants in your county. (Please mark all that apply.) Directly by County Social Services Department By local service providers contracted by the County Social Services Department By referrals to other county agencies By referrals to local service providers Don't know a) Child care r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Transportation (e.g., assistance with bus ticket, car repair, ride share arrangement) r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) Mental health r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) Substance abuse r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 e) Domestic violence r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 f) Language translation r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 g) Legal aid r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 h) Housing assistance r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 i) Other supportive services r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 219 If you selected Other, please go to Question 21c.i. below. If not, please proceed to Question 22a. 21c.i. In Question 21c, you selected Other. Please elaborate on how your department currently undertakes or provides other supportive services to CalWORKs participants in your county. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 22a. Successful implementation often depends on adequate capacity in the county to deliver a needed service and on adequate funding to support the demand for a service. Please indicate whether your county is currently having a shortfall of service capacity (e.g., personnel, physical space) and\/or a shortfall in funding for each of the following services for Employment and\/or Job training. CAPACITY SHORTFALL FUNDING SHORTFALL None Current shortfall in some parts of our county Current shortfall throughout our county Don't know None Current shortfall in some parts of our county Current shortfall throughout our county Don't know a) Subsidized employment r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Job skills training r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) Job search\/job readiness r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) On the job training r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 e) Unsubsidized employment r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 f) Community service r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 g) Other employment r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 If you selected Other for capacity shortfall, please go to Question 22a.g1. If you selected Other for funding shortfall, please go to Question 22a.g2. If not, please proceed to Question 22b. 220 22a.g1. In Question 22a, if you selected Other for capacity shortfalls, please elaborate on the capacity shortfalls for employment and\/or job training services. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 22a.g2. In Question 22a, if you selected Other for funding shortfalls, please elaborate on the funding shortfalls for employment and\/or job training services. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 22b. Please indicate whether your county is currently having a shortfall of service capacity (e.g., personnel, physical space) and\/or a shortfall in funding for each of the following services for Educational Services and\/or Vocational Education\/Training. CAPACITY SHORTFALL FUNDING SHORTFALL None Current shortfall in some parts of our county Current shortfall throughout our county Don't know None Current shortfall in some parts of our county Current shortfall throughout our county Don't know a) Vocational education\/training r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Adult basic education r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) GED preparation r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) Community college\/post- secondary education r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 e) Other education r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 If you selected Other for capacity shortfall, please go to Question 22b.e1. If you selected Other for funding shortfall, please go to Question 22b.e2. If not, please proceed to Question 22c. 221 22b.e1. In Question 22b, if you selected Other for capacity shortfalls, please elaborate on the capacity shortfalls for educational services and\/or vocational education\/training services. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 22b.e2. In Question 22b, if you selected Other for funding shortfalls, please elaborate on the funding shortfalls for educational services and\/or vocational education\/training services. _____________________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ 22c. Please indicate whether your county is currently having a shortfall of service capacity (e.g., personnel, physical space) and\/or a shortfall in funding for each of the following services for Supportive Services. CAPACITY SHORTFALL FUNDING SHORTFALL None Current shortfall in some parts of our county Current shortfall throughout our county Don't know None Current shortfall in some parts of our county Current shortfall throughout our county Don't know a) Child care r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 b) Transportation services (e.g., bus, metro-rail) r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 c) Mental health r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 d) Substance abuse r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 e) Domestic violence r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 f) Translation services r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 g) Housing assistance r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 h) Other supportive services r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 r\uf072 If you selected Other for capacity shortfall, please go to Question 22c.h1. 222 If you selected Other for funding shortfall, please go to Question 22c.h2. If not, please proceed to Question 23. 22c.h1. In Question 22c, if you selected Other for capacity shortfalls, please elaborate on the capacity shortfalls for supportive services. _____________________________________________________________________________ _____________________________________________________________________________ 22c.h2. In Question 22c, if you selected Other for funding shortfalls, please elaborate on the funding shortfalls for supportive services. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ You have reached the end of Section V. Provision of Services to CalWORKs Participants in Your County. Please continue to the next section. To return to a page in this section, please click Back.\" To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit.\" VI. Expanded Subsidized Employment and Family Stabilization Programs and the Reengagement Process The next set of questions is about the Expanded Subsidized Employment (ESE) Program and the Family Stabilization (FS) Program\u2014programs established under AB 74 and closely related to SB 1041. 23. Does your county social services department participate in the CalWORKs WTW Expanded Subsidized Employment (ESE) Program? (Please mark one answer.) r\uf072 Yes r\uf072 No, we opted out of the program. \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 26 r\uf072 No, but we are planning to or are in the process of developing a program for our county. \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 26 223 24. Does your county social services department contract out its ESE Program? (Please mark one answer.) r\uf072 Yes r\uf072 No 24a. If yes, please specify the organization to whom your county social services contracts out its ESE Program. _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ 25. What program options does your county social services department offer as part of its ESE Program? (Please mark all that apply.) r\uf072 Paid work experience with county and local government agencies r\uf072 Paid work experience with private for-profit organizations or the business sector r\uf072 Paid work experience with private nonprofit agencies r\uf072 Job club r\uf072 Participants exempt from WTW are offered volunteer opportunities in the ESE Program r\uf072 Other If you selected Other, please go to Question 25a. If not, please proceed to Question 26. 25a. Please briefly describe Other from Question 25. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 26. Has your county social services department developed a Family Stabilization (FS) Program? r\uf072 Yes \u00e8\uf0e8\u00e8\uf0e8 Go to Question 27 r\uf072 No \u00e8\uf0e8\u00e8\uf0e8 Skip to Question 29 224 27. What services do you currently offer as part of your county's Family Stabilization (FS) Program? (Mark one circle on each line.) Yes No Don't know a) Increased level and\/or intensity of case management \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Treatment for family members of CalWORKs participants (if the situation interferes with the participant's ability to participate in WTW activities) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Intensive day treatment, nonmedical outpatient drug free treatment, or residential treatment \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Emergency shelter \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Movement to transitional housing \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) Rehabilitative services \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Substance abuse counseling\/ treatment \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Other \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 If you responded Yes to Other, please go to Question 27a. If not, please proceed to Question 28. 27a. In Question 27, you selected Yes for Other. Please elaborate on the services you currently offer as part of your county's Family Stabilization (FS) Program. _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ 28. Did your county social services department make any of the following changes in staffing specifically to accommodate the FS Program? Yes No a) Our department hired additional caseworkers r\uf072 r\uf072 b) Our department reassigned caseworkers to work with the FS Program r\uf072 r\uf072 c) Our department created a new unit to manage the FS Program r\uf072 r\uf072 d) Other r\uf072 r\uf072 If you responded Yes to Other, please go to Question 28a. Otherwise, please proceed to Question 29. 225 28a. Please briefly describe Other from Question 28. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ The next set of questions is about your county's experiences in reengaging those individuals who had the AB X4 4 short-term young child exemption. 29. Did your county social services department hire additional staff or reassign staff in order to conduct the reengagement process? Yes No Don't know a) Hired additional administrative staff r\uf072 r\uf072 r\uf072 b) Reassigned administrative staff r\uf072 r\uf072 r\uf072 c) Hired additional caseworker staff r\uf072 r\uf072 r\uf072 d) Reassigned caseworker staff r\uf072 r\uf072 r\uf072 e) Other r\uf072 r\uf072 r\uf072 If you selected Yes for Other, please go to Question 29a. If not, please proceed to Question 30. 29a. Please briefly describe Other from Question 29. _____________________________________________________________________________ _____________________________________________________________________________ 30. In your view, which of the following strategies that your county social services department used to reengage exempt individuals were particularly effective? (Please mark all that apply.) Letters sent to the exempt individual Meeting with exempt individuals by phone or in-person Incentives that we offered Other 30a. If you checked incentives that we offered, please describe the incentives you offered to reengage exempt individuals. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 226 30b. If you checked other, please describe other strategies your county social services department used to reengage exempt individuals that were particularly effective. _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ You have reached the end of Section VI. Expanded Subsidized Employment and Family Stabilization Programs and the Reengagement Process. Please continue to the next section. To return to a page in this section, please click Back. To continue to the next section, please click Next. To exit the survey and return at a later time, please click \"Save and Exit,\" then close the page. 227 VII. Outcomes and Expectations This section asks for your feedback on how implementation of SB 1041 has affected various outcomes for CalWORKs participants and how well the SB 1041 reforms are working in your county. 31. In your opinion, to what extent has implementation of SB 1041 affected each of the following outcomes for the CalWORKs Program and for participants in your county? Much worse Somewhat worse About the same Somewhat better Much better Not applicable a) Work participation rates (WPR) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Participation in WTW activities \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Enrollment in education and training programs\/ community colleges \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Length of time CalWORKs participants spend in educational activities \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Persistence of CalWORKs participants in education\/training activities \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) Compliance with CalWORKs Program rules \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Number of participants receiving sanctions \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Participation in CalFresh by participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 i) Earnings of participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 31a. If the implementation of SB 1041 improved outcomes for the CalWORKs Program and for participants in other ways, please describe below: _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 228 32. In your opinion, how well are the following aspects of the SB 1041 reforms to CalWORKs and related mandates working in your county? (Mark one circle on each line.) Not at all well Slightly well Moderately well Very well Not applicable a) Communication of new CalWORKs program rules to CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 b) Matching CalWORKs participants with appropriate WTW activities \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 c) Provision of supportive services (e.g., child care, domestic violence, housing assistance) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 d) Provision of mental health and\/or substance abuse services \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 e) Coordination with community colleges \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 f) Coordination with vocational education providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 g) Coordination with other county agencies to provide supportive services \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 h) Working with nonprofit service providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 i) Working with employers and job training providers \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 j) Reengagement strategy for clients with the short-term, young child exemption (AB X4 4) \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 k) Tracking WTW participation of CalWORKs participants \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 l) Improving information management of the CalWORKs Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 229 Not at all well Slightly well Moderately well Very well Not applicable m) Design and implementation of the Expanded Subsidized Employment (ESE) Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 n) Design and implementation of the Family Stabilization (FS) Program \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 \u00a6\uf0a6 33. Is there anything else you would like to share about your county's efforts to implement SB 1041 reforms to the CalWORKs Program? Think especially of experiences and decisions that could benefit other counties. _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 34. Do you have recommendations for improving SB 1041? _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 35. Are there any aspects of SB 1041 reforms to CalWORKs that you need more information about? r\uf072 Yes r\uf072 No 35a. If Yes, what information do you need about SB 1041 reforms? _____________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ _________________________________________________________________________________________________________ You have reached the end of Section VII. Outcomes and Expectations. Please provide an estimate of how much time it took to complete the entire survey. 230 _______________________ Please continue to the next page. To return to a page in this section, please click Back. To continue to the next page, please click Next. To exit the survey and return at a later time, please click \"Save and Exit,\" then close the page. You have reached the end of the survey. All of your responses have been saved. If you have not completed the survey, but would like to save and exit the survey and return at a later time to complete the survey, please close your browser. To re-open the survey to the beginning, please click here. If you have completed the full survey and are ready to submit your answers, please click Submit Survey below. After submitting your survey, you will not be able to reenter the survey. Thank you for your participation in this survey! Further information on RAND-AIR's Evaluation of SB 1041 Reforms to California's CalWORKs Program is available online at http:\/\/www.rand.org\/labor\/projects\/calworks-reform-evaluation.html. The survey results will be available in the project's annual report, to be released in late 2015. If you need to make changes to your survey, please contact Cheryl Graczewski at [email protected] or 650-843-8238. http:\/\/www.rand.org\/labor\/projects\/calworks-reform-evaluation.html mailto:[email protected] 231 SB 1041 All-County Survey (ACS) Definitions of SB 1041 Reforms In this survey, we will be asking you about SB 1041 policy reforms to the CalWORKs Program that were implemented January 1, 2013. What we mean by SB 1041 reforms is the following: Changes to the Welfare-to-Work (WTW) time clock o 48 months of support: \uf0a7 24 months of CalWORKs WTW services and activities \uf0a7 24 months of Temporary Cash Assistance for Needy Families (TANF) work activities o Time clock initiation \uf0a7 Those starting the program on or after January 1, 2013, will follow the SB 1041 time clock structure. \uf0a7 Those in the program prior to January 1, 2013, with fewer than 24 months accumulated will be subject to the 24-month CalWORKs WTW time clock, followed by the TANF rules until the 48-month lifetime limit is reached. \uf0a7 Those in the program prior to January 1, 2013, with more than 24 months accumulated will be subject to the 24-month CalWORKs WTW time clock until the 48-month lifetime limit is reached. Changes to the weekly core work requirements and weekly total work requirements o Weekly core requirements: \uf0a7 No core requirement during the WTW 24-month time clock \uf0a7 During the period outside the 24-month time clock, 20 hours of the weekly work requirement for single parents and 30 hours of the weekly work requirement for participants in two-parent cases have to be in core activities that include employment, on-the-job training, and vocational educational training. o Total work requirements: \uf0a7 Single parent, child younger than six years old: 20 hours \uf0a7 Single parent, no child younger than six years old: 30 hours \uf0a7 Two parents: 35 hours Change to how hourly participation requirements are determined o In accordance with SB 855 and ACL 14-80, the total work requirements listed above are determined by an average per week during the month, rather than by a weekly minimum. This method takes the total number of hours in eligible activities in the month and divides it by 4.33. The weekly average rounded to the nearest whole number is then compared with the weekly minimum established for each type of assistance unit. o This change was effective as of July 1, 2014. Cal-Learn o Program reinstated as of April 1, 2013 o Pregnant\/parenting teens will no longer be under WTW rules, but under special Cal- Learn rules. Young child exemption o One lifetime exemption: One adult per family is excused from WTW activities if caring for a child less than two years of age. o Adults under the AB X4 4 young child exemption rules are not required to participate until the county reengages them. \uf0a7 The AB X4 4 short-term young child exemption expired on December 31, 2012. AB X4 4 was enacted on July 28, 2009. It included time-limit exemptions and WTW participation exemptions for clients with young children and time-limit exemptions for clients who have been granted good cause for lack of supportive 232 services. SB 1041 replaced these exemptions with a once-in-a-lifetime exemption for young children. \uf0a7 Counties had until January 1, 2015, to reengage these exempt individuals. Earned income deduction o Effective October 1, 2013: revert back to pre-2011 parameters of $225 disregard plus 50 percent of the remaining earned income We also will cover two additional programs, established under AB 74, that are closely related to SB 1041: Expanded Subsidized Employment (ESE) Program: Additional funding for ESE programs for CalWORKs recipients (see ACL 13-81) Family Stabilization (FS) Program: Effective January 1, 2014: intensive case management and services designed to support the family in overcoming the situation or crisis, which may include, but are not limited to, WTW activities (see ACL 14-12) We also cover Stage One child care services. There are three stages of CalWORKs child care. Stage One is defined as follows: Stage One begins with a family's entry into the CalWORKs program. Clients leave Stage One after six months or when their situation is stable, and when there is a slot available in Stage Two or Three. 233 Evaluation of SB 1041 Reforms to California's CalWORKs Program Focal County Key Informant Interview Protocol October 2014 I. Informed Consent I work for RAND, which is a private, nonprofit, public policy research organization. [OR I work for the American Institutes for Research (AIR).] We've been contracted by the California Department of Social Services (CDSS) to conduct an independent evaluation of SB 1041, which is intended to provide a more flexible approach to supporting CalWORKs participants toward self-sufficiency. [If unfamiliar with SB 1041] Senate Bill (SB) 1041 included significant reforms to the CalWORKs program. These reforms, effective as of January 2013, are designed to support participants' engagement with Welfare-to-Work activities early on and provide flexible, meaningful work activity options that can enhance their ability to secure stable, gainful employment. [If more information is needed], in particular this bill established a 24-month time clock with flexibility in welfare-to-work requirements; lowered the minimum hourly participation requirement for single parents; allowed recipients one lifetime exemption whereby one adult per family is excused from WTW activities if they are caring for a child under two years of age; adjusted the Earned Income Deduction from $112 to $225; and reinstated Cal-Learn, a program that provides intensive case management for teen parents who remain in school.] We also will be asking you a few questions about two additional programs, established under AB 74, that are closely related to SB 1041: the Expanded Subsidized Employment Program and the Family Stabilization Program. Today I am hoping to hear about your views on this subject. The interview will take approximately 45-60 minutes. Your confidential input about the development and implementation of SB 1041 is valuable to us. The information you provide will be kept strictly confidential. We will not share your responses with anyone else outside of the research project. And we will not identify any individuals by name in our study reports, although the focal counties will be identified by name in the project's reports. If we use any quotations from these interviews, we will not attribute them to any individual. Although we won't be identifying you by name, it is possible that someone might be able to identify you by the information you give us. So we recommend that you don't tell us anything that you would not be comfortable with other people reading. Your participation in this interview is voluntary. You may choose not to participate, decline to answer any question, or stop the interview at any time. I plan to audio record it, solely for our note taking purposes. The audio recording will only be used by project staff, and we'll destroy it when the project is done. Do I have your permission to proceed with the interview? [IF NO:] Thank you anyway. [IF YES:] Do I also have your permission to audio record the interview? II. Interview Questions 1. Role. Let's start with your role within the county welfare department what is your position and key responsibilities? How long have you served in this role? 2. Key Features. What are the key features of (or key changes to) SB 1041 that are relevant to your position and responsibilities? Probes: 234 o Changes to the WTW time clock o Changes to the weekly work requirements (e.g., education, employment, on-the-job training, vocational training) o Cal-Learn o Reengagement of individuals with the short-term, young child exemption o Provision of supportive services o Family Stabilization Program o Expanded Subsidized Employment Program 3. Status\/Pace of Implementation. In your county, what has been the pace of implementing SB 1041 for example, has it been a slow process or implemented all at once? a. Please begin with an overview of what has changed under SB 1041 and when these changes were implemented. b. Are there any changes associated with SB 1041 that have yet to take effect? 4. Broader policy context. What other major policy changes occurred at the state-level or county-level during this same time period that may have had implications for SB 1041 implementation? a. Did these other policy changes have any effects on the approach adopted for SB 1041 or on the timing of its implementation? b. Did these other policy changes hinder or facilitate SB 1041 implementation at the county-level? 5. Reporting Requirements. What if anything has specifically changed as a result of SB 1041 in terms of reporting requirements for the counties? a. Has your county been able to meet the state's reporting requirements? b. What challenges, if any, has your county encountered in doing so? If there have been challenges, how are they being addressed? 6. Communication from the CDSS to Counties. How did the state communicate the changes brought about by SB 1041 to your county? In addition to the All County Letters (ACLs) that were sent out to county welfare directors, were there other ways in which CDSS communicated implementation information to the counties (e.g. webinars, meetings)? a. Was this communication adequate? In other words, did your office understand what was expected of them in regard to SB 1041? 7. Technical Assistance. What types of technical assistance (TA) and guidance were provided by the state (CDSS) to counties? a. Were there other sources of support for TA or sources of training? (e.g., the Child Welfare Directors Association, other organizations?) b. Was there collaboration\/coordination across counties (e.g., those in the same consortium) with respect to TA and training? c. Are there unmet TA needs in your county? 8. Communication from County Leadership to County Welfare Department Staff. How did your county communicate SB 1041 changes to the staff? 235 a. From your perspective, to what extent do you think county staff understand the SB 1041 changes? Do county staff struggle with understanding any particular aspect of SB 1041? 9. Communication to CalWORKs Participants. From your perspective, do CalWORKs participants understand the changes brought about by SB 1041? a. How did county staff communicate this information to CalWORKs participants? b. How was communication handled with participants in various categories (e.g., based on clock, ongoing vs. new CalWORKs participants, etc.)? c. Were additional\/different methods used to communicate how the program works before\/after SB1041 was enacted? In other words, what changed, if anything, as a result of SB 1041in regard to communication? d. It is our understanding that not all elements of the legislation were enacted at the same time. In what ways was this handled with respect to informing CalWORKs participants of the program's expectations and benefits? 10. State Monitoring. What types of monitoring activities of the counties is being undertaken by CDSS? By other organizations? a. Do you receive feedback from these monitoring activities? Has it been useful in regard to your quality improvement activities? 11. Impact on County Welfare Department. Reflecting broadly, in what ways has SB 1041 affected your organization? Did your county change the way you do business in order to implement SB 1041? What impact has it had on your staff? a. Has there been changes in regard to staffing levels? b. Did your office reorganize your staffing? For example, did you create cross- functional units or new staff positions, or redefine staff roles? c. Have there been changes in reporting relationships? d. What has been the impact of these changes, if any? e. How has SB 1041 affected your organization's relationships with other departments or agencies at the state-level? How about relationships at the county-level? f. In what ways did SB 1041 influence the resources and\/or budgeting within the county, within your welfare department, within your unit\/program? i. What was the impact of budget changes on recipients? ii. What was the impact of budget changes on caseworkers? 12. Impact on CalWORKs Participants. From your perspective, what is the impact of SB 1041 on participants? 13. Implementation Successes. In your county, what has worked well with SB 1041? 14. Implementation Challenges. What have been the implementation challenges associated with SB 1041 in your county, if any? a. What strategies have been effective, if any, in overcoming these challenges? 15. Coordination among Programs and Systems. From the county's perspective, how effective is coordination among county welfare programs and other systems, in providing 236 services to CalWORKs applicants and to current and former participants? These other systems may include school districts, mental health programs, transportation providers, child care providers, community colleges, community-based organizations, the private sector, alcohol and drug programs, local planning councils, and other organizations. a. What is needed to improve coordination, if anything? b. Beyond coordination, what is needed to improve collaboration with various systems? 16. Data Systems. How well do state and county data systems support the needs of the county in implementing SB 1041? a. Has any new data collection related to SB 1041 created a workload burden for your county? b. Does your county need any additional data, to support the implementation of SB 1041? 17. Referral Process: Could you please describe the referral process in your county for welfare to work participants who require supplemental services such as child care, transportation, mental health or substance abuse, education, domestic violence services? a. To what extent do you feel the referral process is working effectively in your county? Why do you feel the process is effective (or not)? b. Are there services for which you don't feel you have good partnerships or linkages to services available within your county? 18. Supportive Services: To what extent to you feel your county is able to provide the needed child care and transportation services to welfare to work participants? The needed domestic violence, substance abuse, or mental health services? a. Are more CalWORKs participants using child care services now as part of the welfare to work program? b. Are there barriers in your county to child care usage for welfare to work participants (e.g. not enough providers, location of providers)? c. Are there barriers in your county to usage of transportation services for welfare to work participants? d. Are there barriers in your county to usage of domestic violence, substance abuse, or mental health services by welfare to work participants? 19. Education and Vocational Training Services: To what extent to you feel your county is able to provide the needed education and vocational training programs to welfare to work participants? a. Are more CalWORKs participants participating in educational programs now as part of the welfare to work program? b. Are more CalWORKs participants participating in vocational training programs now as part of the welfare to work program? c. In your view what effect, if any, did SB 1041 reforms have in changing access to education and vocational training programs to CalWORKs participants? 237 20. Expanded Subsidized Employment (ESE) Program. In looking at the CDSS website (http:\/\/www.cdss.ca.gov\/calworks\/PG3412.htm), it looks like your county [does\/does not] participate in the WTW Expanded Subsidized Employment program. a. What program options does your county offer? b. To what extent do you feel the program is working effectively in your county? Why? c. Was funding from SB 1041 used to expand the your county's Expanded Employment Subsidized Program? If so, in what ways? 21. Family Stabilization (FS) Program: Has your county developed a family stabilization plan? a. If so, please describe the kinds of services your county offers and whether these services are contracted out. b. Was funding from SB 1041 used to expand or fund your county's Family Stabilization Program? c. To what extent do you feel the program is working effectively in your county? Why? (One outcome may be more individuals receiving services rather than being exempt.) 22. Reengagement of customers with the short-term, young child exemption: Could you please describe the process (outreach) your county went through to reengage these exempt individuals? a. Did your county have to hire or reassign staff in order to conduct the reengagement process? b. To what extent to you feel the reengagement process has been successful? Why? 23. Next Steps. What does your county see as being the next steps with respect to SB1041 implementation? a. Are there improvements to the CalWORKs program that you would recommend? 24. Challenges. What challenges does your county see going forward in implementing the SB 1041 reforms and what steps may be needed to address them? 25. Other. Is there anything else you'd like to share with me today in regard to SB 1041 reforms to the CalWORKs Program? Additional question by respondent type: Budget Director 1. Did counties have adequate staff and funding to support SB 1041 changes? 2. How did the counties change the way they do business to implement SB 1041 ? 3. What challenges did counties have regarding budget changes? 4. What services were supplemented or expanded using Family Stabilization Program, Expanded Subsidized Employment, and\/or Other Supportive Services funding? http:\/\/www.cdss.ca.gov\/calworks\/PG3412.htm 238 5. What services were supplemented or expanded using AB 118 redirected funds? 6. What services were supplemented or expanded using AB 85 redirected funds? 7. To your knowledge, what was the impact [influence] of budget changes on recipients? 8. To your knowledge, what was the impact [influence] of budget changes on caseworkers? 9. How did the state communicate budget changes to counties? 10. How did county leadership communicate budget changes within county? 11. What is the effect [association], if any, of SB 1041 on provision of WTW activities, including timing of WTW plans and use of assessments? Within Welfare Department, Director of CalFresh 1. To what extent, if any, has the implementation of SB1041 in your county affected the CalFresh program? Other county agencies 1. To what extent, if any, has the implementation of SB 1041 in your county affected the services your agency provides to CalWORKs (welfare to work) participants?) Service providers 1. To what extent, if any, has the implementation of SB 1041 in your county affected the services your agency provides to CalWORKs (welfare to work) participants?) Community colleges 1. With passage of SB 1041, Cal-Learn was reinstated after being suspended from July 2011 to July 2012. To what extent do you feel the program is meeting its stated goal of encouraging pregnant and parenting teens to graduate from high school or its equivalent and become self-sufficient? 239 Evaluation of SB 1041 Reforms to California's CalWORKs Program Protocol for Focal County Caseworkers Focus Groups May 2015 Welcome I want to thank you for coming today. My name is _____________ and I will leading today's group discussion. I am a researcher from the RAND Corporation, a private, not for profit research organization based in Santa Monica, CA. We also have ______________ present to take notes for us. [My colleague(s) __________ are also sitting in on today's discussion and may have a few questions for you later on.] The RAND Corporation, in partnership with the American Institutes for Research (AIR), was awarded a contract by the California Department of Social Services (CDSS) to conduct an independent evaluation of the recent reforms to CalWORKs Program. Information collected as part of this project will help CDSS improve the quality of the services that the CalWORKs Program provides. We are conducting focus groups with county caseworkers in different counties to learn about how SB1041 has affected your job and responsibilities; the type of support you need to handle the changes brought about by SB 1041; how changes mandated by SB 1041 were communicated to caseworkers; the type of training you received related to these changes; how you communicated the changes mandated by SB 1041 to aid participants; how well aid participants understood the changes to the CalWORKs program and in particular the WTW requirements; and what the impact of these changes has been on aid participants. The information you share with us today will help inform our understanding of the planning, implementation, and impact of SB 1041 reforms. Does anybody have any questions? Ground Rules Before we begin, I would like to review a few ground rules for the discussion. A. I am going to ask you several questions and I'd like to give everyone a chance to give their opinions. We do not have to go in any particular order but we do want everyone to take part in the discussion. We ask that only one person speak at a time. B. We're interested in your opinions and whatever you have to say is fine with us. There are no right or wrong answers. We are just asking for your opinions based on your own personal experience. We are here to learn from you. C. Don't worry about having a different opinion than someone else, but please do respect each other's answers or opinions. D. If there is a particular question you don't want to answer, you don't have to. E. Feel free to treat this as a discussion and to ask questions of each other and to respond to what others are saying, whether you agree or disagree. F. As I already mentioned we will treat your answers as confidential. We are not going to ask you any information that could identify you and we are only going to use first names or 240 nicknames during the discussion. We also ask that each of you respect the privacy of everyone in the room and not share or repeat what is said here in any way that could identify anyone in this room. G. While RAND will treat your answers as confidential, we cannot guarantee that everyone else in the room will do the same. Therefore, we recommend that you not share information as part of the group discussion that you would not want disclosed outside of this discussion. Ice Breaker Please tell us your first name or nickname only and how long you have been working as a caseworker in [COUNTY NAME's] Welfare Office. Focus Group Discussion Questions 1. Understanding. What is your understanding of SB 1041 changes to the CalWORKs program? a. What specifically changed about the program? b. Welfare to Work Time Clock. What has changed in regard to the time clock? i. What is your understanding of what the 24 month time clock meant for participants? ii. When SB 1041 was implemented, did your county have to calculate the 24 monthly time clock for all WTW participants? If so, who did this? When was it done? Did it require staff overtime to do so? c. What has changed in regard to helping clients enter and remain in the workforce? d. CalFRESH. What has changed in regard to the CalFresh program? e. Earned Income Disregard. What has changed in regard to the earned income disregard? f. Young Child Exemption and Reengagement. What has changed in regard to the young child exemption and reduced hourly work requirements that allow clients to spend more time with their child? i. What was your role in reengaging individuals when this exemption expired? 2. Training and Communication to Caseworkers. What types of training and guidance about SB1041 were provided by the state, county, and county welfare supervisors to caseworkers? a. With respect to the changes that SB 1041 represented, how was this information communicated to you? i. E.g., changes to the core\/noncore, greater flexibility in options for participants, the change to the 24 month time clock, expiration of the young child exemption b. With respect to calculating the 24 month time clock: i. How did you initially learn about the time clock changes? ii. What kind of training did you receive on calculating the 24-month time clock? iii. Was formal training provided by staff development, or training staff, and\/or supervisors? 241 iv. The policy guidance from CDSS evolved overtime on calculating the 24- month time clock. 1. From your perspective, how did that guidance change over time? (e.g., instead of counting total hours per month, use average number of hours)? 2. How did you learn about the guidance changes over time? v. Did you have to go back and re-calculate the 24 month time clock for their WTW caseload? c. Were there other changes to policy guidance related to SB 1041 (e.g., eligibility for young child exemption and reengagement process)? i. How were these other changes communicated to you? ii. Did you receive training on them? d. Do you feel you were given adequate guidance or training on the different changes SB 1041 represented? Why or why not? e. If you had or still have questions about the changes brought about by SB 1041, what did you do? 3. Reporting. What has changed in regard to client reporting requirements? 4. Responsibilities. How has SB 1041 affected your job and responsibilities? a. How has SB 1041 in general affected your caseload? b. What organizational changes or redefining of staff roles have occurred, if any? c. 24 month time clock specifically: i. Who is responsible for calculating the 24-month time clock in your county? (e.g., supervisors, caseworkers?) ii. Who is responsible for updating the 24 month time clocks? Is it done on a monthly basis? Automated or manual? iii. What impact, if any, has the increased flexibility of activities for participants have on work force participation (WPR) rates? 1. On your role as a case manager? 2. On your ability to counsel customers on the options available to them? 3. On your ability to assess barriers customers face? 4. On participants' ability to achieve self-sufficiency? d. How has the Expanded Subsidized Employment program impacted your work with the participants? i. Do you make referrals to the program? ii. What are the barriers and\/or facilitators to working with this program? e. How has the Family Stabilization program impacted your work with the participants? i. How do participants get referred to the program? Do you make referrals? ii. What are the barriers and\/or facilitators to working with this program? f. Do you have the resources and support you need in order to deal with the different changes brought about by SB 1041? Why or why not? 5. Communication to Aid Participants. This question is about how CalWORKs information is communicated to aid participants. 242 a. How were the SB 1041 changes to the CalWORKs program communicated to aid participants? b. How did you communicate the changes to the time clock to aid participants? i. In your opinion, what was the understanding of aid participant of what the 24 month time clock meant for them? (e.g., complete flexibility in activities for 24 months) c. For clients who have been on CalWORKs before SB 1041 and are still active do you think this group understands the changes brought about by SB 1041? d. What elements of SB 1041 do participants understand well? e. What elements tend to be confusing to them? 6. Implementation Successes. In your county, from your perspective as a WTW caseworker what has worked well with SB 1041, if anything? a. Probe about the specific components of SB 1041 7. Implementation Challenges. What are the challenges associated with SB 1041, if any? What strategies have been effective, if any, in overcoming these challenges? a. Probe about the specific components of SB 1041 b. Probe about flexibility in activities participants can choose from 8. Impact on Aid Participants. We've talked about the impact of various components of SB 1041 broadly speaking, what do you think has been the impact of SB 1041 on participants, if any? (If no impact why not?) a. What do you think it means to the participants to have greater flexibility in options (i.e., how do they interpret this change)? b. What effect do you think the greater flexibility in options will have on participants achieving self-sufficiency? c. What effect do you think the 24 month time clock will have on participants achieving self-sufficiency? 9. Client Needs. From your perspective what are the CalWORKs participants' most significant support needs? 10. Client Self-Sufficiency. What do you think participants need in order to ensure they successfully achieve self-sufficiency as quickly as possible? 11. County Needs. What do you need to help you do your job better? 12. Advice to the State. Do you have any advice to the state, in regard to helping counties implement SB 1041? 13. Other. Is there anything else you'd like to share? Thank you for coming today and for sharing your opinions with us. We hope you enjoyed the discussion today. 243 Evaluation of SB 1041 Reforms to California's CalWORKs Program Protocol for Focal County CalWORKs Participant Focus Groups May 2015 Ground Rules Before we begin, I would like to review a few ground rules for the discussion. A. I am going to ask you several questions and I'd like to give everyone a chance to give their opinions. We do not have to go in any particular order but we do want everyone to take part in the discussion. We ask that only one person speak at a time. B. We're interested in your opinions and whatever you have to say is fine with us. There are no right or wrong answers. We are just asking for your opinions based on your own personal experience. We are here to learn from you. C. Don't worry about having a different opinion than someone else, but please do respect each other's answers or opinions. D. If there is a particular question you don't want to answer, you don't have to. E. Feel free to treat this as a discussion and to ask questions of each other and to respond to what others are saying, whether you agree or disagree. F. As I already mentioned we will treat your answers as confidential. We are not going to ask you any information that could identify you and we are only going to use first names or nicknames during the discussion. We also ask that each of you respect the privacy of everyone in the room and not share or repeat what is said here in any way that could identify anyone in this room. G. While RAND will treat your answers as confidential, we cannot guarantee that everyone else in the room will do the same. Therefore, we recommend that you not share information as part of the group discussion that you would not want disclosed outside of this discussion. Ice Breaker I'd like to go around the table and have each of you tell us your first name or nickname only and tell us how long you have been enrolled in the CalWORKs Program. Topic 1: Participation in the CalWORKs Program. 1. What benefits or services are you currently receiving under the CalWORKs Program? a. How did you find out about the services and programs you have access to (e.g., caseworkers, family, friends, read about them) b. Do you feel like you have a good understanding of the benefits and services you are eligible for under the CalWORKs program? 244 i. If you have questions or concerns regarding the benefits and services you are receiving under the program, what do you do? 1. Where do you go for information on the program or for information about the services or benefits for which you are eligible? 2. Is there someone you can talk to about this? Whom? c. What parts of the program are easy to understand and what parts of the program are confusing or not clear? d. How has the CalWORKs Program helped you and your family? i. What programs or services have been most helpful? Least helpful? e. Do you feel like the assistance you receive from the CalWORKs Program is helping you move forward in your life or helping you live like you want to live? Why or why not? Topic 2: Changes to the CalWORKs Program. As some of you may be aware, effective January 2013, changes were made to the CalWORKs program that affected the benefits and services that program participants such as yourselves could receive under the program. For example, the 24-month time clock was implemented, participants\/clients have more flexibility in choosing the activities they might want to pursue to help them achieve self- sufficiency, there are fewer participation hours for single-adult families, changes were made to the weekly core requirements, and the short-term, young child exemption was eliminated. By self-sufficient we mean that you no longer need aid, no longer need public assistance, are able to find a job that pays for your living expenses. 1. Were you aware of any of these changes to the program? 2. IF YES: a. Were there any changes to the number of hours you had to work? b. Were there any changes to the amount of time during which you could receive assistance from the CalWORKs Program? c. Were there any changes to your income tax benefits (e.g., earned income credit) d. Were there any changes to the cash payments you received from the program? e. Were there any changes to the benefits you received under the CalFRESH\/SNAPs\/Food Stamps program? f. Were there any other changes made to the program since January 2013 that you're aware of? If so, what were those changes? 3. WTW 24-month time clock a. Has your caseworker explained to you what your 24-month time clock is? b. Has your caseworker talked with you about how much time you have left on your 24-month time clock? c. Do you know when your 24-month time clock will end? i. If so, what does it mean for you? (in terms of the types of activities you will be able to participate in under the federal TANF rules?) 245 d. Have you received an exemption? (for example, a one-time young child exemption) 4. Activities: a. Has your caseworker had a conversation with you about the types of activities you can participate in during the first 24-months of the CalWORKs Program? b. What is your understanding of what those activities are? c. Are you aware that education is one of the options for your activities? i. Did your caseworker talk to you about your educational options? ii. For those participating in education classes: What type of education classes are you taking? At what location? Are you working towards a GED or AA degree? Do you feel that your education classes are helping you to become self-sufficient? iii. For those not participating in education classes: What factors were important in your decision not to participate in education classes? d. Of the range of activities you could participate in which were most important to you? Probes: i. Job club ii. Job search iii. Job skills training iv. Educational programs v. Vocational training e. Of the range of services available to you which were most important to help you participate in the above activities (or help you find a job)? Probes: i. Transportation ii. Child care iii. Housing iv. Mental health services v. Alcohol\/drug treatment vi. Domestic violence services f. Do you feel that you are able to access the services that you need? i. If not: why? g. Has your caseworker worked with you to develop a WTW plan? Topic 3: Communication to CalWORKs Participants. 1. How did you find out about the changes to the CalWORKs program that we just discussed? a. Probes: the 24-month time clock, increased flexibility in types of activities you can participate in, etc. b. Probes: i. Did you receive a letter from the California Department of Social Services? 246 ii. Did your caseworker talk to you about these changes and what they meant for you? iii. Did you hear about them from other program participants or from other service providers (e.g., the community colleges)? 2. At the time you heard about the changes to the program, did you have a clear understanding of how these changes would affect you? a. IF YES: How did you think the changes would affect you and the activity(ies) you could participate in during the first 24-months of the CalWORKs Program? b. IF NO: What questions or concerns did you have? 3. Do you now feel like you have a clear understanding of how the program works and the benefits or services to which you and your family are eligible? a. If not: What are your concerns or what areas are you uncertain about? 4. How easy or difficult is it to get information or help from CalWORKs program staff? 5. Do you feel like CalWORKs caseworkers understand what you need and the challenges that you face in your day-to-day life? Why or why not? Topic 4: Impact on CalWORKs Participants. 1. Do you feel that you have more flexibility in selecting the activities you can participate in? a. If yes: What do you see as the benefits? 2. Have you or anyone else in your family experienced any problems as a result of the changes to the CalWORKs Program? 3. What changes have you or your family made to your work, childcare, or living situation (e.g., where you live, if your children are living with you, etc.) since the changes to the CalWORKs Program went into effect in January 2013? 4. How have the changes to the program affected your ability to work? a. Has the program helped you to find a job? b. Has these changes helped you to become more self-sufficient? 5. How have the changes to the program affected your ability to continue your education? a. Has the program helped you to continue your education? 6. How have the changes to the program affected your ability to find and pay for childcare? a. Has the program helped you find childcare? 7. And now for the last question, what suggestions or recommendations do you have for improving the CalWORKs Program so that it can better serve you and others like you? Thank you for coming today and for sharing your opinions with us. We hope you enjoyed the discussion today. I'm going to be handing out the payments. As you get them, please check to make sure that the money is in the envelope. HAND OUT PAYMENTS AND ASK PARTICIPANTS TO SIGN THE PAYMENT RECEIPT FORM. 247 Appendix C. Additional Documentation for Administrative Data Documentation in this appendix includes data sources that informed the initial status study, tracking study, and impact study based on administrative data. We describe the administrative data sources, study population derivation, data preparation, and methods used to ensure data integrity. We also describe additional data sources that we anticipate using for analysis in future reports. Data Sources To address the research questions in this report, we used data from several large statewide administrative data systems, namely WDTIP, MEDS, and EDD. Welfare Data Tracking Implementation Project WDTIP, from the Office of Systems and Integrations, is a statewide welfare time-on-aid tracking and reporting system that provides counties with up-to-date information on TANF and CalWORK's applicants and participants. We used these data to identify our WTW study population and to track time on the 24-month and 48-month time-on-aid clocks. CDSS provided extracts of these files as separate data files for monthly CalWORKs WTW program participation, exceptions (i.e., monthly program exceptions from the various CalWORKs WTW and TANF time limits), summary information for TANF and CalWORKs WTW time clocks, and detailed monthly 24-month and 48-month time-on-aid clock information. These data use Client Identification Numbers (CIN) to identify participants and we used this number to link to a cross- walk and other data sources. These data are available from 1998 to the present, and we will continue to receive semiannual updates until April 2017. Medi-Cal Eligibility Data System California's Department of Health Care Services MEDS is a statewide data system used to store such client information as Medi-Cal eligibility and demographics. It uses Social Security numbers to identify individuals. The MEDS data provide monthly information related to Medi- Cal eligibility and eligibility for other state programs, such as the CalWORKs WTW program. The data extracts we used include all individuals in the state from 1998 to the present. CDSS receives quarterly updates from the California Department of Health Care Services and provides us with processed extract files semiannually. The extracts are in two forms: annual monthly extract files and the CDSS-created Longitudinal Database, a single longitudinal file containing all individuals participating in the CalWORKs WTW program from 1998 to the present. We used these data to provide demographic information for our target population, as well as program 248 participation and case type information for those individuals and cases not included in the WDTIP data. Employment Development Division California's EDD provides CDSS with an extract of data containing the wage and employer identification information for all Californians. The employer ID number cannot be attributed to specific employers. These data contain one record per Social Security number per employer identification number per quarter. For the current report, CDSS provided records for all CalWORKs WTW participants starting two years before their enrollment in the CalWORKs WTW program and following them for up to five years after they exit the program. CDSS Cross-Walk To aggregate administrative records for CalWORKs WTW participants, we linked individuals' CINs and Social Security numbers. CDSS maintains a file, updated quarterly, with these linkages for each individual for whom they have an Social Security number. We used this file, which we refer to as the CDSS Crosswalk, to link WDTIP's CIN identifiers with the Social Security number identifiers found in the EDD and MEDS data. For data security reasons, actual Social Security numbers, CINs, and other potentially sensitive identifiers were replaced throughout with randomized pseudo-identifiers. When we refer to linking files by Social Security numbers or CINs, it should be understood that we're working with pseudoidentifiers, not the actual identifiers themselves. While it did not present a substantial challenge to data preparation procedures, it is worth noting that before reducing to our study population, we found 854 CINs in the cross-walk (out of more than 18 million), which had more than one associated Social Security number. Deriving Population and Groups for Status, Tracking, and Impact Studies The study population is composed of all CalWORKs WTW-aided WTW participants, adult and minor parents and guardians who are exempt from WTW activities, and sanctioned participants who do not receive aid.69 The WDTIP program participation file and exception file served as the sources for our population frames for aided and sanctioned participants, respectively.70 Although 69 Unaided sanctioned participants include those sanctioned due to WTW noncompliance; being a fleeing felon; violating a condition of probation or parole; being convicted of a felony for the possession, use, or distribution of a controlled substance; being a custodial parent or caretaker relative who refuses to assign child support rights. We identified these sanctioned participants in the exception file as having exception reason codes 200, 201, 202, 203, 204, or 205, and no record in the program participation file within the same month. 70 At the recommendation of CDSS, we classified participants who were present in both the WDTIP program participation file and the WDTIP exception file with an unaided sanction during the same month as aided, nonsanctioned participants because the inclusion of the participant in the WDTIP program participation file is an indication that the participant received aid. 249 WDTIP primarily tracks CalWORKs WTW and TANF participants' time on aid, the system also includes a margin of error of children and participants in other social service programs. Therefore, we limited WDTIP records to participants with the CalWORKs Program Participation Type indicator and adults and children who are also minor parents. We also limited WDTIP records from 1998 (when TANF was first implemented) to the present.71 We consistently defined our CalWORKs WTW participation sample as described above, regardless of CalWORKs WTW policy changes. For example, before the passage of AB 1468 in April 2015, drug felons were identified as unaided and sanctioned. With the policy change, they should be classified as aided and WTW-eligible. However, some individuals appear in the data after April 2015 with codes identifying them as sanctioned drug felons, and we processed their records as such regardless of the policy change suggesting that they be classified differently. For analysis, the study population is divided into cross-sections or cohorts in order to compare participants at different points in time and address the research questions specific to the status, tracking, and impact studies. The groups and cohorts are summarized in Table C.1. Status study cross-sections are composed of CalWORKs WTW participants in March of a given year. Three status study cross-sections have been created: March 2013, March 2014, and March 2015. Each status study cross-section is also composed of two groups, based on participation prior to the start of SB 1041 in January 2013. Participants were placed into the transitional group if they started in the CalWORKs WTW program for the first time before January 2013 and continued in the CalWORKs WTW program after the policy change. Participants were placed in the post SB 1041 group if they started in the CalWORKs WTW program for the first time in January 2013 or later. We measured first-time participation by identifying the month and year that participants first appeared in the WDTIP program participation or exception files as of January 1998. For example, status study cross-section 1, transitional group is defined as individuals who were participants during March 2013 and first started in the CalWORKs WTW program between January 1998 and December 2012. Status study cross-section 1, post SB 1041 group is defined as individuals who were participants during March 2013 and first started in the CalWORKs WTW program in January, February, or March 2013. Tracking study cohorts are composed of first-time CalWORKs WTW participants in March of a given year. Four tracking study cohorts have been created: 2007, 2009, 2011, and 2013. For example, tracked entry cohort 2007 is defined as individuals who were participants in March 2007, and had not been participants any time between January 1998 and February 2007. 71 We categorized participation according to the start month and year at the recommendation of CDSS. Monthly participation records are automatically generated into the data system each month, with a start date of the first day the month and an end date of the last day of the month. However, CalWORKs eligibility workers may edit these dates and may not reflect actual participation. Furthermore, In rare instances when participants had multiple participation records or sanction records in a given month with conflicting CalWORKs Assistance Units, counties, and\/or aid codes, we retained the record that was last entered into the data source. 250 Table C.1. Summary of CalWORKs WTW Administrative Data Cohorts and Participant Groups Examined for Status, Tracking, and Impact Studies Criteria Status Study Tracking Study Impact Study Years covered 2013, 2014, 2015 2007, 2009, 2011, 2013a 2010, 2011, 2012, 2013, 2014 Months\/quarters March March Quarterly Number of cross- sections or cohorts 3 cross-sections 4 cohorts 20 cohorts Participation status All participants New, first-time participants New, first-time participants Participant groups Transitional: Participant prior to and after SB 1041 Post SB: Participant after SB 1041 only Not applicable Not applicable a We examined participants across all years between 2006 and 2015 and found minimal difference across the years. In Chapter Six and in Appendix D, we present findings for 2007, 2009, 2011, and 2013. Impact study cohorts are composed of first-time CalWORKs WTW participants in a given quarter. Impact study cohorts were created for each quarter between 2010 and 2014, for a total of 20 cohorts. For example, impact study cohort 1 is defined as individuals who were participants in the first quarter of 2010 (January, February, or March 2010) and had not been participants any time between January 1998 and December 2009. Impact study cohort 20 is defined as individuals who were participants in the fourth quarter of 2014 (October, November, or December 2014) and had not been participants any time between January 1998 and September 2014. Approach for Data Preparation As described above, we used multiple data sources to create our analysis data sets. Our goal for these data sets was to prepare files with valid data across each source and time frame. We consulted CDSS throughout the development of our analysis files to ensure we accomplished our goal. The development of our analysis data files used a bottom-up approach, conceptualizing our study questions into variables, creating a master variable list (MVL), creating a data dictionary, then cleaning and merging data into final files. We analyzed and reduced the concepts within the overarching and more-detailed quantitative study questions as stated in Chapter One to create a set of indicator and outcome variables in the MVL. We also used administrative data documentation to inform the MVL development. Once we obtained the WDTIP, MEDS, and EDD administrative data from CDSS, we mapped the data sets' contents onto our MVL. We developed the studies' data dictionary from the subset of the MVL variables required to address the study questions for this report. The data dictionary was continuously refined as we learned more about the administrative data. 251 With a road map in place, we cleaned, merged, and coded the data. We established the population frame as described above, then we added the WDTIP detailed 24-month and 48-month time-clock files, the WDTIP summary time clock, and WDTIP exception files, and matched records from the MEDS and EDD data sources. We excluded individuals from MEDS and EDD who were not identified in our sample frame in a given month, as these individuals were likely to be out of state, tribal TANF, diversion, or other non-CalWORKs WTW classifications. Next, we created the remaining study variables. Although the majority of variables in our data dictionary were readily available from our data sources, we created and further refined additional variables. For example, because many exceptions were not analytically salient, we reported only exemptions identified in the WDTIP exception data source that affected time on the 24-month or 48-month time-on-aid clocks. We reported on exemptions and separated out the exemptions that began in January 2013 specific to the WTW 24-month time clock. We used the full sample frame and data dictionary variables to create three separate analysis data sets for each study. The status, tracking, and impact study analysis data sets each consisted of participants belonging to defined cross-sections or cohorts unique to each study. We also aggregated variables in the tracking study analysis data set to a two-year span and the impact study analysis data set to the quarterly level. Data Integrity Staff at AIR and Stanfield Systems assessed the integrity of the data files and variables prepared for analysis. Internal review included independent replication of code written by data analysts, review of derived metrics in tabular and graphical form, and comparisons to published reports. As part of the process of evaluating the quality and integrity of the prepared data files, our partner, Stanfield Systems, independently replicated key parts of the derived data. They conducted a series of tests, starting with raw data files and conceptual background information to guide the process of creating variables for analysis data sets. Stanfield Systems used this data set to replicate key findings reported in the chapters (i.e. cross-section, cohort, and group counts; population demographics; time on the 24-MTC). Therefore, not only was our coding validated, our design was also replicated independently. We also assessed quality by comparing key indicators using our assembled data to similar numbers published in several CDSS reports and derived from a CDSS-maintained data set used for federal reporting. The coverage, level, frequency, and type of data for these sources are summarized in Table C.2. In particular, county-level reports such as WTW 25 and 25a CalWORKs Activity Reports contain full-population information such as caseloads, discontinuance counts, and applicant denials. A data set used for federal reporting, the Research and Development Enterprise Project (RADEP), uses an annual representative sample of CalWORKs cases. We matched individual-level data from RADEP to data in our analysis file and checked and verified a few key variables that were not checked by Stanfield Systems (i.e., 252 number of children in assistance units, age of youngest child in assistance units, participant date of birth). Data-quality checks thus involved comparing key indicators based on the analysis data sets created for the evaluation studies with independently replicated findings, county-level reports, and the sample-based RADEP data. Table C.2. CDSS Aggregated Reports and Other Administrative Data Data Source Coverage Unit Level\/ Frequency Data Constructs CA 237 CalWORKs Cash Grant Movement Report All applicants and participants since 2006 State level\/ monthly Caseload status CA 253 CalWORKs Report on Reasons for Discontinuances of Cash Grant All participants since 2006 State level\/ monthly Case discontinuance CA 255 CalWORKs Report on Reasons for Denials and Other Non-Approvals of Cash Grant All applicants since 2006 State level\/ monthly Applicant denials WTW 25 and 25a CalWORKs Welfare to Work Activity Report Participants required to participate in WTW since 2006 State level\/ monthly WTW activities, exemptions, terminations Research and Development Enterprise Project (RADEP) Annual (federal fiscal year) representative sample of about 3,500 CalWORKs cases since federal fiscal year 2007 Individual and case level\/ annual Demographics, sources of cash assistance, earnings, other income sources SOURCE: CDSS, undated-a. Looking Forward We expect that future reports will benefit from the richness of additional data sources: unemployment insurance information from EDD and SAWS (the three county-level data systems: C-IV, CalWIN, and LEADER). These data will contribute information about participants' financial well-being, use of services, and involvement in education and training. Table C.3 summarizes the databases that we expect to use in our future reports. The table lists the population covered, the unit of analysis and frequency, and the available measures. As additional data become available from EDD and county consortia, as well as from updated WDTIP, MEDS, and EDD material, both the scope of our analyses and the confidence with which we can make statements about the impact SB 1041 will increase. We expect updates of WDTIP, MEDS, and EDD data used for this report bianually. As these data sets grow, the trends that they help highlight will become clearer, helping paint a more precise picture of the impact of SB 1041. Consortia data from SAWS will increase the scope of our analyses dramatically. Not only will the consortia data overlap with existing data, bolstering the credibility and precision of those metrics included already, they will also add material that addresses a number of additional topic areas, such as information about the participation in services and participation in education and 253 training. Also, we expect to report on additional information about unemployment, use of services, and reasons for leaving the program. Table C.3. Expected Sources of Data Data Source Coverage Unit Level\/ Frequency Available Data Constructs EDD\u2014unemployment insurance All participants since 2006 Individual level\/ quarterly Amount of unemployment insurance SAWS CalWIN C-IV LEADER All participants since 2007 Individual level\/ monthly Public assistance and employment program participation Measures of time accumulation, exceptions, exemptions, sanctions, and eligibility status variables Actual amounts of monthly CalWORKs benefits received 255 Appendix D. Additional Results for Chapter Four ACS Analyses This appendix provides additional analyses of data collected for the ACS. The first section provides results for Tables 4.3 and 4.4 for the full rating scale (i.e., the distribution of responses across did not hinder, minor hindrance, moderate hindrance, and major hindrance ). Results are presented for all counties combined, as well as for small counties, medium-sized counties, and large counties based on caseload size. In the second section, we provide results by county caseload size for questions reported in Chapter Four only for all counties. This affects Tables 4.10, 4.11, 4.18, and 4.19. In the third section, we present results for additional questions not reported in Chapter Four. These findings pertain to the provision of services for CalWORKs WTW participants related to employment, education and training, and supportive services, and counties' assessment of their capacity related to those services. Results for Full Rating Scale Table D.1 presents the full distribution of response for Table 4.4. Table D.2 provides the same response distribution corresponding to Table 4.5. 256 Table D.1. Whether Issues Hindered Implementation: All Counties and by County Caseload Size County Rating of Whether Issue Hindered Implementation Issues Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Not Applicable Total Availability of job opportunities for CalWORKs participants All counties Number 11 6 19 22 0 58 Percentage distribution 19% 10% 33% 38% 0% 100% Small counties Number 2 1 4 13 0 20 Percentage distribution 10% 5% 20% 65% 0% 100% Medium-sized counties Number 4 3 8 5 0 20 Percentage distribution 20% 15% 40% 25% 0% 100% Large counties Number 5 2 7 4 0 18 Percentage distribution 28% 11% 39% 22% 0% 100% Availability of educational opportunities for CalWORKs participants All counties Number 25 15 11 7 0 58 Percentage distribution 43% 26% 19% 12% 0% 100% Small counties Number 4 4 6 6 0 20 Percentage distribution 20% 20% 30% 30% 0% 100% Medium-sized counties Number 13 4 3 0 0 20 Percentage distribution 65% 20% 15% 0% 0% 100% Large counties Number 8 7 2 1 0 18 Percentage distribution 44% 39% 11% 6% 0% 100% Availability of vocational education or on the job training opportunities for CalWORKs participants All counties Number 22 14 15 7 0 58 Percentage distribution 38% 24% 26% 12% 0% 100% Small counties Number 4 2 9 5 0 20 Percentage distribution 20% 10% 45% 25% 0% 100% Medium-sized counties Number 10 5 4 1 0 20 Percentage distribution 50% 25% 20% 5% 0% 100% Large counties Number 8 7 2 1 0 18 Percentage distribution 44% 39% 11% 6% 0% 100% Availability of financial resources for CalWORKs participants All counties Number 29 13 10 3 3 58 Percentage distribution 50% 22% 17% 5% 5% 100% Small counties Number 8 6 2 3 1 20 Percentage distribution 40% 30% 10% 15% 5% 100% Medium-sized counties Number 12 3 4 0 1 20 Percentage distribution 60% 15% 20% 0% 5% 100% Large counties Number 9 4 4 0 1 18 Percentage distribution 50% 22% 22% 0% 6% 100% 257 Table D.1\u2014Continued County Rating of Whether Issue Hindered Implementation Issues Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Not Applicable Total Availability of child care services for CalWORKs participants All counties Number 42 8 4 4 0 58 Percentage distribution 72% 14% 7% 7% 0% 100% Small counties Number 12 3 2 3 0 20 Percentage distribution 60% 15% 10% 15% 0% 100% Medium-sized counties Number 13 4 2 1 0 20 Percentage distribution 65% 20% 10% 5% 0% 100% Large counties Number 17 1 0 0 0 18 Percentage distribution 94% 6% 0% 0% 0% 100% Availability of affordable housing for CalWORKs participants All counties Number 5 8 14 30 1 58 Percentage distribution 9% 14% 24% 52% 2% 100% Small counties Number 0 2 4 13 1 20 Percentage distribution 0% 10% 20% 65% 5% 100% Medium-sized counties Number 0 5 6 9 0 20 Percentage distribution 0% 25% 30% 45% 0% 100% Large counties Number 5 1 4 8 0 18 Percentage distribution 28% 6% 22% 44% 0% 100% Availability of transportation options or transportation resources for CalWORKs participants All counties Number 17 16 14 12 0 58 Percentage distribution 29% 28% 24% 21% 0% 100% Small counties Number 5 3 4 8 0 20 Percentage distribution 25% 15% 20% 40% 0% 100% Medium-sized counties Number 4 6 8 2 0 20 Percentage distribution 20% 30% 40% 10% 0% 100% Large counties Number 8 7 2 2 0 18 Percentage distribution 44% 39% 11% 11% 0% 100% Competition with other state\/federal mandates (e.g., Medi-Cal expansion) All counties Number 15 14 10 16 3 58 Percentage distribution 26% 24% 17% 28% 5% 100% Small counties Number 4 6 4 5 1 20 Percentage distribution 20% 30% 20% 25% 5% 100% Medium-sized counties Number 5 4 3 7 1 20 Percentage distribution 25% 20% 15% 35% 5% 100% Large counties Number 6 4 3 4 1 18 Percentage distribution 33% 22% 17% 22% 6% 100% Availability of line staff (e.g., caseworkers, employment services specialists) who work with and\/or counsel WTW participants All counties Number 18 7 19 14 0 58 Percentage distribution 31% 12% 33% 24% 0% 100% Small counties Number 6 2 8 4 0 20 Percentage distribution 30% 10% 40% 20% 0% 100% Medium-sized counties Number 4 3 7 6 0 20 Percentage distribution 20% 15% 35% 30% 0% 100% Large counties Number 8 2 4 4 0 18 Percentage distribution 44% 11% 22% 22% 0% 100% 258 Table D.1\u2014Continued County Rating of Whether Issue Hindered Implementation Issues Did Not Hinder Minor Hindrance Moderate Hindrance Major Hindrance Not Applicable Total Explaining the complexity of SB 1041 to participants All counties Number 4 8 18 28 0 58 Percentage distribution 7% 14% 31% 48% 0% 100% Small counties Number 3 4 7 6 0 20 Percentage distribution 15% 20% 35% 30% 0% 100% Medium-sized counties Number 1 3 5 11 0 20 Percentage distribution 5% 15% 25% 55% 0% 100% Large counties Number 0 1 6 11 0 18 Percentage distribution 0% 6% 33% 61% 0% 100% Prior staff reductions\/freezes in staff and\/or funding All counties Number 20 11 6 12 9 58 Percentage distribution 34% 19% 10% 21% 16% 100% Small counties Number 8 3 2 2 5 20 Percentage distribution 40% 15% 10% 10% 25% 100% Medium-sized counties Number 6 5 3 5 1 20 Percentage distribution 30% 25% 15% 25% 5% 100% Large counties Number 6 3 1 5 3 18 Percentage distribution 33% 17% 6% 28% 17% 100% Other All counties Number 6 1 3 9 21 40 Percentage distribution 15% 3% 8% 23% 53% 100% Small counties Number 2 0 1 1 6 10 Percentage distribution 20% 0% 10% 10% 60% 100% Medium-sized counties Number 4 1 1 4 7 17 Percentage distribution 24% 6% 6% 24% 41% 100% Large counties Number 0 0 1 4 8 13 Percentage distribution 0% 0% 8% 31% 62% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Percentages are calculated using the number of counties responding to the question as the denominator. 259 Table D.2. Whether Existing Relationships or Partnerships with Organizations or Providers Facilitated Implementation: All Counties and by County Caseload Size County Rating of Whether Issue Hindered Implementation Organization or Provider Did Not Facilitate Minor Facilitator Moderate Facilitator Major Facilitator Not Applicable Total Other county agencies (e.g., mental health, behavioral health, child support services, housing agency) All counties Number 13 17 17 9 2 58 Percentage distribution 22% 29% 29% 16% 3% 100% Small counties Number 6 7 3 3 1 20 Percentage distribution 30% 35% 15% 15% 5% 100% Medium-sized counties Number 5 7 8 0 0 20 Percentage distribution 25% 35% 40% 0% 0% 100% Large counties Number 2 3 6 6 1 18 Percentage distribution 11% 17% 33% 33% 6% 100% Educational providers (e.g., community colleges) All counties Number 14 22 13 5 4 58 Percentage distribution 24% 38% 22% 9% 7% 100% Small counties Number 7 8 4 0 1 20 Percentage distribution 35% 40% 20% 0% 5% 100% Medium-sized counties Number 5 7 6 1 1 20 Percentage distribution 25% 35% 30% 5% 5% 100% Large counties Number 2 7 3 4 2 18 Percentage distribution 11% 39% 17% 22% 11% 100% Vocational education or on the job training providers All counties Number 18 16 12 4 8 58 Percentage distribution 31% 28% 21% 7% 14% 100% Small counties Number 7 5 4 1 3 20 Percentage distribution 35% 25% 20% 5% 15% 100% Medium-sized counties Number 7 6 4 0 3 20 Percentage distribution 35% 30% 20% 0% 15% 100% Large counties Number 4 5 4 3 2 18 Percentage distribution 22% 28% 22% 17% 11% 100% Employment services or job placement providers All counties Number 12 8 10 17 10 57 Percentage distribution 21% 14% 18% 30% 18% 100% Small counties Number 8 2 3 5 2 20 Percentage distribution 40% 10% 15% 25% 10% 100% Medium-sized counties Number 2 2 5 4 6 20 Percentage distribution 10% 10% 25% 20% 30% 100% Large counties Number 2 4 2 8 2 18 Percentage distribution 11% 22% 11% 44% 11% 100% 260 Table D.2\u2014Continued County Rating of Whether Issue Hindered Implementation Organization or Provider Did Not Facilitate Minor Facilitator Moderate Facilitator Major Facilitator Not Applicable Total Community organizations and\/or welfare advocacy organizations All counties Number 25 10 9 4 10 58 Percentage distribution 43% 17% 16% 7% 17% 100% Small counties Number 11 2 2 0 5 20 Percentage distribution 55% 10% 10% 0% 25% 100% Medium-sized counties Number 10 3 2 2 3 20 Percentage distribution 50% 15% 10% 10% 15% 100% Large counties Number 4 5 5 2 2 18 Percentage distribution 22% 28% 28% 11% 11% 100% State organizations (e.g., CDSS, CWDA) All counties Number 7 7 13 18 13 58 Percentage distribution 12% 12% 22% 31% 22% 100% Small counties Number 3 3 2 5 7 20 Percentage distribution 15% 15% 10% 25% 35% 100% Medium-sized counties Number 3 1 6 7 3 20 Percentage distribution 15% 5% 30% 35% 15% 100% Large counties Number 1 3 5 6 3 18 Percentage distribution 6% 17% 28% 33% 17% 100% Other All counties Number 2 1 1 4 24 32 Percentage distribution 6% 3% 3% 13% 75% 100% Small counties Number 1 0 0 1 7 9 Percentage distribution 11% 0% 0% 11% 78% 100% Medium-sized counties Number 1 0 0 1 7 9 Percentage distribution 11% 0% 0% 11% 78% 100% Large counties Number 0 1 1 2 10 14 Percentage distribution 0% 7% 7% 14% 71% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Percentages are calculated using the number of counties responding to the question as the denominator. Results Disaggregated by County Caseload Size Table D.3 provides the disaggregation by county caseload size for the results in Table 4.10 regarding supervisors' assessments of caseworkers' understanding of other SB 1041 components. Table D.4 corresponds to Table 4.11, which reported on supervisor's assessments of participants' understanding of other SB 1041 components. Table D.5 provides disaggregated results for Table 4.18, which reported on counties' assessment of the effect of SB 1041 on outcomes. Table D.6 likewise has disaggregated results corresponding to Table 4.19, which reported on counties' assessment of how well SB 1041 and related mandates are working. In all 261 cases, we also include the results for all counties along with results for small, medium, and large counties based on their caseload size. WTW Caseworkers' Understanding of Other SB 1041 Components Table D.3. Supervisors' Assessment of How Well WTW Caseworkers Understand Other SB 1041 Changes and Related Supports: All Counties and by County Caseload Size Supervisor's Assessment of How Well Caseworkers Understand SB 1041 Change Policy Change Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total Enhanced educational flexibility All counties Number 0 1 39 18 0 58 Percentage distribution 0% 2% 67% 31% 0% 100% Small counties Number 0 0 15 5 0 20 Percentage distribution 0% 0% 75% 25% 0% 100% Medium-sized counties Number 0 1 9 10 0 20 Percentage distribution 0% 5% 45% 50% 0% 100% Large counties Number 0 0 15 3 0 18 Percentage distribution 0% 0% 83% 17% 0% 100% That there are more choices now in WTW activities All counties Number 0 1 23 33 1 58 Percentage distribution 0% 2% 40% 57% 2% 100% Small counties Number 0 0 10 10 0 20 Percentage distribution 0% 0% 50% 50% 0% 100% Medium-sized counties Number 0 1 4 14 1 20 Percentage distribution 0% 5% 20% 70% 5% 100% Large counties Number 0 0 9 9 0 18 Percentage distribution 0% 0% 50% 50% 0% 100% New one-time young child exemption All counties Number 0 0 12 46 0 58 Percentage distribution 0% 0% 21% 79% 0% 100% Small counties Number 0 0 3 17 0 20 Percentage distribution 0% 0% 15% 85% 0% 100% Medium-sized counties Number 0 0 3 17 0 20 Percentage distribution 0% 0% 15% 85% 0% 100% Large counties Number 0 0 6 12 0 18 Percentage distribution 0% 0% 33% 67% 0% 100% Reengagement process (AB X4 4) All counties Number 0 2 22 34 0 58 Percentage distribution 0% 3% 38% 59% 0% 100% Small counties Number 0 0 7 13 0 20 Percentage distribution 0% 0% 35% 65% 0% 100% Medium-sized counties Number 0 1 8 11 0 20 Percentage distribution 0% 5% 40% 55% 0% 100% Large counties Number 0 1 7 10 0 18 Percentage distribution 0% 6% 39% 56% 0% 100% 262 Table D.3\u2014Continued Supervisor's Assessment of How Well Caseworkers Understand SB 1041 Change Policy Change Not at All Well Slightly Well Moderatel y Well Very Well Not Applicable Total ESE program All counties Number 0 4 24 22 8 58 Percentage distribution 0% 7% 41% 38% 14% 100% Small counties Number 0 2 8 4 6 20 Percentage distribution 0% 10% 40% 20% 30% 100% Medium-sized counties Number 0 2 6 10 2 20 Percentage distribution 0% 10% 30% 50% 10% 100% Large counties Number 0 0 10 8 0 18 Percentage distribution 0% 0% 56% 44% 0% 100% FS program All counties Number 0 9 28 20 1 58 Percentage distribution 0% 16% 48% 34% 2% 100% Small counties Number 0 3 9 7 1 20 Percentage distribution 0% 15% 45% 35% 5% 100% Medium-sized counties Number 0 3 10 7 0 20 Percentage distribution 0% 15% 50% 35% 0% 100% Large counties Number 0 3 9 6 0 18 Percentage distribution 0% 17% 50% 33% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer on the Likert scale per policy change. Percentages are calculated using the number of counties responding to the question as the denominator. 263 WTW Participants' Understanding of Other SB 1041 Components Table D.4. Supervisors' Assessment of How Well CalWORKs Participants Understand SB 1041 Changes: All Counties and by County Caseload Size Supervisor's Assessment of How Well CalWORKs Participants Understand SB 1041 Component Change SB 1041 Component Not at All Well Slightly Well Moderately Well Very Well Not Applicable Total New WTW participation requirements All counties Number 2 17 31 7 0 57 Percentage distribution 4% 30% 54% 12% 0% 100% Small counties Number 0 9 9 2 0 20 Percentage distribution 0% 45% 45% 10% 0% 100% Medium-sized counties Number 2 4 10 4 0 20 Percentage distribution 10% 20% 50% 20% 0% 100% Large counties Number 0 4 12 1 0 17 Percentage distribution 0% 24% 71% 6% 0% 100% Increase in choices with respect to the activities for participants during the WTW 24-month time clock All counties Number 3 12 31 10 0 56 Percentage distribution 5% 21% 55% 18% 0% 100% Small counties Number 0 7 11 2 0 20 Percentage distribution 0% 35% 55% 10% 0% 100% Medium-sized counties Number 3 1 11 4 0 19 Percentage distribution 16% 5% 58% 21% 0% 100% Large counties Number 0 4 9 4 0 17 Percentage distribution 0% 24% 53% 24% 0% 100% Reengagement process for those that had short-term young child exemption (AB X4 4) All counties Number 4 10 25 16 3 58 Percentage distribution 7% 17% 43% 28% 5% 100% Small counties Number 0 6 8 5 1 20 Percentage distribution 0% 30% 40% 25% 5% 100% Medium-sized counties Number 3 2 7 6 2 20 Percentage distribution 15% 10% 35% 30% 10% 100% Large counties Number 1 2 10 5 0 18 Percentage distribution 6% 11% 56% 28% 0% 100% New one-time young child exemption All counties Number 1 9 21 27 0 58 Percentage distribution 2% 16% 36% 47% 0% 100% Small counties Number 0 6 7 7 0 20 Percentage distribution 0% 30% 35% 35% 0% 100% Medium-sized counties Number 1 1 5 13 0 20 Percentage distribution 5% 5% 25% 65% 0% 100% Large counties Number 0 2 9 7 0 18 Percentage distribution 0% 11% 50% 39% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer on the Likert scale per component. Percentages are calculated using the number of counties responding to the question as the denominator. 264 Counties' Views Regarding the Effectiveness of SB 1041 Reforms and Related Mandates at County Level Table D.5. Counties' Assessment of the Effect of SB 1041's Implementation on Outcomes: All Counties and by County Caseload Size County Assessment of How SB 1041 Has Affected Outcome Outcomes Much Worse Somewhat Worse About the Same Somewhat Better Much Better Not Applicable Total Work participation rates (WPR) All counties Number 3 14 26 14 1 0 58 Percentage distribution 5% 24% 45% 24% 2% 0% 100% Small counties Number 0 4 10 6 0 0 20 Percentage distribution 0% 20% 50% 30% 0% 0% 100% Medium-sized counties Number 1 6 11 2 0 0 20 Percentage distribution 5% 30% 55% 10% 0% 0% 100% Large counties Number 2 4 5 6 1 0 18 Percentage distribution 11% 22% 28% 33% 6% 0% 100% Participation in WTW activities All counties Number 0 5 30 21 2 0 58 Percentage distribution 0% 9% 52% 36% 3% 0% 100% Small counties Number 0 1 12 7 0 0 20 Percentage distribution 0% 5% 60% 35% 0% 0% 100% Medium-sized counties Number 0 1 11 8 0 0 20 Percentage distribution 0% 5% 55% 40% 0% 0% 100% Large counties Number 0 3 7 6 2 0 18 Percentage distribution 0% 17% 39% 33% 11% 0% 100% Enrollment in education and training programs\/community colleges All counties Number 0 1 32 23 1 0 57 Percentage distribution 0% 2% 56% 40% 2% 0% 100% Small counties Number 0 1 11 7 0 0 19 Percentage distribution 0% 5% 58% 37% 0% 0% 100% Medium-sized counties Number 0 0 12 8 0 0 20 Percentage distribution 0% 0% 60% 40% 0% 0% 100% Large counties Number 0 0 9 8 1 0 18 Percentage distribution 0% 0% 50% 44% 6% 0% 100% Length of time CalWORKs participants spend in educational activities All counties Number 0 4 32 19 3 0 58 Percentage distribution 0% 7% 55% 33% 5% 0% 100% Small counties Number 0 1 14 5 0 0 20 Percentage distribution 0% 5% 70% 25% 0% 0% 100% Medium-sized counties Number 0 1 9 8 2 0 20 Percentage distribution 0% 5% 45% 40% 10% 0% 100% Large counties Number 0 2 9 6 1 0 18 Percentage distribution 0% 11% 50% 33% 6% 0% 100% 265 Table D.5\u2014Continued County Assessment of How SB 1041 Has Affected Outcome Outcomes Much Worse Somewhat Worse About the Same Somewhat Better Much Better Not Applicable Total Persistence of CalWORKs participants in education\/training activities All counties Number 0 1 42 13 1 1 58 Percentage distribution 0% 2% 72% 22% 2% 2% 100% Small counties Number 0 1 15 4 0 0 20 Percentage distribution 0% 5% 75% 20% 0% 0% 100% Medium-sized counties Number 0 0 14 5 1 0 20 Percentage distribution 0% 0% 70% 25% 5% 0% 100% Large counties Number 0 0 13 4 0 1 18 Percentage distribution 0% 0% 72% 22% 0% 6% 100% Compliance with CalWORKs program rules All counties Number 0 10 32 15 1 0 58 Percentage distribution 0% 17% 55% 26% 2% 0% 100% Small counties Number 0 2 12 6 0 0 20 Percentage distribution 0% 10% 60% 30% 0% 0% 100% Medium-sized counties Number 0 4 9 7 0 0 20 Percentage distribution 0% 20% 45% 35% 0% 0% 100% Large counties Number 0 4 11 2 1 0 18 Percentage distribution 0% 22% 61% 11% 6% 0% 100% Number of participants receiving sanctions All counties Number 0 14 29 14 1 0 58 Percentage distribution 0% 24% 50% 24% 2% 0% 100% Small counties Number 0 2 12 6 0 0 20 Percentage distribution 0% 10% 60% 30% 0% 0% 100% Medium-sized counties Number 0 6 8 6 0 0 20 Percentage distribution 0% 30% 40% 30% 0% 0% 100% Large counties Number 0 6 9 2 1 0 18 Percentage distribution 0% 33% 50% 11% 6% 0% 100% Participation in CalFresh All counties Number 0 1 33 6 1 17 58 Percentage distribution 0% 2% 57% 10% 2% 29% 100% Small counties Number 0 1 12 3 0 4 20 Percentage distribution 0% 5% 60% 15% 0% 20% 100% Medium-sized counties Number 0 0 11 1 0 8 20 Percentage distribution 0% 0% 55% 5% 0% 40% 100% Large counties Number 0 0 10 2 1 5 18 Percentage distribution 0% 0% 56% 11% 6% 28% 100% Earnings All counties Number 0 1 31 23 2 1 58 Percentage distribution 0% 2% 53% 40% 3% 2% 100% Small counties Number 0 1 12 7 0 0 20 Percentage distribution 0% 5% 60% 35% 0% 0% 100% Medium-sized counties Number 0 0 12 7 1 0 20 Percentage distribution 0% 0% 60% 35% 5% 0% 100% Large counties Number 0 0 7 9 1 1 18 Percentage distribution 0% 0% 39% 50% 6% 6% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer per outcome. Percentages are calculated using the number of counties responding to each outcome as the denominator. 266 Table D.6. Counties' Assessment of How Well Aspects of SB 1041 and Related Mandates Are Working: All Counties and by County Caseload Size County Assessment of How Well Aspect Is Working Aspects of SB 1041 and Related Mandates Not at all Well Slightly Well Moderately Well Very Well Not Applicable Total Communication of new CalWORKs program rules to CalWORKs participants All counties Number 1 11 34 11 1 58 Percentage distribution 2% 19% 59% 19% 2% 100% Small counties Number 0 7 11 2 0 20 Percentage distribution 0% 35% 55% 10% 0% 100% Medium-sized counties Number 1 2 10 7 0 20 Percentage distribution 5% 10% 50% 35% 0% 100% Large counties Number 0 2 13 2 1 18 Percentage distribution 0% 11% 72% 11% 6% 100% Matching CalWORKs participants with appropriate WTW activities All counties Number 1 7 37 12 1 58 Percentage distribution 2% 12% 64% 21% 2% 100% Small counties Number 0 2 16 2 0 20 Percentage distribution 0% 10% 80% 10% 0% 100% Medium-sized counties Number 1 1 11 7 0 20 Percentage distribution 5% 5% 55% 35% 0% 100% Large counties Number 0 4 10 3 1 18 Percentage distribution 0% 22% 56% 17% 6% 100% Provision of supportive services (e.g., child care, domestic violence, housing assistance) All counties Number 1 5 19 31 2 58 Percentage distribution 2% 9% 33% 53% 3% 100% Small counties Number 1 3 7 8 1 20 Percentage distribution 5% 15% 35% 40% 5% 100% Medium-sized counties Number 0 1 7 12 0 20 Percentage distribution 0% 5% 35% 60% 0% 100% Large counties Number 0 1 5 11 1 18 Percentage distribution 0% 6% 28% 61% 6% 100% Provision of mental health and\/or substance abuse services All counties Number 2 5 26 23 2 58 Percentage distribution 3% 9% 45% 40% 3% 100% Small counties Number 2 1 12 4 1 20 Percentage distribution 10% 5% 60% 20% 5% 100% Medium-sized counties Number 0 2 8 10 0 20 Percentage distribution 0% 10% 40% 50% 0% 100% Large counties Number 0 2 6 9 1 18 Percentage distribution 0% 11% 33% 50% 6% 100% 267 Table D.6\u2014Continued County Assessment of How Well Aspect Is Working Aspects of SB 1041 and Related Mandates Not at all Well Slightly Well Moderately Well Very Well Not Applicable Total Coordination with community colleges All counties Number 0 7 28 20 3 58 Percentage distribution 0% 12% 48% 34% 5% 100% Small counties Number 0 4 10 5 1 20 Percentage distribution 0% 20% 50% 25% 5% 100% Medium-sized counties Number 0 2 9 8 1 20 Percentage distribution 0% 10% 45% 40% 5% 100% Large counties Number 0 1 9 7 1 18 Percentage distribution 0% 6% 50% 39% 6% 100% Coordination with vocational education providers All counties Number 1 6 32 11 8 58 Percentage distribution 2% 10% 55% 19% 14% 100% Small counties Number 0 3 12 1 4 20 Percentage distribution 0% 15% 60% 5% 20% 100% Medium-sized counties Number 0 2 11 4 3 20 Percentage distribution 0% 10% 55% 20% 15% 100% Large counties Number 1 1 9 6 1 18 Percentage distribution 6% 6% 50% 33% 6% 100% Coordination with other county agencies to provide supportive services All counties Number 0 6 18 21 13 58 Percentage distribution 0% 10% 31% 36% 22% 100% Small counties Number 0 1 10 7 2 20 Percentage distribution 0% 5% 50% 35% 10% 100% Medium-sized counties Number 0 4 4 8 4 20 Percentage distribution 0% 20% 20% 40% 20% 100% Large counties Number 0 1 4 6 7 18 Percentage distribution 0% 6% 22% 33% 39% 100% Working with nonprofit service providers All counties Number 0 7 28 18 5 58 Percentage distribution 0% 12% 48% 31% 9% 100% Small counties Number 0 2 12 5 1 20 Percentage distribution 0% 10% 60% 25% 5% 100% Medium-sized counties Number 0 2 7 8 3 20 Percentage distribution 0% 10% 35% 40% 15% 100% Large counties Number 0 3 9 5 1 18 Percentage distribution 0% 17% 50% 28% 6% 100% Working with employers and job training providers All counties Number 0 7 27 22 2 58 Percentage distribution 0% 12% 47% 38% 3% 100% Small counties Number 0 4 10 5 1 20 Percentage distribution 0% 20% 50% 25% 5% 100% Medium-sized counties Number 0 2 10 8 0 20 Percentage distribution 0% 10% 50% 40% 0% 100% Large counties Number 0 1 7 9 1 18 Percentage distribution 0% 6% 39% 50% 6% 100% 268 Table D.6\u2014Continued County Assessment of How Well Aspect Is Working Aspects of SB 1041 and Related Mandates Not at all Well Slightly Well Moderately Well Very Well Not Applicable Total Reengagement strategy for clients with the short-term, young child exemption (AB X4 4) All counties Number 0 9 18 26 4 57 Percentage distribution 0% 16% 32% 46% 7% 100% Small counties Number 0 5 7 6 2 20 Percentage distribution 0% 25% 35% 30% 10% 100% Medium-sized counties Number 0 3 3 13 1 20 Percentage distribution 0% 15% 15% 65% 5% 100% Large counties Number 0 1 8 7 1 17 Percentage distribution 0% 6% 47% 41% 6% 100% Tracking WTW participation of CalWORKs participants All counties Number 5 14 27 9 2 57 Percentage distribution 9% 25% 47% 16% 4% 100% Small counties Number 3 2 11 3 0 19 Percentage distribution 16% 11% 58% 16% 0% 100% Medium-sized counties Number 2 4 10 3 1 20 Percentage distribution 10% 20% 50% 15% 5% 100% Large counties Number 0 8 6 3 1 18 Percentage distribution 0% 44% 33% 17% 6% 100% Improving information management of the CalWORKs program All counties Number 5 18 24 7 4 58 Percentage distribution 9% 31% 41% 12% 7% 100% Small counties Number 2 8 8 1 1 20 Percentage distribution 10% 40% 40% 5% 5% 100% Medium-sized counties Number 2 6 9 2 1 20 Percentage distribution 10% 30% 45% 10% 5% 100% Large counties Number 1 4 7 4 2 18 Percentage distribution 6% 22% 39% 22% 11% 100% Design and implementation of the ESE program All counties Number 1 6 20 23 8 58 Percentage distribution 2% 10% 34% 40% 14% 100% Small counties Number 0 4 8 2 6 20 Percentage distribution 0% 20% 40% 10% 30% 100% Medium-sized counties Number 1 0 7 10 2 20 Percentage distribution 5% 0% 35% 50% 10% 100% Large counties Number 0 2 5 11 0 18 Percentage distribution 0% 11% 28% 61% 0% 100% 269 Table D.6\u2014Continued County Assessment of How Well Aspect Is Working Aspects of SB 1041 and Related Mandates Not at all Well Slightly Well Moderately Well Very Well Not Applicable Total Design and implementation of the FS program All counties Number 0 4 30 23 1 58 Percentage distribution 0% 7% 52% 40% 2% 100% Small counties Number 0 3 14 2 1 20 Percentage distribution 0% 15% 70% 10% 5% 100% Medium-sized counties Number 0 1 8 11 0 20 Percentage distribution 0% 5% 40% 55% 0% 100% Large counties Number 0 0 8 10 0 18 Percentage distribution 0% 0% 44% 56% 0% 100% SOURCE: Authors' analysis of ACS data. NOTE: Caseload size is up to 999 for small counties (20 counties), from 1,000 to 4,999 for medium-sized counties (20 counties), and 5,000 or more for large counties (18 counties). Counties were instructed to mark one answer per outcome. Percentages are calculated using the number of counties responding to the question as the denominator. Additional Survey Results Two topics are addressed in supplemental questions not reported in Chapter Four: county provision of services for CalWORKs WTW participants and the capacity of counties to provide those services. Given the secondary interest in these questions, we report results for all counties only. How Services to CalWORKs WTW Participants Are Provided We asked how county social services departments undertake or provide employment-related services to CalWORKs WTW participants in their county, with results reported in Table D.7. With respect to providing assistance with finding unsubsidized or subsidized employment, it appears that counties use a combination of strategies. Eighty-four percent of counties reported that their social services department directly provides assistance with finding unsubsidized employment. In addition, 59 percent indicated they also contract with local service providers for this purpose. With respect to finding subsidized employment, 64 percent of counties indicated that their social services department directly provides these services and 55 percent indicated they also contract with local service providers. Between a quarter and a third of counties also made referrals to local service providers for subsidized and unsubsidized employment. With respect to assistance with job search and job readiness, 83 percent of counties indicated their social services department directly provided that service (Table D.7). In addition, 64 percent contracted with local service providers and 28 percent made referrals to local service providers. With respect to assistance with placement in on-the-job training, counties used a variety of strategies (Table D.7). Forty-seven percent reported that their county social services department 270 provided this assistance directly, 40 percent contracted with local service providers, 16 percent made referrals to other county agencies, and 21 percent made referrals to local service providers. Table D.7. How Employment-Related Services Are Provided to CalWORKs Participants: All Counties How Employment-Related Services Are Provided to CalWORKs Participants Type of Service All Responding Counties Directly by the County Social Services Department Local Service Providers Contracted by the County Social Services Department Referrals to Other County Agencies Referrals to Local Service Providers Do Not Know Assistance with finding unsubsidized employment Number 58 49 34 7 17 0 Percentage 84% 59% 12% 29% 0% Assistance with finding subsidized employment (public or private sector) Number 58 37 32 7 15 0 Percentage 64% 55% 12% 26% 0% Assistance with placement in on-the-job training Number 58 27 23 9 12 4 Percentage 47% 40% 16% 21% 7% Assistance with finding volunteer or community service opportunities Number 58 46 21 6 11 1 Percentage 79% 36% 10% 19% 2% Assistance with job search and job readiness Number 58 48 37 10 16 0 Percentage 83% 64% 17% 28% 0% Other activities necessary to assist with employment placement or readiness Number 58 27 25 10 18 3 Percentage 47% 43% 17% 31% 5% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark all that apply. Percentages are calculated using the number of counties responding to the question as the denominator. With respect to assistance with finding volunteer or community service opportunities, 79 percent of counties indicated that assistance was provided directly by their social services department and 36 percent contracted with local service providers (Table D.5). One out of five counties also made referrals to local service providers. We also asked how county social services departments undertake or provide various education- and training-related services to CalWORKs WTW participants in their county. For all counties, as reported in Table D.8, the predominant way in which education and vocational services are provided to CalWORKs WTW participants is by referrals to local service providers. In addition, 48 percent of counties contract with local service providers for vocational education\/training and 41 percent for GED preparation. In about a third of counties, adult basic 271 education is also provided through contracts with local service providers; in a quarter of counties, college programming or postsecondary education is also provided this way. Table D.8. How Education- and Training-Related Services Are Provided to CalWORKs Participants: All Counties How Education- and Training-Related Services Are Provided to CalWORKs Participants Type of Service All Responding Counties Directly by the County Social Services Department Local Service Providers Contracted by the County Social Services Department Referrals to Other County Agencies Referrals to Local Service Providers Do Not Know Vocational education or training Number 58 2 28 10 45 0 Percentage 3% 48% 17% 78% 0% Adult basic education Number 58 3 20 4 45 0 Percentage 5% 34% 7% 78% 0% GED Number 58 3 24 7 47 0 Percentage 5% 41% 12% 81% 0% College or postsecondary education Number 58 3 14 1 49 0 Percentage 5% 24% 2% 84% 0% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark all that apply. Percentages are calculated using the number of counties responding to the question as the denominator. Lastly, we asked how county social services departments undertake or provide supportive services such as child care, mental health, domestic violence, and other services to CalWORKs WTW participants in their county. Results are reported in Table D.9. Sixty-seven percent of counties reported that they contracted with local service providers for child care services, with 47 percent also indicating these services were provided by the county social services department and 28 percent made referrals to local service providers. Transportation services refer to such assistance as with bus tickets, car repairs, or ride-share arrangements. This type of assistance is predominantly provided by county social services departments (91 percent) (Table D.9). Housing assistance is provided in multiple ways, with 67 percent of counties reporting that it was provided by their county social services department and 60 percent indicating it was provided by referrals to local providers (Table D.9). A third of counties also reported contracting with local service providers and about the same number made by referrals to other county agencies. 272 Table D.9. How Supportive Services Are Provided to CalWORKs Participants: All Counties How Supportive Services Are Provided to CalWORKs Participants Type of Service All Responding Counties Directly by the County Social Services Department Local Service Providers Contracted by the County Social Services Department Referrals to Other County Agencies Referrals to Local Service Providers Do Not Know Child care Number 58 27 39 6 16 0 Percentage 47% 67% 10% 28% 0% Transportationa Number 58 53 11 3 15 0 Percentage 91% 19% 5% 26% 0% Mental health Number 58 8 33 37 17 0 Percentage 14% 57% 64% 29% 0% Substance abuse Number 58 7 33 34 16 0 Percentage 12% 57% 59% 28% 0% Domestic violence Number 58 12 38 15 33 0 Percentage 21% 66% 26% 57% 0% Language translation Number 58 48 38 3 10 1 Percentage 83% 66% 5% 17% 2% Legal aid Number 58 3 14 7 44 1 Percentage 5% 24% 12% 76% 2% Housing assistance Number 58 39 19 19 35 0 Percentage 67% 33% 33% 60% 0% Other supportive services Number 58 26 10 8 14 5 Percentage 45% 17% 14% 24% 9% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark all that apply. Percentages are calculated using the number of counties responding to the question as the denominator. a Includes, for example, assistance with bus ticket, car repair, ride-share arrangement. Language translation services are predominantly provided by county social services departments (83 percent of counties) or by contracts with local service providers (66 percent) (Table D.9). Legal aid is predominantly provided by referrals to local service providers (76 percent of counties). Domestic violence services are predominantly provided by local service providers through either contracts or referrals (Table D.9). Sixty-six percent of counties reported contracting with local service providers and 57 percent made referrals to these providers. With respect to mental health and substance abuse treatment services, counties predominantly make referrals to other county agencies or contract with local service providers (Table D.9). For example, 64 percent of counties reported that mental health services are provided by referrals to other county agencies and 57 percent of counties indicated contracts with local service providers. With respect to substance abuse treatment services, 59 percent of counties reported that such services are provided by referrals to other county agencies and 57 percent of counties indicated contracts with local service providers. 273 Assessment of Capacity to Provide Services to CalWORKs WTW Participants We asked counties for their assessment of capacity shortfalls for a range of services provided to CalWORKs WTW participants. Overall, counties identified shortfalls in a number of areas (Table D.10). Table D.10. Assessment of Capacity Shortfalls for Provision of Employment-Related Services for CalWORKs Participants: All Counties Assessment of Current Capacity Shortfall Type of Service None Current Shortfall in Some Parts of County Current Shortfall Throughout County Do Not Know Total Subsidized employment Number 34 13 11 0 58 Percentage distribution 59% 22% 19% 0% 100% Job skills training Number 30 20 8 0 58 Percentage distribution 52% 34% 14% 0% 100% Job search\/job readiness Number 35 18 5 0 58 Percentage distribution 60% 31% 9% 0% 100% On the job training Number 25 12 16 4 57 Percentage distribution 44% 21% 28% 7% 100% Unsubsidized employment Number 28 17 13 0 58 Percentage distribution 48% 29% 22% 0% 100% Community service Number 37 14 6 1 58 Percentage distribution 64% 24% 10% 2% 100% Other employment- related services Number 30 5 1 5 41 Percentage distribution 73% 12% 2% 12% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. With respect to employment-related services, as shown in Table D.10, 41 percent of counties reported a shortfall in parts or throughout the county for subsidized employment services and 51 percent reported a shortfall in parts or throughout the county for unsubsidized employment and for community service. With respect to assistance with job search and job readiness, 40 percent of counties reported a capacity shortfall in parts or throughout the county (Table D.10). Forty-nine percent of counties reported a capacity shortfall with respect to on-the-job training and 48 percent reported a capacity shortfall with respect to job skills training in parts or throughout the county. With respect to education- and training-related services, as reported in Table D.11, more than half of counties reported a capacity shortfall in parts or throughout the county for vocational education\/training. Forty-nine percent reported such a shortfall for adult basic education and 45 percent for GED preparation. Fewer counties (38 percent) reported a shortfall for community college or postsecondary education. 274 Table D.11. Assessment of Capacity Shortfalls for Provision of Education- and Training-Related Services for CalWORKs Participants: All Counties Assessment of Current Capacity Shortfall Type of Service None Current Shortfall in Some Parts of County Current Shortfall Throughout County Do Not Know Total Vocational education\/ training Number 26 14 17 1 58 Percentage distribution 45% 24% 29% 2% 100% Adult basic education Number 28 12 16 2 58 Percentage distribution 48% 21% 28% 3% 100% GED preparation Number 29 11 15 3 58 Percentage distribution 50% 19% 26% 5% 100% Community college or postsecondary education Number 35 11 11 1 58 Percentage distribution 60% 19% 19% 2% 100% Other education- related services Number 24 0 6 5 35 Percentage distribution 69% 0% 17% 14% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. With respect to capacity shortfalls for supportive services, as shown in Table D.12, a majority of counties reported capacity shortfalls for transportation and housing assistance (68 percent and 79 percent, respectively). With respect to mental health and substance abuse treatment services, 44 percent and 45 percent, respectively, reported capacity shortfalls in parts or throughout the county. Forty percent reported a capacity shortfall in parts or throughout the county for child care services. Only 23 percent of counties reported such for translation services and 34 percent for domestic violence services. 275 Table D.12. Assessment of Capacity Shortfalls for Provision of Supportive Services for CalWORKs Participants: All Counties Assessment of Current Capacity Shortfall Type of Service None Current Shortfall in Some Parts of County Current Shortfall Throughout County Do Not Know Total Child care Number 35 14 9 0 58 Percentage distribution 60% 24% 16% 0% 100% Transportationa Number 19 23 16 0 58 Percentage distribution 33% 40% 28% 0% 100% Mental health Number 32 17 8 0 57 Percentage distribution 56% 30% 14% 0% 100% Substance abuse Number 32 17 9 0 58 Percentage distribution 55% 29% 16% 0% 100% Domestic violence Number 37 14 6 1 58 Percentage distribution 64% 24% 10% 2% 100% Translation services Number 45 8 5 0 58 Percentage distribution 78% 14% 9% 0% 100% Housing assistance Number 12 14 31 0 57 Percentage distribution 21% 25% 54% 0% 100% Other supportive services Number 26 1 2 6 35 Percentage distribution 74% 3% 6% 17% 100% SOURCE: Authors' analysis of ACS data. NOTE: Counties were instructed to mark one answer. Percentages are calculated using the number of counties responding to the question as the denominator. 277 Appendix E. Additional Documentation for Chapter Six Status and Tracking Studies Analyses This appendix provides tables that document and support the findings summarized in Chapter Six. The sections in this appendix correspond to the sections in the chapter. CalWORKs WTW Participant Demographics Table E.1. Number of CalWORKs WTW Participants and Unemployment Rate: 2006 to 2015 Indicator 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 CalWORKs participants 317,751 321,564 337,435 328,637 354,569 389,047 345,934 332,186 328,854 297,325 Unemployment rate (percent) 4.9 5.1 6.4 10.6 12.2 11.8 10.7 9.1 7.9 6.5 SOURCES: CalWORKs WTW participants: WDTIP files; unemployment rate: EDD unemployment data. NOTES: CalWORKs WTW participation is measured in March of each year. CalWORKs WTW participants includes adults who were in the CalWORKs WTW program and were eligible to work, including those who may have been sanctioned. These participants were members of two-parent families, all other families, and TANF timed-out cases. Unemployment rate is for California and measured in March of each year. Table E.2.a. Number and Percentage of CalWORKs WTW Participants by Gender and by Race\/Ethnicity: 2007, 2009, 2011, 2013, 2015 Number Percentage Characteristic 2007 2009 2011 2013 2015 2007 2009 2011 2013 2015 By sex Male 50,959 61,648 79,729 74,019 66,370 15.8 18.8 20.5 22.3 22.3 Female 201,833 216,563 266,445 245,266 226,606 62.8 65.9 68.5 73.8 76.2 [Not reported] 68,772 50,426 42,873 12,901 4,349 21.4 15.3 11.0 3.9 1.5 Total 321,564 328,637 389,047 332,186 297,325 100.0 100.0 100.0 100.0 100.0 By race or ethnicity White 67,450 73,678 88,173 79,802 72,417 21.0 22.4 22.7 24.0 24.4 Hispanic 99,848 116,766 149,423 137,439 124,917 31.1 35.5 38.4 41.4 42.0 African American 50,293 49,394 58,704 53,657 48,162 15.6 15.0 15.1 16.2 16.2 Native American 2,479 2,376 2,631 2,275 1,986 0.8 0.7 0.7 0.7 0.7 Asian\/Pacific Islander 19,715 18,888 21,457 18,910 18,394 6.1 5.7 5.5 5.7 6.2 Other 6,037 7,241 10,673 10,782 12,239 1.9 2.2 2.7 3.2 4.1 [Not reported] 75,742 60,294 57,986 29,321 19,210 23.6 18.3 14.9 8.8 6.5 Total 321,564 328,637 389,047 332,186 297,325 100.0 100.0 100.0 100.0 100.0 SOURCES: WDTIP and MEDS files. NOTES: Participant characteristics are measured in March of each year. Categories may not add up to 100 percent because of rounding error. 278 Table E.2.b. Median Age of CalWORKs WTW Participants: 2007, 2009, 2011, 2013, 2015 Characteristic 2007 2009 2011 2013 2015 Median age 30 29 29 29 29 SOURCES: WDTIP and MEDS files. NOTE: Participant characteristics are measured in March of each year. CalWORKs WTW Participant Counts Table E.3. Number and Percentage of CalWORKs WTW Participants in the Transitional Group and Post SB Group: Status Cross-Sections in March 2013, March 2014, March 2015 Number Percentage Group 2013 2014 2015 2013 2014 2015 All CalWORKs participants in status study 332,186 328,854 297,325 100.0 100.0 100.0 Transitional group 308,181 242,067 182,291 92.8 73.6 61.3 Post SB 1041 group 24,005 86,787 115,034 7.2 26.4 38.7 SOURCE: WDTIP files. NOTES: The 2013, 2014 and 2015 cross-sections included CalWORKs WTW participants all Two Parent Families, All Other Families, and TANF Timed-Out cases present in March of 2013, 2014, and 2015. Categories may not add up to 100 percent because of rounding error. Table E.4. Number of New CalWORKs WTW Participants: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Group 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 SOURCE: WDTIP files. Time on Aid and WTW Time Clock Table E.5. Average Number of Months of Participation, Counted on the 48-Month Time-on-Aid Clock, and Counted on the 24-Month Time Clock Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Group and Indicator 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 Months of participation 13.0 13.3 13.1 13.1 Months counted on the 48-month time-on-aid clock 9.8 8.5 7.5 9.1 Months counted on WTW 24-month clock Not applicable Not applicable Not applicable 1.9 SOURCES: WDTIP files. NOTE: The WTW 24-month time clock was implemented January 2013. 279 Exemptions and Sanctions Table E.6. Number and Percentage of Participants Who Had an Exemption or Sanction That Stopped the Clock: Status Cross-Sections and Transitional and After SB 1041 Groups in March 2013, March 2014, and March 2015 Number Percentage Group and Indicator 2013 2014 2015 2013 2014 2015 All CalWORKs participants in status study 332,186 328,854 297,325 100.0 100.0 100.0 Participant had an exemption 132,266 104,289 86,993 39.8 31.7 29.3 Participant had a WTW 24-MTC exemption 10,785 27,083 25,493 3.2 8.2 8.6 Participant had a sanction 42,980 41,905 34,316 12.9 12.7 11.5 Transitional group 308,181 242,067 182,291 100.0 100.0 100.0 Participant had an exemption 125,307 74,663 49,803 40.7 30.8 27.3 Participant had a WTW 24-MTC exemption 10,571 21,260 16,719 3.4 8.8 9.2 Participant had a sanction 42,923 37,799 27,663 13.9 15.6 15.2 Post SB 1041 group 24,005 86,787 115,034 100.0 100.0 100.0 Participant had an exemption 6,959 29,626 37,190 29.0 34.1 32.3 Participant had a WTW 24-MTC exemption 214 5,823 8,774 0.9 6.7 7.6 Participant had a sanction 57 4,106 6,653 0.2 4.7 5.8 SOURCE: WDTIP files. NOTES: The exemptions and sanctions stop the WTW 24-month time clock, the 48-month time-on-aid clock, or both. The exemption and sanction categories are not mutually exclusive. The Exemption category includes all WTW exemptions except for WTW 24-MTC exemptions. The WTW 24-MTC Exemption category includes four exemptions that started January 1, 2013. The Sanction category includes three WTW noncompliance sanctions. Categories may not add up to 100 percent because of rounding error. Table E.7. Number and Percentage of Participants Who Had at Least One Exemption and at Least One Sanction Within Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Number Percentage Group and Indicator 2007 2009 2011 2013 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 100.0 100.0 100.0 100.0 Participant had an exemption 3,438 5,654 6,100 3,867 43.7 47.9 57.6 49.2 Participant had a WTW 24-MTC exemption \u2014 \u2014 \u2014 1,258 \u2014 \u2014 \u2014 16.0 Participant had a sanction 956 1,580 1,472 1,112 12.2 13.4 13.9 14.1 SOURCE: WDTIP files. NOTES: The exemptions and sanctions stop the WTW 24-month time clock, the 48-month time-on-aid clock, or both.. For the tracking study, the presence of exemptions and sanctions were measured for 24 months including the entry month. For example, for the 2013 cohort, we counted months from March 2013 to February 2015.The exemption and sanction categories are not mutually exclusive. The Exemption category includes all WTW exemptions except for WTW 24-MTC exemptions. The WTW 24-MTC Exemption category includes four exemptions that started January 1, 2013. The Sanction category includes three WTW noncompliance sanctions. Categories may not add up to 100 percent because of rounding error. \u2014 = not applicable. 280 Leaving the WTW Program Table E.8. Number and Percentage of Participants Who Left the WTW Program One Year and Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Number Percentage Group and Indicator 2007 2009 2011 2013 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 100.0 100.0 100.0 100.0 Participant left at one year 3,947 5,885 5,301 3,833 50.2 49.9 50.0 48.8 Participant left at two years 5,007 7,240 6,996 5,286 63.7 61.3 66.0 67.2 SOURCE: WDTIP files. NOTES: We measured leaving the WTW program after one year as a participant who was not in the program during the last month of their first year of participation after beginning the program. For example, for the 2013 cohort who started in March 2013, if they were not present in the program in February 2014 they were counted as leaving the program. We measured leaving the WTW program after two years as a participant who was not in the CalWORKs WTW program during the last month of their second year of participation after beginning the program. For example, for the 2013 cohort who started in March 2013, if they were not present in the program in February 2015 they were counted as leaving the program. Participants who were sanctioned are not considered to have left the program. Categories may not add up to 100 percent because of rounding error. Employment and Earnings Table E.9. Number and Percentage of Participants Who Were Employed: Status Cross-Sections and Transitional and After SB 1041 Groups in March 2013, March 2014, March 2015 Number Percentage Group and Indicator 2013 2014 2015 2013 2014 2015 All CalWORKs participants in status study 332,186 328,854 297,325 100.0 100.0 100.0 Participant is employed 83,295 96,025 91,858 25.1 29.2 30.9 Transitional group 308,181 242,067 182,291 100.0 100.0 100.0 Participant is employed 76,940 71,296 59,043 25.0 29.5 32.4 Post SB 1041 group 24,005 86,787 115,034 100.0 100.0 100.0 Participant is employed 6,355 24,729 32,815 26.5 28.5 28.5 SOURCES: WDTIP and EDD files. NOTE: Categories may not add up to 100 percent because of rounding error. Table E.10. Average Real Quarterly Earnings of All Participants Who Were Employed: Status Cross-Sections in March 2013, March 2014, March 2015 Group and Indicator 2013 2014 2015 Employed CalWORKs participants in status study 83,152 95,846 91,665 Adjusted quarterly earnings (2013 $) $2,062 $2,181 $2,289 Employed transitional group participants 297,723 241,269 181,919 Adjusted quarterly earnings (2013 $) $2,063 $2,174 $2,296 Employed post SB 1041 group participants 22,339 86,161 114,462 Adjusted quarterly earnings (2013 $) $2,052 $2,200 $2,275 SOURCES: WDTIP and EDD files. NOTE: Quarterly earnings are measured in 2013 first quarter dollars using the CPI (BLS, 2015a) to adjust for inflation. 281 Table E.11. Number and Percentage of Participants Who Were Employed for at Least One Quarter in the Subsequent Two Years After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Number Percentage Group and Indicator 2007 2009 2011 2013 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 100.0 100.0 100.0 100.0 Participant is employed 3,883 5,422 5,452 4,824 49.4 45.9 51.4 61.4 SOURCES: WDTIP and EDD files. Table E.12. Number and Percentage of Participants Who Had Continuous Employment During the First Year and During the Second Year After Entry: Tracked Entry Cohorts 2007, 2009, 2011, 2013 Number Percentage Group and Indicator 2007 2009 2011 2013 2007 2009 2011 2013 All CalWORKs participants in tracking study 7,867 11,804 10,597 7,863 100.0 100.0 100.0 100.0 Participant employed continuously during year one 1,100 1,374 1,350 1,333 14.0 11.6 12.7 17.0 Participant employed continuously during year two 1,413 1,997 2,239 2,158 18.0 16.9 21.1 27.4 SOURCES: WDTIP and EDD files. NOTE: Categories may not add up to 100 percent because of rounding error. Reengagement Table E.13. CalWORKs Participant Status Among Those with the Short-Term WTW Exemption for Young Children in December 2012: March 2013, March 2014, March 2015 Number Percentage Group and Indicator 2013 2014 2015 2013 2014 2015 Participants with short-term WTW exemption for young children as of January 1, 2013 59,876 59,876 59,876 100.0 100.0 100.0 New WTW exemption for young children 883 4,687 3,044 1.5 7.8 5.1 Short term young children exemption 42,835 8,677 28 71.5 14.5 0.0 Sanction 279 3,470 4,997 0.5 5.8 8.3 Other exemptiona 2,953 5,945 5,432 4.9 9.9 9.1 In CalWORKs with no exemption or sanction 6,367 15,978 14,989 10.6 26.7 25.0 Not in CalWORKsb 6,559 21,119 31,386 11.0 35.3 52.4 SOURCE: WDTIP files. NOTES: Categories may not add up to 100 percent because of rounding error. a This category includes exemptions such as exemption for participation in the Cal-Learn program. It also includes a small number of exceptions such as penalty, good cause, extender, and repayment. b This category includes participants not present in the WDTIP data system in March of the given year. 283 Appendix F. Additional Documentation for Chapter Seven Impact Study Analyses This appendix provides tables and information that document and support the findings using state administrative data and the CPS presented in Chapter Seven. State Administrative Data Methods and Supporting Tables For administrative data analysis, CalWORKs WTW participants were defined as individuals in two-parent families, all other families, and TANF timed-out cases. Individuals were considered participants if they were identified in the WDTIP file as an adult or minor parent or guardian who was aided, including if he or she was exempt from WTW activities, or sanctioned and did not receive aid. Tables F.1 to F.3 report the numbers presented unadjusted averages of employment and CalWORKs WTW participation outcomes. Table F.1. Employment and CalWORKs WTW Participation of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment Entry Cohort In Employment (only or also in CalWORKs) In CalWORKs (only or also in Employment) 2010 Q1 31.3 61.6 Q2 32.5 61.6 Q3 35.4 59.6 Q4 35.8 58.8 2011 Q1 34.3 57.2 Q2 36.3 57.6 Q3 37.7 57.7 Q4 38.7 55.4 2012 Q1 36.1 55.7 Q2 38.0 57.0 Q3 39.1 56.7 Q4 40.3 54.5 2013 Q1 38.8 55.7 Q2 40.6 56.3 Q3 41.6 56.3 Q4 41.6 53.8 SOURCE: Authors' analysis of 2010 2014 WDTIP files and EDD employment and earnings files. 284 Table F.2. Employment and CalWORKs WTW Participation of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment, Four Mutually Exclusive Categories Entry Cohort In Employment (not in CalWORKs) In Employment and CalWORKs In CalWORKs (not in Employment) Not in Employment or CalWORKs 2010 Q1 15.1 16.2 45.4 23.3 Q2 15.0 17.5 44.1 23.5 Q3 17.7 17.7 41.9 22.7 Q4 18.4 17.4 41.4 22.8 2011 Q1 18.7 15.6 41.6 24.1 Q2 19.4 16.9 40.6 23.1 Q3 19.8 17.9 39.8 22.5 Q4 21.1 17.6 37.8 23.5 2012 Q1 20.6 15.5 40.2 23.7 Q2 20.7 17.3 39.7 22.3 Q3 20.8 18.3 38.5 22.4 Q4 22.3 18.0 36.5 23.2 2013 Q1 21.3 17.5 38.1 23.0 Q2 21.3 19.2 37.1 22.4 Q3 20.8 20.8 35.5 23.0 Q4 21.6 20.0 33.8 24.6 SOURCE: Authors' analysis of 2010 2014 WDTIP files and EDD employment and earnings files. Table F.3. Average Unemployment Rate Across Counties of First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment Entry Cohort Unemployment Rate 2010 Q1 13.4 Q2 12.7 Q3 12.9 Q4 12.1 2011 Q1 12.4 Q2 11.4 Q3 11.3 Q4 10.5 2012 Q1 10.8 Q2 9.8 Q3 9.8 Q4 9.2 2013 Q1 9.4 Q2 8.1 Q3 8.3 Q4 7.8 SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. 285 For the analysis of regression-adjusted trends, the following linear probability model was estimated: \ud835\udc66\ud835\udc66! = \ud835\udefd\ud835\udefd! + \ud835\udefd\ud835\udefd!\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc431041! + \ud835\udefd\ud835\udefd!\ud835\udc48\ud835\udc48\ud835\udc48\ud835\udc48! + \ud835\udefd\ud835\udefd!\ud835\udc48\ud835\udc48\ud835\udc48\ud835\udc48!! + \ud835\udf03\ud835\udf03!\ud835\udc4b\ud835\udc4b! + \ud835\udefe\ud835\udefe!\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44! ! !!! !!! + \ud835\udeff\ud835\udeff!\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36!! !!!\" !!! + \ud835\udf00\ud835\udf00! where: \ud835\udc66\ud835\udc66! is the outcome for participant i in the fourth quarter after the quarter in which the participant first enrolled in CalWORKs WTW; \ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc43\ud835\udc431041! is an indicator that equals 1 if participant i enrolled in CalWORKs WTW in 2013 or later; \ud835\udc48\ud835\udc48\ud835\udc48\ud835\udc48! is the unemployment rate in county c (centered at the global mean) and \ud835\udc48\ud835\udc48\ud835\udc48\ud835\udc48!! is the unemployment rate squared; \ud835\udc4b\ud835\udc4b! is a vector of individual level characteristics for participant i including: participant sex, race or ethnicity, age, and language, the age of the youngest child and number of children in the case at participants' entry into CalWORKs WTW; \ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44\ud835\udc44! ! are a set of indicator variables for the starting quarter in which participant i enrolled; and, \ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36\ud835\udc36!! are a set of indicator variables for the county in which participant i enrolled. The figures display one line for the pre SB 1041 cohort, the average regression-adjusted values for participants in each cohort: \ud835\udc66\ud835\udc66! !\"# = \ud835\udc66\ud835\udc66! \u2212 \ud835\udc66\ud835\udc66! + \ud835\udc66\ud835\udc66, where: \ud835\udc66\ud835\udc66! is the predicted outcome for participant i from the regression equation; and, \ud835\udc66\ud835\udc66 is the average outcome over the entire analysis sample. For the post SB 1041 cohorts, the regression-adjusted values represent the outcome as if SB 1041 had not been implemented because the predicted value, \ud835\udc66\ud835\udc66!, removes the change in income associated with SB 1041. To calculate the outcome with SB 1041, the coefficient on SB 1041 was added to the change associated with SB 1041 into the regression-adjusted values: \ud835\udc66\ud835\udc66! !\"#,!\"#! !\"!\"#! = \ud835\udc66\ud835\udc66! \u2212 \ud835\udc66\ud835\udc66! + \ud835\udc66\ud835\udc66 + \ud835\udefd\ud835\udefd!. Table F.4 reports the numbers presented in Figures 7.2 and 7.3, while Table F.12 reports the numbers presented in Figures 7.4 through 7.7. In each of these tables the values for the post SB 1041 cohorts are the values with SB 1041. In the final rows of Tables F.4 and F.5, the estimate and standard error of the difference in outcome associated with SB 1041 are presented. 286 Table F.4. Percentage of First-Time CalWORKs WTW Participants Employed and Participating in CalWORKs WTW in the Fourth Quarter After CalWORKs WTW Enrollment, with Controls Entry Cohort In Employment (only or also in CalWORKs) In CalWORKs (only or also in Employment) 2010 Q1 36.3 59.1 Q2 36.5 59.0 Q3 37.5 57.3 Q4 37.2 57.5 2011 Q1 37.8 56.7 Q2 38.0 55.8 Q3 37.7 56.6 Q4 37.8 56.3 2012 Q1 37.3 56.7 Q2 37.3 57.4 Q3 36.9 57.7 Q4 37.4 57.5 2013 Q1 37.8 56.6 Q2 37.5 57.0 Q3 37.1 57.7 Q4 36.9 57.8 Difference for Post-SB1041 Cohorts Estimate 0.2 2.2* Std. Err. 0.3 0.3 SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTE: Controls include county unemployment rate and participant characteristics. An asterisk indicates that the difference is statistically significant (p < 0.05). 287 Table F.5. Percentage of First-Time CalWORKs WTW Participants Employed and Participating in CalWORKs WTW in the Fourth Quarter After CalWORKs WTW Enrollment, Four Mutually Exclusive Categories, with Controls Entry Cohort In Employment (not in CalWORKs) In Employment and CalWORKs In CalWORKs (not in Employment) Not in Employment or CalWORKs 2010 Q1 18.0 18.4 40.7 22.9 Q2 18.1 18.4 40.5 22.9 Q3 19.9 17.6 39.7 22.8 Q4 19.7 17.5 40.0 22.8 2011 Q1 20.0 17.8 38.8 23.4 Q2 20.6 17.4 38.3 23.7 Q3 20.2 17.5 39.1 23.2 Q4 20.2 17.5 38.8 23.5 2012 Q1 19.9 17.4 39.3 23.4 Q2 19.7 17.6 39.8 22.9 Q3 19.3 17.7 40.0 23.1 Q4 19.6 17.9 39.7 22.9 2013 Q1 20.6 17.2 39.4 22.8 Q2 20.1 17.4 39.6 22.9 Q3 18.9 18.2 39.5 23.4 Q4 18.9 18.0 39.8 23.3 Difference for Post- SB1041 Cohorts Estimate 1.9* 2.1* 0.1 0.2 Std. Err. 0.2 0.2 0.3 0.2 SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTE: Controls include county unemployment rate and participant characteristics. An asterisk indicates the difference is statistically significant (p < 0.05). The analysis of real quarterly earnings uses the same methods described above. Average unadjusted earnings are presented in Tables F.6 while supporting numbers for Figure 7.8 are presented in Table F.7. 288 Table F.6. Real Quarterly Earnings for First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment Entry Cohort Real Quarterly Earnings ($) 2010 Q1 991 Q2 1,051 Q3 1,235 Q4 1,209 2011 Q1 1,124 Q2 1,238 Q3 1,272 Q4 1,330 2012 Q1 1,204 Q2 1,295 Q3 1,336 Q4 1,430 2013 Q1 1,346 Q2 1,430 Q3 1,522 Q4 1,586 SOURCE: Authors' analysis of 2010 2014 WDTIP files and EDD employment and earnings files. NOTE: Quarterly earnings are measured in 2013 first quarter dollars using the CPI (BLS, 2015a) to adjust for inflation. 289 Table F.7. Real Quarterly Earnings for First-Time CalWORKs WTW Participants in the Fourth Quarter After CalWORKs WTW Enrollment, with Controls Entry Cohort Real Quarterly Earnings ($) 2010 Q1 1,245 Q2 1,247 Q3 1,326 Q4 1,263 2011 Q1 1,310 Q2 1,340 Q3 1,281 Q4 1,282 2012 Q1 1,299 Q2 1,285 Q3 1,252 Q4 1,294 2013 Q1 1,289 Q2 1,272 Q3 1,278 Q4 1,306 Difference for Post-SB1041 Cohorts Estimate 53.7* Std. Err. 13.5 SOURCE: Authors' analysis of 2010 2014 WDTIP files, EDD employment and earnings files, and EDD county unemployment rate files. NOTES: Quarterly earnings are measured in 2013 first quarter dollars using the CPI (BLS, 2015a) to adjust for inflation. Controls include the county unemployment rate and participant characteristics. An asterisk indicates the difference is statistically significant (p < 0.05). CPS Data Methods and Supporting Tables We now describe the synthetic control group methods used in Chapter Seven. We compare changes in socioeconomic well-being of a sample of potential CalWORKs WTW eligibles and their families to the corresponding changes in a comparison group consisting of other states. Specifically, we investigate changes in poverty level, receipt of public assistance, employment, and enrollment in school and\/or job training programs. In this appendix, we describe the logic underlying the synthetic comparison group method as well as the data and the estimation techniques we used to implement this method. Analytic Approach Case studies are often used to study the impacts of policy interventions on organizations, cities, states, and countries, and causal effects are estimated by comparing the outcomes for the unit or units affected by the intervention (also called the treatment unit[s]) or intervention to the 290 outcomes for a set of unaffected unit(s) (also called the control or comparison unit[s]). The comparison units serve as a proxy for the treatment unit's counterfactual condition: what would have happened to the treatment unit had the treatment unit not been exposed to the event or intervention (Bennett, 2004; Morgan and Winship, 2014; Rubin, 1974). The selection of comparison units (Eisenhardt, 1989; Seawright and Gerring, 2008) is a critical step in minimizing threats to the validity (Shadish, Cook, and Campbell, 2002) of inferences about the impacts of policies or interventions in case study research. Specifically, in order to make valid causal inferences, there must be no case selection bias (Bennett, 2004; George and Bennett, 2005; Shadish, Cook, and Campbell, 2002), and the comparison units must be as similar as possible to the treatment unit on all other characteristics that may influence the outcome. It is only when the comparison group serves as a credible counterfactual that differences in outcomes can be attributed to differences in exposure to the policy or intervention. However, conventional case study methods leave the selection of comparison cases to the discretion of the researcher, which can compromise the validity and generalizability of the research findings because comparison cases can be chosen arbitrarily, and the selection of comparison cases may contain selection bias (George and Bennett, 2005). In the current analysis, we address the issue of case selection bias by using a data-driven approach to select defensible, sound comparison cases, rather than relying on researcher judgments about comparison case suitability. Specifically, we use the synthetic comparison group methods proposed by Abadie and Gardeazabal (2003) and Abadie, Diamond and Hainmueller (2010). With these methods, the comparison group is constructed as a weighted average of the available comparison units. Weights are selected to minimize the difference between the treatment unit and the weighted comparison units prior to the policy or intervention. In this way, the comparison group serves as a credible counterfactual case. In Chapter Five of this report, we apply synthetic comparison group methods to estimate the impacts of the SB 1041 reforms to California's CalWORKs WTW program on participants' socioeconomic well-being.72 SB 1041 is a specific policy intervention that is anticipated to improve socioeconomic outcomes of female-headed families in California. Specifically, we construct a group of comparison states using a weighted average of the outcome for states not affected by SB 1041, and we can make inferences about the impacts of SB 1041 by comparing the outcomes in California to the outcomes of the weighted comparison group states, as these states serve as a reasonable counterfactual for California. In other words, because the comparison group states are constructed to be (nearly) identical to California on all relevant characteristics prior to the implementation of SB 1041, any differences in outcomes can be attributed in part to this policy change. 72 The target population of those potentially eligible for the CalWORKs program consists of female-headed families in the CPS with a child under the age of 18, without a bachelor's degree, living in the state of California. This treatment group is referred to as California for brevity throughout the analysis. Similar populations (female- headed families with children under the age of 18) were examined in comparison states. 291 Statistical Model We investigate the impacts of the SB 1041 reforms to California's CalWORKs WTW program on participants' socioeconomic well-being by comparing socioeconomic well-being of female- headed families in California with a weighted combination of other U.S. states selected to resemble California prior to the implementation of SB 1041. This weighted combination serves as a counterfactual synthetic California without SB 1041, and the impact of SB 1041 can be estimated by finding the difference in outcomes between California and its counterfactual. Formally, we let t be the number of time periods from 2005 to 2013.73 The implementation of SB 1041 occurs in 2013, and so \ud835\udc61\ud835\udc61 = 1, ,8 are the preintervention periods and \ud835\udc61\ud835\udc61 = 9 is the post- SB 1041 time period. If \ud835\udc4c\ud835\udc4c!! is the post-SB 1041 observed outcome for California, and \ud835\udc4c\ud835\udc4c!! is the unobserved counterfactual outcome\u2014that is, the outcome in California had SB 1041 not been implemented\u2014the impact of SB 1041 can be found as \ud835\udeff\ud835\udeff = \ud835\udc4c\ud835\udc4c!! \u2212 \ud835\udc4c\ud835\udc4c!! . However, since \ud835\udc4c\ud835\udc4c!! cannot be observed, we use a weighted combination of other U.S. states selected to resemble California on all relevant background characteristics prior to the implementation of SB 1041 to estimate this counterfactual outcome. Let J be the number of available comparison units (48 U.S. states74), let \ud835\udc4a\ud835\udc4a = \ud835\udc64\ud835\udc64!, ,\ud835\udc64\ud835\udc64! be a vector of (nonnegative) weights such that \ud835\udc64\ud835\udc64! = 1!\"!!! , and let \ud835\udc64\ud835\udc64! represent the weight of the jth comparison state. An estimate of the impact of SB 1041 can be found as \ud835\udeff\ud835\udeff = \ud835\udc4c\ud835\udc4c!! \u2212 \ud835\udc64\ud835\udc64!\ud835\udc4c\ud835\udc4c!!!\"!!! , where \ud835\udc4c\ud835\udc4c!! is the observed outcome for the jth state in the post-SB 1041 time period. Construction of Synthetic Comparison Since different values for W produce different synthetic comparison units, it is important to select a set of weights that produce a comparison group that is as similar to California as possible on all relevant observed background characteristics. The synthetic comparison method determines optimal weights by minimizing the distance between a (k x 1) vector of preintervention characteristics for California, \ud835\udc4b\ud835\udc4b!, and a weighted combination of the preintervention characteristics for comparison states, \ud835\udc4a\ud835\udc4a\ud835\udc4b\ud835\udc4b!. These preintervention characteristics include variables such as sociodemographic characteristics that are known determinants of economic outcomes. We also include the average pre SB 1041 outcomes in the set of covariates to control for time-varying unobserved factors. Specifically, the values in \ud835\udc4a\ud835\udc4a are chosen to minimize the formula: \ud835\udc4b\ud835\udc4b! \u2212 \ud835\udc4b\ud835\udc4b!\ud835\udc4a\ud835\udc4a ! = (\ud835\udc4b\ud835\udc4b! \u2212 \ud835\udc4b\ud835\udc4b!\ud835\udc4a\ud835\udc4a)\u2032\ud835\udc49\ud835\udc49(\ud835\udc4b\ud835\udc4b! \u2212 \ud835\udc4b\ud835\udc4b!\ud835\udc4a\ud835\udc4a) (1) 73 Several outcomes were available in 2014 and 2015. For simplicity, we describe only the case where outcomes were available in the 2005 2013 time period. 74 We exclude Washington, D.C., and Wisconsin. Wisconsin was excluded because Maximum Monthly Benefit data were not available for the 2005 2013 time period. 292 where \ud835\udc49\ud835\udc49is a (k x k) positive semi-definite matrix. The matrix \ud835\udc49\ud835\udc49 assigns weights to each of the covariates included in the model, based on the relative importance of each covariate. There are many ways to select V. Weights may be specified a priori, based on strong theory, or may be determined empirically. In the current analysis, we use the method proposed by Abadie and Gardeazabal (2003) and Abadie, Diamond, and Hainmueller (2010), which selects a positive- definite, diagonal V such that the mean squared prediction error of the outcome variable is minimized for the entire preintervention time period, 2005 2012 (Abadie, Diamond, and Hainmueller, 2011).75 Inference in Synthetic Comparison Group Designs Ideally, in order to make a compelling case that SB 1041 made a large impact on socioeconomic well-being among female-headed families in California, we would like to see that the difference in outcomes between California and the weighted combination of comparison states is sufficiently small in the pre SB 1041 implementation time periods, and appreciably larger after SB 1041 implementation. However, sufficiently small and appreciably larger are terms that confer more art than statistical precision. Abadie, Diamond, and Hainmueller (2010), recommend using placebo tests to make inferences about the magnitude of the observed differences. The logic of these placebo tests is similar in spirit to permutation tests. We treat every comparison unit (in this case, every state that is not California) as if it were the treatment unit, and then reapply the synthetic comparison group methods to the remaining comparison units. This principal is illustrated on a simplified case (with five comparison units) in Figure F.1. 75 Recent work has called attention to the potential for certain values of V to result in biased estimates of impacts. In such cases, closer matches may be achieved in the preintervention time periods and may produce larger gaps in the postintervention time periods. This may occur, for example, by specifying that preintervention outcomes receive all of the weight, or by including all lagged preintervention outcomes across all observable time points as covariates. Choices such as these risk placing too much weight on certain variables at the expense of overall balance. To the extent that V weights do not take into account information about known determinants of the outcome, the validity of inferences about impacts can be compromised (Abadie and Gardeazabal, 2003). In this analysis, we address this issue following Kaul, Kl\u00f6\u00dfner, Pfeifer and Schieler (2015), and use a data-driven process to select V and the average of the outcome's preintervention values over the entire preintervention period as a covariate. 293 Figure F.1. Example of Placebo Tests with Synthetic Control Group Method In the first placebo test, we would treat Unit 1 as the treatment unit (shown as a black square), construct a comparison group from the remaining units (Units 2\u20145, shown as white squares), and then estimate new preintervention differences and a new intervention impact, which we will call \ud835\udeff\ud835\udeff!!, where the p1 subscript is used to indicate that this is the impact estimate for the first placebo test. In the second placebo test, we would treat Unit 2 as the treatment unit, and construct a comparison group from the remaining units (Unit 1, Units 3\u20145). By repeating this process for all of the comparison units, it is possible to determine if there are small differences prior to the intervention, and whether the observed estimate of the impact, \ud835\udeff\ud835\udeff, is markedly different from the estimated impacts from the 5 placebo tests \ud835\udeff\ud835\udeff!!, , \ud835\udeff\ud835\udeff!!. In the case of SB 1041, we have up to 48 placebo tests, one for each of the 48 states included in the comparison group.76 We use these placebo tests to obtain a distribution of impacts, \ud835\udeff\ud835\udeff!!, , \ud835\udeff\ud835\udeff!!\". If the true impact effect that we observe in California is greater in magnitude than 95 percent of our placebo distribution, we consider the effect to be statistically significant. 76 Based on the recommendations in Abadie, Diamond, and Hainmueller (2010), we exclude placebo studies for states that demonstrate poor fit in the preintervention time period, based on the criteria that the mean squared prediction error for these states must be less than five times larger than the mean squared prediction error for California. Unit 1 Unit 2 Unit 3 Unit 4 Unit 5 Placebo Test 1 Placebo Test 2 Placebo Test 3 Placebo Test 4 Placebo Test 5 294 We use the same logic to inspect whether differences between California and the comparison group were sufficiently small prior to SB 1041. Specifically, all the estimated differences in the years 2005 2012 are defined to be sufficiently small if they fall within the 95-percent confidence interval established by the placebo tests. Details of Specific Analyses Socioeconomic well-being was evaluated using the following outcome measures: proportion of female-headed families without bachelor's degrees and children under the age of 18 living below the poverty line proportion of female-headed families without bachelor's degrees and children under the age of 18 living below 125 percent of the poverty line proportion of female-headed families without bachelor's degrees and children under the age of 18 receiving any form of public assistance proportion of female-headed families without bachelor's degrees and children under the age of 18 receiving TANF proportion of female-headed families without bachelor's degrees and children under the age of 18 unemployed in March of a given year number of weeks employed full time among female-headed families without bachelor's degrees and children under the age of 18 proportion of female-headed families without bachelor's degrees and children under the age of 18 enrolled in school in October proportion of female-headed families without bachelor's degrees and children under the age of 18 participating in job training in October. We obtained data for these outcome measures from the CPS. We include in \ud835\udc4b\ud835\udc4b! and \ud835\udc4b\ud835\udc4b! a common set of covariates for California and the 48 comparison states. These predictors and their sources are summarized in Table F.8. In addition, to control for time-varying unobserved factors, we use the mean preintervention (2005 2012) outcome variables as predictors in each respective model. Using the methods described above, we constructed a weighted comparison group that closely resembles California in the 2005 2012 time period. In the following sections, we present information about the quality of the match between California and the comparison group states for each of the eight outcomes. We also present details from the placebo tests, supporting our inferences about match quality and the impact of SB 1041. 295 Table F.8. Pretreatment Covariates Used in Synthetic Comparison Group Analyses State-Level Variables Source Percentage of adult population who are Hispanic U.S. Census Bureau (undated) Percentage of adult population who are non-Hispanic African American U.S. Census Bureau (undated) Percentage of adult population who are non-Hispanic white U.S. Census Bureau (undated) Percentage of adult population who are foreign born U.S. Census Bureau (undated) Percentage of population age 18 and under U.S. Census Bureau (undated) Percentage of adult population with a bachelor's degree U.S. Census Bureau (undated) Percentage of families below poverty line U.S. Census Bureau (undated) Percentage of families that are single-parent families U.S. Census Bureau (undated) Percentage of births to unmarried women U.S. Centers for Disease Control (2015) Unemployment rate BLS (undated) Maximum monthly income eligibility for TANF Urban Institute (2014) Maximum monthly TANF benefit Urban Institute (2014) Lifetime TANF benefit limit Urban Institute (2014) Analysis of Poverty Rates Poverty rates among female-headed families with children under the age of 18 were measured in two ways: the proportion living below the poverty line, and the proportion living below 125 percent of the poverty line. Baseline characteristics for California and the synthetic comparison, as well as the \ud835\udc49\ud835\udc49-matrix weights, are shown in Tables F.9 and F.10, for the proportion living below the poverty line and the proportion living below 125 percent of the poverty line. The first two columns in Tables F.9 and F.10 display the means for each of the covariates included in the model for California and for the weighted comparison group. These columns show that the comparison states are fairly similar to California in terms of the pretreatment sociodemographic characteristics, and can serve as a defensible counterfactual. The third column shows the \ud835\udc49\ud835\udc49-matrix weights for each covariate. These values represent the relative importance of each of the covariates based upon its power to predict preintervention trends in poverty rates. Covariates with larger values are given more importance. For example, variables capturing the percentage of families that are below the poverty line are given a large amount of importance, whereas the percentage of foreign-born individuals is given little importance. Importantly, characteristics where there are larger differences between California and the comparison group have small V-matrix values and are given relatively little importance. For example, the Maximum Monthly Income Eligibility for Welfare variable shows some imbalance in Table F.9, but this variable is given almost no importance in the analysis. 296 Table F.9. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Living Below the Poverty Line Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.06 <0.005 Percentage of families that are single parent families 0.28 0.28 0.06 Percentage of families below poverty line 0.10 0.10 0.04 Maximum monthly welfare benefit 0.26 0.13 <0.005 Maximum monthly income eligibility for welfare 0.39 0.26 <0.005 Lifetime welfare benefit limit 57.0 60.0 0.01 Percentage age 18 and under 0.26 0.26 0.05 Percentage Hispanic 0.37 0.26 0.04 Percentage non-Hispanic black 0.06 0.09 0.04 Percentage non-Hispanic white 0.41 0.44 0.14 Percentage with college degree 0.30 0.28 0.04 Percentage foreign born 0.27 0.17 0.04 Percentage of births to unmarried women 0.39 0.39 0.03 Percentage below poverty line 2005 2012 0.27 0.27 0.47 Table F.10. Pre-Treatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Living Below 125 Percent of the Poverty Line Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.06 <0.005 Percentage of families that are single parent families 0.28 0.29 0.08 Percentage of families below poverty line 0.10 0.10 0.03 Maximum monthly welfare benefit 0.26 0.21 0.01 Maximum monthly income eligibility for welfare 0.39 0.35 <0.005 Lifetime welfare benefit limit 57.0 55.3 <0.005 Percentage age 18 and under 0.26 0.26 0.02 Percentage Hispanic 0.37 0.24 0.01 Percentage non-Hispanic black 0.06 0.07 0.04 Percentage non-Hispanic white 0.41 0.59 <0.005 Percentage with college degree 0.30 0.29 0.09 Percentage foreign born 0.27 0.14 <0.005 Percentage of births to unmarried women 0.39 0.39 0.07 Percentage below 125 percent of poverty line 2005 2012 0.36 0.36 0.64 297 Tables F.11 and F.12 display the weights of each comparison state for the two poverty measures\u2014i.e., the W weights in Equation (1). The weights in Table F.11. suggest that poverty- rate trends in California prior to the passage of SB 1041 are best reproduced by a weighted combination of Hawaii, New Jersey, Nevada, and Texas, with Texas receiving most of the weight. All other potential comparison states are assigned no weight. The weights in Table F.12 suggest that the 125 percent poverty rate trends in California prior to the passage of SB 1041 are best reproduced by a weighted combination of Alaska, Hawaii, Massachusetts, New Jersey, New Mexico, New York, and Utah, with New Mexico and New York receiving most of the weight. All other potential comparison states are assigned no weight. The V and W weights reported in Tables F.9 to F.12 are used to implement the synthetic comparison group methods and to estimate the counterfactual comparison outcome trends that are presented in Chapter Seven. Table F.11. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Living Below the Poverty Line State Weight Texas 0.55 Hawaii 0.23 New Jersey 0.17 Nevada 0.05 Table F.12. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Living Below 125 Percent of the Poverty Line State Weight New Mexico 0.31 New York 0.28 Utah 0.20 New Jersey 0.12 Alaska 0.09 Massachusetts <0.005 Hawaii <0.005 298 Inferences about whether the implementation of SB 1041 had an impact on poverty were made using the placebo tests described above. Table F.13 summarizes the distributions for each placebo test, and provides a 95-percent confidence interval for each time point in the 2005 2013 period. To recall, we are looking for, ideally, (1) sufficiently small (insignificant) gaps in the pre SB 1041 time period and (2) demonstrably larger gaps in the post SB 1041 time period. The first criteria would give evidence that the comparison group serves as a defensible counterfactual, and the second would give evidence that the policy implementation was impactful. The first and fourth columns of numbers show the difference between California and the comparison group for each year in the period 2005 2013. We use the 2.5th and 97.5th percentiles from the placebo test distributions to create 95-percent confidence intervals to evaluate the magnitude of these differences. If the estimated differences fall within the range of the 2.5th and 97.5th percentiles, we consider the difference to be nonsignificant. If the estimated difference is above the 97.5th percentile or below the 2.5th percentile, we consider the difference to be significant. In the time periods 2005 2012, overall, these 95-percent confidence intervals suggest that there are, in fact, sufficiently small differences between California and the comparison group states. The one exception is in 2009 for the poverty measure. With overall similarity between California and the comparison group states, we believe the inferences about the impacts of SB 1041 are valid. However, in 2013, the estimated differences also fall within the 95-percent confidence intervals, suggesting that there was not a significant impact of SB 1041 on poverty, as measured either by percentage below the poverty line, or percentage below 125 percent of the poverty line. Table F.13. Estimate of Differences Between California and Comparison Groups States with Corresponding 95-Percent Confidence Intervals for Poverty Outcomes Poverty 125 percent of Poverty Placebo States Placebo States Year Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile 2005 0.005 0.023 0.019 0.002 0.040 0.026 2006 0.010 0.017 0.021 0.004 0.027 0.036 2007 0.003 0.034 0.021 0.023 0.034 0.034 2008 0.001 0.026 0.017 0.006 0.024 0.044 2009 0.016 0.015 0.013 0.010 0.033 0.033 2010 0.009 0.014 0.023 0.002 0.037 0.024 2011 0.003 0.019 0.028 0.003 0.043 0.029 2012 0.002 0.030 0.027 0.023 0.032 0.035 2013 0.026 0.070 0.065 0.001 0.076 0.108 299 Analysis of Public Assistance Receipt Receipt of public assistance among female-headed families with children under the age of 18 was measured in two ways: the proportion receiving any public assistance in the previous calendar year and the proportion receiving TANF during the previous calendar year. Baseline characteristics for California and the comparison group states, as well as the \ud835\udc49\ud835\udc49-matrix weights are shown in Tables F.14 and F.15, for proportion receiving any public assistance, and the proportion receiving TANF. The first two columns in Tables F.14 and F.15 display the means for each of the covariates included in the model for California and for the weighted comparison group. These columns show that the comparison states are fairly similar to California in terms of the pretreatment sociodemographic characteristics, and can serve as a defensible counterfactual. The third column shows the \ud835\udc49\ud835\udc49-matrix weights for each covariate. These values represent the relative importance of each of the covariates based upon its power to predict preintervention trends in public assistance receipt. Covariates with larger values are given more importance. For example, variables capturing the percentage of families receiving public assistance in the pre SB 1041 time period are given a large amount of importance, whereas the percentage of individuals with a college degree is given little importance. Importantly, characteristics where there are larger differences between California and the comparison group have small V-matrix values and are given relatively little importance. For example, the variable for the percentage of Hispanics shows some imbalance, but this variable is given almost no importance in either public assistance analysis. Table F.14. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Receiving Any Form of Public Assistance Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.08 0.06 Percentage of families that are single parent families 0.28 0.30 0.11 Percentage of families below poverty line 0.10 0.10 0.08 Maximum monthly welfare benefit 0.26 0.22 0.08 Maximum monthly income eligibility for welfare 0.39 0.34 <0.005 Lifetime welfare benefit limit 57.0 55.7 0.01 Percentage age 18 and under 0.26 0.23 <0.005 Percentage Hispanic 0.37 0.06 0.01 Percentage non-Hispanic black 0.06 0.11 0.03 Percentage non-Hispanic white 0.41 0.78 0.01 Percentage with college degree 0.30 0.29 <0.005 Percentage foreign born 0.27 0.09 <0.005 Percentage of births to unmarried women 0.39 0.39 0.11 Percentage receiving public assistance 2005 2012 0.10 0.10 0.50 300 Table F.15. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Receiving TANF Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.07 <0.005 Percentage of families that are single parent families 0.28 0.28 0.13 Percentage of families below poverty line 0.10 0.08 <0.005 Maximum monthly welfare benefit 0.26 0.19 <0.005 Maximum monthly income eligibility for welfare 0.39 0.28 <0.005 Lifetime welfare benefit limit 57.0 59.8 <0.005 Percentage age 18 and under 0.26 0.23 0.01 Percentage Hispanic 0.37 0.14 0.01 Percentage non-Hispanic black 0.06 0.07 0.08 Percentage non-Hispanic white 0.41 0.67 0.01 Percentage with college degree 0.30 0.36 <0.005 Percentage foreign born 0.27 0.15 0.12 Percentage of births to unmarried women 0.39 0.36 0.09 Percentage receiving TANF 2005 2012 0.08 0.08 0.51 Tables F.16 and F.17 display the weights of each comparison state for the two poverty measures. The weights in Table F.16 suggest that public assistance trends in California prior to the passage of SB 1041 are best reproduced by a weighted combination of Maine, Massachusetts, Michigan, New York, and Vermont, with Michigan receiving most of the weight. All other potential comparison states are assigned no weight. The weights in Table F.17 suggest that the TANF receipt trends in California prior to the passage of SB-1041 are best reproduced by a weighted combination of Hawaii, Massachusetts, New Jersey, New Mexico, New York and Rhode Island, with Massachusetts receiving most of the weight. All other potential comparison states are assigned no weight. Table F.16. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Receiving Any Public Assistance State Weight Michigan 0.57 Massachusetts 0.18 New York 0.11 Maine 0.09 Vermont 0.05 301 Table F.17. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Receiving TANF State Weight Massachusetts 0.59 New Jersey 0.20 New Mexico 0.09 Hawaii 0.07 Rhode Island 0.05 New York <0.005 The V and W weights reported in Tables F.14 F.17 are used to implement the synthetic comparison group methods and to estimate the counterfactual comparison outcome trends that are presented in Chapter Seven. Inferences about whether the implementation of SB 1041 had an impact on public assistance were made using the placebo tests described above. Table F.18 summarizes the distributions for each placebo test, and provides a 95-percent confidence interval for each time point in the 2005 2013 period. As a reminder, we are looking for, ideally, (1) sufficiently small (insignificant) gaps in the pre SB 1041 time period and (2) demonstrably larger gaps in the post SB 1041 time period. Table F.18. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for Public Assistance Outcomes Public Assistance TANF Placebo States Placebo States Year Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile 2005 0.012 0.036 0.038 0.003 0.038 0.038 2006 0.018 0.041 0.047 0.007 0.032 0.043 2007 0.026 0.032 0.028 0.016 0.028 0.022 2008 0.005 0.049 0.044 0.006 0.041 0.041 2009 0.001 0.026 0.056 0.020 0.028 0.051 2010 0.025 0.042 0.044 0.040 0.029 0.047 2011 0.025 0.033 0.041 0.017 0.024 0.042 2012 0.039 0.043 0.035 0.021 0.044 0.034 2013 0.068 0.067 0.080 0.025 0.057 0.082 302 We use the 2.5th and 97.5th percentiles from the placebo test distributions to create 95-percent confidence intervals to evaluate the magnitude of these differences. If the estimated differences fall within the range of the 2.5th and 97.5th percentiles, we consider the difference to be sufficiently small. If the estimated difference is above the 97.5th percentile or below the 2.5th percentile, we consider the difference to be significant. In the time periods 2005 2012, overall, these 95-percent confidence intervals suggest that there are, in fact, sufficiently small differences between California and the comparison group. With overall similarity between California and the comparison group, we believe the inferences on the impacts of SB 1041 are valid. However, in 2013, the estimated differences also fall within the 95-percent confidence intervals, suggesting that there was not a significant impact of SB 1041 on public assistance receipt, as measured by either percentage receiving any form of public assistance or percentage receiving TANF. Analysis of Employment Employment among female-headed families with children under the age of 18 was measured in two ways: the proportion of unemployed families at the time of the March survey, and the number of weeks worked full time in the calendar year (available through 2013). Baseline characteristics for California and the comparison group states, as well as the \ud835\udc49\ud835\udc49-matrix weights, are shown in Tables F.19 and F.20, for proportion unemployed and the number of weeks employed full time. Table F.19. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Unemployed in March Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.08 0.10 Percentage of families that are single parent families 0.28 0.29 0.06 Percentage of families below poverty line 0.10 0.09 0.03 Maximum monthly welfare benefit 0.26 0.19 0.01 Maximum monthly income eligibility for welfare 0.39 0.39 0.09 Lifetime welfare benefit limit 57.0 58.1 0.04 Percentage age 18 and under 0.26 0.24 <0.005 Percentage Hispanic 0.37 0.12 <0.005 Percentage non-Hispanic black 0.06 0.08 0.03 Percentage non-Hispanic white 0.41 0.60 0.05 Percentage with college degree 0.30 0.29 0.16 Percentage foreign born 0.27 0.13 <0.005 Percentage of births to unmarried women 0.39 0.40 0.04 Percentage unemployed in March 2005 2012 0.08 0.08 0.25 303 Table F.20. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Number of Weeks Employed Full-Time Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.06 <0.005 Percentage of families that are single parent families 0.28 0.28 0.11 Percentage of families below poverty line 0.10 0.11 0.02 Maximum monthly welfare benefit 0.26 0.16 0.01 Maximum monthly income eligibility for welfare 0.39 0.27 <0.005 Lifetime welfare benefit limit 57.0 50.6 <0.005 Percentage age 18 and under 0.26 0.27 <0.005 Percentage Hispanic 0.37 0.27 0.01 Percentage non-Hispanic black 0.06 0.05 0.01 Percentage non-Hispanic white 0.41 0.60 0.04 Percentage with college degree 0.30 0.27 0.02 Percentage foreign born 0.27 0.13 0.05 Percentage of births to unmarried women 0.39 0.38 <0.005 Number of weeks worked 2005 2012 21.8 22.3 0.66 The first two columns in Tables F.19 and F.20 display the means for each of the covariates included in the model for California and for the weighted comparison group. These columns show that the comparison states are fairly similar to California in terms of the pretreatment sociodemographic characteristics, and can serve as a defensible counterfactual. The third column shows the \ud835\udc49\ud835\udc49-matrix weights for each covariate. Variables capturing average employment trends in the pre-SB 1041 time period are given a large amount of importance. Importantly, characteristics where there are larger differences between California and the comparison group have small V-matrix values and are given relatively little importance. Tables F.21 and F.22 display the weights of each comparison state for the two employment measures. The weights in Table F.21 suggest that unemployment trends in California prior to the passage of SB-1041 are best reproduced by a weighted combination of Alaska, Hawaii, Illinois, Michigan, Nevada, New Jersey, and Rhode Island, with Illinois, Rhode Island, and Hawaii receiving most of the weight. All other potential comparison states are assigned no weight. The weights in Table F.22 suggest that the full time employment trends in California prior to the passage of SB-1041 are best reproduced by a weighted combination of Arizona, Massachusetts, New Mexico, New York, Texas, and Utah, with Arizona and Utah receiving most of the weight. All other potential comparison states are assigned no weight. 304 Table F.21. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Unemployed in March State Weight Illinois 0.29 Rhode Island 0.22 Hawaii 0.21 Michigan 0.13 Nevada 0.09 Alaska 0.07 New Jersey <0.005 Table F.22. Comparison Group States and Their Associated Weights for Comparisons with California in the Number of Weeks Employed Full-Time State Weight Arizona 0.30 Utah 0.26 New Mexico 0.17 Texas 0.15 New York 0.12 Massachusetts <0.005 The V and W weights reported in Tables F.19 F.22 are used to implement the synthetic comparison group methods and to estimate the counterfactual comparison outcome trends that are presented in Chapter Seven. Inferences about whether the implementation of SB 1041 had an impact on employment were made using placebo tests. Table F.23 summarizes the distributions for each placebo test, and provides a 95-percent confidence interval for each time point in the 2005 2015 period for unemployment, and for each time point in the 2005 2013 time period for weeks worked full time. As a reminder, we are looking for, ideally, (1) sufficiently small (insignificant) gaps in the pre SB 1041 time period and (2) demonstrably larger gaps in the post-SB 1041 time period. 305 Table F.23. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for Employment Outcomes Unemployment in March Weeks Worked Full-Time Placebo States Placebo States Year Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile 2005 0.004 0.008 0.016 0.466 1.946 2.064 2006 0.002 0.015 0.016 1.111 1.822 2.006 2007 0.010 0.015 0.013 1.110 1.516 2.421 2008 0.000 0.008 0.013 0.254 2.133 2.178 2009 0.005 0.021 0.008 0.414 1.963 2.250 2010 0.006 0.012 0.020 1.186 1.863 2.688 2011 0.002 0.011 0.014 0.030 1.670 2.184 2012 0.006 0.007 0.010 0.997 1.699 2.300 2013 0.005 0.036 0.049 0.718 6.084 5.694 2014 0.002 0.043 0.058 \u2014 \u2014 \u2014 2015 0.029 0.033 0.053 \u2014 \u2014 \u2014 We use the 2.5th and 97.5th percentiles from the placebo test distributions to create 95-percent confidence intervals to evaluate the magnitude of these differences. In the time periods 2005 2012, overall, these 95-percent confidence intervals suggest that there are, in fact, sufficiently small differences between California and the comparison group states. With overall similarity between California and the comparison group, we believe the inferences the impacts of SB 1041 are valid. However, in the post SB 1041 years, the estimated differences also fall within the 95-percent confidence intervals, suggesting that there was not a significant impact of SB 1041 on employment, as measured either by March unemployment rates or the number of full-time weeks of employment in the prior calendar year. Analysis of Schooling and Training Schooling was measured as the proportion of household heads that were enrolled in school programs at the time of the October supplement. Training was measured as the proportion of household heads that were participating in job-training programs during the same time period. Baseline characteristics for California and the comparison group states, as well as the \ud835\udc49\ud835\udc49-matrix weights, are shown in Tables F.24 and F.25, for proportion enrolled in school, and the proportion participating in job training. 306 Table F.24. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Enrolled in School in October Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.07 0.03 Percentage of families that are single parent families 0.28 0.29 0.10 Percentage of families below poverty line 0.10 0.09 0.12 Maximum monthly welfare benefit 0.26 0.21 0.04 Maximum monthly income eligibility for welfare 0.39 0.39 0.12 Lifetime welfare benefit limit 57.00 60.00 0.06 Percentage age 18 and under 0.26 0.25 0.17 Percentage Hispanic 0.37 0.18 <0.001 Percentage non-Hispanic black 0.06 0.07 0.05 Percentage non-Hispanic white 0.41 0.52 0.05 Percentage with college degree 0.30 0.27 0.05 Percentage foreign born 0.27 0.15 0.04 Percentage of births to unmarried women 0.39 0.40 0.09 Percentage enrolled in school 2005 2012 0.11 0.10 0.05 Table F.25. Pretreatment Covariate Balance and V-Matrix Weights for Comparisons with California in the Proportion Participating in Job Training Variable California Comparison V-Matrix Weight Unemployment rate 0.09 0.07 0.05 Percentage of families that are single parent families 0.28 0.30 0.15 Percentage of families below poverty line 0.10 0.10 0.12 Maximum monthly welfare benefit 0.26 0.18 0.01 Maximum monthly income eligibility for welfare 0.39 0.36 0.03 Lifetime welfare benefit limit 57.0 60.0 0.02 Percentage age 18 and under 0.26 0.26 <0.001 Percentage Hispanic 0.37 0.24 0.03 Percentage non-Hispanic black 0.06 0.07 0.05 Percentage non-Hispanic white 0.41 0.56 0.03 Percentage with college degree 0.30 0.26 0.03 Percentage foreign born 0.27 0.13 <0.001 Percentage of births to unmarried women 0.39 0.39 0.22 Percentage participating in job training 2005 2012 0.03 0.03 0.21 The first two columns in Tables F.24 and F.25 show that the comparison states are fairly similar to California in terms of the pretreatment sociodemographic characteristics, and can serve as a defensible counterfactual. The third column shows the \ud835\udc49\ud835\udc49-matrix weights for each covariate. 307 Importantly, characteristics where there are larger differences between California and the comparison group have small V-matrix values and are given relatively little importance. Tables F.26 and F.27 display the weights of each comparison state for the two schooling measures. The weights in Table F.26 suggest that schooling trends in California prior to the passage of SB 1041 are best reproduced by a weighted combination of Alaska, Hawaii, Nevada, New Jersey, New York and Texas, with Alaska and Texas receiving most of the weight. All other potential comparison states are assigned no weight. The weights in Table F.27 suggest that the job training participation trends in California prior to the passage of SB 1041 are best reproduced by a weighted combination of Alaska, Colorado, Nevada, New Mexico, Texas, and Washington, with Texas and Alaska receiving most of the weight. All other potential comparison states are assigned no weight. The V and W weights reported in Tables F.24 F.27 are used to implement the synthetic comparison group methods and to estimate the counterfactual comparison outcome trends that are presented in Chapter Seven. Table F.26. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Enrolled in School in October State Weight Alaska 0.30 Texas 0.24 New York 0.16 Hawaii 0.16 Nevada 0.15 New Jersey <0.005 Table F.27. Comparison Group States and Their Associated Weights for Comparisons with California in the Proportion Participating in Job Training State Weight Texas 0.32 Alaska 0.30 Nevada 0.22 Colorado 0.10 New Mexico 0.06 Washington <0.005 308 Inferences about whether the implementation of SB 1041 had an impact on schooling were made using placebo tests. Table F.28 summarizes the distributions for each placebo test, and provides a 95-percent confidence interval for each time point in the 2005 2014 period. As a reminder, we are looking for, ideally, (1) sufficiently small (insignificant) gaps in the pre SB 1041 time period and (2) demonstrably larger gaps in the post SB 1041 time period. The first and fourth columns of numbers show the difference between California and the comparison group for each year in the analysis period. We use the 2.5th and 97.5th percentiles from the placebo tests to create a 95-percent confidence interval to evaluate the magnitude of these differences. In the time periods 2005 2012, overall, these 95-percent confidence intervals suggest that there are, in fact, sufficiently small differences between California and the comparison group states. The one exception is 2006 for the school enrollment outcome. With overall similarity between California and the comparison, we believe the inferences of the impacts of SB 1041 are valid. However, in 2013 and 2014, the gap estimates also fall within the 95-percent confidence intervals, suggesting that there was not a significant impact of SB 1041 on schooling, as measured either by school enrollment or job-training participation. Table F.28. Estimate of Gaps Between California and Its Comparison State and Corresponding 95-Percent Confidence Intervals for School and Training Outcomes School Enrollment in October Participation in Job Training Placebo States Placebo States Year Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile Difference Between California and Comparison Group 2.5th Percentile 97.5th Percentile 2005 0.008 0.009 0.008 0.004 0.016 0.012 2006 0.011 0.023 0.009 0.006 0.009 0.009 2007 0.008 0.025 0.032 0.005 0.017 0.012 2008 0.009 0.018 0.018 0.003 0.013 0.013 2009 0.007 0.018 0.022 0.003 0.010 0.011 2010 0.005 0.014 0.010 0.003 0.007 0.014 2011 0.006 0.019 0.025 0.002 0.011 0.014 2012 0.000 0.024 0.031 0.006 0.012 0.010 2013 0.015 0.048 0.046 0.005 0.024 0.032 2014 0.006 0.047 0.035 0.011 0.021 0.054 309 References AB 74\u2014See Assembly Bill No. 74. AB 98\u2014 See Assembly Bill No. 98. AB 1468\u2014See Assembly Bill No. 1468. AB X4 4\u2014See Assembly Bill No. X4. 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Bos, Aleksandra Holod, and Charles Blankenship, Evaluation of the SB 1041 Reforms to California's CalWORKs Program: Background and Study Design, RR-919, Santa Monica, Calif.: RAND Corporation, 2015. As of March 1, 2016: http:\/\/www.rand.org\/pubs\/research_reports\/RR919.html Kaul, A., S. Kl\u00f6\u00dfner, G. Pfeifer, and M. Schieler, Synthetic Control Methods: Never Use All Pre- Intervention Outcomes as Economic Predictors, 2015. As of March 1, 2016: http:\/\/www.oekonometrie.uni-saarland.de\/papers\/SCM_Predictors.pdf Klerman, Jacob Alex, and Jane McClure Burstain, Sanctions in the CalWORKs Program, Santa Monica, Calif.: RAND Corporation, TR-540-CDSS, 2008. As of February 9, 2015: http:\/\/www.rand.org\/pubs\/technical_reports\/TR540.html Klerman, Jacob Alex, and Patricia A. Ebener, Welfare Reform in California: Results of the 1999 All-County Implementation Survey, Santa Monica, Calif.: RAND Corporation, MR-1180- CDSS, 2001. As of March 1, 2016: http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1180.html Klerman, Jacob Alex, V. Joseph Hotz, Elaine Reardon, Amy G. Cox, Donna O. Farley, Steven Haider, Guido Imbens, and Robert F. Schoeni, Welfare Reform in California: Early Results from the Impact Analysis, Santa Monica, Calif.: RAND Corporation, MR-1358-CDSS, 2003. As of February 9, 2015: http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1358.html http:\/\/www.irp.wisc.edu\/publications\/dps\/pdfs\/dp122401.pdf https:\/\/aspe.hhs.gov\/legacy-page\/aspe-nawrs-presentation-cross-state-examination-families-leaving-welfare-findings-aspe-funded-leavers-studies-149916 http:\/\/www.rand.org\/pubs\/research_reports\/RR919.html http:\/\/www.oekonometrie.uni-saarland.de\/papers\/SCM_Predictors.pdf http:\/\/www.rand.org\/pubs\/technical_reports\/TR540.html http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1180.html http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1358.html 315 Klerman, Jacob Alex, Gail L. Zellman, Tammi Chun, Nicole Humphrey, Elaine Reardon, Donna O. Farley, Patricia A. Ebener, and Paul S. Steinberg, Welfare Reform in California: State and County Implementation of CalWORKs in the Second Year, Santa Monica, Calif.: RAND Corporation, MR-1177-CDSS, 2001. As of March 1, 2016: http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1177.html RAND Working Paper WR-743 Legislative Analyst's Office, The 2012 13 Budget: The Governor's CalWORKs and Child Care Proposals, February 22, 2012. As of June 16, 2016: http:\/\/www.lao.ca.gov\/analysis\/2012\/ss\/calworks-child-care-022212.aspx London, Rebecca A., and Jane G. Mauldon, Time Running Out: A Portrait of California Families Reaching the CalWORKs Time Limit in 2004, Oakland, Calif.: Welfare Policy Research Project, November 2006. Matsudaira, J. D., and R. M. Blank, The Impact of Earnings Disregards on the Behavior of Low-Income Families, Journal of Policy Analysis and Management, Vol. 22, 2014, pp. 7 35. Morgan, S. L., and C. Winship, Counterfactuals and Causal Inference, Cambridge, UK: Cambridge University Press, 2014. New Web-Based Public Assistance Eligibility System to Serve over 3.5 Million, Sentinel News Service, October 7, 2015. As of June 16, 2016: https:\/\/lasentinel.net\/new-web-based-public-assistance-eligibility-system-to-serve-over-3-5- million.html Public Policy Institute of California, CalWORKS in Transition, March 2012. As of June 16, 2016: http:\/\/www.ppic.org\/main\/publication_quick.asp?i=1011 RAND Corporation, SB 1041 2016 All-County Survey (ACS), undated. As of June 16, 2016: http:\/\/www.rand.org\/labor\/CalWORKs\/acs.html Reardon, Elaine, Christine DeMartini, and Jacob Alex Klerman, Results from the First California Health and Social Services Survey, Santa Monica, Calif.: RAND Corporation, TR-121-CDSS, 2004. As of March 1, 2016: http:\/\/www.rand.org\/pubs\/technical_reports\/TR121.html Reed, Diane F., and Kate Karpilow, Understanding CalWORKs: A Primer for Service Providers and Policymakers, Sacramento, Calif.: California Center for Research on Women and Families, 2010. As of March 1, 2016: http:\/\/www.ccrwf.org\/wp-content\/uploads\/2010\/05\/ccrwf-calworks-primer-2nd-edition.pdf Rubin, D. B., Estimating Causal Effects of Treatments in Randomized and Nonrandomized Studies, Journal of Educational Psychology, Vol. 66, No. 5, 1974. http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1177.html http:\/\/www.lao.ca.gov\/analysis\/2012\/ss\/calworks-child-care-022212.aspx https:\/\/lasentinel.net\/new-web-based-public-assistance-eligibility-system-to-serve-over-3-5-million.html http:\/\/www.ppic.org\/main\/publication_quick.asp?i=1011 http:\/\/www.rand.org\/labor\/CalWORKs\/acs.html http:\/\/www.rand.org\/pubs\/technical_reports\/TR121.html http:\/\/www.ccrwf.org\/wp-content\/uploads\/2010\/05\/ccrwf-calworks-primer-2nd-edition.pdf 316 SB 72\u2014 See Senate Bill No. 72. SB 855\u2014 See Senate Bill No. 855. SB 1041\u2014See Senate Bill No. 1041. SB 1104\u2014 See Senate Bill No. 1104. Schott, Liz, and LaDonna Pavetti, Changes in TANF Work Requirements Could Make Them More Effective in Promoting Employment, Washington, D.C.: Center on Budget and Policy Priorities, 2013. As of June 16, 2016: http:\/\/www.cbpp.org\/sites\/default\/files\/atoms\/files\/2-26-13tanf.pdf Seawright, J., and J. Gerring, Case Selection Techniques in Case Study Research: A Menu of Qualitative and Quantitative Options, Political Research Quarterly, Vol. 61, No. 2, 2008, pp. 294 308. Senate Bill No. 72, California Budget Act of 2011, Chapter 8, Human Services, Sacramento, Calif., 2011. Senate Bill No. 855, California Budget Act of 2013, Chapter 29, Human Services, Sacramento, Calif., 2013. Senate Bill No. 1041, California Budget Act of 2012, Chapter 47, Human Services, Sacramento, Calif., 2012. Senate Bill No. 1104, California Budget Act of 2004, Chapter 229, Human Services, Sacramento, Calif., 2004. Shadish, W.R., T. D. Cook, and D. T. Campbell, Experimental and Quasi-Experimental Designs for Generalized Causal Inference, Boston, Mass.: Cengage Learning, 2002. State of California, Welfare Data Tracking Implementation Project, 2014. As of August 29, 2016: http:\/\/www.wdtip.ca.gov Urban Institute, Welfare Rules Databook, Washington, D.C., 2014. As of March 1, 2016: http:\/\/anfdata.urban.org\/wrd\/databook.cfm U.S. Bureau of Labor Statistics, Local Area Unemployment Statistics, Washington, D.C., undated. As of March 1, 2016: http:\/\/www.bls.gov\/lau\/ \u2014\u2014\u2014, Consumer Price Index Detailed Reports, Washington, D.C., 2015a. As of March 1, 2016: http:\/\/www.bls.gov\/cpi\/ http:\/\/www.cbpp.org\/sites\/default\/files\/atoms\/files\/2-26-13tanf.pdf http:\/\/www.wdtip.ca.gov http:\/\/anfdata.urban.org\/wrd\/databook.cfm http:\/\/www.bls.gov\/lau\/ http:\/\/www.bls.gov\/cpi\/ 317 \u2014\u2014\u2014, Handbook of Methods, Washington, D.C., 2015b. As of March 1, 2016: http:\/\/www.bls.gov\/opub\/hom\/ U.S. Census Bureau, American FactFinder, Washington, D.C., undated. March 1, 2016: http:\/\/factfinder.census.gov\/faces\/nav\/jsf\/pages\/index.xhtml U.S. Centers for Disease Control and Prevention, Births: Final Data for 2013, National Vital Statistics Reports, Vol. 64, No. 1, 2015. U.S. Department of Health and Human Services, TANF Tenth Report to Congress, Washington, D.C.: Office of Family Assistance, Administration for Children and Families, 2013. As of March 1, 2016: http:\/\/www.acf.hhs.gov\/programs\/ofa\/resource\/tenth-report-to-congress Zellman, Gail L., Jacob Alex Klerman, Elaine Reardon, Donna O. Farley, Nicole Humphrey, Tammi Chun, and Paul S. Steinberg, Welfare Reform in California: State and County Implementation of CalWORKs in the First Year, Santa Monica, Calif.: RAND Corporation, MR-1051-CDSS, 1999. As of February 9, 2015: http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1051.html http:\/\/www.bls.gov\/opub\/hom\/ http:\/\/factfinder.census.gov\/faces\/nav\/jsf\/pages\/index.xhtml http:\/\/www.acf.hhs.gov\/programs\/ofa\/resource\/tenth-report-to-congress http:\/\/www.rand.org\/pubs\/monograph_reports\/MR1051.html www.rand.org RR-1348-CDSS EDUCATION and RAND LABOR AND POPULATION 9 7 8 0 8 3 3 0 9 5 5 5 8 ISBN-13 978-0-8330-9555-8 ISBN-10 0-8330-9555-2 59600 $96.00 The California Budget Act of 2012, through trailer Senate Bill (SB) 1041, contained significant reforms to the California Work Opportunity and Responsibility to Kids (CalWORKs) program. CalWORKs is California's Temporary Assistance for Needy Families (TANF) program, a central component of the safety net that provides cash aid for low-income families with children. The SB 1041 reforms to CalWORKs aim to engage participants in more-intensive work activities as early as possible, while also providing more flexibility in work activity options and increased incentives for work as participants move toward self-sufficiency. The California legislature included a provision in the bill for an independent evaluation to determine if SB 1041 is achieving its objectives and if there are any unintended consequences. Following the background and study design report, this first evaluation report provides initial findings from the process study based on the first wave of an online All-County Survey (ACS) and qualitative data from state-level interviews and interviews and focus groups conducted in six focal counties. Findings from the status and tracking studies are based on analysis of state administrative data. Initial insights on participant outcomes in terms of welfare use and employment are explored with state administrative data and nationally representative data from the Current Population Survey. Future reports will be based on further qualitative and quantitative data collection, including a second wave of the ACS, additional interviews and focus groups in the focal counties, both state- and county-level administrative data, and the first wave of the California Socioeconomic Survey. http:\/\/www.rand.org "

” United States Department of Agriculture Office of Inspector General What Were OIG’s Objectives OIG evaluated FNS’ controls over SNAP administrative costs, with a specific focus on whether States with county- administered programs were effectively and efficiently controlling costs and minimizing variances. What OIG Reviewed From October 2015 to June 2016, we reviewed FNS’ controls, operations, and policies for SNAP administrative costs. We visited State and county offices for county- administered food assistance programs in California, New York, and Ohio to review FY 2014 expense records and controls for monitoring and reporting costs. What OIG Recommends FNS needs to deobligate over $111 million of invalid obligations in California, and recover $3.6 million from Ohio. Also, FNS needs to identify the causes for the cost-per-case variances between States. Finally, the agency should issue guidance to its regional offices for conducting financial management reviews, and to the States for filing expenditure claims and reports in accordance with Federal laws. OIG reviewed FNS and State oversight and monitoring of reimbursable SNAP administrative costs from programs administered by counties. What OIG Found The Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) and the States should strengthen financial management controls to improve efficiency and the effective use of over $3.6 billion of Supplemental Nutrition Assistance Program (SNAP) administrative funds. FNS could be more proactive in analyzing and containing variances in SNAP costs-per-case, which range from $10 per case to as high as $34 per case in States with county-administered programs, suggesting possible waste and operational inefficiencies. The agency’s regional offices’ financial management reviews and risk assessments are not consistent, and the national office has not developed guidance to ensure consistent results. Weaknesses in State and county financial management controls and a lack of effective FNS oversight led to inaccurate program financial reporting and questioned costs. California did not properly establish financial obligations, resulting in $111 million in unsupported obligations for fiscal year (FY) 2014. Although required to ensure State compliance with Federal financial management regulations, FNS Western Regional Office (WRO) management allowed California to submit estimates rather than the required actual costs. In Ohio, the State and counties inappropriately commingled costs, rendering $3.6 million unallowable. States and counties reported expenditures for payment in FY 2014 for costs that were incurred in FY 2013, because FNS continues to allow States to use a process that is out of compliance with Federal law, which we identified in previous audit reports. FNS generally concurred with our recommendations and OIG was able to accept management decision for 8 of the 14 recommendations. Further action from the agency is needed before management decision can be reached for the remaining recommendations. SNAP Administrative Costs Audit Report 27601-0003-22 United States Department of Agriculture Office of Inspector General Washington, D.C. 20250 DATE: September 29, 2016 AUDIT NUMBER: 27601-0003-22 TO: Audrey Rowe Administrator Food and Nutrition Service ATTN: Mark Porter Director Office of Internal Controls, Audits and Investigations FROM: Gil H. Harden Assistant Inspector General for Audit SUBJECT: SNAP Administrative Costs This report presents the results of the subject review. Your written response to the official draft is included in its entirety at the end of the report. Your responses and the Office of Inspector General’s (OIG) position are incorporated into the relevant sections of the report. Based on your written responses, we have accepted management decision on Recommendations 3, 5, 6, 7, 8, 9, 11, and 14. Management decision has not been reached for Recommendations 1, 2, 4, 10, 12, and 13. The actions needed to reach management decision for these recommendations are described under the relevant OIG Position sections. In accordance with Departmental Regulation 1720-1, please furnish a reply within 60 days describing the corrective actions taken or planned, and timeframes for implementing the recommendations for which management decisions have not been reached. Please note that the regulation requires management decision to be reached on all recommendations within 6 months from report issuance, and final action to be taken within 1 year of each management decision to prevent being listed in the Department’s annual Agency Financial Report. Please follow your internal agency procedures in forwarding final action correspondence to the Office of the Chief Financial Officer. We appreciate the courtesies and cooperation extended to us by members of your staff during our audit fieldwork and subsequent discussions. This report contains publicly available information and will be posted in its entirety to our website (http:\/\/www.usda.gov\/oig) in the near future. http:\/\/www.usda.gov\/oig Table of Contents Background and Objectives ………………………………………………………………………… 1 Section 1: FNS Reviews and Monitoring Could be Strengthened ………………… 4 Finding 1: FNS Should Determine Causes of Variances and Identify and Share Best Practices to Contain Costs …………………………………………………………. 4 Recommendation 1 ……………………………………………………………………………. 7 Recommendation 2 ……………………………………………………………………………. 8 Finding 2: FNS Needs to Conduct Financial Management Reviews More Consistently ……………………………………………………………………………………………….. 9 Recommendation 3 ………………………………………………………………………….. 11 Recommendation 4 ………………………………………………………………………….. 11 Section 2: Deficiencies in FNS Oversight and the Lack of Effective State and County Financial Management Controls Led to Inaccurate Program Financial Reporting ………………………………………………………………………………….. 12 Finding 3: FNS Internal Reviews Did Not Identify More Than $111 Million in Unsupported Unliquidated Obligations for California ……………………………….. 12 Recommendation 5 ………………………………………………………………………….. 15 Recommendation 6 ………………………………………………………………………….. 16 Recommendation 7 ………………………………………………………………………….. 16 Recommendation 8 ………………………………………………………………………….. 16 Finding 4: FNS Needs to Provide Adequate Oversight to Ensure Expenditures are Charged to the Appropriate Fiscal Year ………………………… 18 Recommendation 9 ………………………………………………………………………….. 20 Recommendation 10 ………………………………………………………………………… 20 Finding 5: Ohio Needs to Establish Controls to Ensure Proper Reporting of Grant Funds …………………………………………………………………………………………….. 22 Recommendation 11 ………………………………………………………………………… 25 Recommendation 12 ………………………………………………………………………… 25 Finding 6: California Needs to Submit Timely Reports of Actual Expenditures Instead of Estimated Expenditures ………………………………………. 26 Recommendation 13 …………………………………………………………………………27 Recommendation 14 …………………………………………………………………………28 Scope and Methodology …………………………………………………………………………….29 Abbreviations ……………………………………………………………………………………………31 Exhibit A: Summary of Monetary Results………………………………………………….32 Recommendation 12 ………………………………………………………………………… 25 Finding 6: California Needs to Submit Timely Reports of Actual Expenditures Instead of Estimated Expenditures ……………………………………………………………. 26 Recommendation 13 ………………………………………………………………………… 27 Recommendation 14 ………………………………………………………………………… 28 Scope and Methodology ……………………………………………………………………………. 29 Abbreviations …………………………………………………………………………………………… 31 Exhibit A: Summary of Monetary Results …………………………………………………. 32 Exhibit B: Audit Sites Visited …………………………………………………………………… 33 Agency’s Response ……………………………………………………………………………………. 34 Background and Objectives AUDIT REPORT 27601-0003-22 1 Background The Supplemental Nutrition Assistance Program (SNAP) is authorized by the Food and Nutrition Act of 2008, as amended.1 It was reauthorized by the Agriculture Act of 2014 and is the nation’s largest food and nutrition assistance program.2 SNAP was designed to increase the food purchasing power of eligible low-income households and help them afford a more nutritious diet. In fiscal year (FY) 2014, State agencies issued SNAP benefits of about $70 billion to 46.5 million people participating in the program. SNAP is administered by the Food and Nutrition Service (FNS) national office, seven FNS regional offices, and State agencies.3 In addition, some States administer SNAP at the county level. These States pass Federal SNAP administrative funds through to the counties for program functions performed by county agencies. FNS oversees the States’ implementation of SNAP to ensure they carry out the program in accordance with Federal laws and regulations. States are responsible for determining whether the recipient’s household meets the program’s eligibility requirements, calculating monthly benefits for qualified households, and issuing benefits to those households. FNS funds the full cost of SNAP benefits and generally reimburses the States for 50 percent of their administrative costs. In FY 2014, the Federal share of SNAP administrative costs nationwide totaled over $3.6 billion. Half of these costs ($1.8 billion) were incurred by States that are administered at the county level. Out of the 53 States and territories that participate in SNAP, 10 are administered at the county level.4 The FY 2014 average administrative cost per SNAP case (i.e., per household) per month for these 10 county-administered States is over $21, as opposed to under $10 per case for the State-administered States. The cost-per-case varied significantly among the 10 county- administered States in FY 2014, with costs ranging as high as $34 (California) and as low as $10 (Ohio) per case. Federal regulations establish uniform requirements for the management of SNAP administrative funds provided to State agencies. Appendix A, Principles for Determining Costs Applicable to Administration of SNAP by State Agencies, sets forth the principles for determining the allowable costs of administering the program.5 In addition, the Office of Management and Budget (OMB) Circular A-87 provides cost principles for State, local, and Indian Tribal 1 SNAP was initially authorized as the Food Stamp Program via the Food Stamp Act of 1964. In 2008, the Food Stamp Act was renamed the Food and Nutrition Act of 2008, and the Food Stamp Program was renamed the Supplemental Nutrition Assistance Program. See Food, Conservation, and Energy Act of 2008, Pub. L. No. 110-246, 4001, 122 Stat. 1651, 1853. Agricultural Act of 2014, Pub. L. No. 113-79, 128 Stat. 649 (2014 Farm Bill). 3 The program is operated in 50 States, the District of Columbia, Guam, and the Virgin Islands. Puerto Rico, Northern Marianas, and American Samoa receive Nutrition Assistance Program block grants in lieu of SNAP. The 10 county-administered States are California, Colorado, Minnesota, New Jersey, New York, North Carolina, North Dakota, Ohio, Virginia, and Wisconsin. 5 7 C.F.R. 277.1. 2 4 governments. 2 AUDIT REPORT 27601-0003-22 6 A State agency and its counties administering SNAP base their direct and indirect administrative costs on their cost allocation plans (CAP) approved by the United States Department of Health and Human Services, the cognizant Federal agency.7 SNAP administrative costs are charged directly or allocated based on approved methodologies, including random moment time studies. Under random moment time studies, management selects a statistical sample of employees to indicate the programs they worked on at the sample time. The information is compiled and used to distribute costs to each program. State agencies report their cumulative SNAP expenditures on the FNS-778 SNAP worksheet, which is then summarized and reported on the Federal Financial Report Standard Form (SF) 425. The States are reimbursed for their SNAP administrative expenditures based on the information reported on these reports. These forms are due 30 days after the end of each quarter, with a final annual report due December 30. The State agencies may amend the final report up to 3 years after the end of the fiscal year, and may receive reimbursement for expenses that are reported within 2 years after the quarter in which the expenditure was incurred. Costs claimed on SF-425 are reported in various categories including Certification, Automated Data Processing, Employment and Training (E&T), and Fraud Control. Certification typically accounts for 60 percent of all costs and includes costs related to accepting and processing the applications, salaries, benefits, travel expenses, supervisory, clerical, and other support costs. FNS relies on its own national and regional office reviews to ensure funds provided for SNAP administration have been used as approved. FNS regional offices conduct financial management reviews, which serve as the primary management control to ensure that State administrative expense claims are accurate and allowable. Obtaining such assurance is central to validating FNS’ disbursement of Federal funds to States. At least once every 5 years, an FNS regional office must perform a financial management review of SNAP for each State agency. Financial management reviews evaluate the use of Federal funds, reporting and recordkeeping, review of the claims payment process, implementation of the State agency’s monitoring responsibilities, and initiation and completion of corrective action. Federal agencies also use the OMB A-133 single audit process as a key tool to drive accountability for grants awarded to States. State and local governments are required by the Single Audit Act to have an annual audit of their Federal awards.8 6 Effective December 26, 2014, 2 C.F.R. Part 200, commonly referred to as the Super-Circular, replaced Federal grants management rules in 7 C.F.R. Parts 3016, 3019, and 3052; and the cost principles in 2 C.F.R. Parts 220 (A- 21), 225 (A-87), and 230 (A-122) for FNS and State agencies. OMB Circular A-87 requires two types of CAPs. The Central Services or Statewide cost allocation plan is used to allocate costs of central service organizations (e.g., print shops, mail rooms, etc.) to the user organizations that operate Federal programs. The Public Assistance Cost Allocation Plan (PACAP) is a special-purpose CAP used by State and local service agencies to allocate costs to Federal programs such as SNAP, Temporary Aid to Needy Families, or Medicaid. All administrative costs (direct and indirect) are normally charged to Federal awards by implementing the PACAP. 7 8 Single Audit Act of 1984, Public Law 98-502, and the Single Audit Act Amendments of 1996, Public Law 104- 156. Objectives The objective of our audit was to evaluate FNS’ controls over SNAP administrative costs. Specifically, our objective was to determine if States with county-administered programs were effectively and efficiently controlling costs and minimizing variances. AUDIT REPORT 27601-0003-22 3 Section 1: FNS Reviews and Monitoring Could be Strengthened 4 AUDIT REPORT 27601-0003-22 Finding 1: FNS Should Determine Causes of Variances and Identify and Share Best Practices to Contain Costs FNS has a responsibility to ensure SNAP administrative Federal funds are used effectively. However, we found that FNS could be more proactive in monitoring and minimizing the large variances among State and county SNAP administrative costs. The administrative costs per SNAP case per month for county-administered States in FY 2014 range from $10 per case in Ohio to $34 in California. County costs also vary significantly, with New York City and Erie County (New York) at $23 and $13 respectively, and Los Angeles and San Francisco counties at $27 and $73 respectively, per case in FY 2014. Large variances in SNAP administrative costs continue as FNS does not perform adequate monitoring or conduct sufficient coordination with States and counties to assist in containing costs, minimizing variances, and sharing best practices. As a result, FNS is unable to ensure it has efficient and effective State and county operations involving the Federal share of SNAP administrative costs, which total over $3.6 billion in FY 2014.9 The Federal Government has a responsibility to act as a careful steward of taxpayer dollars, ensuring Federal funds are used for purposes that are appropriate, cost effective, and important to the core mission of agencies.10 In addition, OMB Circular A-123 requires agencies to establish appropriate internal controls to ensure the efficiency and effectiveness of their operations.11 FNS issues an annual State Activity Report that outlines the administrative cost per SNAP case for each State. This report has shown significant variances in the SNAP administrative cost-per- case among the States, suggesting possible waste and operational inefficiencies. For example, in FY 2014, the average cost-per-case for the 10 county-administered States was over $21 per case, as opposed to under $10 per case for State-administered States. The cost-per-case for all of the States and territories in FY 2014 ranged from under $4 a case (Florida) to over $38 a case (Virgin Islands). Among the county-administered States, Ohio had the lowest cost at $10 and California had the highest cost at $34 a case (see Table 1). 9 Of the $3.6 billion, $1.8 billion was for the 10 county-administered States. During our review, we determined that high variances of SNAP administrative costs occur in both State-administered and county-administered States. FNS officials confirmed that the cost variances for both county and State-administered programs are not reviewed. 10 OMB, Promoting Efficient Spending to Support Agency Operations, Memorandum M-12-12 (May 11, 2012). 11 OMB, Management’s Responsibility for Internal Control, Circular A-123 (December 21, 2004). Table 1: FY 2014 Federal Cost-Per-Case for County-Administered States AUDIT REPORT 27601-0003-22 5 State Federal Cost-Per- Case Per Month Federal Share of Administrative Costs Households Participating (Monthly) California $34.06 $825,316,195 2,019,272 New Jersey $26.23 $138,400,032 439,695 North Dakota $25.06 $7,521,986 25,011 Minnesota $21.22 $66,304,561 260,437 New York $18.60 $379,028,505 1,698,559 Virginia $18.23 $97,049,140 443,607 Colorado $16.87 $47,381,997 234,098 Wisconsin $11.76 $59,386,007 420,833 North Carolina $10.52 $96,058,619 761,105 Ohio $ 9.55 $97,648,695 851,972 We also calculated the SNAP cost-per-case for FY 2014 for counties in New York, California, and Ohio, and we also identified large variances. For example, in FY 2014 the cost-per-case for counties in New York ranged from $8 to $29 per case; in California, $13 to $73 per case; and in Ohio, $2 to $17 per case. Among the counties in our audit sample, San Francisco’s cost-per-case for FY 2014 was $73, while Los Angeles’ and New York City’s costs-per-case were $27 and $23, respectively (see Table 2). Table 2: FY 2014 Federal Share of Cost-Per-Case for Counties in OIG Audit Sample Counties Federal Cost- Per-Case Per Month Federal Share of Administrative Costs Households Participating (Monthly) San Francisco, California $72.61 $27,947,139 32,074 Los Angeles, California $27.24 $187,426,575 573,282 New York City, New York $22.92 $273,429,818 994,004 Erie, New York $12.51 $12,729,342 84,764 Cuyahoga, Ohio $ 8.95 $15,247,987 141,946 Hamilton, Ohio $ 5.70 $4,227,683 61,772 During our review of national office operations, we determined that while FNS calculates and reports the cost-per-case data for States, it is not analyzing or reviewing these data to identify trends to help reduce and contain costs. FNS officials stated it would not be useful to compare the States’ SNAP expenditures as each State has significant autonomy in how it structures and implements the program. One of the common explanations FNS, State, and county officials gave to explain the high variances was that the cost of living varies significantly from State to State. While we would agree that cost of living differences could account for a portion of the variances, it does not seem reasonable that it would account for costs that are three to four times higher in some areas. For example, California’s SNAP cost-per-case rate is almost twice as high as New York’s, and San Francisco’s rate is over three times higher than New York City’s rate. In our opinion, data from the Bureau of Labor Statistics (BLS) suggests the cost of living among these areas is not as dramatically disparate. For example, BLS estimates the average wage for all occupations in San Francisco was $66,900, as opposed to $61,300 for New York City. 6 AUDIT REPORT 27601-0003-22 12 FNS officials believe that many other factors may also influence the cost variances, such as the number of offices required to serve an area, the use of different State eligibility systems, and the implementation of different policy options by States.13 FNS contracted for a study that was published in 2008 that determined the feasibility of assessing the States’ varying rates for SNAP administrative costs.14 This report determined that there are multiple feasible ways to assess the causes of the variances. The study outlined five approaches for identifying the causes that vary in the amount of time and resources it would take to complete. For example, according to the study the first option is a relatively modest, low cost first step that could provide immediate insight and identify directions for future research. Since certification costs account for approximately 60 percent of all administrative costs, the five options focus on certification costs and specifically on the costs of eligibility workers.15 However, following the issuance of the report, there was no FNS follow-up or oversight of cost variances to determine the reasons for the variances and possibly share best practices in an attempt to reduce costs among States and counties. FNS officials stated that they never evaluated the results of the feasibility study to make a determination on whether they should pursue any of the five recommended approaches for analyzing the variances. FNS national office staff stated that reviewing and monitoring variances would most likely occur at the agency’s regional offices, since the regional offices have intimate knowledge of and better relationships with the States. However, in our visits to the FNS regional and State offices, we did not identify that those offices conducted such reviews. FNS regional office officials stated it would be difficult to compare large States like New York and California to other smaller States in their regions due to the large differences in the number of SNAP participants and the cost of living. While we believe FNS could better coordinate with States and counties to help contain costs, OIG acknowledges there are certain factors outside of FNS’ control. For instance, since SNAP 12 Bureau of Labor Statistics, May 2015 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates. The estimates are calculated with data collected from employers in all industry sectors in San Francisco-Oakland-Hayward, California; New York-Jersey City-White Plains, New York; and New Jersey Metropolitan Division. SNAP’s laws, regulations, and waivers provide State agencies with various policy options. This flexibility helps States to adapt the program to target benefits to those most in need and streamline program administration and field operations. U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis, Feasibility of Assessing Causes of State Variation in Food Stamp Program Administrative Costs: Final Report, by Christopher Logan and Jacob Alex Klerman. Project Officer: Jenny Laster Genser, Alexandria, Virginia (September 2008). 15 Certification includes costs associated with accepting and processing SNAP applications. This includes salaries, benefits, travel expenses, supervisory, clerical, and other support costs. 13 14 administrative costs are an appropriated entitlement, States are not limited in the amount of administrative costs allowed for reimbursement. While the funding is provided in the annual appropriations acts, the level of spending for appropriated entitlements is not controlled through the annual appropriations process. Instead, the level of spending for appropriated entitlements, like other entitlements, is based on the benefit and eligibility criteria established in law, and the amount provided in appropriations acts is based on meeting this projected level. As long as the expenses are for allowable purposes and directly benefit SNAP, and as long as sufficient amounts of funding have been appropriated, then they are reimbursable. An FNS official stated that because these funds are entitlements, FNS has little control over the amount of the States’ expenditures. The official stated FNS cannot force a State to reduce its expenditures if they are allowed under program regulations. The lack of limitations on the amount and use of SNAP administrative funds may be partially responsible for the high cost-per-case in some States. In addition, the nature and structure of the reimbursement of SNAP administrative costs does not effectively encourage States and counties to reduce costs. In States that are county-administered, States, counties, and the Federal government are each typically responsible for only a percentage of the costs. For example, in California, the State and counties are typically responsible for 35 percent and 15 percent respectively, while the Federal government typically covers the remaining 50 percent of all eligible SNAP administrative costs. However, a majority of the expenditures occur at the county level. There is less financial incentive for a county office to reduce costs or staffing when it is only responsible for covering 15 percent of the cost. AUDIT REPORT 27601-0003-22 7 The shared responsibility for the funding of SNAP expenditures, combined with States’ legal autonomy in the amount of expenditures allowed for reimbursement, produces a control environment that is less conducive to the effective use of funds and containment of costs. This type of control environment increases the risk of waste and inefficient use of funds, and thus creates a greater need for FNS oversight and monitoring of costs. FNS has a responsibility to ensure SNAP administrative Federal funds are used effectively, and as such the agency should be coordinating with States and counties to control costs and minimize variances. Without proper oversight, it will not be able to ensure efficient and effective State and county operations. In addition, if appropriations for SNAP administrative costs are insufficient to cover the total needs of all of the States during a given year, then some States might receive an inequitable allocation of funding. Recommendation 1 Use the recommendations of the 2008 feasibility study to identify the causes of SNAP administrative cost variances and share any best practices that are discovered as a result of the study with States and counties. Agency Response In its September 26, 2016, response, FNS concurred with this recommendation. A study that models available State-level data will be included in the FNS Research and Evaluation Plan for FY 2018. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We are unable to accept management decision for this recommendation. FNS’ response indicates that a new study will be added to the Research and Evaluation Plan for FY 2018. FNS’ proposed corrective action does not address how the 2008 study recommendations will be used to identify the causes of variances and how they plan to share any best practices that might result from the identification of those causes. To reach management decision, FNS needs to show how it plans to use the recommendations from the 2008 study to identify and share best practices, if identified, with States and counties within the next fiscal year. Recommendation 2 Perform and document continuous monitoring and analyses on a yearly basis of State administrative cost variances to identify and share trends and any best practices to reduce SNAP costs. Agency Response In its September 26, 2016, response, FNS concurred with this recommendation. FNS will analyze existing State-level administrative expense data to monitor State cost-per-case variances and identify trends. FNS will share with States any identified cost containment strategies that do not negatively affect State Program performance. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We are unable to accept management decision for this recommendation. To reach management decision, FNS should show how it plans to conduct this review yearly and how it plans to share the identified cost containment strategies. 8 AUDIT REPORT 27601-0003-22 Finding 2: FNS Needs to Conduct Financial Management Reviews More Consistently FNS conducts financial management reviews to ensure that the information grantees report is accurate, complete, and represents proper expenditures of Federal funds. We found, however, that FNS regional offices were conducting these reviews differently. For instance, the Northeast Regional Office (NERO) reviews its largest State and largest county, New York and New York City, every year. However, the Western Regional Office (WRO) only reviews its largest State, California, every 5 years, and it does not review individual counties. This occurred because FNS allows the regional offices autonomy in their selection of States for financial management reviews. In addition, FNS regional offices do not consistently apply risk factors when selecting States for these reviews due to lack of standard written procedures for reviewing and approving the region’s selection of States. In particular, the regional offices assigned risk to States differently. Since each regional office must choose which reviews to perform based on risk, it is critical that these risk levels are assigned consistently. Unless FNS performs these financial management reviews consistently, it cannot ensure that grantees are using Federal funds appropriately. Agencies are required to establish and maintain internal controls. AUDIT REPORT 27601-0003-22 9 16 These internal controls help management fulfill its responsibilities and address identified risks.17 FNS’ financial management review is an integral part of FNS’s total program of management control and financial accountability. 18 This review is conducted on-site by FNS regional offices, ensuring the financial information reported by grantees is correct, complete, and represents proper expenditures of Federal funds. Because FNS cannot review every grantee\/program each year, the agency uses a risk-based approach to select those States it will review. FNS’ annual risk-based approach assigns a numerical score to a grantee based on factors such as when the grantee was last reviewed, funding, prior findings, etc. All grantees are ranked from this score to determine the highest risk grantee\/program to review. Based on high score, some programs could be reviewed more frequently. At a minimum, each major program area is required to be reviewed at least once every 5 years; however, FNS allows regions flexibility in determining more frequent reviews based on the region’s knowledge and experience with the grantees. NERO reviews New York annually because of the high level of funding the State receives for its SNAP program. Comparatively, California has the highest funded SNAP program in FNS’ Western Region. Even though California receives twice the SNAP funds New York receives, WRO scheduled reviews of SNAP administrative costs for California no more frequently than every fifth year.19 Based on FNS’ procedures requiring regions to create four tiers based upon funding levels that best fit their regions, New York’s risk analysis for level of funding scored 16 OMB, Management’s Responsibility for Internal Control, Circular A-123 (December 21, 2004). 17 GAO-14-704G, Standards for Internal Controls in the Federal Government (September 2014). 18 USDA FNS, Financial Management Review Guide (FMR) (March 2009). 19 WRO’s last three SNAP financial management reviews for California were conducted in 2003, 2011, and 2016. As such, WRO actually did not meet the 5 year review requirement between 2003 and 2011. very concerned. Just as NERO scored New York’s funding as very concerned, WRO’s risk analysis should have scored California very concerned, as California accounts for 76 percent of the region’s SNAP funding. We found, however, that WRO did not follow FNS’ four-tier procedure. This occurred because even though this four-tier procedure for determining risk level is in writing, no written procedure exists to ensure it is followed and approved prior to selection for review. We found that the financial management reviews are not consistent in reviewing counties for the three county-administered States we visited: California, New York, and Ohio. For instance, we found that while NERO visits both the New York State office and the State’s largest county, WRO does not review California counties and the Midwest Regional Office does not review Ohio counties due to limited resources and time constraints. During our visit to one county in Ohio, we found that the State had improperly commingled $3.6 million of SNAP E&T funding (see Finding 5 of this report). Because of this error, Ohio must return those funds to FNS. In this instance, if regional offices had been conducting financial management reviews consistently in all States, then FNS might have discovered and corrected or prevented this error. Additionally, NERO’s own review of New York had no findings at the State agency level, but NERO had findings and questioned costs at the county level. NERO questioned SNAP E&T costs for Temporary Assistance for Needy Families (TANF) recipients since regulations exempt TANF recipients from participating in SNAP E&T work requirements. Additionally, FNS had findings regarding the county’s contracting for SNAP E&T and required additional clauses to protect federal funds. FNS should review counties in county-administrated States consistently to better ensure grantees are using Federal funds appropriately. FNS officials acknowledged that the financial management reviews should be more consistent and FNS has been working to improve its review process. Starting in FY 2014, FNS hired contractors to review each of the agency’s regional offices. These reviews noted that standard operating procedures for the regional and national selection process were not documented. These reviews indicated that documented procedures would help ensure selections and plans were uniform, reviewed, and approved. Additionally, FNS officials stated that FNS has been rewriting its 2009 financial management review guide to provide updated guidance and plans to publish the new guide in calendar year 2016. FNS also established a quality assurance team in early 2016 to assist in the financial management review process to improve consistency and quality of reviews. As FNS continues to improve its financial management review process, FNS must also establish written procedures for approving the regions’ selection of States for financial management reviews. Written procedures should strengthen consistency among regions when applying risk factors in ranking and selecting States and programs for review. FNS’ risk-based approach to selecting States for review is a necessary tool for the agency, and written procedures ensuring the approach is documented, reviewed, and approved would increase the accuracy and consistency of the level of risk assigned in the financial management review process. Additionally, since a majority of costs occur at the county level in county-administered States, FNS should include counties as part of the financial management review process so that it can identify and prevent administrative cost issues. 10 AUDIT REPORT 27601-0003-22 Recommendation 3 Establish standard written procedures for reviewing and approving the risk-based approach used by regions to select States for financial management reviews. Agency Response In its September 26, 2016, response, FNS concurred with this recommendation. FNS will formalize, in writing, the procedures for reviewing and approving the risk analyzer results used by regional offices to select State agencies for financial management reviews. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. Recommendation 4 Establish written requirements and procedures for regional offices to select counties to review in county-administered States. Agency Response In its September 26, 2016, response, FNS stated it will establish written requirements and procedures for regional offices to assess controls of State agency oversight of counties in county- administered State agencies. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We are unable to accept management decision for this recommendation. FNS’ response indicates that it will require the regional offices to review the States oversight of the counties, but it does not address how it will ensure counties are selected for review. To reach management decision, FNS should establish procedures requiring regional offices to select and review county offices in county-administered States during the financial management reviews. AUDIT REPORT 27601-0003-22 11 Section 2: Deficiencies in FNS Oversight and the Lack of Effective State and County Financial Management Controls Led to Inaccurate Program Financial Reporting 12 AUDIT REPORT 27601-0003-22 Finding 3: FNS Internal Reviews Did Not Identify More Than $111 Million in Unsupported Unliquidated Obligations for California The California Department of Social Services (CDSS) did not appropriately follow Federal regulations for the establishment and liquidation of financial obligations. This occurred because CDSS did not collect supporting obligation data from its reporting counties and, as stated by CDSS officials, did not deobligate unsupported unliquidated obligations because of concerns over access to the funds in the case of unexpected events.20 Also, FNS’ WRO did not perform adequate reviews, and the reviews lacked necessary procedures to validate these unliquidated obligations. As a result, CDSS has unsupported unliquidated obligations totaling over $111 million for FY 2014 that should be deobligated and put to better use. Federal regulations state that an amount should only be recorded as an obligation when supported by documentary evidence, such as a written order that binds the agency to pay for goods or services.21 Departmental regulations require agencies to review unliquidated obligations and submit a quarterly certification attesting to the validity of these obligations to the Office of the Chief Financial Officer.22 Obligations should be deobligated unless there is a documented need for the obligation to remain open. The Departmental regulations state that the optimum use of funds requires that all current and prior year obligations be continuously reviewed to ensure that obligated balances are not over or understated and that the obligations are properly documented and reported. Reviews and reports of unliquidated obligations are necessary to properly report obligation balances, certify the validity of obligated balances, make funds available that otherwise would not be used, and reduce the risk of misuse and theft of funds. Such reviews improve FNS’ and the Department of the Treasury’s ability to forecast outlay and borrowing needs. Improper reporting of unliquidated obligations impacts FNS’ ability to accurately analyze expenditure data and budget for future expenses. During our work, we found that CDSS lacked support for unliquidated obligations and WRO did not perform adequate reviews of these obligations to ensure that they were supported by appropriate documentation and represented valid needs. 20 Unliquidated obligations represent the balance remaining from the amount of orders placed, contracts or other binding agreements awarded, or services rendered after making any payments or processing deobligations. Unliquidated obligations consist of undelivered orders and accounts payable. 21 31 U.S.C. 1501 (a). 22 USDA Departmental Regulation 2230-001, Reviews of Unliquidated Obligations (Oct. 15, 2014). CDSS Lacked Documentation for Unliquidated Obligations States are required to submit quarterly and year-end Federal financial reports AUDIT REPORT 27601-0003-22 13 23 to FNS detailing the total amount of expenditures and unliquidated obligations.24 CDSS did not report any unliquidated obligations in its quarterly FY 2014 Federal financial reports. On the final year-end report submitted on December 29, 2014, CDSS reported $693 million in Federal expenditures and $133 million in the Federal share of unliquidated obligations. CDSS submitted 2 revisions to this year-end Federal financial report, with the latest submitted over 15 months after the end of the fiscal year, showing the total amount of Federal unliquidated obligations for FY 2014 as approximately $125 million.25 In our review of CDSS’ FY 2014 unliquidated obligations, we identified unliquidated obligations that were not based on actual obligations representing valid needs. CDSS was unable to provide supporting documentary evidence showing the validity of at least $111 million of the approximately $125 million in unliquidated obligations.26 CDSS is unable to determine or report the actual amount of unliquidated obligations because it does not collect unliquidated obligation data from each county.27 CDSS officials stated that the amount reported as unliquidated obligations is an estimate based on the amount that was budgeted for the counties’ expenditures. Since the unliquidated obligations were based on budgeted amounts rather than on actual obligations that have not been paid yet, there was no supporting documentation for us to review. While the final Federal financial report is due December 30, States have 2 years to receive reimbursement for any amendments to their reports, subject to the availability of funds.28 CDSS is overstating its unliquidated obligations to ensure funds are available to make any adjustments to its claim during this 2 year period. A CDSS official stated that she did not want to return the money to FNS because she was unsure if CDSS would be able to get the money back if needed for an unforeseen expense. The official stated that CDSS anticipates returning a large majority of the FY 2014 unliquidated obligations in September 2016. In fact, CDSS has historically returned large amounts of funds 2 years after the end of the fiscal year. For example, CDSS returned $51 million of FY 2012 funds in September and October 2014 and $62 million of FY 2013 funds in September 2015 (see Table 3). 23 SF-425 Federal Financial Report and FNS-778 SNAP Worksheet for the SF-425. 24 7 C.F.R. 277.11 (c) requires that these reports be submitted 30 days after the end of each quarter for the quarterly reports and December 30th for the year-end reports. This was the most recent submission on file at the time of OIG’s onsite fieldwork of CDSS in February and March 2016. The remaining $14 million includes E&T allocations to the counties, which CDSS officials expect to liquidate, and obligations supported by specific contracts. Therefore we are not taking exception to this amount. 27 There are 58 counties in California. 7 C.F.R. 277.11 (d)(2) states, subject to the availability of funds from the appropriation for the year in which th 28 e expenditure was incurred, FNS may reimburse State agencies for an allowable expenditure only if the State agency files a claim with FNS for that expenditure within two years after the calendar quarter in which the State agency (or local agency) incurred the cost. 25 26 Table 3: CDSS Prior Years Unliquidated Obligation Activity 14 AUDIT REPORT 27601-0003-22 CDSS Reporting of Unliquidated Obligations FY 2012 FY 2013 FY 2014 Federal Share of Unliquidated Obligations on Initial Year-end Federal Financial Report $52,236,946 $77,063,014 $132,598,252 Total Funds Returned on Final Year- end Federal Financial Report $51,011,576 $62,204,204 _ Percent of Unliquidated Obligations Not Used 97.7% 80.7% _ Month the Funds were Returned by CDSS September and October 2014 September 2015 _ The FNS Regional Office Did Not Perform Adequate Reviews of State Financial Reports FNS’ regional offices are required to obtain documentation to support any unliquidated obligations reported at grant close-out.29 While WRO requested supporting documentation from CDSS, its review was inadequate because the documentation provided by CDSS was not specific enough. For example, the supporting documentation provided by CDSS identified $111,399,656 in FY 2014 unliquidated obligations with the payee listed as counties and an anticipated liquidation date listed as September 30, 2016. There was no additional itemization or support for this amount, such as individual line items showing the specific obligation amounts, payees and purposes, dates the specific obligations were established, and individual dates of anticipated liquidation.30 Had the office followed up with CDSS and requested a more detailed list of the obligations, it might have discovered that the unliquidated obligations are estimates based on budgeted amounts and not based on actual obligations. In addition to not identifying these invalid obligations at grant close-out, FNS did not identify them during its required quarterly reviews of unliquidated obligations.31 Regional offices are required to review and certify quarterly the validity of unliquidated obligations that have had no activity within the past 12 months. CDSS reported its unliquidated obligations as a lump sum, and even though a large portion of the unliquidated obligations had no activity, a small amount of funds was gradually liquidated. This kept the unliquidated obligation status as active and thus the obligations went undetected by FNS. FNS is also required to review and certify all accounts payable (which includes unliquidated obligations) on a quarterly basis. However, FNS’ guidance for these certifications only requires 29 Grant close-out is the annual financial reconciliation of FNS program funds that determines the final grant levels for the grant period. FNS IPAS-671 Operating Procedures, Annual Financial Reconciliation (Close-out) of Program Grants, requires supporting documentation for unliquidated obligations to include the payee and the purpose, date the obligation was established, anticipated date of liquidation, and the amount. 31 USDA Departmental Regulation 2230-001, Reviews of Unliquidated Obligations (Oct. 15, 2014). 30 regional offices to obtain supporting documentation in the form of a financial status report (such as SF-425) and a signed statement confirming the dollar amounts from the grantee. AUDIT REPORT 27601-0003-22 15 32 There is no requirement to review additional supporting documentation such as contracts or reports from the grantee’s financial system. As such, these quarterly reviews did not identify CDSS’ invalid unliquidated obligations. FNS also might have identified the practice of reporting invalid unliquidated obligations if it performed more frequent financial management reviews. Regional offices are required to perform a financial management review of each State’s SNAP operations every 3 to 5 years. The last SNAP review for California was in FY 2011, and it only reviewed American Reinvestment and Recovery Act funding and not regular administrative funds. The last California review prior to 2011 was in 2003. Shortly after our fieldwork, FNS conducted another financial management review for California and identified the same unliquidated obligation issue we found. Had FNS conducted more frequent reviews of California, it might have been able to identify this issue earlier (see Finding 2 for more discussion about FNS’ financial management review practices). Amounts inappropriately recorded as unliquidated obligations represent missed opportunities to pursue other uses of funds. As a result of CDSS’ invalid obligations, $111 million of Federal funds remained idle and unavailable to be used in support of FNS’ program and mission goals. As such, we recommend FNS deobligate $111,399,656 in invalid obligations reported by CDSS and take steps to ensure that future unliquidated obligations are valid and appropriately documented. Recommendation 5 Deobligate $111,399,656 in invalid unliquidated obligations reported by CDSS. Agency Response In its September 26, 2016, response, FNS stated it will review the $111,399,656 in unliquidated obligations reported by CDSS and determine if any of these obligations are eligible for reimbursement. If any obligations are allowable, FNS will reduce the $111,399,656 by that amount and deobligate the remainder. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. 32 FNS IPAS-212 Operating Procedures, Financial Certifications (Dec. 31, 2014). Recommendation 6 Review all SNAP administrative cost unliquidated obligations currently outstanding for States in the Western Region to ensure that they represent actual obligations for valid needs. Agency Response In its September 26, 2016, response, FNS concurred with this recommendation. FNS will identify all the State agencies in the Western Region that have outstanding unliquidated obligations for FY 2014 and FY 2015. Based on this information, FNS will contact the State agencies identified and request that they provide adequate documentation to support their outstanding unliquidated obligations. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. Recommendation 7 Require CDSS to collect unliquidated obligation data from the counties and report these data on its quarterly and final Federal financial reports. Agency Response In its September 26, 2016, response, FNS stated that FNS program regulations at 7 CFR Part 277.11 already require State agencies to collect unliquidated obligation data to complete their financial status report. However, FNS will remind State agencies, in a memo, where they are county-administered, that they should be collecting unliquidated obligation data from their counties in order to properly report this information on their quarterly and final financial status reports. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. Recommendation 8 Revise FNS IPAS-212 Operating Procedures to require the regional offices to review independent source data, such as specific contracts or reports from the grantee’s financial system, during the regional office reviews of unliquidated obligations to ensure that they represent valid needs. 16 AUDIT REPORT 27601-0003-22 Agency Response In its September 26, 2016, response, FNS stated that FNS Program Accounting Standard Operating Procedures (PASOPs) entitled Financial Certifications, Version 1.0, (which replaced FNS IPAS-212 Operating Procedures) require that all current and prior year obligations be continuously reviewed to ensure that obligated balances are not overstated or understated and that these obligations are properly documented and reported. FNS will remind regional offices, in a memo, about the requirements for validating reported unliquidated obligations on the quarterly and final financial status reports. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. AUDIT REPORT 27601-0003-22 17 Finding 4: FNS Needs to Provide Adequate Oversight to Ensure Expenditures are Charged to the Appropriate Fiscal Year We found the States and counties in our review operate without a process or accounting system in place to ensure that SNAP administrative expenditures are charged to the correct Federal appropriation. The three States charged and reported expenditures incurred in FY 2013 to FY 2014, the year in which payments were made. This occurred because FNS has not provided sufficient oversight and guidance to ensure that county-administered States are reporting and charging funds to the correct fiscal year. OIG has previously reported on the issue of fiscal year integrity at least three times in the last three decades, and FNS has not taken effective action to address this known issue. As a result, FNS has enabled States to continue to use a process that is not in compliance with Federal regulations. Specifically, the States we reviewed submitted inaccurate Federal financial reports overstating their claims for administrative expenditures in FY 2014, resulting in an over-reimbursement by FNS. Federal appropriation law states that an appropriation limited to a definite period (e.g., 1 year) is available only for payment of expenses incurred during that time period. 18 AUDIT REPORT 27601-0003-22 33 In addition, Federal regulations stipulate that a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.34 In the county-administered States we reviewed, counties submit quarterly or monthly claims to the State detailing the amount of SNAP administrative expenditures the county used. The State compiles all of the county claims, combines them with all of the State-level expenditures, and reports this on its Federal financial reports submitted to FNS.35 We found that all three States and the six counties in our sample improperly claimed and reported expenditures on FY 2014 financial reports that were incurred during FY 2013. All the States and counties in our sample reported expenditures on a cash basis by the payment date rather than when the expenses were incurred.36 For example, a common exception we identified was for employee salaries: pay periods worked in September of FY 2013 were paid in October 2014 with FY 2014 funds. In one county, we identified 14 out of 25 expenditures on the claim from the first quarter of FY 2014 that were for expenses incurred in the prior fiscal year, totaling $838,524.33.37 The county officials stated the claiming process and system used is established by the State and that they have not received any guidance on how to report expenditures to meet Federal requirements. CDSS created a template in the accounting\/reporting system that all of the counties use to submit 33 31 U.S.C. 1502 (a). 34 2 C.F.R. 200.309. 35 SF-425 Federal Financial Report and FNS-778 SNAP Worksheet for the SF-425. 36 method in which expenses are recorded when incurred. 37 San Francisco County. Cash basis accounting records expenses when they are paid. Accrual basis accounting refers to the accounting expense claims. In another county AUDIT REPORT 27601-0003-22 19 38 reviewed we identified eight expenses totaling over $11 million from FY 2014 that were incurred in the prior year.39 We also identified that California’s FY 2014 financial reports included State operation cost adjustments for transactions in prior State fiscal years (2011-2013) in excess of $22,000. California officials stated that since the adjustments take place in the current fiscal year, they view these expenses as current and thus pay them out of the current year’s funds. However, since these expenses were incurred in the prior years, the State should have amended its prior year financial reports to report and charge any allowable expenses to the correct fiscal year.40 In three previous audits issued in July 1993,41 July 2002,42 and June 2013,43 OIG reported States had charged expenses to the incorrect fiscal year. Additionally, OIG identified three FNS financial management reviews that reported fiscal year integrity issues. FNS officials stated they have been aware of this issue since the early 2000s, and their expectation is that expenditures should be reported only for obligations that were incurred during the fiscal year. Officials added that if expenses are incurred but not yet paid, then the States should report these as unliquidated obligations in the year the expenses were incurred. FNS officials explained that, in response to this issue, they developed a draft policy memo more than 5 years ago, but it was never finalized and released. Officials did not know why the original policy memo was not released after it was drafted. FNS officials noted a similar issue was recently identified during a financial management review in Wyoming. The agency informed us it is in the process of updating the prior draft policy memo to address the issue, but is waiting to release it until they discuss it with OMB. If FNS continues to allow States to report and charge incurred expenses from one year to the following year, States could potentially be reimbursed for more expenditures than they were approved for that year. In addition, inconsistent reporting of expenditures by States makes it difficult for management to effectively compare and analyze program data. We conclude that FNS has not properly managed and addressed the known issue of fiscal year integrity and enabled States to continue using a process that results in expenditures being charged to the improper fiscal year. FNS’ awareness of this issue without an overall agency response demonstrates a management control weakness and increases risk of future, more significant violations. As such, we recommend that FNS develop guidance that addresses this problem, and require States to submit plans for ensuring the fiscal year integrity of expenditures. 38 Los Angeles County. OIG cannot determine how much of these amounts were eventually charged to SNAP because all of the sampled expenditures were allocated to various programs through time studies. 40 7 C.F.R. 277.11 (d)(2) – Subject to the availability of funds from the appropriation year in which the expenditure was incurred, FNS may reimburse State agencies for an allowable expenditure only if the State agency files a claim with FNS for that expenditure within two years after the calendar quarter in which the State agency (or local agency) incurred the cost. 41 Audit Report No. 27018-0004-SF, Food Stamp Program Administrative Costs State of California, July 1993. 42 Audit Report No. 27099-0018-SF, Food Stamp Program Administrative Costs California, July 2002. 43 Audit Report No. 27703-0001-22, Recovery Act Impacts on Supplemental Nutrition Assistance Program Phase II, June 2013. 39 Recommendation 9 Develop standardized guidance and procedures for ensuring the States utilize a process that reports expenditures in the proper fiscal year. Agency Response In its September 26, 2016, response, FNS concurred with this recommendation. FNS will develop and provide standardized guidance for ensuring State agencies report expenditures in the proper fiscal year. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. Recommendation 10 Identify all States that do not utilize a process for reporting expenditures in the proper fiscal year and require those States to develop and submit a plan to FNS for approval detailing the process they will use to collect and report expenditures in the proper fiscal year. Agency Response In its September 26, 2016, response, FNS stated that the process for ensuring proper fiscal year integrity is the financial management reviews. FNS will review the past 3 years’ financial management reviews and identify all State agencies whose report included a fiscal year integrity finding. Based on this list, FNS will request the State agencies to provide FNS with a plan to come into compliance with fiscal year integrity requirements, unless they have already provided this information. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We are unable to accept management decision for this recommendation. The FNS response does not include the process of FNS reviewing and approving applicable States’ plans to ensure they will result in the reporting of expenditures in the proper fiscal year. Additionally, reviewing financial management reviews would not identify all States with fiscal year integrity issues, as each regional office is given flexibility in what review procedures it conducts. For example, the most recent financial management reviews OIG obtained for New York and Ohio did not identify fiscal year integrity issues. However, during our audit, we determined that these two States did not utilize a process for reporting expenditures in the proper fiscal year. To reach management decision, FNS should (1) document the methodology it will use that will accurately identify all States that are not utilizing a process for reporting expenditures in the correct fiscal 20 AUDIT REPORT 27601-0003-22 year, and (2) document how it will review and approve applicable States plans to ensure the plans will result in compliance with fiscal year integrity reporting requirements. AUDIT REPORT 27601-0003-22 21 Finding 5: Ohio Needs to Establish Controls to Ensure Proper Reporting of Grant Funds The Ohio Department of Jobs and Family Services (ODJFS) did not correctly report expenditures for reimbursement from SNAP E&T funds in the counties’ accounting system, resulting in approximately $3.6 million in questioned costs. ODJFS claimed that amount as E&T administrative expenditures, although the counties originally reported that amount as participation expenditures. However, since the money was commingled at the county level, ODJFS does not know if those expenditures were all participation expenditures. This occurred because ODJFS did not have adequate controls over its counties’ accounting processes or its own accounting processes for recording year-end adjustments to administrative expenditures eligible for reimbursement. This uncertainty about the nature of the actual expenses undermines the integrity of Federal funds and is unallowable under FNS’ E&T program funding. Federal regulations for financial management of grants require accurate records of program operations 22 AUDIT REPORT 27601-0003-22 44 and state that cost allocation plans should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards. 45 We found the counties did not properly account for excess administrative costs, resulting in ODJFS creating year-end adjustments to reallocate costs to several accounts. Those adjustments were made in error and resulted in invalid reimbursements and the commingling of funds intended for other specific purposes. ODJFS further commingled E&T funds at the end of the fiscal year, moving the funds claimed by the counties as participation expenditures into the administrative funds account, in violation of Federal regulations. FNS’ E&T funding program assists SNAP participants in gaining the necessary skills, training, work, or experience to increase self-sufficiency. States receive a Federally-funded, 100 percent reimbursement administrative grant (100% E&T Grant) for administrative expenditures associated with operating an E&T program.46 If a State exhausts its 100% E&T Grant, it may receive reimbursement of additional administrative expenditures through a 50 percent reimbursement grant (50% E&T Grant).47 Additionally, States may receive assistance from FNS for covering SNAP E&T participants’ expenses such as dependent care costs, transportation, personal safety items, uniforms, etc. However, these expenditures may not be paid with E&T administrative grant funds, but instead are eligible for 50 percent reimbursement through separate Federal grants specifically for E&T participation expenditures (E&T Dependent Care and E&T Transportation).48 E&T administrative and participation expenditures must be separately reported on FNS’ financial reporting forms (see Figure 1). 44 7 C.F.R. 277.6. 45 2 C.F.R. 225 appendix C. 46 7 C.F.R. 273.7 (d)(1)(i). 47 7 C.F.R. 273.7 (d)(2). 48 7 C.F.R. 273.7 (d)(4). Figure 1: Four Types of SNAP E&T Program Grants SNAP E&T PROGRAM GRANTS Administrative Grants 1) 100% E&T Grant Expenditures are eligible for 100% reimbursement 2) 50% E&T Grant Excess expenditures are eligible for 50% reimbursement Participation Grants 3) E&T Dependent Care Expenditures are eligible for 50% reimbursement 4) E&T Transportation Expenditures are eligible for 50% reimbursement OJDFS policy states that expenditures that exceed eligibility for the 100% E&T Grant should be reported as 50% E&T Grant expenditures and the counties will be reimbursed accordingly. AUDIT REPORT 27601-0003-22 23 49 However, during our visits to the counties in March 2016, we found the counties did not have an account in the county finance information system for the allocation for the 50% E&T Grant. Instead, the counties made adjustments to the E&T Transportation account to facilitate reimbursement of excess administrative expenditures, which in FY 2014 were approximately $9 million. Additionally, ODJFS’ State-level finance information system recorded approximately $6 million more as E&T Transportation expenditures from the counties. Therefore, ODJFS reported total E&T Transportation expenditures of approximately $15 million on its FY 2014 4th quarter financial report, which was more than twice the amount FNS had approved in the State’s budget or State plan of operations. Upon closing its FY 2014 Federal accounts, FNS informed ODJFS that E&T Transportation expenditures exceeded the FNS-approved budget and therefore ODJFS would need to use State funds to cover the overage. ODJFS responded by filing a final financial report with adjusted expenditures, reallocating $7.8 million of the $15 million to the three other E&T grant categories; over $4.2 million was moved to the 50% E&T Grant and the 50% E&T Dependent 49 ODJFS Fiscal Administrative Procedure Manual, 5101:9-6-09.3 (March 2013). 24 AUDIT REPORT 27601-0003-22 Care accounts, and approximately $3.6 million was moved to the 100% E&T Grant account, without ensuring that these disbursements were appropriately categorized (see Table 4). Table 4: ODJFS FY 2014 Adjustments and Transfers for E&T Accounts Administrative Grant E&T 100% Administrative Grant E&T 50% Participation Grant E&T Dependent Care Participation Grant E&T Transportation 4 th Quarter Report $1,662,338 $4,942,003 $32,924 $15,022,889 Adjustments\/Transfers $3,575,424 $3,176,697 $1,119,296 ($7,871,417) Final Report $5,237,762 $8,118,700 $1,152,220 $7,151,472 These adjustments were made so that expenditures would match the FNS-budgeted funds as approved by FNS in August 2013 and additional 100% E&T funds approved in May 2014 (see Table 5). Table 5: ODJFS FY 2014 Final Report Compared to Budget Administrative Grant E&T 100% Administrative Grant E&T 50% Participation Grant E&T Dependent Care Participation Grant E&T Transportation FY 2014 Budget $5,237,762 $10,000,000 $1,152,220 $7,151,472 Final Report $5,237,762 $8,118,700 $1,152,220 $7,151,472 In August 2015, FNS visited ODJFS to conduct a periodic financial management review of the FY 2014 State administrative costs for SNAP. The agency’s review discovered an $8 million revenue discrepancy attributed to adjustment errors, which ODJFS covered with State funds. However, FNS did not report issues with the E&T accounts or discover the $7.8 million discrepancy. Since the agency’s review was limited to the State office, it did not review any of the Ohio counties that administer the program. Had FNS visited the county offices, it might have discovered the counties were adjusting participation expenditures to account for administrative expenditures. Since the 50% E&T Grant and both E&T participation grants are funded by the same apportionment, the effect of a State’s commingling of these expenditures is not significant. 50 However, the 100% E&T Grant is funded through a separate apportionment, therefore claims for such expenditures must be appropriately categorized to facilitate appropriate disbursement of funds. As such, the $3.6 million reported by ODJFS as 100% E&T Grant expenditures is not allowed because that amount may include participation expenditures. FNS will need to recover the $3.6 million of commingled costs unless ODJFS, through its counties, can provide documentation of each county’s adjustments for E&T administrative and\/or participation expenditures. 50 According to OMB A-11 Section 120.1, Preparation, Submission, and Execution of the Budget (July 2016), an apportionment is an OMB-approved plan to use budgetary resources. It typically limits the obligations that may be incurred for specified time periods, programs, activities, projects, objects, or any combination thereof. Recommendation 11 Require ODJFS to establish adequate procedures for counties to separate and claim SNAP E&T expenditures. Agency Response In its September 26, 2016, response, FNS stated that it will issue a memo to Ohio that requires it to establish procedures for properly reporting SNAP E&T expenditures in the correct funding category, so that the State agency can properly report this information on its quarterly and final financial status reports. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. Recommendation 12 Review the $3,575,424 in FY 2014 E&T Grant expenditures from ODJFS to determine if any of these funds are eligible for reimbursement and establish an account receivable from the State as needed. Agency Response In its September 26, 2016, response, FNS stated it will review the $3,575,424 in FY 2014 E&T grant expenditures reported by ODJFS on its final financial status report for FY 2014 and determine if any of these expenditures are eligible for reimbursement. Based on the results of the review, FNS will establish an accounts receivable for the balance determined not to be eligible for reimbursement. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We agree with FNS’ proposed corrective action for this recommendation. However, to achieve management decision, FNS needs to provide us with documentation that an accounts receivable has been established for the agreed-upon amount. AUDIT REPORT 27601-0003-22 25 Finding 6: California Needs to Submit Timely Reports of Actual Expenditures Instead of Estimated Expenditures OIG identified that CDSS submitted two sets of financial reports to FNS for the year’s quarters and the fiscal year during FY 2014: one set with estimated administrative expenditures, and a second set with actual expenditures. This occurred because FNS’ WRO does not hold CDSS accountable for submitting the required financial reports that contain actual cost data by the required 30-day reporting deadline. 26 AUDIT REPORT 27601-0003-22 51 Rather, WRO has approved CDSS’ practice of reporting estimates on the initial financial reports and supplying actual expenditures later. However, FNS uses the estimated figures from CDSS’ 30-day reports when performing quarterly analyses. The use of estimated expenditures on these reports limits FNS’ ability to provide adequate oversight and proper analysis of State administrative expenses because the quarterly reports being reviewed do not contain actual expenditures. The financial reporting requirements section of the Federal regulation requires quarterly expenditure reports to be submitted up to 30 days after the end of the quarter.52 Final fiscal year reports are due to FNS by December 30. State administrative costs for SNAP are first reported using the FNS-778 SNAP worksheet, which is then summarized and reported on the SF-425 Federal financial report. The FNS-778 instructions note that the outlays reported on this Federal form should include the sum of actual cash disbursements.53 Additionally, the regulation provides a means for State agencies to request extensions of reporting due dates if necessary, and these requests should be the method used to accommodate States to ensure that consistent data are reported on Federal financial reports. We found that in FY 2014 CDSS reported estimated, not actual, administrative expenses on its Federal financial reports 30 days after the close of each quarter or fiscal year and then submitted a revised report with actual figures 90 days after the end of the quarter. CDSS officials explained that they are unable to meet the 30-day reporting deadline because California’s counties do not submit expenditure claims to the State until 30 days after the quarter. One county official in California stated that the process for claiming expenditures is time consuming due to the county’s oversight and approval process, which involves multiple levels of county officials reviewing the claim before it is submitted to CDSS. WRO officials stated they approved CDSS’ practice of reporting estimated expenditures within the 30-day reporting requirement and then reporting actual expenditures 60 days later as a way to report costs on the financial reports by the 30-day reporting deadline. However, WRO did not communicate with FNS’ national office when it approved CDSS’ methodology, and the forms used for the reports did not have any identifiers to make users aware of the use of estimated expenditures instead of actuals. The FNS national office did not acknowledge awareness of the use of estimated expenditures in the reports. When we informed FNS about CDSS’ use of estimated expenditures, one official stated that California is too big to compile all the data and 51 SF-425 Federal Financial Report and FNS-778 SNAP Worksheet for the SF-425. 52 7 C.F.R. 277.11 (c)(4). 53 FNS-778\/778A SNAP Worksheet for the SF-425 Instructions, Item 10b. meet the deadline, and added that FNS uses the submitted figures because the agency needs complete data for planning each quarter, whether or not they are correct. The use of estimated expenditures on the Federal financial reports impacts multiple areas within FNS. FNS performs quarterly analyses and oversight of the States using the States’ quarterly financial reports. If the reviewed quarterly reports do not contain actual expenditures, any variance or trending analysis performed by WRO and the national office would be misleading. CDSS officials stated that estimated expenditures are within 5-10 percent of the actual expenditures reported. However, we identified variances as much as 19 percent (over $33 million) between the estimated and revised FY 2014 reports. We note that other county-administered States meet FNS’ reporting requirements. OIG reviewed two other States during this audit and found that both were able to report actual expenditures within the required deadlines. One of the states, New York, has the second highest Federal share of SNAP administrative costs and successfully reported actual expenditures within the 30-day reporting requirement. We conclude that for FNS to make timely decisions, it is imperative that FNS receives reliable data from a State that receives almost 23 percent of FNS’ budget for administrative expenses. Therefore, we believe FNS needs to take immediate action to provide appropriate oversight that ensures CDSS develops the appropriate processes for timely submission of quarterly and final financial reports that use actual expenditures, as required by Federal and agency guidance and regulations. Recommendation 13 Require CDSS to timely submit quarterly and final Federal financial reports containing actual expenditures. Agency Response In its September 26, 2016, response, FNS stated that program regulations at 7 CFR Part 277.11 already require timely submission of quarterly and final financial status reports. FNS will issue a memo that reiterates the need for State agencies to submit timely financial status reports that contain accurate expenditures or obligations. FNS will require approval of a State’s methodology if they are unable to report actual expenditures or obligations in a county administered State. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We are unable to accept management decision for this recommendation. States are required to submit actual expenditures on the quarterly and final Federal financial reports and FNS should require CDSS to comply with this requirement. The regulation at 7 CFR Part 277.11 provides a means for State agencies to request extensions of reporting due dates if necessary and this should be the method FNS uses to accommodate States that are unable to report actual expenditures or obligations timely. AUDIT REPORT 27601-0003-22 27 Recommendation 14 Develop standardized guidance and procedures for regional offices to communicate any deviations or exceptions granted to States by regional officials to the FNS national office. Agency Response In its September 26, 2016, response, FNS stated that it will issue a memo to the regional offices requiring them to communicate to the National Office any deviations or exceptions granted to State agencies regarding reporting expenditures on the quarterly and final financial status reports. FNS estimates this corrective action will be completed by September 30, 2017. OIG Position We accept management decision for this recommendation. 28 AUDIT REPORT 27601-0003-22 Scope and Methodology AUDIT REPORT 27601-0003-22 29 We conducted this audit to evaluate FNS’ controls over SNAP administrative costs for FY 2014. Specifically, we determined if States with county-administered programs were effectively and efficiently controlling costs and minimizing variances. We conducted fieldwork at the FNS national office, three FNS regional offices, three State agencies, and six county offices from October 2015 through June 2016. We non-statistically selected the three county-administered State agencies with the highest, median, and lowest administrative cost-per-case for FY 2014: California, New York, and Ohio. Additionally, we non-statistically selected two counties for review at each State agency based on high and low cost-per-case and total SNAP program costs (see Exhibit B for audit sites visited). At FNS’ national office, we familiarized ourselves with FNS’ policies, program operations, and internal controls related to SNAP administrative costs. At the agency’s regional offices, we evaluated oversight responsibilities and operating policies. At the State offices, we evaluated the agencies’ controls for monitoring and reporting SNAP administrative costs, including the oversight responsibilities over the county offices to ensure costs are accurate and allowable. At the county offices, we reviewed the county claim expenses to determine compliance with FNS’ SNAP administrative cost regulations and policies. To accomplish our audit, we: \u00b7 Reviewed Criteria: We reviewed the pertinent laws and regulations governing SNAP administrative costs. We also reviewed FNS’ policies and procedures that provide guidance to State agencies and county offices. We reviewed the procedures State agencies established to ensure county office compliance with SNAP administrative costs guidance. \u00b7 Interviewed FNS and State Agency Personnel: We interviewed FNS and State agency officials to gain an understanding of their roles in monitoring SNAP administrative costs and to determine what controls are in place to ensure compliance with SNAP administrative cost guidance. \u00b7 Conducted Site Visits: We performed fieldwork at FNS, State, and county offices to evaluate FNS controls for effectively and efficiently controlling costs and minimizing variances for SNAP administrative costs. \u00b7 Reviewed FNS Regional Office Oversight: We reviewed the most recent SNAP financial management reviews completed for the States in our sample to verify if there were any findings related to SNAP administrative costs. We reviewed the regional offices’ oversight of the State agencies’ Federal financial reports (SF-425) and SNAP budget for SNAP administrative costs. \u00b7 Reviewed State Agencies’ Submission of SNAP Administrative Costs: We reviewed the FY 2014 Federal financial reports submitted to FNS to determine if they are accurate and complete. We also reviewed the cost allocation plans to determine how the State agencies calculate the expenses submitted on their Federal financial reports. We reviewed a non-statistical sample of FY 2014 costs to determine if they were appropriate and allowable. \u00b7 Reviewed State Agencies’ SNAP Administrative Cost Review Process: We reviewed the State agencies’ SNAP administrative cost review process to identify any deficiencies related to the county offices’ compliance with SNAP administrative cost laws, regulations, policies, and procedures. \u00b7 Reviewed County Offices’ Claim Expense Records: At the county office, we reviewed a non-statistical sample of county claim expense records used to support the SNAP administrative costs included in the State agencies’ Federal financial reports submitted to FNS. During the course of our audit, we did not rely on or verify information in any agency electronic information systems and we make no representation regarding the adequacy of any agency computer systems or the information generated from them. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. 30 AUDIT REPORT 27601-0003-22 Abbreviations AUDIT REPORT 27601-0003-22 31 BLS ………………………………….Bureau of Labor Statistics CAP ………………………………….Cost Allocation Plan CDSS………………………………..California Department of Social Services C.F.R. ……………………………….Code of Federal Regulations E&T………………………………….Employment and Training FNS ………………………………….Food and Nutrition Service FY ……………………………………Fiscal Year NERO ……………………………….Northeast Regional Office ODJFS ………………………………Ohio Department of Jobs and Family Services OIG ………………………………….Office of Inspector General OMB ………………………………..Office of Management and Budget PACAP ……………………………..Public Assistance Cost Allocation Plan SF …………………………………….Standard Form SNAP ……………………………….Supplemental Nutrition Assistance Program TANF ……………………………….Temporary Assistance for Needy Families U.S.C. ……………………………….United States Code USDA ……………………………….United States Department of Agriculture WRO ..Western Regional Office Exhibit A: Summary of Monetary Results 32 AUDIT REPORT 27601-0003-22 This exhibit lists findings and recommendations that had a monetary result, and includes the type and amount of the monetary result. Finding Recommendation Description Amount Category 3 5 Unsupported unliquidated obligations $ 111,399,656 Funds to be put to better use 5 12 FNS commingled SNAP E&T funds $ 3,575,424 Questioned Costs, Recovery Exhibit B: Audit Sites Visited AUDIT REPORT 27601-0003-22 33 This exhibit lists the audit sites visited during audit fieldwork. Audit Site Location FNS National Office Alexandria, Virginia FNS Northeast Regional Office State Office New York Office of Temporary and Disability Assistance County Offices New York City Human Resources Administration Erie County Department of Social Services Boston, Massachusetts Albany, New York New York, New York Buffalo, New York FNS Western Regional Office State Office California Department of Social Services County Offices Los Angeles Department of Public Social Services San Francisco Human Services Agency San Francisco, California Sacramento, California Los Angeles, California San Francisco, California FNS Midwest Regional Office State Office Ohio Department of Job and Family Services County Offices Cuyahoga County Job and Family Services Hamilton County Job and Family Services Chicago, Illinois Columbus, Ohio Cleveland, Ohio Cincinnati, Ohio Agency’s Response 34 AUDIT REPORT 27601-0003-22 USDA’S FOOD AND NUTRITION SERVICE RESPONSE TO AUDIT REPORT United States Department of Agriculture Food and Nutrition Service 3101 Park Center Drive Room 712 Alexandria, VA 22302-1500 DATE: September 26, 2016 AUDIT NUMBER: 27601-0003-22 TO: Gil H. Harden Assistant Inspector General for Audit FROM: Audrey Rowe \/s\/ Administrator Food and Nutrition Service SUBJECT: SNAP Administrative Costs This letter responds to the official draft report for audit number 27601-0003-22, SNAP Administrative Costs. Specifically, the Food and Nutrition Service (FNS) is responding to the fourteen recommendations in the report. OIG Recommendation 1: Use the recommendations of the 2008 feasibility study to identify the causes of SNAP administrative cost variances and share any best practices that are discovered as a result of the study with States and counties. FNS Response: FNS concurs with this recommendation. A study that models available State-level data will be included in the FNS Research and Evaluation Plan for FY 2018. Estimated Completion Date: September 30, 2017 OIG Recommendation 2: (Updated by OIG on September 13, 2016) Perform and document continuous monitoring and analyses on a yearly basis of State administrative cost variances to identify and share trends and any best practices to reduce SNAP costs. FNS Response: FNS concurs with this recommendation. FNS will analyze existing State-level administrative expense data to monitor State cost-per-case variances and identify trends. FNS will share with States any identified cost containment strategies that do not negatively affect State Program performance. Estimated Completion Date: September 30, 2017 P a g e | 2 OIG Recommendation 3: Establish standard written procedures for reviewing and approving the risk-based approach used by regions to select States for financial management reviews. FNS Response: FNS concurs with this recommendation. FNS will formalize in writing our procedures for reviewing and approving the risk analyzer results used by regional offices to select State agencies for financial management reviews. Estimated Completion Date: September 30, 2017 OIG Recommendation 4: Establish written requirements and procedures for regional offices to select counties to review in county-administered States. FNS Response: FNS will establish written requirements and procedures for Regional Offices to assess controls of State agency oversight of counties in county-administered State agencies. Estimated Completion Date: September 30, 2017 OIG Recommendation 5: Deobligate $111,399,656 in invalid unliquidated obligations reported by CDSS. FNS Response: FNS will review the $111,399,656 in unliquidated obligations reported by CDSS and determine if any of these obligations are eligible for reimbursement. If any obligations are allowable, we will reduce the $111,399,656 by that amount and de- obligate the remainder. Estimated Completion Date: September 30, 2017 OIG Recommendation 6: Review all SNAP administrative cost unliquidated obligations currently outstanding for States in the Western Region to ensure that they represent actual obligations for valid needs. FNS Response: FNS concurs with this recommendation. FNS will identify all the State agencies in the Western Region who have outstanding unliquidated obligations for FY 2014 and FY 2015. Based on this information, FNS will contact the State agencies identified and request that they provide adequate documentation to support their outstanding unliquidated obligations. Estimated Completion Date: September 30, 2017 AN EQUAL OPPORTUNITY EMPLOYER P a g e | 3 OIG Recommendation 7: Require CDSS to collect unliquidated obligation data from the counties and report these data on its quarterly and final Federal financial reports. FNS Response: FNS program regulations at 7 CFR Part 277.11 already require State agencies to collect unliquidated obligation data to complete their financial status report. However, we will remind State agencies, in a memo, where they are county-administered, that they should be collecting unliquidated obligation data from their counties in order to properly report this information on their quarterly and final financial status reports. Estimated Completion Date: September 30, 2017 OIG Recommendation 8: Revise FNS IPAS-212 Operating Procedures to require the regional offices to review independent source data, such as specific contracts or reports from the grantee’s financial system, during the regional office reviews of unliquidated obligations to ensure that they represent valid needs. FNS Response: FNS Program Accounting Standard Operating Procedures (PASOPs) entitled, Financial Certifications, Version 1.0, (which replaced FNS IPAS-212 Operating Procedures) require that all current and prior year obligations be continuously reviewed to ensure that obligated balances are not overstated or understated and that these obligations are properly documented and reported. FNS will remind regional offices, in a memo, about the requirements for validating reported unliquidated obligations on the quarterly and final financial status reports. Estimated Completion Date: September 30, 2017 OIG Recommendation 9: Develop standardized guidance and procedures for ensuring the States utilize a process that reports expenditures in the proper fiscal year. FNS Response: FNS concurs with this recommendation. FNS will develop and provide standardized guidance for ensuring State agencies report expenditures in the proper fiscal year. Estimated Completion Date: September 30, 2017 OIG Recommendation 10: Identify all States that do not utilize a process for reporting expenditures in the proper fiscal year and require those States to develop and submit a plan to FNS for approval AN EQUAL OPPORTUNITY EMPLOYER P a g e | 4 detailing the process they will use to collect and report expenditures in the proper fiscal year. FNS Response: The FNS process for ensuring proper fiscal year integrity is the financial management reviews (FMRs). FNS will review the past three years FMRs and identify all State agencies whose report included a fiscal year integrity finding. Based on this list we will request the State agencies to provide us with a plan to come into compliance with fiscal year integrity requirements, unless they have already provided this information. Estimated Completion Date: September 30, 2017 OIG Recommendation 11: Require ODJFS to establish adequate procedures for counties to separate and claim SNAP E&T expenditures. FNS Response: FNS will issue a memo to Ohio that requires them to establish procedures for properly reporting SNAP E&T expenditures in the correct funding category, so that the State agency can properly report this information on their quarterly and final financial status reports. Estimated Completion Date: September 30, 2017 OIG Recommendation 12: Review the $3,575,424 in FY 2014 E&T Grant expenditures from ODJFS to determine if any of these funds are eligible for reimbursement and establish an account receivable from the State as needed. FNS Response: FNS will review the $3,575,424 in FY2014 E&T grant expenditures reported by ODJFS on their final financial status report for FY 2014 and determine if any of these expenditures are eligible for reimbursement. Based on the results of the review, we will establish an accounts receivable for the balance determined not to be eligible for reimbursement. Estimated Completion Date: September 30, 2017 OIG Recommendation 13: Require CDSS to timely submit quarterly and final Federal financial reports containing actual expenditures. FNS Response: FNS program regulations at 7 CFR Part 277.11 already require timely submission of quarterly and final financial status reports. FNS will issue a memo that reiterates the need for State agencies to submit timely financial status reports that contain accurate expenditures or obligations. We will require approval of a State’s methodology AN EQUAL OPPORTUNITY EMPLOYER P a g e | 5 if they are unable to report actual expenditures or obligations in a county administered State. Estimated Completion Date: September 30, 2017 OIG Recommendation 14: Develop standardized guidance and procedures for regional offices to communicate any deviations or exceptions granted to States by regional officials to the FNS national office. FNS Response: FNS will issue a memo to the regional offices requiring them to communicate to the National Office any deviations or exceptions granted to State agencies regarding reporting expenditures on the quarterly and final financial status reports. Estimated Completion Date: September 30, 2017 AN EQUAL OPPORTUNITY EMPLOYER To learn more about OIG, visit our website at www.usda.gov\/oig\/index.htm How To Report Suspected Wrongdoing in USDA Programs Fraud, Waste, and Abuse File complaint online: http:\/\/www.usda.gov\/oig\/hotline.htm Click on Submit a Complaint Telephone: 800-424-9121 Fax: 202-690-2474 Bribes or Gratuities 202-720-7257 (24 hours a day) The U.S. Department of Agriculture (USDA) prohibits discrimination in all of its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex (including gender identity and expression), marital status, familial status, parental status, religion, sexual orientation, political beliefs, genetic information, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require al- ternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Assistant Secretary for Civil Rights, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW., Stop 9410, Washington, D.C. 20250-9410, or call toll-free at (866) 632-9992 (English) or (800) 877-8339 (TDD) or (866) 377-8642 (English Federal-relay) or (800) 845-6136 (Spanish Federal-relay). USDA is an equal opportunity provider and employer. Background and Objectives Section 1: FNS Reviews and Monitoring Could be Strengthened Finding 1: FNS Should Determine Causes of Variances and Identify and Share Best Practices to Contain Costs Recommendation 1 Recommendation 2 Finding 2: FNS Needs to Conduct Financial Management Reviews More Consistently Recommendation 3 Recommendation 4 Section 2: Deficiencies in FNS Oversight and the Lack of Effective State and County Financial Management Controls Led to Inaccurate Program Financial Reporting Finding 3: FNS Internal Reviews Did Not Identify More Than 111 Million in Unsupported Unliquidated Obligations for California Recommendation 5 Recommendation 6 Recommendation 7 Recommendation 8 Finding 4: FNS Needs to Provide Adequate Oversight to Ensure Expenditures are Charged to the Appropriate Fiscal Year Recommendation 9 Recommendation 10 Finding 5: Ohio Needs to Establish Controls to Ensure Proper Reporting of Grant Funds Recommendation 11 Recommendation 12 Finding 6: California Needs to Submit Timely Reports of Actual Expenditures Instead of Estimated Expenditures Recommendation 13 Recommendation 14 Scope and Methodology Abbreviations Exhibit A: Summary of Monetary Results Exhibit B: Audit Sites Visited Agency’s Response 27601-0003-22_cover.pdf 09703-0001-22_summary.pdf What Were OIG’s Objectives What OIG Reviewed What OIG Recommends OIG evaluated RUS’ Recovery Act performance measures and controls over expenditures for WWD loans and grants to assess whether the agency used Recovery Act funds to achieve Recovery Act goals. What OIG Found Blank Page Blank Page Text1: SNAP Administrative Costs Report number: Audit Report 27601-0003-22 Date: September 2016 2016-09-29T09:23:23-0400 GILROY HARDEN ”

” United States Department of Agriculture Examination of the Effect of SNAP Benefit and Eligibility Parameters on Low-Income Households Food and Nutrition Service October 2017 Office of Policy Support 3101 Park Center Drive Alexandria, VA 22302 USDA is an equal opportunity provider, employer, and lender. Examination of the Effect of SNAP Benefit and Eligibility Parameters on Low-Income Households Final Report Joshua Leftin Thomas Godfrey James Mabli Nancy Wemmerus Stephen Tordella Submitted to: Submitted by: USDA Food and Nutrition Service Decision Demographics Office of Policy Support 4312 North 39th Street SNAP Research and Analysis Division Arlington, VA 22207-4606 3101 Park Center Drive, Room 1014 Alexandria, VA 22302 Project Officer: Project Director: Bob Dalrymple Stephen Tordella This study was conducted under contract number AG-3198-C-15-0015 with the Food and Nutrition Service, U.S. Department of Agriculture. The report is available at http:\/\/www.fns.usda.gov\/fns\/research.htm Suggested citation: Leftin, J., Godfrey, T., Mabli, J., Wemmerus, N., & Tordella, T. (2017). Examination of the Effect of SNAP Benefit and Eligibility Parameters on Low-Income Households. Prepared by Decision Demographics under Contract No. AG-3198-C-15-0015. Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service. http:\/\/www.fns.usda.gov\/fns\/research.htm Acknowledgements This report was prepared for the U.S. Department of Agriculture’s Food and Nutrition Service, Office of Policy Support by Stephen Tordella, Thomas Godfrey, and Nancy Wemmerus of Decision Demographics and Joshua Leftin and James Mabli of Mathematica Policy Research, with quality assurance review by Laura Castner of Mathematica. The authors thank Bob Dalrymple, Julia Druhan, Kathryn Law, Barbara Murphy, Kameron Burt, Mary Rose Conroy, Sasha Gersten-Paal, Sarah Goldberg, Jessica Luna, and Miles Patrie of the Food and Nutrition Service for providing guidance and reviewing the report. Editorial consultant Susan Freis Falknor, graphic designer Mannie Tobie, Priscilla Foran of Decision Demographics, and Alma Vigil, Alexander Bohn, Katherine Bencio, Bruce Schechter, and Karen Cunnyngham of Mathematica also made important contributions to the report. Page intentionally blank i EXECUTIVE SUMMARY This study for the U.S. Department of Agriculture (USDA) Food andNutrition Service (FNS) examines how well the policies that determine benefit levels for the Supplemental Nutrition Assistance Program (SNAP) reflect the current spending patterns of low\u00adincome households. It is a national study that draws on Federal data resources to examine the expenditures of low\u00adincome households across the United States in 2013 and 2014. Generally, SNAP benefit levels are based on net household income, which accounts for a set of deductions intended to capture household spending on housing, health care, work\u00adrelated costs, and other specified expenses. These expenses reduce what is available for food purchases. To determine household SNAP benefit levels, FNS assumes that households spend 30 percent of their net income on food. Over the years, however, changes in household spending patterns on food, housing, health care, transportation, and other areas may have led to incongruences between SNAP eligibility criteria and benefit levels and the current circumstances of low\u00adincome households. This study finds that SNAP’s existing deduction amounts generally reflect the expenditures reported by low\u00adincome households covered by the deductions. However, this finding applies to SNAP’s current deduction structure and households that qualify for those deductions. Some household types not covered by the deductions have substantial expenditures, particularly in the area of medical costs\u2014a deduction available only to elderly and disabled participants. This Summary provides a broad overview of a comprehensive report. For detailed analyses of the findings introduced here, see complete report, at http:\/\/www.fns.usda. gov\/fns\/research.htm About SNAP SNAP\u2014the nation’s largest nutrition\u00adassistance program\u2014provides eligible low\u00adincome households a monthly benefit to be spent on food, with the aim to reduce food insecurity and improve nutrition. SNAP served an average of 22.5 million households with 45.8 million individuals per month in 2015. Participating households received an average monthly benefit of $258 to supplement their spending on food. The maximum benefit available to SNAP\u00adeligible households is based on the cost of the USDA’s Thrifty Food Plan, a national standard for a nutritious diet at a minimal cost. Implicit in SNAP program rules are assumptions about the income available to households to spend on food; indeed, benefit amounts are keyed to a household’s net income, after certain deductions. The following box shows allowable SNAP deductions for monthly expenditures on certain nonfood items when computing net income. ii Note: The box does not summarize State options pertaining to how deductions are treated. Deduction type Who is eligible? How deduction is computed under Federal rules Standard deduction All households Equal to fixed dollar amount that varies by household size and for Alaska, Hawaii, Guam, and the Virgin Islands; indexed annually to inflation Earned income deduction Households with earned income Equal to 20 percent of monthly household earned income Dependent care deduction Households with dependents Equal to monthly out\u00adof\u00adpocket expenses for the care of children and other dependents while other household members work, seek employment, or attend school Medical expense deduction Households with elderly individuals (age 60+) or disabled individuals Equal to monthly out\u00adof\u00adpocket health care expenses that exceed $35 incurred on behalf of elderly or disabled household members Child support payment deduction Households making legally obligated child support payments Equal to monthly child support payments Equal to out\u00adof\u00adpocket monthly rent, mortgage payments, utility bills, Excess shelter expense deduction All households property taxes, and insurance that total more than half of household income after subtracting other deductions. Households without elderly or disabled individuals are subject to a cap that varies for Alaska, Hawaii, Guam, and the Virgin Islands and is indexed annually to inflation. About this study This study, Examination of the Effect of SNAP Benefit and Eligibility Parameters on Low\u00adIncome Households, was funded by FNS and carried out by Decision Demographics and Mathematica Policy Research. The study analyzes household spending patterns and deduction usage among low\u00adincome households in 2013 and 2014. The study draws on national data, including the Consumer Expenditure Survey (CE), SNAP participant information from the program’s Quality Control data files, and a SNAP eligibility and participation simulation model based on Survey of Income and Program Participation data. The primary objectives of the study are to describe low\u00adincome household spending patterns across various expense categories and household types and to assess the alignment between reported spending and current SNAP policies. The study defines low\u00adincome households as those whose total income is under 200 percent of poverty. Specifically, the study addresses the following questions: What share of their budgets do low\u00adincome households spend on food, housing, health care, transportation, and other items? How do these spending patterns vary across different types of households? How well do SNAP deductions and the SNAP benefit reduction rate (the rule that reduces SNAP benefits by 30 cents for each additional dollar of net income) reflect real costs faced by low\u00adincome households? Do low\u00adincome households have any major expenditures that are not captured in the current deductions? How do households use SNAP deductions when they are initially certified and later recertified for the program? Is there any evidence that households face structural barriers to claiming a deduction, such as reporting and documentation requirements or privacy concerns? iii This study uses nationally representative data to compare low\u00adincome household spending to existing SNAP deductions. Summary of findings 1. Shelter, food, and transportation dominate low\u00adincome household spending. Of the approximately $2,300 spent monthly by the average low\u00adincome household, nearly 40 percent is spent on housing (Figure 1). Food, both at home and away from home, accounts for almost $1 out of every $5 spent, as does transportation. Together, these three categories account for nearly three\u00adquarters of the average household’s spending. The next largest share is spent on health care, with other goods and services such as insurance and pensions, clothing, and entertainment accounting for smaller shares. iv Figure 1. Low\u00adincome household spending patterns Source: 2013 and 2014 Consumer Expenditure Survey. Personal insurance and pensions 4% Entertainment 4% Cash contributions 3% Education 2% Other spending 4% Food at home 15% Housing 37% Other goods and services 17% Food away from home 4% Transportation 17% Health care 8% Clothing 2% Average spending = About $2,300 per month Table 1 shows how different categories of low\u00adincome households allocate their spending as a percentage, or share, of their total expenditures. While at first glance, housing, food, and transportation generally predominate, distinguishing factors reflect the circumstances of different household types. v Table 1. Low\u00adincome household spending Source: 2013 and 2014 Consumer Expenditure Survey. All low\u00adincome households Housing 37% Share of expenditures Food Transportation 19% 17% Health 8% care Other 19% Presence of children Children 36% 21% 19% 5% 19% No children 37% 18% 15% 10% 19% Presence of people age 60+ People age 60 or older 36% 18% 15% 13% 17% No one age 60 or older 37% 20% 18% 5% 20% Income as a percentage of poverty 0 to 49 percent 40% 21% 16% 6% 18% 50 to 99 percent 39% 21% 15% 6% 19% 100 to 130 percent 37% 19% 17% 8% 19% Over 130 percent 35% 18% 18% 9% 20% Household head employment Employed 36% 20% 19% 5% 21% Unemployed 46% 23% 14% 5% 13% Not in labor force 37% 20% 17% 6% 20% Locality Urban 37% 19% 17% 8% 19% Rural 30% 20% 19% 10% 20% Households with children. The average household with children present spends relatively more on food and transportation and less on health care than when there are no children. Households with people age 60 or older. Health care spending reaches 13 percent for the average household that has elderly members, higher than any other household type, while their transportation and food spending are relatively low. Households by income. Income is measured in relation to the Federal poverty guidelines. Those with the lowest income devote the largest share of their spending to housing, on average. This percentage decreases with rising income. The same pattern holds for food spending. The opposite applies to the percentages spent on health care and all other items that rise with income. Households by employment. A larger share of household spending is devoted to the basics of housing and food when the household head is unemployed. Average spending patterns do not vary much between whether the household head is employed or not in the labor force. Locality. Spending on housing is the principal differentiator between urban and rural households\u2014the average rural household spends relatively less. Urban and rural households spend about the same share on food, but rural transportation and health care spending are higher. 2. Most SNAP deductions generally reflect actual expenditures. For some types of households not covered by the deductions, however, expenses may be large. The earned income deduction closely approximates work\u00adrelated expenses. The deduction is meant to approximate costs associated with working, such as commuting expenses, work uniforms, and payroll taxes. Working individuals, also called earners, report spending on gasoline and motor oil, parking and tolls, and uniforms more often than non\u00adearners. These expenditures generally increase with increased earnings. When combined with payroll taxes, they sum to around 19 percent of average earnings\u2014close to the existing SNAP deduction that is set at 20 percent of earned income (Figure 2). vi Figure 2. Work\u00adrelated expenses approximate the current earned income deduction for low\u00adincome households Note: The available data could not identify all work\u00adrelated expenditures or whether all expenditures in these categories were necessarily related to working. Different methods of estimating work\u00adrelated costs range as high as 30 percent of earnings. Source: 2013 and 2014 Consumer Expenditure Survey. Gasoline $2,089 Payroll taxes $1,518 Parking and tolls $81 Uniforms $1 19% of average annual earnings ($19,839) $3,689 20% of $19,839 = $3,968 However, the available data cannot identify all work-related expenditures and, for those expenditures used in the analysis above (for example, gasoline), the data cannot identify whether they were necessarily related to working. Work-related expenses may be higher or lower than 19 percent, depending on which expenditure types are classified as being associated with working. The medical expense deduction compensates for health care expenses for elderly or disabled individuals. However, it does not apply to other household members, whose expenses can be high. Households spending more than $35 out of pocket on the health care of elderly or disabled members may deduct that amount from gross income. Figure 3 shows that low-income households reporting health care spending average substantially more than $35 per month. vii Out-of-pocket health care expenditures are more common for households with elderly or disabled members than for those without, and they spend an average of $318 per month. However, the data do not indicate whether the medical expenses pertained to elderly or disabled household members, whose expenses in excess of $35 are deductible, or to other household members, whose expenses are not deductible. Households without elderly or disabled individuals also incur sizeable medical expenses, but the medical expense deduction is not available to them. Almost half of these households report spending on health care, averaging $224 per month. All low-income households With elderly or disabled individuals Without elderly or disabled individuals Percentage of low-income households reporting out-of-pocket medical expenses, with mean amount 65% 47% 83% $285 per month Figure 3. Low-income households with elderly or disabled members have high health care spending Source: 2013 and 2014 Consumer Expenditure Survey. $318 per month $224 per month SNAP’s excess shelter expense deduction is intended to offset the housing costs that low\u00adincome households face, such as rent, mortgage payments, utility bills, property taxes, and insurance, that are high relative to their income. When this spending exceeds 50 percent of net income after subtracting all other deductions from a household’s gross income, households may claim this deduction. Two additional factors affect calculation of the deduction: Households without elderly or disabled individuals are subject to a dollar limit on the shelter deduction\u2014a shelter cap. In the contiguous United States, the shelter cap was $478 per month in 2014. Instead of using actual utility expenses, many States use predetermined amounts, called Standard Utility Allowances, to add to a household’s actual rent or mortgage expense. For some low\u00adincome households, the cap on the excess shelter expense deduction results in the deduction not fully covering all excess shelter expenses. Figure 4 shows that the shelter cap limits the excess shelter expense deduction amount for some participating households. In particular, 14 percent of participating households without elderly or disabled individuals would realize an increase in SNAP benefits if the shelter cap were removed. Figure 4. The shelter cap limits the excess shelter expense deduction amount of one in seven SNAP participating households without elderly or disabled members. Note: Only households without elderly or disabled individuals are subject to a shelter cap. Sources: Fiscal year 2013 and 2014 SNAP QC data files and simulations using the 2013 and 2014 SNAP QC Minimodels. 14% 86% Shelter cap limits SNAP benefits Shelter cap does not limit SNAP benefits viii ix While the shelter cap may limit the amount of the excess shelter expense deduction, State Standard Utility Allowances (SUAs) may inflate the amount of the deduction relative to actual costs. Figure 5 shows that utility amounts used in the SNAP excess shelter expense deduction were higher, on average, than actual utility expenses for low\u00adincome households. The utility amounts are often based on State SUAs. The Figure 5. tility amounts allowed by he SNAP deduction exceed ctual expenditures ote: The totals exclude ouseholds with no utility mount (SNAP QC) and ouseholds with no utility xpenditures (CE). ources: Fiscal year 2013 and 2014 NAP QC data files for utility mounts, and 2013 and 2014 onsumer Expenditure Survey for tility expenditures U t a N h a h e S S a C u $396 $254 Average utility amount used for computing SNAP excess shelter expense deduction for participating households Average utility expenditures for all low\u00adincome households mean utility amount for SNAP participants (based on either an SUA or actual costs) is $396, compared to $254 in average monthly utility spending for low\u00adincome households. These estimates exclude households with no utility amount or no utility expenditures. 3. Low\u00adincome households spend less than 30 percent of after\u00adtax income but more than 30 percent of net income on food. Since the inception of the program, SNAP rules have assumed that participating households spend about 30 percent of their net income on food, with SNAP providing the difference between that amount and the maximum SNAP benefit. This percentage is often referred to as the benefit reduction rate, because each dollar of net income reduces SNAP benefits by 30 cents (Figure 6). Figure 6. SNAP benefit formula Household SNAP benefit Maximim benefit (based on the Thrifty Food Plan) 30% of household net income The project team evaluated whether this benefit reduction rate reflects current food spending as a percentage of after\u00adtax income, finding that low\u00adincome households spend about 20 percent of after\u00adtax income on food at home. This is lower than the 30 percent used as a basis for the benefit reduction rate but larger than a 12 to 17 percent range found in a recent Institute of Medicine1 assessment. The project team also compared food spending as a percentage of net income to the benefit reduction rate, finding that low\u00adincome households spend about 42 percent of their net income on food at home. However, the CE data show a large discrepancy between reported available income and expenditures, with expenditures exceeding gross income by about 50 percent for most low\u00adincome households. Examining an alternate assumption that total expenditures (excluding SNAP benefits) more appropriately capture households’ total available resources, the project team found that food at home spending excluding the SNAP benefit is a much lower share of total expenditures (13 percent) than of net income (42 percent). Because findings vary substantially by measure of household resources and the CE data present limitations, the project team recommends caution in interpreting these findings and making comparisons with other studies. 4. Low\u00adincome households do not receive deductions for some common types of expenditures, and the proportion of SNAP participants taking certain deductions does not always match well with reported expenditure patterns for low\u00adincome households. SNAP deductions are determined when participating households initially apply for or recertify their eligibility for SNAP benefits. Households may experience changes in earnings and income between initial certification and subsequent recertification, along with changes in housing, health care, and dependent care expenses that affect their deductions. The project team examined deduction availability and usage by: Considering whether low\u00adincome households incur costs that are not included in the deductions but that could be considered Comparing the percentage of participating SNAP households that take each deduction type at initial certification and recertification Assessing whether there is evidence of structural barriers that might keep low\u00adincome households from reporting certain expenses Study findings vary widely by approach used. Results are inconclusive because of this and other data limitations. x The project team analyzed data for low\u00adincome households and SNAP participants to explore the need for deductions, their actual usage, and actual amounts. The findings show that: SNAP deductions do not capture certain common household expenses that low\u00adincome households have, such as spending on housing repairs or maintenance, vehicle\u00adrelated expenses not associated with commuting, and finance, late charges, or interest on student loans. Nearly three\u00adquarters of SNAP households take an excess shelter expense deduction, and 32 percent have an earned income deduction. The other deductions are used much less frequently. Greater percentages of households use the earned income, excess shelter expense, dependent care, and medical expense deductions at recertification than households in their initial certification, but the differences are generally small. There is no significant difference in the use of the child support payment deduction at initial certification and recertification. Figure 7 shows that the percentage of low\u00adincome households with spending on rent or mortgage, health care, and child care is often higher xi Figure 7: The percentage of households reporting specific expenditures exceeds the percentage claiming related SNAP deductions Notes: Rent or mortgage: The figure for participating households represents reported rent or mortgage expenditures used toward the excess shelter expense deduction. Medical expense: Percentages pertain to households with elderly or disabled individuals. Expenditures are in excess of $35. Dependent care: Percentages pertain to households with children. Sources: 2013 and 2014 Consumer Expenditure Survey; fiscal year 2013 and 2014 SNAP QC data files. Participating households with deduction Low\u00adincome households with expenditure Rent or Medical Dependent Child support mortgage expense care payment 2%2% 9%7% 64% 10% 95% 67% than the percentage of SNAP participants that use the corresponding deduction. This could signify structural barriers such as difficulty acquiring or providing required documentation on expenditures, or it could reflect differences between the broader low\u00adincome population and the portion of the population that participates in SNAP. It is also possible that households with low gross incomes such that their net incomes are zero after applying the standard deduction may elect not to report expenses such as shelter and medical because they would already be eligible for a maximum SNAP benefit without any additional deductions. Summary This study updates information on the share of their budget that low\u00ad income households spend on food, housing, health care, transportation, and other items. It also investigates whether SNAP eligibility rules and benefit amounts accurately reflect current spending patterns for low\u00ad income households The study finds that SNAP’s existing deductions generally reflect the expenditures reported by low\u00adincome households. For example, work\u00ad related expenditures and taxes for earners sum to an amount close to the percentage of earnings that are deductible for SNAP participants. In addition, some deductions such as the child support payment deduction are equal to the expenditure amount by definition. However, this overall finding applies only to SNAP’s current deduction structure and the households that qualify for those deductions. Some household types not covered by the deductions can have substantial expenditures, particularly in the area of health care. Households without elderly or disabled individuals are not eligible for a medical expense deduction, yet those households incur sizeable health care expenses each month. In addition, some households have expenditures on items not included in the existing deductions, such as vehicle expenses, housing repairs and maintenance, and charges pertaining to education loans. The share of after\u00adtax income that low\u00adincome households spend on food at home is lower than the 30 percent used as a basis for the benefit reduction rate, but the share of net income spent on food at home is higher than the 30 percent benefit reduction rate. For most households, SNAP’s existing deductions generally reflect the expenditures reported by low\u00adincome households. xii expenditures were much greater than income in the CE, calling into question whether reported gross income adequately captures the resources available to households with which to purchase goods and services. Consumption decisions may be based not only on current income, but on expectations of future earnings and assets, making expenditures a valid alternative measure of a household’s budget. The share of total expenditures spent on food at home is lower than 30 percent. Because of the inconsistency in findings depending on which measure of resources is used, as well as other data limitations, caution should be used in interpreting these findings and making comparisons with other studies. Differences between reported household spending patterns and the use of SNAP deductions suggest that some eligible households may not be claiming housing, medical, and other SNAP deductions to which they may be entitled. xiii About the data and methods This study uses data primarily from the 2013 and 2014 Consumer Expenditure Survey (CE) public\u00aduse files2 and the 2013 and 2014 SNAP Quality Control (QC) data files3, supplemented with results from the Food and Nutrition Service’s SNAP QC based microsimulation model and Survey of Income and Program Participation based microsimulation model.4 The 2013 and 2014 CE data were the most recent available at the time of the study. In discussions of spending patterns, the household is shorthand for the CE consumer unit \u2014 which is broadly defined as a single person living alone or two or more people living together who share responsibility for several major types of expenses. In discussions of expenditures and deductions for actual SNAP participants, the household is the SNAP filing unit as observed in the SNAP QC data. All analyses use descriptive methods, except for part of the examination of costs at certification and recertification, which uses a SNAP QC\u00adbased regression model. 1 Institute of Medicine & National Research Council. (2013). Supplemental Nutrition Assistance Program: Examining the Evidence to Define Benefit Adequacy. Adv Nutr. 4: 477\u00ad478. http:\/\/advances.nutrition.org\/content\/4\/4\/477.full 2 U.S. Department of Labor, Bureau of Labor Statistics, Division of Consumer Expenditure Survey. Users’ Documentation Interview Survey Public\u00adUse Microdata (PUMD) Consumer Expenditure, 2013 and 2014. http:\/\/www.bls.gov\/cex\/csxmicrodoc.htm 3 Vigil, Alma, Kelsey Farson Gray, Shivani Kochhar, and Bruce Schechter. Technical Documentation for the Fiscal Year 2014 Supplemental Nutrition Assistance Program Quality Control Database and the QC Minimodel. Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, 2015. 4 Leftin, Joshua, Joel Smith, Karen Cunnyngham, and Carole Trippe. Technical Working Paper: Creation of the 2011 MATH SIPP+ Microsimulation Model and Database. Final report submitted to U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, 2014. xiv AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report Table of Contents I. INTRODUCTION …………………………………………………………………………………………………………… 1 A. Overview of SNAP …………………………………………………………………………………………………….. 1 B. Historical and current SNAP deductions ……………………………………………………………………….. 2 C. Organization of the report ……………………………………………………………………………………………. 5 II. SUMMARY OF DATA AND METHODS ………………………………………………………………………… 6 A. Analyses with CE data ………………………………………………………………………………………………… 6 B. Analyses with SNAP QC data ……………………………………………………………………………………… 9 C. Analyses with the 2013 and 2014 QC Minimodels ……………………………………………………….. 10 D. Analyses with the SIPP and CPS-based microsimulation model …………………………………….. 11 III. LOW-INCOME HOUSEHOLD SPENDING PATTERNS …………………………………………………. 12 A. Household spending on all goods and services …………………………………………………………….. 13 B. Differences in household spending for different household types ……………………………………. 17 IV. ADEQUACY OF CURRENT DEDUCTIONS ………………………………………………………………….. 22 A. Earned income deduction ………………………………………………………………………………………….. 22 B. Medical expense deduction ………………………………………………………………………………………… 25 C. Excess shelter expense deduction ……………………………………………………………………………….. 29 D. Standard deduction …………………………………………………………………………………………………… 33 V. ADEQUACY OF THE BENEFIT REDUCTION RATE ……………………………………………………. 36 A. Comparison of food spending patterns to historical data ……………………………………………….. 36 B. Comparison of food spending as a percentage of net income to the benefit reduction rate …. 38 C. Limitations ………………………………………………………………………………………………………………. 41 VI. DEDUCTION USAGE AND AVAILABILITY ………………………………………………………………… 43 A. Deduction usage ………………………………………………………………………………………………………. 43 B. Expenses not included in the deductions ……………………………………………………………………… 58 VII. CONCLUSION ……………………………………………………………………………………………………………. 61 A. Summary of key findings ………………………………………………………………………………………….. 61 B. Policy implications …………………………………………………………………………………………………… 63 C. Recommendations for future research …………………………………………………………………………. 64 REFERENCES …………………………………………………………………………………………………………………… 69 APPENDICES ……………………………………………………………………………………………………………………. 72 Appendix A: Detailed description of data and methods Appendices B F: Analysis tables Appendix G: Summary of food expenditure estimates for low-income households AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report Acronyms used in this report ARRA American Recovery and Reinvestment Act of 2009 BLS Bureau of Labor Statistics CE Consumer Expenditure Survey CPS Current Population Survey FNS Food and Nutrition Service GA General Assistance LUA Limited Utility Allowance MFIP Minnesota Family Investment Program PUMD Public Use Microdata file SIPP Survey of Income and Program Participation SNAP Supplemental Nutrition Assistance Program SNAP QC SNAP Quality Control Data file SSI Supplemental Security Income SSI-CAP SSI Combined Application Project SUA Standard Utility Allowance TANF Temporary Assistance for Needy Families TFP Thrifty Food Plan USDA United States Department of Agriculture AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 1 I. INTRODUCTION The Supplemental Nutrition Assistance Program (SNAP) provides a monthly benefit to eligible low-income households to spend on food to reduce food insecurity and improve nutrition and well-being. The SNAP allotment, based on the monthly cost of the four-person Thrifty Food Plan (TFP), is intended to provide participating households with an amount that, together with their own resources, gives them access to a healthy diet. Implicit in the SNAP rules are assumptions about the amount of households’ own resources that households are able to spend on food relative to other necessary expenditures such as shelter, transportation, and health care. To the extent that these assumptions do not reflect eligible households’ actual spending patterns, the SNAP benefit amount may be inadequate to allow households to purchase food that aligns with the TFP. In this study, we examine whether SNAP eligibility rules that determine the size of the SNAP benefit allotment accurately reflect current spending patterns for low-income households. In particular, the research addresses the following three study objectives, primarily by using Consumer Expenditure Survey (CE) and SNAP Quality Control (QC) data files for fiscal years 2013 and 2014: 1. Determine the share that various categories of expenses account for in low-income households’ monthly budgets 2. Determine how the shares of these categories of expenses vary by demographic, economic, and geographic subgroups 3. Assess how well the SNAP eligibility determination and benefit-level parameters capture the real costs faced by low-income households In the remainder of this chapter, we provide background on SNAP eligibility rules and the process through which benefit amounts are determined. A. Overview of SNAP SNAP is the largest of the 15 domestic food and nutrition assistance programs administered by the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS). According to FNS administrative records, the program served approximately 45.8 million people in 22.5 million households in an average month during fiscal year 2015, with an average monthly household benefit of $258. Individuals who live together and customarily purchase and prepare food together apply for benefits as one SNAP household (or filing unit). If eligible, they are certified for a period of time before they must reapply for benefits. Certification periods differ depending on State guidelines and household circumstances. The average certification periods in fiscal years 2013 and 2014, respectively, were 12.7 and 12.9 months. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 2 To be eligible for SNAP, most households without elderly or disabled individuals must have monthly gross income at or below 130 percent of Federal poverty guidelines, monthly net income after allowable deductions at or below 100 percent of the poverty guidelines, and countable assets at or below a threshold ($2,250 in fiscal year 2015). Households with elderly or disabled individuals are exempt from the gross income limit (although their net income must be at or below the net income limit) and may have up to $3,250 in countable resources. SNAP benefit amounts are calculated by subtracting 30 percent of a household’s net income from the maximum benefit for that household’s size and location. The 30 percent amount, called the benefit reduction rate, represents the percentage of a household’s net cash income that is expected to be spent on food, with SNAP benefits providing the difference between that amount and the maximum benefit, which is based on the cost of a nutritionally adequate diet. Certain households receiving public assistance or related services are considered categorically eligible for SNAP and are subject to different SNAP income and resource limits, as determined by States individually. Income limits for categorically eligible households differ by State and range from 130 percent to 200 percent of Federal poverty guidelines, while resource limits are waived in some States and are higher than the standard SNAP resource limits in others. However, categorically eligible households must meet all other SNAP rules and have incomes low enough to be eligible for a benefit. B. Historical and current SNAP deductions SNAP was first authorized as a permanent program in the Food Stamp Act of 1964 (Pub. L 88-525). To receive SNAP benefits, households were required to purchase their benefits, paying an amount commensurate with their normal expenditures for food and receiving a benefit amount such that they could more nearly obtain a low-cost, nutritionally adequate diet (FNS, 2014). An amendment (Pub. L. 91-671) later limited households’ purchase requirements to 30 percent of their income. By the mid-1970s, SNAP became a nationwide program, under which households were entitled to deductions that reduced the value of their income before determining the amount of program benefits, resulting in a higher SNAP allotment. The deductions were for: \uf0b7 Work allowances, up to $30 per month \uf0b7 Mandatory payroll deductions from earned income \uf0b7 Medical expenses if expenditures exceed $10 per month \uf0b7 Child care payments \uf0b7 Tuition and mandatory fees \uf0b7 Court-ordered support and alimony payments \uf0b7 Unusual expenses incurred due to disaster or casualty losses which could not be reasonably anticipated by the household \uf0b7 Shelter expenses in excess of 30 percent of household monthly income, after all other allowable deductions are made (adjusted net income) AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 3 The Food Stamp Act of 1977 (Pub. L 95-113) combined some of the smaller, less frequent deductions into a $60 standard deduction.1 It also converted the work allowance to an earned income deduction equal to 20 percent of earnings, established a $75 limit on the child care (dependent care) deduction, and modified the excess shelter expense deduction to equal shelter expenses in excess of 50 percent of net income, not to exceed $80 in combination with the child care deduction. Finally, the legislation eliminated the purchase requirement, establishing the current calculation formula for the SNAP benefit. Rules governing current deductions have changed only slightly since implementation of the Food Stamp Act of 1977. Below, we describe the current deductions and summarize them in Table I.1. 1. Standard deduction All participating SNAP households receive a standard deduction based on household size and region (contiguous United States, Alaska, Hawaii, Guam, and the Virgin Islands). The standard deduction is indexed annually to inflation; in fiscal year 2014, it was equal to $152 for one- to three-person households in the contiguous United States and $163, $191, and $219, respectively, for households in the contiguous United States with four, five, and six or more people. 2. Earned income deduction Households may deduct 20 percent of combined earnings from their gross income. The deduction is intended to incentivize employment and compensate households for work-related costs, excluding dependent care, which is captured in its own deduction. Costs might include those associated with commuting (such as gasoline, motor oil, parking, and tolls), uniforms, and payroll taxes. 3. Dependent care deduction Households with dependents receive a deduction for out-of-pocket expenditures for the care of children and other dependents while other household members work, seek employment, or attend school. 1 Deductions eliminated by the Food Stamp Act of 1977 included those for (1) court-ordered support or alimony payments; (2) tuition and mandatory fees assessed by educational institutions; and (3) unusual expenses incurred as a consequence of disaster or casualty losses which could not be reasonably anticipated by the household (U.S. House Comm. on Agriculture, 1977). The medical expense deduction and child support payment deduction were also discontinued in 1977, but they were both reinstated within a few years. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 4 4. Medical expense deduction Households with elderly individuals (age 60 or older) or nonelderly disabled individuals may receive a medical expense deduction.2 In most States, such households may deduct combined out-of-pocket medical expenditures exceeding $35 incurred on behalf of elderly or disabled household members. Recurring medical expenses such as doctor’s visits and prescriptions are converted to a monthly amount based on frequency, and one-time medical expenses may be either prorated over the remainder of the months in the unit’s certification period or deducted in the month the expense is billed or otherwise becomes due (FNS, 2012). In 15 States as of September 2014, standard medical deduction demonstration projects used standard deduction amounts for medical expenses that exceeded $35 but remained below a specified limit. The standard medical deduction demonstration amount ranged from $83 in New Hampshire to $210 in Illinois. 5. Child support payment deduction In all States, households may receive a deduction for legally obligated child support payments made to or for a nonmember of the household. Beginning in 2002, with the implementation of the SNAP provisions in the Farm Security and Rural Investment Act of 2002, States have had the option to treat legally obligated child support payments made to non- household members as an income exclusion rather than as a deduction. Eighteen States took the option as of September 2013. 6. Excess shelter expense deduction A household is entitled to a deduction equal to shelter expenses (such as rent, mortgage payments, utility bills, property taxes, and insurance) that exceed 50 percent of its adjusted net income. Adjusted net income is countable income after all other potential deductions are subtracted from gross income. Instead of using actual utility expenses, many States use Standard Utility Allowances (SUAs), which are specified dollar amounts set by State agencies, to calculate a household’s total shelter expense. For households without elderly or disabled individuals, the amount of this deduction cannot exceed a maximum amount (the shelter cap) which is indexed annually to inflation. The shelter cap in fiscal year 2014 in the contiguous United States was $478. Households with elderly or disabled individuals may subtract the full value of shelter expenses that exceed 50 percent of 2 Generally, a person is considered to be disabled for SNAP eligibility purposes if he or she receives Federal or State disability or blindness payments or other disability retirement benefits from a government agency under the Social Security Act, including Supplemental Security Income (SSI) or Social Security disability or blindness payments; receives an annuity under the Railroad Retirement Act and is (1) eligible for Medicare or (2) considered to be disabled based on SSI rules; is a veteran who is totally disabled, permanently housebound, or in need of regular aid and attendance; or is permanently disabled and receiving veterans’ benefits as a surviving spouse or child of a veteran. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 5 their adjusted net income. Some States also allow homeless households a deduction of $143 for shelter expenses. Table I.1. Summary of SNAP deductions Deduction type Who is eligible? How deduction is computed under Federal rules Standard deduction All households Equal to fixed dollar amount that varies by household size and for Alaska, Hawaii, Guam, and the Virgin Islands; indexed annually to inflation Earned income deduction Households with earned income Equal to 20 percent of monthly household earned income Dependent care deduction Households with dependents Equal to monthly out-of-pocket expenses for the care of children and other dependents while other household members work, seek employment, or attend school Medical expense deduction Households with elderly or disabled individuals Equal to monthly out-of-pocket health care expenses that exceed $35 incurred on behalf of elderly or disabled household members Child support payment deduction Households making legally obligated child support payments Equal to monthly child support payments Excess shelter expense deduction All households Equal to out-of-pocket monthly rent, mortgage payments, utility bills, property taxes, and insurance in excess of half of household income after subtracting other deductions, subject to a cap for households without elderly or disabled individuals that varies for Alaska, Hawaii, Guam, and the Virgin Islands; indexed annually to inflation Note: The table does not summarize State options pertaining to how deductions are treated. C. Organization of the report In Chapter II, we describe the data sources and methods used for the study, and, in Chapter III, we present findings from our analyses of low-income households’ spending patterns, covering the first two study objectives. In Chapters IV, V, and VI, we address the third study objective by assessing the extent to which current SNAP eligibility and benefit determination rules capture true household spending patterns. We conclude in Chapter VII with a summary of the findings, their implications and limitations, and possibilities for further research. A glossary of frequently used terms appears after Chapter VII. Appendices provide a detailed methods discussion (Appendix A) and supplemental tables (Appendices B through G). Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 6 II. SUMMARY OF DATA AND METHODS We drew on the most recent data available from several sources to conduct the study. To address all research questions for the first two study objectives and many research questions for the third study objective, we used the 2013 and 2014 Bureau of Labor Statistics (BLS) Consumer Expenditure Survey (CE). For the third study objective, we supplemented the CE-based analyses with analyses that used (1) the 2013 and 2014 SNAP Quality Control (QC) data files and a QC- based microsimulation model (the QC Minimodel) and (2) a Survey of Income and Program Participation (SIPP) and Current Population Survey (CPS) based microsimulation model. In this chapter, we discuss the data sources and the analytic methodologies used to address the research questions. A. Analyses with CE data The CE, administered by the Census Bureau for the BLS, provides highly detailed U.S. consumer expenditure data that simultaneously measure a variety of household spending behaviors, allowing analysis of the amount and proportion of a household’s budget spent on specific categories of goods and services. The survey also includes information on household characteristics, income, and financial data. We used CE data to address Objectives 1 and 2, producing a complete account of expenditures by spending category for low-income households and detailing how the shares vary by important demographic, economic, and geographic characteristics. We also used the data to address topics under Objective 3, including assessments of (1) how expenditures for low-income households compare with the SNAP deductions and the benefit reduction rate, (2) which frequently occurring expenditures are not captured by existing deductions, and (3) how the percentage of low-income households with various types of expenditures compares to the percentage of households claiming SNAP deductions for such expenses. 1. Interview structure The CE consists of two quarterly surveys, the Interview Survey and the Diary Survey, that provide information on the purchasing habits of approximately 7,000 households. In the current study, we made exclusive use of Interview Survey data collected over five consecutive quarters; each year’s data set accounts for about 35,000 household records. The initial interview collects demographic and family characteristics data. At each interview, respondents report expenditures for the three calendar months preceding the interview month. For example, interviews conducted in April 2013 provided expenditure data for January through March 2013. The second- and fifth- quarter interviews collect income and components of income; respondents provide the information as annual amounts. Even though the third- and fourth-quarter interviews generally do not collect income, the CE data file provides income amounts for these periods. These amounts are usually the same as those for the second quarter unless (1) income was imputed and the imputation changed; (2) someone in the unit started or stopped working; or (3) the composition of the CE unit changed. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 7 2. The consumer unit The unit of analysis in the CE is the consumer unit, defined as (1) occupants related by blood, marriage, adoption, or some other legal arrangement; (2) a single person who is living alone or sharing a household with others, but who is financially independent; or (3) two or more people living together who share responsibility for at least two out of the three major types of expenses\u2014food, housing, and other expenses. A consumer unit can differ from a SNAP household which, under SNAP rules, is defined as individuals who live together and customarily purchase and prepare food together. For simplicity, we use household in place of consumer unit when we discuss the findings. 3. Stacking the CE data The 2014 Public-Use Microdata were released in September 2015 and were the most recent data available at the time of our analysis. The file contains information on expenditures for January through December 2014, though the survey design is such that the data were collected through March 2015. To obtain a larger sample, we stacked (pooled) the 2013 and 2014 data, after confirming that there were no major changes in the design or contents between the two years. We did not make any inflation adjustments (Appendix A provides a discussion). As described, each annual CE data file summarizes five quarters of experience. The fifth quarter overlaps the subsequent year and facilitates data file production and accommodates coding and sample design changes. Given that the fifth quarter of the 2013 CE data set overlaps with the first quarter of the 2014 data, we did not include the first quarter of 2014 in the stacked analysis file in order to avoid double counting. 4. Annualizing monthly expenditures The CE data provide expenditures as quarterly values; however, income is an annual measure. To annualize expenditures and calculate weighted average expenditure amounts, we used a method created by the BLS that is described in the CE Interview data documentation and sample program. We first adjusted the quarterly expenditure amounts to include only those expenditures made in calendar years 2013 and 2014. For example, for respondents interviewed in February 2013 who reported expenditure data from December 2012, January 2013, and February 2013, we included only the January and February 2013 expenditure amounts. We summed the adjusted quarterly expenditure amounts to obtain a weighted expenditure total. To obtain an average annual expenditure amount, we divided the weighted expenditure total by the weighted number of households, adjusting for the number of months of expenditure data each household contributed and for the CE’s rolling sample design. In this case, given that each quarter of interviews is designed to represent an independent sample, the use of data from several quarters to estimate annual totals requires the sum of the adjusted weights to be divided by 12 (equal to three months times four quarters) when using one year of data and by 24 (equal to three months times eight quarters) when using two years of data. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 8 In addition to presenting weighted average expenditure amounts, we present shares of total expenditures spent on specific categories of goods and services. To calculate the share of total expenditures spent on a specific expense category such as Food at Home, we calculated the weighted average expenditures on food at home and divided by the weighted average total expenditures for all goods and services. In the case of uncommon, one-time large expenses such as a vehicle purchase or high medical bills, annualized expenses for the consumer units that experience such expenses can appear improbably large, such as a sample member spending $12,000 on a car in a given quarter. When calculating average expenditure amounts across all units, these large values are offset by the lack of purchases in other quarters, and thus are smoothed over time. When estimating average expenditures among those units with positive expenditures, however, these large, one- time purchases may bias the estimate upward because the data is restricted to those quarters with positive expenditures. For analyses of average monthly expenditures, we divided annualized expenditures by 12. 5. Defining gross income We defined gross income as total consumer unit income in the past 12 months before taxes minus the annual SNAP benefit amount, which the CE includes in its definition of income. When calculating expenditures as a percentage of income, we modified the definition to use after-tax income, a better measure of disposable income than before-tax income. We used an income measure that included imputations of income carried out by the BLS in combination with the income as reported by respondents. Exploratory tabulations that were restricted to reported income revealed inconsistencies between respondents’ employment and earnings (which form part of total income). For example, only about half of the consumer units with employed unit heads reported earnings. In many cases, the data indicated that the respondent either did not know or refused to provide the requested information. When describing income reporting in the CE, the BLS acknowledges respondents’ lack of information or refusal to report the requested information and therefore provides an imputed income measure that is used throughout this report (BLS, 2016). 6. Determining poverty guidelines Poverty guidelines issued by the U.S. Department of Health and Human Services provide the basis for the Federal fiscal year’s SNAP gross and net monthly income eligibility standards. We identified the poverty guideline for each consumer unit based on the unit’s size, State of residence, and interview month. We used a single set of guidelines for consumer units located within the 48 contiguous States and the District of Columbia and for records on which the State was not identified; we applied State-specific guidelines for consumer units in Alaska and Hawaii. The CE interview month dictated the specific poverty guideline applied to a household. We used the guidelines that reflected the Federal fiscal year that accounted for the majority of months in AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 9 the lookback period. For the April 2013 and April 2014 interviews\u2014with six months of lookback in each of two years\u2014we applied the poverty guidelines of the more recent fiscal year. 7. Defining low-income households Once we determined the appropriate poverty guidelines for a consumer unit, we calculated income as a percentage of the poverty level by dividing the gross income by the poverty level for that unit. We defined low-income households in the data as those consumer units with annual gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Not all low-income households that we examine in this study are eligible for SNAP. Some may not satisfy the income or resource eligibility criteria, and some may be otherwise categorically ineligible for SNAP. B. Analyses with SNAP QC data The SNAP QC data file is derived from SNAP’s QC system that measures the accuracy of State eligibility and benefit determinations. It contains detailed demographic, economic, and SNAP eligibility information, in addition to information on deduction use and amounts of deductions, for a nationally representative sample of approximately 48,000 SNAP households each fiscal year (Filion et al., 2014; Vigil et al., 2015). The data are weighted to ensure that the weighted totals match three adjusted SNAP Program Operations totals: the monthly number of SNAP households by State and stratum, the monthly number of SNAP participants by State, and the monthly total benefits issued by State. The totals are adjusted by removing benefits issued in error and benefits issued through the SNAP disaster assistance program because the SNAP QC data do not include cases with either of these conditions. We used these adjusted data to address most topics under Objective 3. 1. The SNAP unit The SNAP unit (also called the SNAP household in the tables and in our description of the findings) was the unit of observation and the unit of analysis. SNAP units comprise individuals who purchase and prepare food together and who are together certified for and receive SNAP benefits. 2. Stacking the SNAP QC data For all QC-based analyses, we stacked the fiscal year 2013 and 2014 SNAP QC data files so that the combined data cover October 2012 through September 2014. There were no substantial changes in the structure or content of the fiscal year 2014 file relative to the fiscal year 2013 file. We multiplied the sample weights by one-half to make the findings representative of an average month in the combined fiscal year 2013 and 2014 period. The combined data contain observations for 97,819 SNAP households. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 10 3. Analysis restrictions We excluded from most analyses SNAP households participating in State programs for which income is not used in their SNAP benefit determinations.3 We imposed some additional restrictions for tables that compared SNAP QC based findings with CE findings, thereby increasing the comparability of the two groups of households (discussed in more detail in Appendix A). 4. Multivariate analysis approach We used the stacked fiscal year 2013 2014 SNAP QC data for descriptive and multivariate regression analyses to examine whether the rates of deduction use for excess shelter costs, medical costs, and transportation costs are maintained at recertification and whether households with similar circumstances that do not deduct certain medical, shelter, or transportation costs have comparably similar SNAP allotments. The data used for the analyses consist of the amount of the deductions and the marginal effectiveness of each deduction, which measures the amount of the increase in net income if the deduction type were not used. The data also include the SNAP benefit allotment and a variable that identifies whether the most recent action on a case was a new certification or a recertification. In the first set of regressions, the dependent variables were the deduction amounts and the marginal effectiveness of the deductions and the main independent variable was whether the most recent certification was the initial certification or a recertification. In the second set of regressions, the SNAP allotment was the dependent variable, and the main independent variable was a measure of whether the SNAP household took the deduction.4 Each set of regressions included the same set of explanatory variables consisting of demographic and economic characteristics of SNAP households. Additional details are described in Appendix A. C. Analyses with the 2013 and 2014 QC Minimodels The QC Minimodel uses SNAP QC data to simulate the impact of various policy changes to SNAP on current SNAP participants. The 2013 and 2014 QC Minimodels use the fiscal year 2013 and 2014 SNAP QC data files, respectively.5 We used the 2013 and 2014 QC Minimodels to assess the effect of removing the shelter deduction cap for SNAP households without elderly or disabled individuals (presented in Chapter IV). The simulation results represent combined results from both models. With all 3 These include households eligible for SNAP through the Minnesota Family Investment Program (MFIP) or a Supplemental Security Income-Combined Application Project (SSI-CAP). 4 Results from the second set of regressions are not discussed in the report, but are presented in Appendix Table F.3. 5 The 2014 QC Minimodel simulates benefits that were in place after the sunset of the American Recovery and Reinvestment Act (ARRA) benefit amounts. Because the ARRA benefits were in place for only one month during the fiscal year (October 2013), the QC file used with the model does not differ substantially from the original fiscal year 2014 SNAP QC data file. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 11 results presented as percentages, we did not need to use weighting adjustments to account for the use of two years of data. Filion et al. (2015) and Vigil et al. (2015) present more information on the QC Minimodels. D. Analyses with the SIPP and CPS-based microsimulation model Some research questions discussed in Chapters IV and V required the calculation of expenditures in the CE as a percentage of SNAP net income. Given that we did not have sufficient information to derive net income in the CE, we used a microsimulation model database, the fiscal year 2015 Baseline of the 2011 MATH SIPP+ model, to obtain the needed information. We calculated net income as a percentage of gross income for certain household types that have income at or below 200 percent of poverty and that we simulated as eligible for and participating in SNAP. We then applied the resultant ratios to gross income of the same groups in the CE. The model calculates net income by subtracting estimated deductions from gross income. We derived the ratios by using data from 2011 and SNAP rules from fiscal year 2015, with dollar values deflated to 2011. Therefore, the estimates used to derive the ratios do not align precisely with the same 2013 2014 period of the CE data. Leftin et al. (2014a) describe the model, with additional detail presented in Appendix A. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 12 III. LOW-INCOME HOUSEHOLD SPENDING PATTERNS Understanding household spending patterns across a broad range of goods and services provides needed context for assessing how well existing SNAP eligibility and benefit rules capture the real costs faced by participants. Determining the share of a household’s budget that it spends on food, for example, can help policymakers understand the efficacy of the 30 percent benefit reduction rate and whether the food spending patterns that were assessed when designing SNAP hold true today. Determining budget shares for other goods and services can also indicate how well SNAP deductions account for the most costly and most common types of expenses. Finally, knowing whether these spending patterns vary across different types of households can help policymakers determine whether SNAP deductions are adequately responsive to certain subgroups that tend to incur particularly large expenses. A central challenge is how to best measure a household’s budget given the available data. The CE provides information on total expenditures on goods and services, as well as gross income. As discussed in greater detail below and in Chapter V, total expenditures exceed gross income for most low-income households in the CE, suggesting that (1) expenditures reflect the true resources available to a household; (2) many households make purchases with savings and credit; or (3) expenditure or income information may be misreported. Consistent with how the BLS describes spending patterns (BLS, 2016) as well as other research on low-income household spending patterns (e.g., Mabli & Malsberger, 2013), we define budget shares spent on goods and services by calculating the percentage of total expenditures within each major category of goods and services.6 We present shares of expenditures for all households and low-income households across major categories of goods and services, including food, housing, domestic services, apparel, health care, transportation, and other goods and services (Table III.1). We describe total spending across all goods and services and then examine spending on specific types of goods and services as shares of total expenditures. Next, we compare household spending to household income and examine spending categories as shares of total income. We conclude by presenting spending patterns for different types of households, such as households with and without children and lower- and higher-income households. 6 The data do not identify whether expenditures were made with income, savings, credit, or through other means. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 13 Table III.1. Major budget categories of goods and services Spending category Types of goods and services Food at home Food and nonalcoholic beverages purchased at grocery, convenience, or specialty stores; food and beverages purchased and prepared by household during out-of- town trips Food away from home Food or board at school; catered affairs; food and nonalcoholic beverages at restaurants, cafes, and fast-food places on trips; dining out at restaurants, cafeterias, and drive-ins (excluding alcoholic beverages); school meals for preschool and school-age children; meals received as pay Apparel and apparel services Clothing for men, women, and children; footwear; apparel services such as dry- cleaning and laundering Housing Mortgage, interest, property taxes, rent, other lodging expenses, maintenance, repairs, insurance; utilities such as natural gas, electricity, fuel oil, telephone services, and water; textiles, furniture, and flooring; appliances (major, small, and miscellaneous); other household expenses and miscellaneous equipment Domestic services Babysitting and child care, adult and older adult care, housekeeping, gardening and lawn care, pest control Health Health insurance, medical services, prescription drugs, medical supplies Transportation New or used cars, trucks, or other vehicles; gas or motor oil; vehicle finance charges, maintenance and repairs, insurance, and rentals; public transportation Other Fees and admissions; televisions, radios, and sound equipment; pets, toys, and playground equipment; other entertainment; personal care; reading; education; tobacco and smoking supplies; cash contributions; alcohol; personal insurance; miscellaneous goods and services Source: Consumer Expenditure Survey Interview data files. A. Household spending on all goods and services Among all households in the CE, spending on goods and services averaged $4,128 each month, or $49,536 per year, in 2013 and 2014. The differences in spending across households were sizable, with 25.5 percent of all households spending at most $24,000 per year (equivalent to $2,000 per month) and 36.9 percent of all households spending more than $48,000 (equivalent to $4,000 per month) (Figure III.1). Compared to all households, low-income households reported lower average expenditures at $2,319 per month, or $27,828 per year, with over half of low-income households (53.9 percent) spending at most $24,000 per year. Low-income households spent the largest shares of their expenditures on housing, food, transportation, and other goods and services not categorized elsewhere (Figure III.2). As a share of total spending, they spent 36.7 percent on housing, with most of the amount allocated to rent and utilities; 19.4 percent on food; 16.8 percent on transportation; and 16.4 percent on other goods and services, made up mostly of personal insurance and pensions, entertainment, cash contributions, and education. Spending on food amounted to 15.0 percent on food at home and 4.4 percent on food away from home.7 Remaining household expenditures went to health care 7 This estimate of food at home as a percentage of total expenditures does not exclude the reported SNAP benefit amount from food at home expenditures or from total expenditures. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 14 (7.9 percent), comprised mostly of health insurance expenses; apparel (1.9 percent); and domestic services such as child care (0.9 percent). Relative to all households, low-income households spent larger shares of total expenditures on housing and food and smaller shares on other goods and services (Figure III.2). The share spent on food was 19.4 percent for low-income households and 15.1 percent for all households, the difference stemming from differences in food-at-home expenditures, which were 15.0 percent for low-income households and 10.3 percent for all households.8 Similarly, the share spent on housing for low-income households was 36.7 percent versus 31.8 percent for all households. The shares spent on other categories of goods and services were about eight percentage points smaller for low-income households than for all households (16.4 versus 24.8 percent). It is common to assess spending patterns by comparing shares of total expenditures spent on major budget categories of goods and services, thereby ensuring that all the shares sum to 100 percent (Mabli & Malsberger, 2013). Such an approach is useful when comparing shares across different types of households, such as all households and low-income households, or when examining trends. It can, however, give rise to challenges in policy analyses focused on low- income populations. For example, components of SNAP rules such as the benefit reduction rate are based on assumptions about spending as a percentage of net income, without consideration of other potential resources such as savings and credit. Therefore, we also examined spending patterns by describing shares of spending as a percentage of total after-tax income rather than as a percentage of total expenditures.9 Most low-income households had higher expenditures than income. Low-income households spent 149.0 percent of total income, on average, reporting $27,828 in annual expenditures and $18,680 in annual income. Expenditures were higher than income for all ranges of expenditures that we used, except for households in the lowest range\u2014$0 to $12,000\u2014that spent 97.4 percent of income (Figure III.3). Households in the higher ranges of expenditures each spent substantially more than 100 percent of income. In contrast, average spending was 77.1 percent of total income for all households (lower- and higher-income households), ranging from 71.3 to 85.4 percent of income across the five expenditure groups. Spending on housing, food, and transportation accounted for the largest shares of income, with spending on housing exceeding half of total income for low-income households (54.7 percent) and nearly one-quarter of total income for all households (24.5 percent) (Figure III.4). 8 This is in line with the body of economics literature called Engel’s law, which states that the proportion of total expenditures spent on food should decrease as income increases (Fraker, 1990; Castner & Mabli, 2010). 9 In Appendix B, we also provide tables presenting differences in spending patterns for households with savings or checking account balances and households with debt. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 15 For low-income households, 28.8 percent of total gross income went to food expenditures\u201422.3 percent on food at home and 6.5 percent on food away from home. Figure III.1. Total annual spending for all households and low-income households, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. 5.9 19.6 21.4 16.2 36.9 15.1 38.8 24.7 11.2 10.1 0 10 20 30 40 50 $0 to $12,000 $12,001 to $24,000 $24,001 to $36,000 $36,001 to $48,000 $48,001 or more P e rc e n ta g e o f h o u s e h o ld s All households Low-income households AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 16 Figure III.2. Expenditure shares for all households and low-income households, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the household as reported in the CE. Mean expenditure shares include contributions from households that report zero expenditures of that type. Mean monthly expenditure amounts appear in Appendix Table B.1. a Spending on other goods and services for low-income households was comprised mostly of spending on personal insurance and pensions, entertainment, cash contributions, and education. Figure III.3. Share of gross income spent on all goods and services for all households and low- income households, by annual expenditure amount, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. 31.8 10.3 4.8 17.4 7.6 1.8 1.4 24.8 36.7 15.0 4.4 16.8 7.9 1.9 0.9 16.4 0 10 20 30 40 50 Housing Food at home Food away from home Transportation Health care Apparel Domestic services Other goods and services \u1d43 P e rc e n ta g e o f to ta l e x p e n d it u re s All households Low-income households 77.1 84.2 85.4 75.4 71.3 77.9 149.0 97.4 119.2 128.5 147.0 284.5 0 50 100 150 200 250 300 350 Any expenditure amount $0 to $12,000 $12,001 to $24,000 $24,001 to $36,000 $36,001 to $48,000 $48,001 or more P e rc e n ta g e o f h o u s e h o ld in c o m e s p e n t All households Low-income households AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 17 Figure III.4. Shares of gross income spent on major categories of goods and services for all households and low-income households, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the household as reported in the CE. Mean expenditure shares include contributions from households that report zero expenditures of that type. a Spending on other goods and services for low-income households was comprised mostly of spending on personal insurance and pensions. B. Differences in household spending for different household types To assess how types of spending as a share of total expenditures vary by demographic and economic characteristics and by geography, we estimated expenditure shares (as a percentage of total spending) by characteristics such as household size and composition (including presence of children, elderly, or disabled individuals), employment status, income level, and metropolitan status. The types of goods and services purchased by households varied only modestly across different types of low-income households (Table III.2). Housing expenditures were the largest expenditure share for all household types, typically representing about 35 to 40 percent of total household spending. Expenditures on food (at home and away), transportation, and other goods and services were the next-largest shares across all household types, followed by shares of spending on health care and apparel. Although households generally demonstrated similar spending patterns in terms of allocating the greatest share of resources to housing, followed by food and transportation, the sizes of the shares differed for different types of households (Table III.2). In some cases, the differences were modest. The share of total expenditures spent on housing, for example, varied from 39.6 percent for households with income at less than 50 percent of the poverty guidelines to 35.0 percent for households with income between 130 and 200 percent of the poverty guidelines. 24.5 7.9 3.7 13.5 5.9 1.4 1.0 19.1 54.7 22.3 6.5 25.0 11.9 2.9 1.3 24.4 0 10 20 30 40 50 60 Housing Food at home Food away from home Transportation Health care Apparel Domestic services Other goods and services \u1d43 P e rc e n ta g e o f h o u s e h o ld in c o m e s p e n t All households Low-income households AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 18 Housing expenditure shares for households with no elderly individuals were similar to those for households with elderly individuals (37.1 and 36.1 percent). There were larger differences in the share spent on housing according to whether the household head was employed or unemployed (36.2 and 45.5 percent) or whether the household lived in an urban or rural area (37.4 and 30.4 percent). Expenditure shares on food varied according to household size, income, and composition. The share spent on food increased with household size, from 17.7 percent for single-person households to 21.5 percent for households with five or more people (Figure III.5). The shares reflect an increase in spending on food at home from 13.0 to 17.7 percent and a decrease in spending on food away from home spending from 4.7 to 3.8 percent. The share spent on food decreased with income as a percentage of the poverty guidelines, from 21.2 percent for households with income under 50 percent of the guidelines to 18.2 percent for households with income greater than 130 percent and less than 200 percent of the guidelines (Figure III.6), reflecting the net effect of food-at-home shares that decreased with income and food-away-from-home shares that marginally increased with income. There were some differences in spending on food at home by household composition. Compared to households with no children, households with children spent a greater share on food at home (16.8 percent for households with children versus 13.6 percent for those without children) (Figure III.7). Similarly, households with a nonelderly disabled individual spent a greater share on food at home than households without a nonelderly disabled individual (17.6 versus 14.6 percent). However, there was little difference in the share spent for households with an elderly individual and households without an elderly individual (14.2 and 15.4 percent). AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 19 Table III.2. Mean expenditure shares for low-income households by household characteristic and expenditure type, 2013 2014 Food Housing, excluding domestic services Apparel Health care Trans- portation Other goods and services All households 19.3 36.7 1.9 7.9 16.8 17.3 Households with: Household size 1 person 17.8 39.8 1.6 9.3 13.1 18.6 2 people 18.4 34.6 1.4 10.7 17.5 17.4 3 people 20.0 37.3 2.3 6.3 18.6 15.7 4 or more people 21.3 35.3 2.5 5.2 18.9 16.8 Presence of children Children 20.8 36.2 2.6 4.9 19.1 16.3 No children 18.2 37.1 1.4 10.1 15.1 18.0 Presence of elderly individuals Elderly individuals 18.4 36.1 1.3 13.4 14.9 15.9 No elderly individuals 19.9 37.1 2.3 4.5 18.0 18.2 Income as a percentage of poverty guidelines 0 to under 50 percent 21.1 39.6 2.3 5.5 15.6 15.8 50 to under 100 percent 21.1 38.7 2.1 6.4 14.9 16.8 100 to 130 percent 18.9 36.7 1.8 8.4 16.9 17.2 More than 130 percent to 200 percent 18.2 35.0 1.7 9.2 17.9 18.1 Employment status of household head a Employed 19.5 36.2 2.2 5.0 18.7 18.3 Unemployed 23.1 45.5 1.8 5.0 13.5 11.2 Not in labor force 20.3 37.2 2.1 6.0 16.6 17.8 Geography Urban 19.2 37.4 1.9 7.7 16.5 17.2 Rural 20.2 30.4 1.7 10.1 19.3 18.3 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure shares are defined as annual expenditures of a certain type divided by total annual expenditures for the household. Mean expenditure shares include contributions from households that report zero expenditures of that type. Domestic services expenditures are included in the Other goods and services column. a Children and elderly adults are excluded from those not in the labor force. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 20 Figure III.5. Expenditure shares on food for low-income households, by household size, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure shares are defined as annual expenditures of a certain type divided by total annual expenditures for the household. Mean expenditure shares include contributions from households that report zero expenditures of that type. Figure III.6. Expenditure shares on food for low-income households, by gross income as a percentage of the poverty guidelines, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure shares are defined as annual expenditures of a certain type divided by total annual expenditures for the household. Mean expenditure shares include contributions from households that report zero expenditures of that type. 13.0 13.9 15.9 16.7 17.7 4.7 4.5 4.1 4.3 3.8 0 5 10 15 20 25 1 person 2 people 3 people 4 people 5 or more people P e rc e n ta g e o f to ta l e x p e n d it u re s Food at home Food away from home 17.0 16.7 14.7 13.7 4.2 4.3 4.3 4.5 0 5 10 15 20 25 0 to under 50 percent 50 to under 100 percent 100 to 130 percent More than 130 percent to 200 percent P e rc e n ta g e o f to ta l e x p e n d it u re s Food at home Food away from home AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 21 Figure III.7. Expenditure shares on food for low-income households, by household composition, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Expenditure shares are defined as annual expenditures of a certain type divided by total annual expenditures for the household. Mean expenditure shares include contributions from households that report zero expenditures of that type. Expenditure shares on transportation varied according to household size, the presence of children in the household, employment status of the household head, and metropolitan status. The share spent on transportation was markedly lower for single-person households at 13.1 percent compared to 17.5 to 19.3 percent for households with more than one person (Table III.2). Households with children spent a larger share on transportation relative to households without children (19.1 versus 15.1 percent), as did households with an employed head relative to an unemployed head (18.7 versus 13.5 percent) and households in rural areas relative to those in urban areas (19.3 versus 16.5 percent). Low-income households spent an average of nearly 8 percent of their total expenditures on health care, consisting largely of health insurance expenses, but the share differed by income and the presence of children or an elderly individual in the household. The share spent on health care increased with income as a percentage of the poverty guidelines, from 5.5 percent for households with income under 50 percent of the guidelines to 9.2 percent for households with income greater than 130 percent and less than 200 percent of the guidelines (Table III.2). It was smaller for households with children compared to those without children (4.9 versus 10.1 percent) and households without an elderly individual compared to those with an elderly individual (4.5 versus 13.4 percent). 16.8 13.6 14.2 15.4 17.6 14.6 4.0 4.6 4.2 4.5 3.1 4.5 0 5 10 15 20 25 Households with children Households without children Households with an elderly individual Households without an elderly individual Households with a nonelderly disabled individual Households without a nonelderly disabled individual P e rc e n ta g e o f to ta l e x p e n d it u re s Food at home Food away from home AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 22 IV. ADEQUACY OF CURRENT DEDUCTIONS For most households, SNAP eligibility and monthly benefit amounts are determined on the basis of net income, which is intended to represent the disposable income available to households for the purchase of food. Net income is calculated by subtracting deductions permitted under SNAP from a household’s monthly gross income. The deductions include an earned income deduction, medical expense deduction, excess shelter expense deduction, standard deduction, dependent care deduction, and child support payment deduction.10 In this chapter, we assess how well the SNAP deductions align with the actual spending of low-income households. We focus on four of the six deductions: the earned income deduction, medical expense deduction, excess shelter expense deduction, and standard deduction. Given that the dependent care deduction and child support payment deduction are always set equal to expenses and that all households with such expenses are allowed to take those deductions, the two deductions reflect actual spending for households by design. Therefore, we do not analyze those deductions here. A. Earned income deduction About 57 percent of low-income households had earnings in 2013 2014. Households receive a deduction equal to 20 percent of their earnings; the deduction is intended to approximate costs associated with working, except for dependent care, which is captured in its own deduction. Such costs might include those associated with commuting such as gasoline, motor oil, parking, and tolls; mandatory work uniforms; and payroll taxes. Payroll taxes are approximately 7.65 percent of earnings, which is the sum of 6.20 percent for Social Security and 1.45 percent for Medicare. To assess how well the earned income deduction aligned with households’ actual work- related expenditures, we examined whether: 1. Households with earnings more commonly incurred certain expenditures associated with working 2. Spending associated with working increased with the level of earnings 3. The amount of spending on work-related expenses equaled about 20 percent of earnings 10 As discussed in Chapter I, States have the option to use a child support payment income exclusion instead. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 23 Compared to those without earnings, a greater percentage of low-income households with earnings incurred expenses that could be associated with working (Table IV.1). For example, 86.4 percent of low-income households with earnings reported gasoline or motor oil expenses compared with 70.3 percent of low-income households without earnings. Spending on parking and tolls was less common but followed a similar pattern among households with and without earnings; 11.9 percent of households with earnings had expenditures on parking and tolls compared with 5.6 percent of households without earnings. Expenditures on uniforms for individuals age 16 or older were uncommon for all household types; however, the percentage of households with earnings that reported expenditures on uniforms (1.4 percent) was still noticeably higher than the percentage for households without earnings (0.2 percent). The percentage of low-income households with work-related expenses generally increased with earnings (Table IV.1). We use a $15,000 break point because it is approximately what a person would earn by working full-time at the 2014 Federal minimum wage of $7.25 per hour. Four out of five (80.8 percent) households with annual earnings at or below $15,000 had gasoline and motor oil expenses compared with 89.0 percent of households with earnings between $15,000 and $30,000 and 93.2 percent of households with earnings greater than $30,000. While rare, spending on uniforms was nearly twice as common for households with earnings greater than $30,000 than for those with earnings at or below $15,000 (2.0 versus 1.1 percent). In contrast, expenditures on parking and tolls were fairly similar across earnings levels. Table IV.1. Percentage of low-income households with selected expenditure types by presence and amount of annual earned income, 2013 2014 Annual earned income Positive earned income $0 Any amount More than $0 to $15,000 More than $15,000 to $30,000 More than $30,000 Percentage of households with expenditures on Gasoline and motor oil 70.3 86.4 80.8 89.0 93.2 Parking and tolls 5.6 11.9 12.2 11.3 12.1 Uniforms a 0.2 1.4 1.1 1.3 2.0 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a For this table, uniform expenses are restricted to those purchased for individuals age 16 or older. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 24 Not only did the percentage of households with gasoline and motor oil expenditures increase with earnings; the amount these households spent on gasoline and motor oil also increased with earnings (Table IV.2). Among households with such spending, expenditure amounts were $2,042 for households in the lowest earnings category, $2,305 for those in the middle earnings category, and $3,242 for those in the highest earnings category. Spending on parking and tolls and on uniforms did not vary with earnings as much as gasoline and motor oil expenditures did. Table IV.2. Mean annual expenditures by presence and amount of income for low-income households with expense type, 2013 2014 Annual earned income Positive earned income $0 Any amount Up to $15,000 $15,001 to $30,000 More than $30,000 Mean annual expenditures\/tax among households with expense type\/tax Gasoline and motor oil $1,561 $2,418 $2,042 $2,305 $3,242 Parking and tolls $715 $683 $689 $619 $771 Uniforms a $116 $102 $105 $90 $111 Payroll taxes b $0 $1,518 $545 $1,690 $3,159 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Households with negative earnings from self-employment are categorized as having $0 of earnings in this table. a For this table, uniform expenses are restricted to those purchased for individuals age 16 or older. b Payroll taxes are estimated as 7.65 percent of earnings. Spending on gasoline and motor oil, parking and tolls, and uniforms combined with estimated payroll taxes totaled about 18.6 percent of mean earnings, close to the 20 percent amount of the earned income deduction (Figure IV.1). Mean annual earnings for low-income households were $19,839 while the sum of annual expenditures on gasoline and motor oil ($2,089), parking and tolls ($81), uniforms ($1), and payroll taxes ($1,518) was about $3,689, roughly $280 less than the amount equivalent to 20 percent of mean earnings ($3,968). When considering how these expenses compare to the deduction of 20 percent of earned income, it is important to acknowledge that the available data could not identify whether all expenditures in these categories were necessarily related to working and may not have captured all work-related expenditures. For example, we included parking as a commuting expense but could not discern from the data whether parking expenditures were or were not associated with work. On the other hand, we did not include expenditures on vehicle insurance, which is required for vehicle owners, in part because the data did not provide information on whether a household used the vehicle exclusively for commuting or would have otherwise owned a vehicle regardless of the need to commute. Our analysis balanced these tradeoffs by including as commuting costs those expenditures that can reasonably be expected to increase with commuting length and frequency, such as gasoline, motor oil, parking, and tolls, and excluding expenditures on items AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 25 such as vehicle maintenance that likely do not differ as much for individuals that use vehicles to commute and individuals that use vehicles for non-commuting purposes. Figure IV.1. Comparison of annual work-related expenditures to 20 percent of average annual earnings for low-income households Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. B. Medical expense deduction A medical expense deduction is available only to households with elderly or disabled individuals. In 2013 2014, households with elderly or disabled individuals accounted for 50.7 percent of low-income households and 38.0 percent of participating SNAP households.11 In most States, such households may deduct average monthly combined out-of-pocket medical expenses exceeding $35 incurred on behalf of elderly or disabled household members. Standard medical deduction demonstration projects, authorized in some States, use standardized deduction amounts for medical expenses that exceeded $35 but remained below a specified limit (Table IV.3). Fifteen States in fiscal year 2014 and 14 States in fiscal year 2013 used standard medical deductions to simplify expense reporting and administration. Standard medical deduction amounts ranged from a minimum of $83 in New Hampshire to a maximum of $210 in Illinois over the two fiscal years, with a median of $140. 11 The first percentage is based on the CE sample and the second percentage on the SNAP QC sample. Parking & tolls $81 0% 20% 40% 60% 80% 100% Average earnings Work-related expenses Payroll taxes Gasoline $19,839 $3,689 $3,968 (20%) $1,518 $2,089 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 26 Table IV.3. State medical deduction demonstration projects, fiscal years 2013 2014 State If medical expenses are >$35 but less than or equal to Then household receives standard medical deduction of Arkansas $138 $103 Idaho a $179 $144 Illinois $245 $210 Iowa $140 $105 Kansas $175 $140 Massachusetts October 2012 February 2014 $125 $90 March 2014 September 2014 $190 $155 Missouri $200 $165 New Hampshire $118 $83 North Dakota b $200 $165 Rhode Island $176 $141 South Dakota $200 $165 Texas $137 $102 Vermont $173 $138 Virginia $175 $140 Wyoming $138 $103 Source: U.S. Department of Agriculture, FNS. Table adapted from Vigil et al. (2015). Note: If verified expenses were greater than the maximum medical expense used for the standardized deduction, then States used the actual expenses minus $35. a Idaho implemented its program in November 2013. b North Dakota implemented its program in April 2013. If households in States with standard medical deduction demonstration projects provide verification of their actual expenditures and those expenditures are higher than the standard medical deduction plus $35, then the household may receive a medical expense deduction equal to their actual expenses minus $35 in lieu of the standard medical deduction. Using SNAP QC data from fiscal year 2014, we find that that about 26 percent of participating SNAP households with medical expense deductions in standard medical deduction States had a deduction greater than the standard amount, ranging from 15 percent in Virginia to nearly 49 percent in Massachusetts (Table IV.4). AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 27 Table IV.4. Distribution of medical expense deduction amounts in relation to the standard medical deduction among SNAP households in States with standard medical deduction demonstration programs in fiscal year 2014 Households with a medical expense deduction in standard medical deduction demonstration States Total Medical expense deduction equals the standard medical deduction amount Medical expense deduction is greater than the standard medical deduction amount Total SNAP households in State (000) State standard medical deduction amount Number (000) Percent of total SNAP households Number (000) Percent of total with medical expense deduction Number (000) Percent of total with medical expense deduction All 4,830 283 5.9 208 73.6 75 26.4 Arkansas 216 $103 10 4.4 8 82.8 2 17.2 Idaho a 81 $144 4 4.5 3 84.5 1 15.5 Illinois 998 $210 39 3.9 30 78.6 8 21.4 Iowa 191 $105 9 4.5 7 79.3 2 20.7 Kansas 133 $140 11 8.2 7 65.8 4 34.2 Massachusetts b 483 $90\/$155 41 8.5 21 51.2 20 48.8 Missouri 402 $165 46 11.4 38 84.0 7 16.0 New Hampshire 53 $83 3 6.6 2 64.3 1 35.7 North Dakota 25 $165 3 13.6 2 59.0 1 41.0 Rhode Island 99 $141 8 8.2 6 74.9 2 25.1 South Dakota 44 $165 3 6.9 2 64.5 1 35.5 Texas 1,601 $102 81 5.0 61 76.1 19 23.9 Vermont 48 $138 10 20.2 6 60.8 4 39.2 Virginia 442 $140 15 3.4 13 85.3 2 14.7 Wyoming 15 $103 1 6.9 1 75.4 0 24.6 Source: Weighted totals from the fiscal year 2014 SNAP QC data file. a Idaho implemented its demonstration project in November 2013. As such, the table excludes Idaho SNAP QC household records from October 2013. b Massachusetts’ standard medical deduction demonstration project amount increased from $90 to $155 in March 2014. To determine whether the medical expense deduction was responsive to expenditures of low- income households, we assessed the prevalence and amount of medical expenditures, including health insurance, medical services, and prescription drugs and medical supplies, for all low- income households and for those with and without elderly or disabled individuals, and how often the amount exceeded $35. Medical expenditures in the CE include only those that were not reimbursed and appear to be well-aligned with those that are countable under SNAP rules. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 28 Out-of-pocket medical expenditures were common for all low-income households but occurred more frequently among households with elderly or disabled individuals than among those without such individuals (Figure IV.2). More than four out of five low-income households with elderly or disabled individuals had medical expenses (83.1 percent) compared with 46.9 percent of households without elderly or disabled individuals. The data do not, however, provide sufficient information to determine whether the medical expenses pertained to elderly or disabled members of the household, for whom expenses in excess of $35 are deductible, or to other household members, for whom expenses are not deductible. Figure IV.2. Percentage of low-income households with medical expenses Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Medical expenses are for all members of the household and cannot be separated into those exclusively for elderly or disabled individuals. a We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. The CE does not include sufficient information to identify individuals who meet the SNAP disability criteria described in Chapter I. Average medical expenses among households that incurred such expenses were usually substantially more than $35 per month (Figure IV.3). Only 9.6 percent of households with elderly or disabled members had average monthly medical expenses at or below $35. These households would not receive a medical expense deduction. More than 80 percent had expenses greater than $100 and therefore would be eligible for at least a $65 medical expense deduction if all eligible expenses (as defined by SNAP rules) pertained to elderly or disabled members of the household and if the household verified its expenses. Among households without elderly or disabled individuals, 76.7 percent had average monthly medical expenses in excess of $35, and more than half (56.4 percent) had expenses greater than $100 per month. The average expenditure among households without elderly or disabled individuals and with medical 65.3 83.1 46.9 0 20 40 60 80 100 All With elderly or disabled individuals\u1d43 Without elderly or disabled individuals P e rc e n ta g e AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 29 expenses in excess of $35 was, at $224 (not shown in Figure IV.3), about 30 percent lower than that for households with elderly or disabled individuals, at $318. Figure IV.3. Distribution of average monthly medical expenditure amounts among low-income households with medical expenses, 2013 2014 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Due to the design of the CE, the expenditure amounts that contribute to household-level distributions cannot be restricted to those that occur within the 2013 and 2014 calendar years. Some are representative of the fourth quarter of 2012 or the first quarter of 2015. Medical expenses are for all members of the household and cannot be disaggregated into only those for elderly or disabled individuals. a We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. The CE does not include sufficient information to identify individuals who meet the SNAP disability criteria described in Chapter I. C. Excess shelter expense deduction A household is entitled to a deduction equal to shelter expenses (such as rent, mortgage payments, utility bills, property taxes, and insurance) that exceed 50 percent of its adjusted net income. Adjusted net income is countable income after all other potential deductions are subtracted from gross income. The difference between total shelter expenditures and 50 percent of adjusted net income is the excess shelter expense amount. Households without any elderly or disabled individuals are subject to a maximum deduction called the shelter cap, which was $478 Greater than $0 to $35 10% $36 to $100 7% $101 to $500 66% $501 to $1,000 13% $1,001 or more 4% With elderly or disabled individuals\u1d43 Greater than $0 to $35 23% $36 to $100 20% $101 to $500 46% $501 to $1,000 8% $1,001 or more 3% Without elderly or disabled individuals AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 30 in the contiguous United States in fiscal year 2014 and varied for Alaska, Hawaii, Guam, and the Virgin Islands. More than 99 percent of low-income households in the CE had housing expenditures in fiscal years 2013 2014, accounting for 36.7 percent of their total expenditures. With these expenditures so prevalent, it is particularly important to assess whether the excess shelter expense deduction reflects current expenditure patterns. To assess the adequacy of the deduction, we conducted the following analyses: \uf0b7 To assess the effect of the shelter cap, we used the SNAP QC based microsimulation models to analyze how often households without elderly or disabled individuals had an excess shelter expense deduction that was limited by the shelter cap (that is, their SNAP benefit would have been higher in the absence of the shelter cap). \uf0b7 We assessed the share of adjusted net income (defined as net income plus the excess shelter expense deduction) that low-income households typically spent on housing and utilities. SNAP households spending less than 50 percent of their adjusted net income on shelter expenses were not entitled to an excess shelter expense deduction. The analysis assessed the prevalence of households with shelter expenses large enough to permit the households to receive the deduction. \uf0b7 We compared the mean monthly utility amounts for participating SNAP households used in the SNAP excess shelter expense deduction calculation to the actual utility expenditures for low-income households and assessed whether there were differences across geographic regions. The analysis assessed Standard Utility Allowances (SUAs), which are the basis for countable utility expenditures for most participating households. 1. The shelter cap About 68.5 percent of participating SNAP households without elderly or disabled individuals received an excess shelter expense deduction in fiscal years 2013 2014. For these types of households, the amount of the excess shelter expense is compared to the shelter cap when determining the amount of the excess shelter expense deduction. We simulated the deduction without the cap and determined the percentage of households whose benefits were limited by the cap (that is, those households that would receive a higher SNAP allotment if the shelter cap were removed). Overall, the shelter cap limited the benefits of 20.2 percent of all SNAP households with (1) no elderly or disabled individuals, and (2) an excess shelter expense deduction, and it limited the benefits of 13.9 percent of all SNAP households with no elderly or disabled individuals (Appendix Table D.4). 2. Shelter expenditures as a percentage of adjusted net income In fiscal year 2014, 72.0 percent of participating SNAP households received an excess shelter expense deduction, and 30.6 percent received a shelter deduction equal to or greater than the shelter cap (Farson Gray & Kochhar, 2015). To assess whether a typical low-income household AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 31 would have expenditures high enough to take an excess shelter expense deduction if their rent\/mortgage, property taxes, homeowner\/rental insurance, and actual utility expenses (rather than SUAs) were used, we compared shelter expenses as a percentage of adjusted net income to the 50 percent threshold at which households begin to qualify for the deduction. Low-income households spent 55.5 percent of their adjusted net income on shelter expenditures (Table IV.5).12 This percentage was similar for households with elderly individuals or nonelderly disabled individuals (53.6 percent) and those without elderly or nonelderly disabled individuals (57.2 percent). The mean dollar value that equates to 55.5 percent of adjusted net income for all low-income units is $738 per month, and the mean dollar value that equates to 50 percent of adjusted net income is $665. Therefore, low-income households would be expected to have an average excess shelter expense deduction of $73, which compares to an average excess shelter expense deduction of $290 for participating SNAP households in fiscal year 2014 (Farson Gray & Kochhar, 2015). The difference could be attributed to differences in the two sets of households we are comparing (low-income households in the CE and participating SNAP households in the SNAP QC data). For example, low-income households in the CE not necessarily eligible for SNAP may have higher gross income (and, thus, higher adjusted net income) relative to participating SNAP households in the SNAP QC data, which would lower the excess shelter expense deduction if shelter expenses remain constant. Table IV.5. Shelter expenditures as a share of adjusted net income, 2013 2014 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. Countable shelter expenditures include those for owned dwellings, rental dwellings, utilities, property taxes, and insurance. Adjusted net income is the sum of net income plus the excess shelter expense deduction. In other words, it is equal to countable income after all other potential deductions except for the excess shelter expense deduction are subtracted from gross income. a In the CE, we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. 12 A description of our method appears in Appendix A. Subgroup Countable shelter expenditures as a percentage of adjusted net income All low-income households 55.5 Elderly or nonelderly disabled individuals a 53.6 No elderly or nonelderly disabled individuals 57.2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 32 3. SUAs One component of countable shelter expenses is the monthly utility amount. Instead of using actual utility expenses, most States use SUAs to calculate the utility expense component of total shelter expenses. There are several types of SUAs: \uf0b7 The heating and cooling SUA (HCSUA) is used for SNAP households with heating and cooling expenses that are not included in rent. \uf0b7 The Limited Utility Allowance (LUA) is used for SNAP households that have two or more types of utility expenditures but do not have heating and cooling expenses separate from rent. Both the HCSUA and LUA generally include all utilities, including telephones. \uf0b7 The telephone allowance is used for SNAP households with telephone expenses but without any other utility expenses. \uf0b7 Other standard amounts may be provided for utilities such as electricity, water, sewer, trash, and gas\/fuel. For participating SNAP households with positive utility amounts, we compared mean monthly amounts used in the SNAP shelter deduction calculation, which are usually based on the SUAs described above, to actual mean monthly utility expenditures for low-income households among those with positive utility expenditures (Figure IV.4). Overall, utility amounts used in the SNAP excess shelter expense deduction calculation were $396 for SNAP households with a positive amount compared with expenditures of $254 for low-income households with positive expenses. By Census regions the respective amounts were $572 and $260 in the Northeast, $418 and $236 in the Midwest, $304 and $272 in the South, and $348 and $232 in the West. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 33 Figure IV.4. Mean utility amounts in the SNAP QC data file compared with utility expenditures for low-income households in the CE by geographic region, among SNAP participants with a positive utility amount and low-income households with positive utility expenses, 2013 2014 Sources: Weighted tabulations of 2013 and 2014 CE Interview data files and tabulations of fiscal year 2013 and 2014 SNAP QC data files. Notes: We define low-income households in the SNAP QC data file as SNAP households with gross income at or below 200 percent of the poverty guidelines. Low-income households in the CE are those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a SNAP households in States with mandatory SUA policies receive a Standard Utility Allowance for their shelter deduction if they incur heating or cooling expenses and have two or more utility expenses. SNAP households in States with non-mandatory SUA policies receive a utility amount equal to either an SUA or actual monthly utility expenses (including $0 if no expenses were incurred). D. Standard deduction SNAP households receive a standard deduction based on household size and region (contiguous United States, Alaska, Hawaii, Guam, and the Virgin Islands). The standard deduction is indexed annually to inflation; in fiscal year 2014 for the contiguous United States, it was equal to $152 for one- to three-person households, and $163, $191, and $219, respectively, for households with four, five, and six or more people. The standard deduction replaced three deductions that were in place prior to the Food Stamp Act of 1977. The deductions pertained to (1) court-ordered support or alimony payments; (2) tuition and mandatory fees assessed by educational institutions; and (3) unusual expenses incurred due to disaster or casualty losses which could not be reasonably anticipated by the household.13 The medical expense deduction 13 Food Stamp Act of 1977. Report 95-464 on H.R. 7940. $396 $572 $418 $304 $348 $254 $260 $236 $272 $232 $0 $100 $200 $300 $400 $500 $600 $700 All Northeast Midwest South West Mean utility amount used in SNAP excess shelter expense deduction calculation among households with positive utility amount (SNAP QC) \u1d43 Mean monthly actual utility expenditures among low-income households with positive utility expenditures (CE) AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 34 and child support payment deduction were also discontinued in 1977 but were both reinstated within a few years. Drawing on data from the CE, we assessed the size of the standard deduction compared with two of the expenses it replaced in 1977: alimony expenses and education expenses.14 We tabulated the expenses’ prevalence and dollar amounts by household size (Table IV.6). Very few low-income households (one-tenth of one percent) reported alimony expenses. Because so few households had such expenses, we could not reliably infer the monthly amount of the expense. Overall, 10.8 percent of low-income households incurred education expenses, including those for children. The expenses relate to tuition, test preparation and tutoring services, school books, supplies, and equipment, and other school expenses, including rentals. Monthly expenses for households with education expenses were higher than the fiscal year 2014 standard deductions. The percentage of households with such expenses increased with household size, ranging from 8.6 percent for one- to three-person households to 20.3 percent for households with six or more members. Even though the standard deduction more than covers total education expenses among all low-income households, which were less than $60 per month across all household sizes, it would not compensate average monthly education expenses for households with such expenses (Table IV.7). For example, the $163 standard deduction for four-person SNAP households in the contiguous United States in fiscal year 2014 would cover only 58.6 percent of the average education expense ($278) among the 15.9 percent of four-person low- income households facing such expenses. Table IV.6. Prevalence of expenditure types associated with deductions prior to the Food Stamp Act of 1977 by household size for low-income households, 2013 2014 Household size All low- income households 1 3 4 5 6+ Percentage of households with alimony contributions 0.1 0.1 0.1 0.1 0.0 Percentage of households with education expenses 10.8 8.6 15.9 19.4 20.3 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. 14 We could not assess unusual expenses incurred due to disaster or casualty loss because the CE captures only regular, typical expenses. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 35 Table IV.7. Dollar amounts of education expenses by household size for low-income households compared with fiscal year 2014 standard deduction amounts in the contiguous United States, 2013 2014 All low-income households Household size 1 3 4 5 6+ Education expenses a Among all households $54 $57 $44 $32 $47 Among all households with expense $500 $668 $278 $166 $230 Standard deduction Dollar amount (contiguous United States) $152 $163 $191 $219 As a percentage of monthly education expenses among households with expense 22.8 58.6 115.1 95.2 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a Education expenditures include tuition, test preparation and tutoring services, school books, supplies, and equipment, and other school expenses including rentals. Student loan payments are not included in the education expenditures tabulated above. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 36 V. ADEQUACY OF THE BENEFIT REDUCTION RATE The SNAP benefit amount decreases with rising net income. Since the inception of SNAP, program rules have assumed that SNAP households spend about 30 percent of their net income on food, with SNAP benefits providing the difference between that amount and the maximum benefit available to households with no net income.15 This is referred to as the benefit reduction rate because each additional dollar of net income reduces SNAP benefits by 30 cents. The 30-percent benefit reduction rate was largely based on historical calculations of food spending as a percentage of household after-tax income (Orshansky, 1957; Hanson, 2008). Using food consumption data from 1955, Orshansky estimated that the average household spent one- third of its after-tax income on food. The benefit reduction rate of 0.30 has remained unchanged since the 1977 Food Stamp Act (IOM, 2013). In this chapter, we assess the benefit reduction rate from two perspectives. First, we assess whether the 30 percent benefit reduction rate reflects current spending on food as a percentage of after-tax income for the low-income households included in our study. This percentage allows us to compare current spending patterns with those on which the benefit reduction rate was based. Second, we estimate food spending as a percentage of net income, defined programmatically as a household’s gross income minus allowable deductions. This percentage allows us to assess how households’ food spending as a percentage of net income compares to the 30-percent benefit reduction rate. As we describe at the end of this chapter, there are limitations related to SNAP participation and benefit reporting in the CE and a large discrepancy between reported gross income and expenditure amounts in the CE. Based on these limitations, caution should be used in interpreting the findings from this analysis and making comparisons with other studies. A. Comparison of food spending as a percentage of after-tax income to the benefit reduction rate Our estimates of the share of after-tax income spent on food are based on food at home spending, rather than total food spending. The original benefit reduction rate of 30 percent was set using 1964 survey data before SNAP benefits were available and at a time when food away from home accounted for only a small portion of total food spending. As such, the original benefit reduction rate was calculated using total food expenditures, which was a close approximation to expenditures on food at home at the time. However, food away from home, which may not be purchased with SNAP benefits, now accounts for a much higher percentage of all U.S. consumer food expenditures than it did in the 1960s and 1970s (ERS, 2016). As discussed in Chapter III, the CE provides separate information on expenditures for food at home and expenditures for food away from home, excluding meals as pay, allowing us to account for these food expenditures separately. Therefore, reflecting the policy that SNAP benefits may be 15 Net income in this report refers to gross income less SNAP deduction amounts. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 37 used only to purchase food to be prepared at home, we assess food spending using only food at home expenditures, rather than total food expenditures. The ideal data with which to assess whether the benefit reduction rate accurately reflects current food spending patterns would be representative of all low-income households that are eligible for SNAP but do not already participate in the program. This would ensure that the data we use best reflect what households’ food spending behavior would be in the absence of SNAP. Research spanning several decades has shown that an additional dollar of SNAP benefits is associated with an increase in food spending ranging from $0.17 to $0.47, on average (Mabli et al. 2013; Fox et al. 2004; Fraker 1990). That food spending does not increase dollar-for-dollar with SNAP benefits suggests that some households replace part of their out-of-pocket food spending with food purchased with SNAP benefits, freeing up cash resources for other needs. In the most recent qualitative study of SNAP household’s food spending behavior conducted for FNS, Edin et al. (2013) provide support that participating SNAP households often build their monthly budgets around SNAP, allocating their cash resources toward their bills and other, often urgent, financial needs triggered by a sudden loss of income or increase in expenditures. In this way, SNAP eases the financial tradeoffs households must make as they strive to bring their budgets into balance, and may stave off material hardship. Knowing that SNAP participation affects food expenditures, our ideal dataset cannot include SNAP participants without some type of adjustment for their SNAP participation. In addition, we cannot rely only on nonparticipating low-income households because non-participating households have been shown to be systematically different than participating SNAP households (Nord & Golla, 2009). Instead, for all SNAP participants in the data, we removed the SNAP benefit amount from food at home expenditures and income. In doing so, this approach assumes that households in the CE participating in SNAP would not change their food spending behavior in the absence of participation in the program. For example, a household with $1,000 in income and $50 in benefits that reports spending $250 on food is assumed to spend $200 on food in absence of the program. Excluding SNAP benefits from households’ food spending and income amounts leads to a lower estimate of share of after-tax income spent on food. Using the example above, we compute three versions of the share of after-tax income spent on food at home: removing SNAP benefits from both food at home expenditures and income (equal to $200\/$950 or 21.1 percent); including SNAP benefits in both food at home expenditures and income (equal to $250\/$1,000 or 25 percent); and including SNAP benefits in food at home expenditures, but excluding it from income (equal to $250\/$950 or 26.3 percent). As we show below, however, the main findings did not differ greatly depending on the exclusion of SNAP benefits from either food at home expenditures or income. In 2013 2014, low-income households spent 19.5 percent of after-tax income on food at home (Table V.1). The estimates ranged from 19.5 to 22.3 percent, depending on whether SNAP benefits were excluded from food expenditures or income. These percentages are lower than the 30 percent used as a basis for the benefit reduction rate and are larger than those found in a AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 38 recent Institute of Medicine (IOM) report, which ranged from 11.7 percent for households with annual incomes over $70,000 to 16.8 percent for households with annual incomes between $5,000 and $9,999; the average among all households (including higher-income households) was 13 percent (IOM, 2013).16 Table V.1. Percentage of after-tax income spent on food at home, by whether SNAP benefits were included in food spending and income measures, 2013 2014 Whether SNAP benefits are included in food spending and income measures Food at home expenditures as a percentage of after-tax income Removed from both food at home and income a 19.5 Included in both food at home and income 21.5 Included in food at home; removed from income 22.3 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. B. Comparison of food spending as a percentage of net income to the benefit reduction rate SNAP legislation defines the benefit reduction rate as the percentage of a household’s net income (after deductions) spent on food. The ideal data with which to assess whether the benefit reduction rate accurately reflects current food spending as a percentage of net income would contain reliable information on household net income and food expenditures. This ideal information is not available, posing several challenges for measuring food spending as a percentage of net income and interpreting the estimates. While the CE offers comprehensive information on spending on goods and services, including food spending, it includes gross income information only. As described in Chapter II and Appendix A, we sought to address this challenge by approximating the amount of net income for each household using the CE gross income amount and an adjustment factor obtained from the MATH SIPP+ microsimulation model. In 2013 2014, low-income households spent 42.4 percent of net income on food at home (Table V.2). The estimates ranged from 42.4 to 48.6 percent, depending on whether SNAP benefits were excluded from food expenditures or income. These estimates are higher than the 30 percent benefit reduction rate currently used to determine benefits. 16 Data in the IOM report were based on 2010 CE data tabulated by the BLS and were based on pre-tax income, rather than after-tax income. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 39 Table V.2. Percentage of net income spent on food at home, by whether SNAP benefits were included in food spending and income measures, 2013 2014 Whether SNAP benefits are included in food spending and income measures Food at home expenditures as a percentage of net income Removed from both food at home and income a 42.4 Included in both food at home and income 47.0 Included in food at home; removed from income 48.6 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. The percentage of net income that low-income households spent on food was higher for smaller households than for larger households; higher for households without children than for households with children; and higher for households without elderly or disabled individuals than for those with elderly or disabled individuals (Figures V.1 and V.2). These findings did not vary according to whether SNAP benefits were excluded from food spending amounts and income (not shown in figures). However, the findings shown in Figures V.1 and V.2 use the approach that removes SNAP benefits from food expenditures and income. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 40 Figure V.1. Food at home expenditures as a share of net income among low-income households by household size, 2013 2014 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. Gross income is defined as after-tax income minus the household SNAP benefit. We apply an adjustment factor, described in Appendix A, to convert gross income to net income. 53.1 49.6 37.9 35.0 29.4 0 20 40 60 80 100 1 person 2 people 3 people 4 people 5 or more people F o o d a t h o m e s p e n d in g a s p e rc e n ta g e o f n e t in c o m e 30 Current benefit reduction rate AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 41 Figure V.2. Food at home expenditures as a share of net income among low-income households by household composition, 2013 2014 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. Gross income is defined as after-tax income minus the household SNAP benefit. We apply an adjustment factor, described in Appendix A, to convert gross income to net income. a In the CE, we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C. Limitations The findings in this chapter should be interpreted with the following limitations in mind. First, the above analyses compared the benefit reduction rate to food expenditures as a percentage of either after-tax income or net income. Both income measures are based on CE gross income. However, the CE data show a large discrepancy between the amount of income that low-income households have available to them and their actual expenditures. As described in Chapter III, average total expenditures in the CE were about 1.5 times higher than gross income for low-income households, suggesting that gross income may be misreported or that income does not accurately capture the amount of resources available to households with which to purchase goods and services (for example, households may be drawing from savings or other assets, spending on credit, or living beyond their means). Although the data do not allow us to identify the reasons for the discrepancy, it is important to consider whether income is capturing a household’s total available resources. Thus, we also examined food spending as a percentage of 35.1 50.9 41.3 43.9 0 20 40 60 80 100 Children No children Elderly or nonelderly disabled individuals \u1d43 No elderly or nonelderly disabled individuals F o o d a t h o m e s p e n d in g a s p e rc e n ta g e o f n e t in c o m e 30 Current benefit reduction rate AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 42 total expenditures. As we did with the income-based measures, we removed SNAP benefits from both food at home expenditures and total expenditures. Food at home expenditures as a percentage of total expenditures were 13.4 percent.17 This estimate was lower than food expenditures as a percentage of after-tax income (20.2 percent) because expenditures generally exceed income in the CE. It was also lower than the estimate of food spending as a percentage of net income (43.5 percent) because expenditures generally exceed income and SNAP deduction amounts were not subtracted from expenditures. Another limitation is that it is unclear whether the food expenditures that participating SNAP households incur include (or exclude) expenditures made with their SNAP benefit. For respondents that include it, we are correctly deducting SNAP benefits from their food spending. For respondents that exclude expenditures made with their benefit and, instead, report food spending only using out-of-pocket resources, we are incorrectly reducing food spending amounts and underestimating the benefit reduction rate. A third limitation is that SNAP receipt and benefit amounts tend to be underreported in the CE (Meyer & Goerge, 2011). Previous research comparing annual SNAP participation in the 2004 2010 CE with average monthly participation levels from FNS program data found the extent of this underestimation to be about 38 percent on average (Mabli & Malsberger, 2013). Comparing CE data to the 2013-2014 SNAP QC data shows that the CE contains about 50 percent of SNAP participants in administrative data. Because so many households in the CE are likely counted as nonparticipants even though they actually participate, we are not reducing their food spending and gross income amounts by the SNAP benefit, leading to overestimates of the measures of the benefit reduction rate. A fourth limitation is that by removing SNAP benefits from gross income when estimating the benefit reduction rate based on after-tax income, and by applying deductions to gross income when estimating the benefit reduction rate based on net income, we are assuming that households in the CE would not change their food spending behavior when their income is reduced. This is at odds with empirical data, which show that households with higher income spend a larger percentage on food (BLS, 2015). Given these limitations related to SNAP participation and benefit reporting and the large discrepancy between income and expenditures in the CE, we recommend that caution be used in interpreting the findings from this analysis and making comparisons with other studies. 17 This estimate differs from the estimate of food at home expenditures as a percentage of total expenditures presented in Chapter III of 15.0 percent because the Chapter III estimate does not remove SNAP benefits from food at home or total expenditures. Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 43 VI. DEDUCTION USAGE AND AVAILABILITY In Chapters IV and V, we assessed the adequacy of the SNAP deductions and the benefit reduction rate, focusing on whether the rules governing the existing deductions and the amount of the benefit reduction rate reflect the spending patterns of low-income households. In this chapter, we shift the focus to deduction usage, including households’ access to deductions, and availability. In Section A, we discuss the percentage of participating SNAP households that take each deduction type and then address: 1. Whether deduction usage increases when households recertify for SNAP, relative to when they are initially certified upon joining the program 2. Whether there is evidence of structural barriers to claiming available deductions that might keep low-income households from reporting certain expenses For information on actual SNAP deduction receipt and amounts, we use the SNAP QC data file, which contains data on the characteristics and deduction amounts of SNAP participants. In Section B, using CE data we look into whether low-income households incur expenses that are not included in the deductions but that might be considered for inclusion. A. Deduction usage Under two sets of circumstances, households may incur expenses associated with a deduction but not receive the deduction. First, they might face structural barriers such as difficulty in documenting the expenditure. Second, they might be ineligible for the deduction despite incurring a seemingly related expense. For example, individuals with dependent care expenditures may not be eligible for the deduction if they are not working. In this section, using 2013 and 2014 SNAP QC data, we discuss deduction usage among SNAP participants, whether deduction usage and amounts increase at recertification, and whether structural barriers might keep households from reporting certain expenses. 1. Deduction usage among SNAP Participants To understand further the extent of deduction usage, we turned to the 2013 2014 SNAP QC data to examine the percentage of SNAP households using deductions and the amount of the deductions. Given that households’ circumstances may change from the time they first enter SNAP to the time at which they recertify for the program, we also compare deduction usage at initial certification versus recertification to assess whether the usage and amounts of deductions remain unchanged. All SNAP households in 2013 2014 had a positive total deduction, defined as the sum of the household’s standard, earned income, medical expense, dependent care, child support payment, and excess shelter expense deduction because they all had a positive standard deduction regardless of whether they also used other deductions (Figure VI.1). Nearly three-quarters (74.0 percent) of SNAP households had an excess shelter expense deduction. The next most common deduction was for earned income, at 32.1 percent. The medical, dependent care, and child AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 44 support payment deductions were much less common; 2.2 to 5.1 percent of households had these deductions. Figure VI.1. Percentage of SNAP households that use deductions, by deduction type Source: Fiscal year 2013 and 2014 SNAP QC data files. The average amount of the total deduction across all SNAP households was $530 (Figure VI.2). On average, the deduction amounts among households with the deduction ranged from $155 for the medical expense deduction to $384 for the excess shelter expense deduction. Even though the earned income deduction was the second most common deduction, the amount of the deduction was smaller than that of most other deduction types, at $213. The net income calculation involves subtracting deductions from total income, but each deduction can influence net income in several ways: \uf0b7 The combined deductions may total more than the household’s income, essentially leaving some of the deductions unused. As a simple example, it is useful to consider a household with less income than the standard deduction; only the portion of the standard deduction equaling the household’s income would actually be used by the household. \uf0b7 All of the other deductions can increase the excess shelter expense deduction because each deduction can lower adjusted net income and half of adjusted net income is subtracted from shelter expenses to determine the excess shelter expense deduction. In this case, each individual deduction is worth not only its own value but also the value of the increase in the excess shelter expense deduction that the deduction creates. \uf0b7 A household with its excess shelter expense deduction limited by the shelter deduction cap may not be affected as much by the other deductions as would be a household not limited by the shelter cap. Alone or in combination, the deductions can lower the adjusted 100.0 74.0 32.1 5.1 3.6 2.2 0 20 40 60 80 100 Total deduction Excess shelter expense deduction Earned income deduction Medical expense deduction Dependent care deduction Child support payment deduction P e rc e n ta g e o f h o u s e h o ld s AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 45 net income but may push (or keep) the excess shelter expense calculation above the cap and therefore not benefit the household to the greatest degree possible. To assess the full effect of any deduction on the net income calculation, we examine the marginal effectiveness of the deductions. We calculate marginal effectiveness as the difference between the actual calculated net income and what the net income would have been in the absence of the deduction, independent of the order in which the deductions were applied (with the exception of the excess shelter expense deduction, which is always applied last because it depends on the value of adjusted net income). The average marginal effectiveness ranged from $204 for the medical expense deduction to $334 for the excess shelter expense deduction (Figure VI.2). Figure VI.2. Deduction amount and marginal effectiveness for SNAP households, by deduction type Source: Fiscal year 2013 and 2014 SNAP QC data files. a We do not include the average amount of the marginal effectiveness of the total deduction because it does not have a straightforward interpretation. In Figures VI.1 and VI.2, we describe deduction usage and amounts among all SNAP households. For many households, however, economic conditions and household composition change over the period during which they participate in SNAP (Leftin et al., 2014b). To assess whether deduction usage also changes over the course of a household’s SNAP participation, we statistically compared deduction usage by all SNAP households recorded at initial certification in the SNAP QC sample to usage by all SNAP households recorded at the most recent recertification appointment. The certification period varies with the likelihood of a change in a SNAP household’s financial circumstances. In fiscal year 2014, 28.5 percent of households had certification periods that were 6 months or less and half had certification periods that were 13 $530 $156 $384 $213 $155 $260 $235 $193 $334 $295 $204 $322 $288 0 100 200 300 400 500 600 Total deduction \u1d43 Standard deduction Excess shelter expense deduction Earned income deduction Medical expense deduction Dependent care deduction Child support payment deduction A v e ra g e a m o u n t Deduction amount Marginal effectiveness of deduction AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 46 months or less (Farson Gray & Kochhar, 2015). Given that the SNAP QC data do not follow the same set of SNAP participants over time, we were unable to examine deduction usage at the first recertification appointment. For households with a 12-month certification period, for example, deduction usage at recertification may be measured at the 12-month appointment for some households and at the 24-month appointment for others. Thus, we have no option but to compare deduction usage at initial certification with deduction usage at or after the most recent recertification. All households had a positive total deduction amount at both initial certification and recertification. A statistically significant higher percentage of households used the earned income, excess shelter expense, dependent care, and medical expense deductions at recertification than at certification, but the differences were generally small. The percentage of households that used the excess shelter expense deduction was 7.9 percentage points greater at recertification than at certification (77.0 and 69.1 percent, respectively) (Figure VI.3). Changes in the usage of other deductions were smaller. The percentage of households that used the earned income deduction was 1.2 percentage points greater at recertification than at certification (32.6 and 31.4 percent, respectively). For the dependent care and medical expense deductions, the increases were 1.1 percentage points (4.1 percent at recertification and 3.0 percent at certification) and 0.8 percentage points (5.4 percent at recertification and 4.6 percent at certification). There was no statistically significant difference in the use of the child support payment deduction at initial certification and recertification. Figure VI.3. Percentage of SNAP households that use deductions, by deduction type and whether the last SNAP certification was a new certification or recertification Source: Fiscal year 2013 and 2014 SNAP QC data files. * Difference between percentage at recertification and initial certification is statistically significant at the 0.05 level, two-tailed test. 100.0 31.4 2.3 3.0 4.6 69.1 100.0 32.6* 2.1 4.1* 5.4* 77.0* 0 20 40 60 80 100 120 Total deduction Earned income deduction Child support payment deduction Dependent care deduction Medical expense deduction Excess shelter expense deduction P e rc e n ta g e o f h o u s e h o ld s Households after initial certification Households at or after recertification AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 47 As with deduction usage, the amount of the deduction among households with the deduction generally remained steady over time for the total deduction and most deduction types (Figure VI.4). On average, households’ total deductions were $36 greater at recertification than at initial certification ($544 versus $508), but this difference was not statistically significant. The average earned income deduction was $7 greater at recertification than at certification ($215 versus $208) while the dependent care and child support payment deductions were, on average, $25 and $33 lower at recertification than at certification. There was no significant change in the amount of the medical or excess shelter expense deductions at initial certification and recertification. Even though the amounts for most deduction types were either lower or unchanged, the average total deduction amount was slightly higher at recertification than at certification because larger percentages of households received most types of deductions at recertification, as shown in Figure VI.3. Figure VI.4. Deduction amounts for SNAP households, by deduction type and whether the last SNAP certification was a new certification or recertification Source: Fiscal year 2013 and 2014 SNAP QC data files. * Difference between percentage at recertification and initial certification is statistically significant at the 0.05 level, two- tailed test. Changes in marginal effectiveness were consistent with changes in the amounts of the deductions for the total deduction and for the dependent care deduction (Figure VI.5). Although the earned income deduction was slightly larger for households at recertification versus initial certification, there was no statistically significant change in the marginal effectiveness of the earned income deduction. In addition, there was no change in the excess shelter expense deduction amount between the two time points, but the marginal effectiveness was more than $7 larger at recertification than at certification. $508 $208 $255 $277 $148 $387 $544 $215* $222* $252* $159 $383 $0 $100 $200 $300 $400 $500 $600 Total deduction Earned income deduction Child support payment deduction Dependent care deduction Medical expense deduction Excess shelter expense deduction A v e ra g e a m o u n t Households after initial certification Households at or after recertification AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 48 Figure VI.5. Marginal effectiveness for SNAP households, by deduction type and whether the last SNAP certification was a new certification or recertification Source: Fiscal year 2013 and 2014 SNAP QC data files. Note: We do not include the total deduction in this table because its marginal effectiveness does not have a straightforward interpretation. * Difference between percentage at recertification and initial certification is statistically significant at the 0.05 level, two-tailed test. Descriptive comparisons in Figures VI.3 through VI.5 show that the percentage of households using deductions differed at recertification versus initial certification for several deduction types, although the changes were generally small. Similarly, there were differences over time in the amount of the deductions, but the overall differences were also small. Even though differences between deductions at initial certification and recertification could be driven by changes in household reporting behavior, they could also stem from a difference in the characteristics of households that remain in SNAP past their first recertification date and households that leave SNAP within the initial certification period. To identify whether household characteristics play a role in the differences in the usage and amount of deductions, we conducted a multivariate analysis of the differences in deduction usage, amounts, and marginal effectiveness at initial certification and recertification, accounting for differences in the characteristics of households at the two time periods. The characteristics included household size and composition, amounts of gross earned and unearned income, indicators of receipt of other income such as TANF and SSI, and locality. If differences remain in the percentage of households with deductions (or deduction amounts) after accounting for changes in these household characteristics, then we can be more confident that differences in deduction usage at certification and recertification do not reflect compositional changes in the population of SNAP $293 $301 $343 $196 $329 $297* $280 $312 $208* $337 $0 $50 $100 $150 $200 $250 $300 $350 $400 $450 Earned income deduction Child support payment deduction Dependent care deduction Medical expense deduction Excess shelter expense deduction A v e ra g e a m o u n t Households after initial certification Households at or after recertification AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 49 households and instead more likely reflect differences in households’ propensity to report certain expenses used in determining deductions.18 Changes between initial certification and recertification in the percentage of households that use deductions after accounting for changes in household characteristics (Table VI.1) were slightly different than the changes presented in Figure VI.3, which did not account for changes in household characteristics. We still observed increases in the percentage of households with the dependent care and excess shelter deductions, but the increases were half as large after accounting for household characteristics. For example, the percentage of households with an excess shelter expense deduction increased by 7.9 percentage points without accounting for household characteristics (Figure VI.3) but increased by 3.1 percentage points after accounting for these characteristics (Table VI.1). In addition, the percentage of households with the dependent care deduction increased by 1.1 percentage points without accounting for household characteristics but increased by 0.6 percentage points after accounting for these characteristics. In contrast, usage of the medical expense deduction increased when unadjusted by characteristics but decreased in usage after accounting for household characteristics. Changes in deduction amounts after accounting for changes in household characteristics (Table VI.1) were generally similar to the changes presented in Figure VI.4. For example, there were significant decreases in the amounts of the child support payment deduction and dependent care deduction, and no statistically significant change in the amount of the medical expense deduction. Consideration of the marginal effectiveness in place of the deduction amount showed similar findings. The results of the above analyses suggest that differences in deduction usage at initial certification and recertification partly reflect compositional changes in the population of SNAP households and partly reflect differences in households’ propensity to report certain expenses used in determining deductions. Differences in deduction amounts at initial certification and recertification seem primarily to reflect differences in households’ propensity to report certain expenses used to determine deductions. 18 We did not include the earned income deduction in these analyses, given that the earned income deduction is determined solely by the presence of earned income and not by the reporting of other expenses. Households with earnings receive the deduction, and those without earnings do not. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 50 Table VI.1. Regression-adjusted percentage of SNAP households with deduction, mean amount of deduction, and marginal effectiveness of deduction by deduction type and whether the last SNAP certification was a new certification or recertification, 2013 2014 Percentage of SNAP households with deduction Mean amount of deduction among households with deduction Marginal effectiveness of deduction Deduction type Households after initial certification Households after recertification Difference Households after initial certification Households after recertification Difference Households after initial certification Households after recertification Difference Total deductions 100.0 100.0 0.0 $526 $533 $6* n.a. n.a. n.a. Child support payment 2.3 2.1 -0.2 $251 $225 -$26* $292 $285 -$7 Dependent care 3.3 3.9 0.6* $281 $251 -$31* $346 $311 -$35* Medical expense 5.7 4.8 -0.9* $149 $158 $9 $197 $208 $11 Excess shelter expense 72.2 75.3 3.1* $389 $382 -$7* $333 $335 $2 Sources: Regression-adjusted output from the fiscal year 2013 and 2014 SNAP QC data files. Notes: Percentages of SNAP households with deductions and mean amounts of deductions are adjusted for SNAP household size; presence of children, an elderly individual, or a disabled nonelderly individual in the household; an indicator of whether there are multiple adults in the household; SNAP household-level gross income; an indicator of whether the household has earned income; an indicator of whether the household has unearned income; indicators of whether the household has TANF, GA, SSI, or Social Security income; and locality (metropolitan, micropolitan, or rural). The analysis excluded MFIP and SSI-CAP households, for which deductions are not applicable. n.a.: The marginal effectiveness of the total deduction is excluded from the table because it does not have a straightforward interpretation. * Difference between outcome at recertification and initial certification is statistically significant at the 0.05 level, two-tailed test. 2. Evidence of structural barriers For several reasons, a low-income household applying for SNAP may decide not to report certain expenses. A household may, for example, experience difficulty in acquiring or providing the needed documentation, have privacy concerns, or perceive a stigma associated with providing the required information. If the household fails to report certain types of expenses, then it could lose the opportunity for a deduction. For example, a household with an elderly or disabled member that fails to report medical expenses may lose the opportunity to claim a medical expense deduction even if it is eligible for one, potentially lowering its total benefit amount. Certain SNAP policies aim to reduce barriers to claiming deductions. As discussed in Chapter IV, Standard Utility Allowances are meant to ease the task of reporting all monthly utility bills, and standard medical deduction demonstration projects are intended to reduce medical expense reporting burdens. In addition, the SNAP benefit calculation excludes some or AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 51 all deductions for households with standardized SNAP benefits.19 Finally, some State demonstration projects include policies aimed at simplifying SNAP reporting requirements and thereby removing barriers to claiming deductions. To examine the extent to which barriers may possibly prevent households from reporting certain expenses, we compared the percentage of households with pre-tax income at or below 130 percent of the poverty guidelines (the SNAP gross income eligibility cutoff) that report certain expenses in the CE with the percentage of participating SNAP households in the SNAP QC data file with that expense or deduction type. To increase the comparability of the two groups of households, we restricted households in the SNAP QC file to those with gross income at or below 130 percent of poverty and removed cases from Guam and the Virgin Islands. Due to these restrictions, the percentage of participating households with certain types of deductions varies slightly from those presented earlier in the chapter, where those restrictions did not apply. We examined medical expenses and the medical expense deduction, child care expenses and the dependent care deduction, child support payments and deductions, and rent and mortgage expenses. a. Medical expenses and deductions Only households with average monthly out-of-pocket medical expenditures for elderly or disabled individuals greater than $35 may qualify for a medical expense deduction. The percentage of low-income households with elderly or nonelderly disabled individuals and out-of- pocket medical expenditures greater than $35 per month was much higher than the percentage of SNAP households with elderly or nonelderly disabled individuals that had a medical expense deduction (Table VI.2). Whereas 64.2 percent of low-income households with elderly or disabled individuals had monthly medical expenses in excess of $35, only 9.7 percent of SNAP households with elderly or disabled individuals received the deduction. As mentioned, we cannot identify in the CE whether the medical expenses for households with elderly or disabled individuals pertained to the elderly or disabled household members, or to other members of the household. Furthermore, the estimate of the percentage of SNAP households with elderly or disabled individuals receiving the deduction would be moderately higher if the universe were not restricted to households with gross income at or below 130 percent of poverty. In fiscal year 2014, 16.8 percent of households with elderly individuals and 9.4 percent of households with nonelderly disabled members claimed a medical expense deduction (Farson Gray and Kochhar 2015). The types of low-income households that more frequently incurred out-of-pocket medical expenses greater than $35 (relative to all low-income households) also tended to receive a medical expense deduction more frequently. For example, 77.7 percent of low-income households that included both disabled and elderly individuals had medical expenses greater than $35 compared with only 42.8 percent of households with disabled individuals but no elderly 19 These include households participating in the Minnesota Family Investment Project in Minnesota and Supplemental Security Income (SSI) Combined Application Projects in 15 States. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 52 individuals. Consistent with this pattern, the percentage of participating SNAP households with elderly and disabled individuals that had a medical expense deduction was nearly double the percentage for SNAP households with disabled individuals but no elderly individuals (14.4 versus 7.4 percent). Other types of low-income households that more commonly had medical expenditures greater than $35 and SNAP households that received the medical expense deduction included those with elderly household heads and those with Social Security income. Table VI.2. Percentage of households in the CE with annual income at or below 130 percent of poverty with average monthly out-of-pocket medical expenses greater than $35 compared with the percentage of SNAP households with a medical expense deduction in the SNAP QC data file by household type, 2013 2014 Characteristic Percentage of households with out- of-pocket medical expenditures greater than $35 per month (CE) Percentage of households with medical expense deduction (SNAP QC) All households with elderly or nonelderly disabled individuals a 64.2 9.7 Household composition Nonelderly disabled individuals 48.5 7.6 And elderly individuals 77.7 14.4 And no elderly individuals 42.8 7.4 Elderly individuals 73.0 12.3 And no disabled individuals 74.9 12.2 Age of household head Nonelderly 33.6 7.7 Age 60 to 69 65.0 10.8 Age 70 to 79 78.3 13.0 Age 80 or older 84.7 15.1 Receipt of assistance from: SNAP 34.2 9.7 Social Security 74.2 15.6 SSI 40.2 2.7 Sources: Weighted tabulations of 2013 and 2014 CE Interview data files and tabulations of fiscal year 2013 and 2014 SNAP QC data files. Notes: Both the CE and SNAP QC files are restricted to households with gross income (excluding SNAP benefit amounts in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any households in Guam or the Virgin Islands because the CE does not include these households. Medical expenses are for all members of the household and cannot be disaggregated into members who are elderly or disabled. a In the SNAP QC, SNAP households with disabled individuals are identified as those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 53 b. Child care expenditures and the dependent care deduction The dependent care deduction is available to households that incur out-of-pocket expenditures for care of a dependent because such care is necessary for a household member to seek, accept, or continue employment; attend training; or pursue education. The CE includes data on child care expenses but lacks complete information on expenses associated with caring for other dependents. We compared the percentage of low-income households with child care expenses in the CE to the percentage of SNAP participants with the dependent care deduction in the SNAP QC data (Table VI.3). We found that about 8.6 percent of low-income households with children had child care expenditures compared with 6.9 percent of participating households with children that received the dependent care deduction. Low-income households with one adult and children more often had child care expenditures than did those with multiple adults and children (11.7 versus 7.1 percent). Likewise, households with single adults and children more often received the dependent care deduction (9.0 versus 3.1 percent). The difference between the percentage of households with child care expenses and the percentage receiving the deduction was small for households with school-age children, but it was particularly large for households with preschool-age children. For example, 30.3 percent of low- income households with one adult and preschool-age children had child care expenses, whereas only 13.0 percent of such households participating in SNAP received the dependent care deduction. c. Child support payments and the child support expense deduction In most States, households with court-ordered child support payments receive a child support payment deduction. After excluding SNAP participants in the 18 States where households were able to use child support payments as an income exclusion rather than as a deduction, we found that the percentage of low-income households that reported child support payments in the CE (1.9 percent) was about the same as the percentage of participating SNAP households that received the deduction (2.0 percent) (Table VI.4). Household types that most frequently had child support payments and the deduction included larger households (with four to five people or more), those with nonelderly disabled individuals, and those with earnings slightly above poverty (between 100 and 130 percent of the poverty guidelines). Households with elderly individuals and those with unemployed individuals least often had child support payments or deductions. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 54 Table VI.3. Percentage of households with children and annual income at or below 130 percent of poverty in the CE with child care expenses and percentage of participating SNAP households with children with the dependent care deduction, by household type, 2013 2014 Characteristic Percentage of households with child care expenditures (CE) Percentage of households with dependent care deduction (SNAP QC) All households with children 8.6 6.9 Household size 1 person 0.0 6.1 2 people 11.2 6.9 3 people 8.6 7.8 4 people 8.2 6.6 5 or more people 7.9 6.1 Household composition One adult 11.7 9.0 Only preschool-age children (age 0 to 4) 30.3 13.0 Only school-age children (age 5 to 17) 5.5 5.1 Both preschool- and school-age children 17.3 13.8 Multiple adults 7.1 3.1 Only preschool-age children (age 0 to 4) 12.8 3.4 Only school-age children (age 5 to 17) 2.2 2.4 Both preschool- and school-age children 11.3 4.2 Income as a percentage of poverty guidelines 0 percent to 50 percent 8.2 2.0 Greater than 50 percent to 100 percent 8.1 9.4 Greater than 100 percent to 130 percent 9.8 18.5 Receipt of assistance from: Social Security 2.4 3.0 SSI 2.4 3.0 TANF 7.3 1.7 Sources: Weighted tabulations of 2013 and 2014 CE Interview data files and tabulations of fiscal year 2013 and 2014 SNAP QC data files. Notes: Both the CE and SNAP QC files are restricted to households with gross income (excluding SNAP benefit amounts in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any households in Guam or the Virgin Islands because the CE does not include these households. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 55 Table VI.4. Percentage of households with annual income at or below 130 percent of poverty in the CE with child support payments and percentage of participating SNAP households with a child support payment deduction by household type, 2013 2014 Characteristic Percentage of households with child support payments (CE) Percentage of households with child support payment deduction a (SNAP QC) All households 1.9 2.0 Household size 1 person 1.5 1.8 2 to 3 people 1.7 1.8 4 to 5 people 3.0 2.8 6 or more people 3.1 3.2 Household composition With children 2.6 2.2 With nonelderly adults 2.4 2.3 With elderly individuals 0.9 0.9 With nonelderly disabled individuals b 2.8 3.0 Earnings as a percentage of poverty guidelines 0 percent to 50 percent 1.5 1.6 Greater than 50 percent to 100 percent 2.6 3.4 Greater than 100 percent to 130 percent 3.2 5.0 Employment status of household head Employed c 2.8 3.3 Unemployed 1.5 1.3 Not in labor force 1.8 1.8 Source: Weighted tabulations of 2013 and 2014 CE Interview data files and tabulations of fiscal year 2013 and 2014 SNAP QC data files. Notes: Both the CE and SNAP QC files are restricted to households with gross income (excluding SNAP benefit amounts in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any households in Guam or the Virgin Islands because the CE does not include these households. a We excluded, from both the numerator and denominator, SNAP households living in the 18 States that, as of September 2013, took the option to treat child support payments as an income exclusion rather than as a deduction for some households. Implicit in this method is the assumption that the percentage of households with child support expenditures is similar across both the group of States that treats some child support payments as exclusions and the group of States that treats the payments exclusively as deductions. b In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working c Children and elderly adults are excluded from those not in the labor force. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 56 d. Shelter expenses Households must report rent or mortgage expenses for them to be included in the calculation of the excess shelter expense deduction. Even though nearly all low-income households in the CE had rent or mortgage expenses overall (94.6 percent), only about two thirds of participating SNAP households (67.3 percent) had a rent or mortgage amount that contributed to the excess shelter expense calculation (Table VI.5). Specifically, at least 91 percent of every subgroup of low-income households in the CE that we examined reported positive rent or mortgage expenses, whereas fewer than 60 percent of some types of participating SNAP households, including those with no elderly or disabled individuals and those with income at or below 50 percent of poverty guidelines, had rent or mortgage amounts used for the deduction. About 75.1 percent of participating households with children, 82.3 percent of those with elderly individuals, and 88.5 percent of those with nonelderly disabled individuals had positive rent or mortgage amounts used for the deduction. Participating households residing in the Northeast had rent or mortgage amounts used for the deduction more often than those in other regions, as did households in urban areas relative to those in rural areas. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 57 Table VI.5. Percentage of households with annual income at or below 130 percent of poverty in the CE with reported rent or mortgage expenses in the CE and percentage of participating SNAP households with positive rent expenses in the SNAP QC data file by household type, 2013 2014 Characteristic Percentage of households with rent or mortgage expenses (CE) Percentage of households with rent or mortgage expenses (SNAP QC) All households 94.6 67.3 Household size 1 person 93.5 59.5 2 people 95.7 72.0 3 people 94.4 75.6 4 people 95.4 78.2 5 or more people 96.8 81.8 Household composition With children 95.3 75.1 With nonelderly adults 94.1 62.5 With elderly individuals 96.3 82.3 With nonelderly disabled individuals a 94.8 88.5 With no elderly individuals or nonelderly disabled individuals 93.5 56.6 Income as a percentage of poverty guidelines 0 percent to 50 percent 91.4 40.5 Greater than 50 percent to 100 percent 95.6 88.3 Greater than 100 percent to 130 percent 97.1 93.2 Geography Northeast 94.7 77.9 Midwest 95.6 66.2 South 93.8 62.8 West 95.3 69.2 Urban b 94.9 67.5 Rural 92.7 62.7 Sources: Weighted tabulations of 2013 and 2014 CE Interview data files and tabulations of fiscal year 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to households with gross income (excluding SNAP benefit amounts in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any households in Guam or the Virgin Islands because the CE does not include these households. a In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. b In the SNAP QC data, we classify households in metropolitan and micropolitan areas as urban. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 58 B. Expenses not included in the deductions Current SNAP deductions are intended to be responsive to medical, shelter, child support, and dependent care expenditures. In addition, the earned income deduction aims to capture costs associated with working while the standard deduction is a catch-all deduction for certain miscellaneous expenses.20 Households also incur other types of expenses, however, that are not captured in the existing deductions. Here, we examine the prevalence and amounts of those other types of expenses. Based on (1) a review of large or common expenditures for low-income households, (2) a review of the types of new deductions proposed at the time of the Food Stamp Act of 1977, and (3) availability of expense data in the CE, we assessed the prevalence and amounts of the following types of average monthly expenses: \uf0b7 Apparel \uf0b7 Finance, late charges, and interest on student loans \uf0b7 Housing or property repairs and maintenance (expenses usually not captured in the excess shelter expense deduction unless they were due to substantial damage from a natural disaster) \uf0b7 Personal care appliances and services21 \uf0b7 Vehicle expenses, including (1) finance charges, (2) maintenance and repair expenses, (3) insurance, (4) purchases of new cars and trucks, (5) purchases of used cars and trucks, and (6) vehicle rental, leases, licenses, and other charges Of the expenditures we examined, the most common type for low-income households was apparel (Table VI.6). More than 60 percent reported such expenses, and households with these expenses reported spending an average of $72 per month. Personal care appliances and services were the second most common type of expenditure, incurred by 41.6 percent of households at an average of $28 per month. 20 In Chapter IV, we examined expenses that were included in the deductions prior to the enactment of the Food Stamp Act of 1977, when the standard deduction replaced them. 21 Personal care expenses as shown include only wigs, personal care appliances, and personal care services. The interview survey excludes smaller, frequently purchased expenditures, which include expenditures on items typically considered personal care products (e.g., products for hair care, bathing, oral hygiene, shaving needs, or cosmetics) (Bee et al., 2015). These types of purchases are collected only in the CE Diary survey and thus are excluded from this study. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 59 Table VI.6. Most common types of expenditures not included in the SNAP deductions for low-income households, 2013 2014 Expenditure type Percentage of households with expenditure type Monthly amount of expense among households with expenditure type Apparel 61.9 $72 Personal care a 41.6 $28 Vehicle insurance 39.9 $111 Vehicle maintenance and repairs 39.5 $85 Vehicle rental, leases, licenses, and other charges 22.4 $65 Finance, late charges, and interest for student loans in the last month b 20.7 $69 Housing or property repairs and maintenance 19.9 $222 Vehicle finance charges 14.9 $50 Source: Weighted tabulations of the 2013 and 2014 CE Interview data files. a Personal care expenses as shown include only wigs, personal care appliances, and personal care services. b This information is available only in the fifth-quarter CE interview. Certain types of vehicle-related expenses were also relatively common while purchases of new or used cars and trucks were not common (not presented in table). Nearly 40 percent of low- income households incurred monthly expenditures for vehicle insurance and vehicle maintenance and repairs, amounting to $111 and $85 per month, respectively. Nearly one quarter (22.4 percent) of low-income households had vehicle rental, leases, licenses, or other charges totaling about $65 per month on average, and 14.9 percent had vehicle finance charges amounting to $50 per month for households with the expense. Purchases of new or used cars or trucks were uncommon. About 3 percent of low-income households reported purchases of used cars or trucks, and less than one percent reported purchases of new cars or trucks. Nearly 21 percent of low-income households incurred expenditures for finance, late charges, or interest on student loans, averaging $69 per month for households with such expenditures. A greater percentage of low-income households had student loans (20.7 percent) than had education expenses (10.8 percent, as observed in Chapter IV). About 20 percent of low-income households reported expenditures associated with housing or property repairs and maintenance. The excess shelter expense deduction is based on expenses for rent or mortgage, utilities, property taxes, and insurance but it does not cover repair and maintenance expenses unless they were for a home that was substantially damaged or destroyed due to a natural disaster such as a fire or flood. During discussions about the Food Stamp Act of 1977, some policymakers suggested expanding the excess shelter expense deduction to include these expenses. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 60 Throughout this analysis, readers should note that the quarterly interview design in the CE, along with our method for annualizing expenditures and converting them to average monthly amounts, could lead to the overstatement of one-time expenditures for some households and to the understatement for other households. In particular, average monthly expenditure amounts among households with large but infrequently occurring expenditures can be overstated. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 61 VII. CONCLUSION In this study, we investigated whether SNAP eligibility rules that determine the size of the SNAP benefit allotment accurately reflect current spending patterns for low-income households. A. Summary of key findings Using 2013 and 2014 CE data, we found that low-income households spent an average of approximately $2,300 per month on goods and services. On average, they spent 37 percent of total annual expenditures on housing, 19 percent on food (including 15 percent on food at home and 4 percent on food away from home), and 17 percent on transportation. CE data revealed a discrepancy between reported income available to low-income households and their actual expenditures, with expenditures being about 1.5 times higher than reported gross income on average. The types of goods and services purchased by low-income households varied only modestly across different household types. However, although low-income households generally exhibited similar spending patterns in terms of spending the largest shares of their total expenditures on housing followed by food and transportation, the sizes of the shares differed for different household types. For example, low-income households with relatively higher income spent smaller shares of total expenditures on housing and food but larger shares on transportation and health care than households with lower income. Households with elderly individuals spent nearly as much on health care expenses as they did on transportation. SNAP deductions, with the exception of some provisions specified in the excess shelter expense deduction, generally reflected the actual expenditures reported by low-income households. For example, work-related expenditures combined with estimated payroll taxes totaled nearly 19 percent of mean earnings among earners, which is close to the percentage of earnings (20 percent) that participating SNAP households may deduct from gross income for the earned income deduction. Likewise, 83 percent of low-income households with elderly or disabled individuals incurred out-of-pocket medical expenses, averaging $318 per month, and would be able to deduct the full amount above $35. Two provisions specified in the excess shelter expense deduction that translated into household deduction amounts that did not fully reflect expenditures were: 1. The shelter cap. Households without any elderly or disabled individuals are subject to a cap on the excess shelter expense deduction. The cap limited the SNAP benefit of 14 percent of participating households without elderly or disabled individuals. 2. Countable utility expenditures. Utility amounts used in the SNAP excess shelter expense deduction for SNAP participants, often based on State Standard Utility Allowances, were higher on average than actual utility expenses for low-income households. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 62 Even though the existing SNAP deductions reflected expenditures relatively well for the types of households covered by the deductions, some household types not covered by the deductions can incur substantial expenditures. In particular, the medical expense deduction is available only to households whose medical expenditures are for elderly or disabled individuals; 47 percent of households without elderly or disabled members incurred medical expenses averaging $224 per month and would not be eligible for a medical expense deduction. In addition to assessing deduction amounts, we assessed whether the 30 percent benefit reduction rate reflects current spending on food as a percentage of after-tax income for the low- income households included in our study. This calculation allows us to compare current spending patterns with those on which the benefit reduction rate was originally based. We found that low- income households spent about 20 percent of after-tax income on food at home, which is lower than the 30 percent used as a basis for the benefit reduction rate and is larger than the 12 to 17 percent range found in IOM (2013). We also estimated food spending as a percentage of net income and compared this percentage to the 30-percent benefit reduction rate. We found that low-income households spent about 42 percent of their net income on food at home. However, the CE data show a large discrepancy between the amount of income that low-income households have available to them and their actual expenditures, with expenditures exceeding gross income by about 50 percent for most low-income households. Under the alternative assumption that consumption decisions are based not only on current income, but on expectations of future earnings and assets, expenditures may be a more appropriate measure of a household’s budget in the CE. Examining the benefit reduction rate based on total expenditures minus SNAP benefits and food at home expenditures minus SNAP benefits, food at home spending as a percentage of total expenditures were much lower (13 percent) than food expenditures as a percentage of net income. Because of the inconsistency in findings depending on which measure of household resources is used as well as other data limitations, we recommend that caution be used in interpreting the findings from this analysis and making comparisons with other studies. Finally, we examined deduction usage and availability by (1) examining the percentage of participating SNAP households that took each deduction type, including at initial certification and at or after recertification; (2) assessing whether there is evidence of structural barriers to claiming available deductions that might have kept low-income households from reporting certain expenses (SNAP QC data provided information on actual deduction usage and amounts for SNAP participants); and (3) considering whether low-income households incurred costs that are not included in the deductions but that might be considered. We found that: \uf0b7 Nearly three-quarters of SNAP households had an excess shelter expense deduction and 32 percent had an earned income deduction; the other deductions were much less common. \uf0b7 Greater percentages of households used the earned income, excess shelter expense, dependent care, and medical expense deductions after recertification than at initial AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 63 certification, although the differences were generally small. There was no statistically significant difference in the use of the child support payment deduction at initial certification versus after recertification. \uf0b7 The percentage of low-income households with certain types of expenditures, such as medical, rent or mortgage, and child care, was often higher than the percentage of SNAP participants using the deduction. The difference could suggest either the presence of structural barriers\u2014such as difficulty in acquiring or providing (or an unwillingness to provide) the needed documentation on expenditures\u2014or differences between the broader low-income population and the segment of the population that participates in SNAP. It is also possible that households with low gross incomes such that their net incomes are zero after applying the standard deduction may elect not to report expenses such as shelter and medical because they would already be eligible for a maximum SNAP allotment without any additional deductions. \uf0b7 SNAP deductions do not capture certain household expenses that are prevalent among low-income households, such as spending on housing repairs or maintenance, vehicle costs not associated with commuting, and finance, late charges, or interest on student loans. B. Policy implications The purpose of the study was to provide FNS with evidence on whether the existing deductions and the benefit reduction rate are appropriate, given the spending patterns of low- income households. Although FNS does not have statutory power to change SNAP legislation and regulations, these findings may be considered in recommending changes to policymakers. The findings in this report have the following policy implications: 1. For households covered by the deductions, most SNAP deductions generally reflected the actual expenditures reported by low-income households. This means that on average, across all household types eligible for the deductions, the deductions are capturing households’ expenses as intended. An exception, however, is that the shelter cap limited the size of the effective excess shelter expense deduction for 14 percent of households without elderly or disabled individuals, such that removing the cap would result in a larger SNAP benefit allotment. Policymakers could consider increasing or removing the cap. This would allow households without elderly or disabled individuals to receive a deduction that reflects their total countable shelter expenditures. Another exception is that utility amounts used in the SNAP excess shelter expense deduction were higher on average than actual utility expenses for low-income households. The utility amounts used for the deduction are often based on State Standard Utility Allowances. FNS should continue to assess how State Standard Utility Allowances compare with actual utility costs so that policymakers may consider whether the allowances are appropriate. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 64 2. For some types of households currently not covered by the deductions, expenditures can be large. For example, the medical expense deduction is not available to households without elderly or disabled individuals; yet, such households incur sizeable medical expenses. The 47 percent of these household types with medical expenditures spend an average of $224 per month. Policymakers could consider whether extending the medical expense deduction to the affected households is appropriate. 3. Policymakers should consider whether SNAP deductions should be expanded to capture certain common household expenses not currently captured. Possibilities include expenses on housing repairs or maintenance that did not arise due to a natural disaster and vehicles and other transportation costs not used for commuting. 4. Our findings suggest that SNAP participants may face structural barriers to claiming certain deductions. We observed, for example, that the percentage of low- income households with elderly or disabled individuals, gross income at or below 130 percent of poverty, and monthly out-of-pocket medical expenditures greater than $35 is much larger than the percentage of participating SNAP households with elderly or disabled individuals and gross income at or below 130 percent of poverty that receive the deduction. Similarly, nearly all low-income households have rent or mortgage expenditures, but rent or mortgage expenditures are included in the excess shelter expense deduction of only about two-thirds of participating SNAP households. We recommend that FNS examine why some households that likely incur excess shelter or countable medical expenditures are not reporting these expenditures. C. Recommendations for future research FNS may wish to consider some additional analyses to address data limitations or to obtain more precise results. Our suggestions are as follows: 1. Combine multiple years of data to increase sample sizes and explore regional differences. In this study, we found that spending patterns varied by geographic region. We focused on regional differences when assessing how utility expenditures for low- income households compared with utility amounts used for the excess shelter expense deduction. However, we did not conduct in-depth analyses on whether other deductible expenditures, such as out-of-pocket expenditures, or food spending varied across regions. FNS may wish to consider integrating CE data from 2015 and earlier years, thereby increasing precision when focusing on smaller samples of households, such as those in a specific region, to investigate whether existing deductions and the benefit reduction rate reflect spending patterns in each region. 2. Obtain information from SNAP participants on medical expenditures for households with elderly or disabled individuals. To determine the amount of the medical expense deduction, SNAP counts only out-of-pocket medical expenditures that are attributable to elderly or disabled individuals in the household. The CE does not AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 65 indicate whether medical expenditures in households with elderly or disabled individuals are for the elderly or disabled members or for other household members. Thus, comparing actual medical expenditures to deduction amounts for CE households may be inaccurate if those expenditures relate to nonelderly or nondisabled members of the household. FNS could explore the feasibility of obtaining data on medical expenditures for SNAP participants through another source and in greater detail. 3. Assess options for identifying large, one-time expenditures in the CE and treating them in the analysis as one-time annual expenditures rather than as repeated quarterly expenditures. The quarterly interview design in the CE, along with our method for annualizing expenditures and converting them to average monthly amounts, could lead to the overstatement of one-time expenditures for some households and to the understatement for other households. In particular, average monthly expenditure amounts among households with large but infrequently occurring expenditures can be overstated. Researchers could assess options for identifying one-time expenditures and treating them as annual expenditures rather than as repeated quarterly expenditures. 4. Integrate data from other sources to examine food expenditures as a percentage of net income. Patterns of income reporting in the CE differ substantially from those in the Current Population Survey (CPS), which is considered more reliable. Furthermore, income amounts in the CE are often inconsistent with employment status. As such, the BLS often imputes income for households in the CE. Nonetheless, in the aggregate, we found that expenditures for low-income households were about 150 percent of total income. The CPS, which includes data on food expenditures and income, could provide an alternative data source for examining the benefit reduction rate. Even though the CPS may report income more accurately, use of CPS data to estimate the benefit reduction rate would not address the challenge for policymakers regarding whether the benefit reduction rate should calculate food spending as a share of total net income or total available resources. Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 66 Glossary Adjusted net income Countable income after all potential deductions except for the excess shelter expense deduction are subtracted from gross income. Benefit reduction rate The percentage by which benefits in a public assistance program are reduced as income rises. The SNAP benefit is reduced by 30 cents for each additional dollar of net income. Certification period Length of time a household is certified to receive SNAP benefits. When the certification period expires, households must be recertified to continue receiving benefits. Child support payment deduction Deduction from gross income for households with legally obligated child support payments made to or for a nonmember of the household. The deduction amount is equal to the monthly child support payment. States may choose to exclude child support payments from gross income rather than use the deduction. Children Individuals under age 18. Consumer Expenditure Survey (CE) An annual national survey administered by the U.S. Census Bureau for the U.S. Bureau of Labor Statistics. It provides extensive data on the purchasing habits of U.S. consumers. Consumer unit In the CE, a consumer unit consists of any of the following: (1) all members of a particular household who are related by blood, marriage, adoption, or other legal arrangements; (2) a person living alone or sharing a household with others or living as a roomer in a private home or lodging house or in permanent living quarters in a hotel or motel, but who is financially independent; or (3) two or more persons living together who use their incomes to make joint expenditure decisions. Deductions Allowable deductions from a household’s gross monthly income used to arrive at SNAP net monthly income. See also Child support payment deduction, Dependent care deduction, Earned income deduction, Excess shelter expense deduction, Medical expense deduction, MFIP, SSI-CAP, Standard deduction, and Total deduction. Dependent care deduction Deduction from gross income for households with expenses involved in caring for dependents while other household members work, seek employment, or attend school. Earned income Includes wages, salaries, self employment, and other reported earned income. Earned income deduction Deduction from gross income for households with earnings, equal to 20 percent of the combined earnings of household members. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 67 Elderly individuals Individuals age 60 or older. Excess shelter expense deduction Deduction from gross income for households with shelter costs, equal to those shelter costs that exceed 50 percent of the household’s countable income after all other potential deductions are subtracted from gross income. There is a limit ( shelter cap ) on the deduction for households without elderly or disabled members. Food Stamp Act of 1977 Established uniform national eligibility standards for SNAP; eliminated the purchase requirement and simplified items pertaining to eligibility requirements and benefit amounts, including deductions. Gross income Total monthly countable income of a household in dollars, before applying deductions. Household: CE See Consumer unit Household: SNAP Individuals who live in a residential unit and purchase and prepare food together. Low-income household Unless otherwise specified, households with gross income (excluding SNAP benefit amounts) at or below 200 percent of U.S. Department of Health and Human Services poverty guidelines. MATH SIPP+ model SIPP- and CPS-based microsimulation model that simulates SNAP eligibility and participation using current or recent SNAP rules and data from a recent SIPP panel. This study uses the 2015 Baseline of the 2011 MATH SIPP+ model, which simulates 2015 SNAP rules using 2011 data. Maximum benefit SNAP benefits are calculated by subtracting 30 percent of a household’s net income from the maximum possible benefit amount to which it is entitled based on household size and residence in the contiguous United States, Alaska, Hawaii, Guam, and the Virgin Islands. Marginal effectiveness of a deduction The amount that a households’ net income would have increased in the absence of a deduction Medical expense deduction Deduction from gross income for households with elderly or disabled members, equal to out-of-pocket medical expenses incurred by the elderly or disabled person that exceed $35. Minnesota Family Investment Program (MFIP) Minnesota’s cash assistance program, which jointly calculates SNAP benefits and cash assistance for participating households. Net income Total monthly income for households in dollars, after applying deductions. Nonelderly disabled individual In the CE, individuals who list illness, disability, or inability to work as their reason for not working. In the SNAP QC data file, individuals with a disability-based assistance payment or with a reported medical expense deduction. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 68 Payroll taxes Equal to approximately 7.65 percent of earnings, which is the sum of 6.20 percent for Social Security and 1.45 percent for Medicare. Poverty guidelines Issued by the U.S. Department of Health and Human Services, they are developed on the basis of the poverty thresholds published by the Census Bureau. QC Minimodel SNAP QC-based microsimulation model that simulates the effect of changes to SNAP on eligibility and benefit amounts. This study uses the 2013 and 2014 QC Minimodels, which simulate SNAP rules in place in fiscal year 2013 and fiscal year 2014, respectively. Shelter cap Maximum excess shelter expense deduction for households without elderly or disabled members. SNAP Quality Control (QC) data Administrative data derived from the SNAP quality control system that contains detailed demographic, economic, and SNAP eligibility information, in addition to information on deduction use and amounts, for a nationally representative sample of approximately 48,000 SNAP households. SSI combined application project (SSI CAP) Demonstration projects with a goal of streamlining the procedures for providing SNAP benefits to certain households eligible for both SNAP and SSI. Standard deduction Deduction from gross income for all households, which varies by household size and for areas outside of the contiguous United States. Standard medical deduction demonstration projects Demonstration projects that use a standard medical expense deduction amount for SNAP households with elderly or disabled members and medical expenses above $35 but below a specified limit. Standard Utility Allowance (SUA) Specified dollar amounts set by State agencies that States may use in place of actual utility costs to calculate a household’s total shelter expenses. Thrifty Food Plan Market basket of goods based on an economical and nutritious diet, adjusted for household size and composition. Used to determine maximum SNAP benefit amounts. Total deduction Includes child support payment, dependent care, earned income, excess shelter expense, medical, and standard deductions to which SNAP households are entitled. Unearned income In the CE, unearned income includes TANF, GA, SSI, Social Security, unemployment benefits, veterans benefits, workers’ compensation, other government benefits, contributions, deemed income, education loans, child support, wage supplementations, energy assistance, State diversion payments, and other unearned income. Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 69 References Bee, A., B. D. Meyer, and J. X. Sullivan. (2015). The Validity of Consumption Data: Are the Consumer Expenditure Interview and Diary Surveys Informative? In C. Carroll, T. Crossley, & J. Sabelhaus (Eds.), Improving the Measurement of Consumer Expenditures, pp. 204 240. University of Chicago Press. Castner, L. & J. Mabli. (2010). Low-Income Household Spending Patterns and Measures of Poverty. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, April. Edin, K., Boyd, M., Mabli, J., Ohls, J., Worthington, J., Green, S., Redel, N., & Sridharan, S. (2013). SNAP Food Security In-Depth Interview Study. Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service. Farson Gray, K. & S. Kochhar. (2015). Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2014. Report No. SNAP-15-CHAR. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, December. Filion, K., E. Eslami, K. Bencio & B. Schechter. (2014). Technical Documentation for the Fiscal Year 2013 Supplemental Nutrition Assistance Program Quality Control Database and the QC Minimodel. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, October. Fox M.K., Hamilton W., Lin B.H. (2004). Effects of food assistance and nutrition programs on nutrition and health: Volume 3, Literature Review. US Department of Agriculture, Economic Research Service, Food Assistance and Nutrition Research Report No. 19-3. Washington, DC. www.ers.usda.gov\/publications\/fanrr19-3\/ Fraker, T. M. (1990). Effects of Food Stamps on Food Consumption: A Review of the Literature. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, December. Hanson, K. (2008). Mollie Orshansky’s Strategy to Poverty Measurement as a Relationship between Household Food Expenditures and Economy Food Plan. Review of Agricultural Economics, 30 (3), 572-580. Institute of Medicine (IOM) & National Research Council. (2013). Supplemental Nutrition Assistance Program: Examining the Evidence to Define Benefit Adequacy. Adv Nutr. 4: 477- 478. http:\/\/advances.nutrition.org\/content\/4\/4\/477.full Leftin, J., J. Smith, K. Cunnyngham, & C. Trippe. (2014a). Technical Working Paper: Creation of the 2011 MATH SIPP+ Microsimulation Model and Database. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, February. Leftin, J., N. Wemmerus, J. Mabli, T. Godfrey, & S. Tordella. (2014b). Dynamics of Supplemental Nutrition Assistance Program Participation from 2008 to 2012. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Decision Demographics, December. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 70 Mabli, J., Ohls, J., Dragoset, L. Castner, L., & Santos. B. (2013). Measuring the Effect of Supplemental Nutrition Assistance Program (SNAP) Participation on Food Security. Prepared by Mathematica Policy Research for the US Department of Agriculture, Food and Nutrition Service, August. http:\/\/www.fns.usda.gov\/sites\/default\/files\/Measuring2013.pdf Mabli, J., & R. Malsberger. (2013). Recent Trends in Spending Patterns of Supplemental Nutrition Assistance Program Participants and Other Low-Income Americans. Monthly Labor Review, September. http:\/\/www.bls.gov\/opub\/mlr\/2013\/article\/mabli-malsberger.htm Meyer, B. & R. Goerge (2011). Errors in Survey Reporting and Imputation and Their Effects on Estimates of Food Stamp Program Participation. US Census Bureau Center for Economic Studies Paper No. CES-WP-11-14. http:\/\/dx.doi.org\/10.2139\/ssrn.1824261 Nord, M. & Golla, M. (2009). Does SNAP Decrease Food Insecurity? Untangling the Self- Selection Effect. Economic Research Report No. 85, US Dept. of Agriculture, Economic Research Service. October. http:\/\/www.ers.usda.gov\/publications\/err-economic-research- report\/err85.aspx Orshansky, M. (1957). Food consumption and dietary levels of households in the United States: Some highlights from the Household Food Consumption Survey, Spring 1955, ARS 62-6. Washington, DC: USDA, ARS. Pub. L. No. 88-525. (1964). Food Stamp Act of 1964, 78 Stat. 703 (codified as amended in 7 U.S.C. ch. 51, 2011 et seq.) http:\/\/www.fns.usda.gov\/sites\/default\/files\/PL_88-525.pdf Pub. L. No. 91-671. (1971). An Act to amend the Food Stamp Act of 1964. 78 Stat. 703; 7 U.S.C., 2011. http:\/\/uscode.house.gov\/statutes\/pl\/91\/671.pdf Pub. L. No. 95-113. (1977). Food Stamp Act of 1977, 91 Stat. 913-1045. https:\/\/www.gpo.gov\/fdsys\/pkg\/STATUTE-91\/pdf\/STATUTE-91-Pg913.pdf U.S. Bureau of Labor Statistics (BLS). (2016). Consumer Expenditure Survey. http:\/\/www.bls.gov\/cex\/. Also see Frequently Asked Questions (FAQs), http:\/\/www.bls.gov\/cex\/csxfaqs.htm#q22 , Description of Income Imputation Beginning with 2004 Data, http:\/\/www.bls.gov\/cex\/csximpute.htm , and CE Tables, http:\/\/www.bls.gov\/cex\/tables.htm, and Combined Income, http:\/\/www.bls.gov\/cex\/2015\/combined\/income.pdf U.S. Department of Agriculture, Economic Research Service (ERS). (2016). ERS Food Expenditure Series http:\/\/www.ers.usda.gov\/data-products\/food-expenditures.aspx. Accessed October 14, 2016. U.S. Department of Agriculture, Food and Nutrition Service (FNS). (2012). FNS Handbook 310, but dated October 2012. http:\/\/www.fns.usda.gov\/sites\/default\/files\/FNS_310_Handbook.pdf. Accessed on July 21, 2016. U.S. Department of Health and Human Services (2011). The 2011 HHS Poverty Guidelines, Office of The Assistant Secretary for Planning and Evaluation. https:\/\/aspe.hhs.gov\/2011-hhs-poverty-guidelines U.S. Department of Health and Human Services (2012). The 2012 HHS Poverty Guidelines, Office of The Assistant Secretary for Planning and Evaluation. https:\/\/aspe.hhs.gov\/2012-hhs-poverty-guidelines AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 71 U.S. Department of Health and Human Services (2013). The 2013 HHS Poverty Guidelines, Office of The Assistant Secretary for Planning and Evaluation. https:\/\/aspe.hhs.gov\/2013-poverty-guidelines#guidelines U.S. House Comm. on Agriculture, H.R. Doc. No. 7940, 95th Cong., 1st Sess. (1977). Report together with supplemental views, dissenting views, minority views, additional views. U.S. Government Printing Office, Washington, DC. Vigil, A., K. Farson Gray, S. Kochhar & B. Schechter. (2015). Technical Documentation for the Fiscal Year 2014 Supplemental Nutrition Assistance Program Quality Control Database and the QC Minimodel. Report submitted to the U.S. Department of Agriculture, Food and Nutrition Service. Washington, DC: Mathematica Policy Research, December. Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report 72 Appendices Appendix A: Detailed description of data and methods Appendix B: Chapter III Analysis Tables (Research Objective 1) Appendix C: Chapter III Analysis Tables (Research Objective 2) Appendix D: Chapter IV Analysis Tables (Research Objective 3) Appendix E: Chapter V Analysis Tables (Research Objective 3) Appendix F: Chapter VI Analysis Tables (Research Objective 3) Appendix G: Summary of food expenditure estimates for low-income households Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A Appendix A: Detailed description of data and methods Table of Contents A. Overview of the CE data …………………………………………………………………………………………. A-1 B. Step-by-step processing of CE data ………………………………………………………………………….. A-6 C. Overview of the SNAP QC data ………………………………………………………………………………. A-7 D. QC-based analyses of deduction usage ……………………………………………………………………… A-8 E. Overview of the microsimulation models ………………………………………………………………… A-10 F. Analyses using both CE and SNAP QC data ……………………………………………………………. A-11 G. Analyses using both CE data and microsimulation modeling …………………………………….. A-11 H. Analysis using both SNAP QC data and microsimulation modeling …………………………… A-11 We drew on the most recent data available from several sources to conduct the study. To address all research questions for the first two study objectives and many research questions for the third study objective, we used the 2013 and 2014 Bureau of Labor Statistics (BLS) Consumer Expenditure Surveys (CE). For the third study objective, we supplemented the CE-based analyses with analyses that used (1) the 2013 and 2014 SNAP Quality Control (QC) data files and the QC Minimodel and (2) the 2015 Baseline of the 2011 MATH SIPP+ model. In Chapter II, we summarized the data sources and the analytic methodologies used to address the research questions. In this appendix, we describe the data and methods in more detail, including the steps we took to process the data and methods we used for analyses that combined data from multiple sources. A. Overview of the CE data The CE, administered by the Census Bureau for the BLS, provides highly detailed U.S. consumer expenditure data that simultaneously measure a variety of household spending behaviors, thereby allowing analysis of the amount and proportion of a household’s budget spent on specific categories of goods and services. The major expenditure categories are food at home, food away from home, housing, apparel, health care, transportation, and other goods and services, including personal insurance and pensions, entertainment, cash contributions, and education. In Chapter III, we list subcategories included in each expenditure type (Table III.1). The survey also includes information on household characteristics and income as well as financial data. We used CE data primarily to address Objectives 1 and 2, producing a complete account of expenditures by spending category for low-income households and detailing how the shares vary by important demographic, economic, and geographic characteristics. We also used the data to A-1 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A address topics under Objective 3, including assessments of (1) how expenditures among low- income households compare with the SNAP deductions and the benefit reduction rate, (2) which frequently occurring expenditures are not captured by existing deductions, and (3) how the percentage of low-income households with various types of expenditures compares with the percentage of households claiming SNAP deductions for such expenses. 1. Interview structure The CE consists of two quarterly surveys, the Interview Survey and the Diary Survey, that provide information on the purchasing habits of approximately 7,000 households. In the current study, we made exclusive use of Interview survey data collected over five consecutive quarters; each year’s data set accounts for about 35,000 household records. The initial interview collects demographic and family characteristics data. At each interview, respondents report expenditures for the three calendar months preceding the interview month. For example, interviews conducted in April 2013 provided expenditure data for January 2013 through March 2013. The second- and fifth- quarter interviews collect income and components of income; respondents provide the information as annual amounts. Even though the third- and fourth-quarter interviews generally do not collect income, the CE data file provides income amounts for these periods. The amounts are usually the same as those for the second quarter unless (1) income was imputed and the imputation changed; (2) someone in the unit started or stopped working; or (3) the composition of the CE unit changed. 2. The consumer unit The unit of analysis in the CE is the consumer unit, defined as (1) occupants related by blood, marriage, adoption, or some other legal arrangement; (2) a single person who is living alone or sharing a household with others but who is financially independent1; or (3) two or more people living together who share responsibility for at least two out of the three major types of expenses\u2014food, housing, and other living expenses. A consumer unit may differ from a SNAP household, which, under SNAP rules, is defined as individuals who live together and customarily purchase and prepare food together. For simplicity, we use household in place of consumer unit when we discuss the findings. 3. Stacking the CE data The BLS released the 2014 Public-Use Microdata in September 2015; these were the most recent data available at the time of our analysis. The file contains information on expenditures for January 2014 through December 2014, though the survey design is such that the data were collected through March 2015. To obtain a larger sample, we stacked (pooled) the 2013 and 2014 data after confirming that there were no major changes in the survey design or content between the two years. As described, each annual CE data file summarizes five quarters of experience. The fifth quarter overlaps the subsequent year and facilitates data file production and accommodates 1 These include financially independent individuals who are living as roomers in a private home or lodging house or in permanent living quarters in a hotel or motel. A-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A coding and sample design changes. Given that the fifth quarter of the 2013 CE data set overlaps with the first quarter of the 2014 data, we did not include the first quarter of 2014 in the stacked analysis file in order to avoid double counting. 4. Annualizing monthly expenditures The CE data provide expenditures as quarterly values; however, income is an annual measure. To annualize expenditures and calculate weighted average expenditure amounts, we used a method created by the BLS that is described in the CE Interview data documentation and sample program. We first adjusted the quarterly expenditure amounts to include only those expenditures made in calendar years 2013 and 2014. For example, for respondents interviewed in February 2013 who reported expenditure data from December 2012, January 2013, and February 2013, we included only the January 2013 and February 2013 expenditure amounts. We summed the adjusted quarterly expenditure amounts to obtain a weighted expenditure total. To obtain an average annual expenditure amount, we divided the weighted expenditure total by the weighted number of households, adjusting for the number of months of expenditure data each household contributed and for the CE’s rolling sample design. In this case, given that each quarter of interviews is designed to represent an independent sample, the use of data from several quarters to estimate annual totals requires the sum of the adjusted weights to be divided by 12 (equal to three months times four quarters) when using one year of data and to be divided by 24 (equal to three months times eight quarters) when using two years of data. In addition to presenting weighted average expenditure amounts, we present shares of total expenditures spent on specific categories of goods and services. To calculate the share of total expenditures spent on a specific expense category such as Food at Home, we calculated the weighted average expenditures on food at home and divided by the weighted average total expenditures for all goods and services. In the case of uncommon, one-time large expenses such as a vehicle purchase or high medical bills, annualized expenses for the consumer units that incur such expenses can appear improbably large, such as a sample member spending $12,000 on a car in a given quarter. When calculating average expenditure amounts across all units, these large values are offset by the lack of purchases in other quarters, and thus are smoothed over time. When estimating average expenditures among those units with positive expenditures, however, these large, one-time purchases may bias the estimate upward because the data is restricted to those quarters with positive expenditures. For analyses of average monthly expenditures, we divided annualized expenditures by 12. 5. Determining sample sizes The annualizing procedure described above adjusts each consumer unit’s quarterly expenditure value by the number of months the consumer unit contributed to a calendar year estimate. The BLS refers to this as a consumer unit’s number of months in scope. Consumer units interviewed in February 2013, for example, contribute one month (January) and have one month in scope; those interviewed in March 2013 contribute two months (January and February) A-3 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A and have two months in scope; and those interviewed in April 2013 contribute three months (January, February, and March) and have three months in scope. The unweighted sample size for the annual mean expenditure totals or annual expenditure shares based on two years of data is equal to the sum of the month in scope divided by 24. The weighted sample size for the annual mean expenditure totals or annual expenditure shares based on two years of data is equal to the sum of the product of the month in scope and the survey weight divided by 24. 6. Inflation The average monthly, nonseasonally adjusted Consumer Price Index for all urban consumers (CPI-U) increased by 1.6 percent from calendar year 2013 to calendar year 2014 (http:\/\/www.bls.gov\/cpi\/#tables). However, we did not inflation-adjust 2013 expenditure dollar values to 2014 levels (or to any other point in time). Thus, unless otherwise noted, our CE estimates are representative of expenditures made in 2013 and 2014. 7. Defining gross income We defined gross income as total consumer unit income in the past 12 months before taxes minus the annual SNAP benefit amount. When calculating expenditures as a percentage of income, we modified the definition to use after-tax income, a better measure of disposable income. We used an income measure that included imputations of income carried out by the BLS in combination with the income as reported by respondents. Exploratory tabulations restricted to reported income revealed inconsistencies between respondents’ employment and earnings (which form part of total income). For example, only about half of the consumer units with employed unit heads reported earnings. In many cases, the data indicated that the respondent either did not know or refused to provide the requested information. When describing income reporting in the CE, the BLS acknowledges respondents’ lack of information or refusal to report the requested information and therefore provides an imputed income measure that is used throughout this report (BLS, 2016). 8. Determining poverty guidelines Poverty guidelines issued by the U.S. Department of Health and Human Services provide the basis for the Federal fiscal year’s SNAP gross and net monthly income eligibility standards. We identified the poverty guideline for each consumer unit based on the unit’s size, State of residence, and interview month. We used a single set of guidelines for consumer units located within the 48 contiguous States and the District of Columbia and for records on which the State was not identified2; we applied State-specific guidelines for consumer units in Alaska and Hawaii. Our approach followed the guidelines that reflect the Federal fiscal year in which the majority of months of the lookback period fell (U.S. Department of Health and Human Services, 2011, 2012, & 2013). For example, the earliest interview included in this study, conducted in February 2013, had an income lookback period of February 2012 to January 2013. Given that 2 About 15 percent of records in the CE have a suppressed State identifier; for example, the State of residence is suppressed to protect respondent confidentiality when sampling units fall into small States or across State lines. A-4 (http:\/\/www.bls.gov\/cpi\/#tables) AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A eight months of the period fell in fiscal year 2012, we used the January 2011 guidelines for these consumer units. For the April 2013 and April 2014 interviews, six months of the lookback fell in two consecutive fiscal years. For these interview months, we applied the poverty guidelines of the more recent fiscal year. In Table A.1, we provide information on which poverty guideline we used for each interview month. Table A.1. Number of months of lookback in Federal fiscal year, CE Interview survey 2013 2014, and specific poverty guidelines applied in this study 2011 Guidelines 2012 Guidelines 2013 Guidelines 2014 Guidelines Months in fiscal Months in fiscal Months in fiscal Months in fiscal year 2012 year 2013 year 2014 year 2015 January (October 2011 to (October 2012 to (October 2013 to (October 2014 to Poverty Interview Lookback months: September September September September guidelines month From To 2012) 2013) 2014) 2015) applied Feb-13 Feb-12 Jan-13 8 4 2011 Mar-13 Mar-12 Feb-13 7 5 2011 Apr-13 Apr-12 Mar-13 6 6 2012 May-13 May-12 Apr-13 5 7 2012 Jun-13 Jun-12 May-13 4 8 2012 Jul-13 Jul-12 Jun-13 3 9 2012 Aug-13 Aug-12 Jul-13 2 10 2012 Sep-13 Sep-12 Aug-13 1 11 2012 Oct-13 Oct-12 Sep-13 12 2012 Nov-13 Nov-12 Oct-13 11 1 2012 Dec-13 Dec-12 Nov-13 10 2 2012 Jan-14 Jan-13 Dec-13 9 3 2012 Feb-14 Feb-13 Jan-14 8 4 2012 Mar-14 Mar-13 Feb-14 7 5 2012 Apr-14 Apr-13 Mar-14 6 6 2013 May-14 May-13 Apr-14 5 7 2013 Jun-14 Jun-13 May-14 4 8 2013 Jul-14 Jul-13 Jun-14 3 9 2013 Aug-14 Aug-13 Jul-14 2 10 2013 Sep-14 Sep-13 Aug-14 1 11 2013 Oct-14 Oct-13 Sep-14 12 2013 Nov-14 Nov-13 Oct-14 11 1 2013 Dec-14 Dec-13 Nov-14 10 2 2013 Jan-15 Jan-14 Dec-14 9 3 2013 Feb-15 Feb-14 Jan-15 8 4 2013 Mar-15 Mar-14 Feb-15 7 5 2013 Source: U.S. Department of Health and Human Services Poverty Guidelines for 2011, 2002, and 2013. 9. Defining low-income households Once we determined the appropriate poverty guidelines for a consumer unit, we calculated income as a percentage of the poverty level by dividing the (imputed) gross income by the poverty level for that unit. We defined low-income households in the data as those consumer units with gross income (excluding SNAP benefit amounts) at or below 200 percent of the A-5 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A poverty guidelines. Not all low-income households that we examine in this study are eligible for SNAP. Some may not satisfy the income or resource eligibility criteria, and some may be otherwise categorically ineligible for SNAP. B. Step-by-step processing of CE data We used the CE Interview Public Use Microdata (PUMD) files for 2013 and 2014, downloaded in SAS format from http:\/\/www.bls.gov\/cex\/pumd_data.htm. The BLS separately stores sets of data files for each year of the PUMD data, organized by content area and file structure by quarter. The core of our analysis file incorporates information from the quarterly files for each consumer unit; each individual consumer unit can contribute up to four quarters of information. Each Quarterly Interview Survey file consists of six sets of files that summarize expenditures into logical broad groups of expenditure types. From the 2013 and 2014 CE, we took both the quarterly Consumer Unit Characteristics and Income File (FMLI) and the quarterly Member Characteristics and Income File (MEMI). The BLS also summarizes and stores detailed transaction data on separate topics in 43 annual-level expenditure files. The individual expenditure transactions are summed for each quarter the respondent is in the survey and combined with the core quarterly PUMD data. This procedure was performed with seven extracts for each consumer unit from these files from both the 2013 and 2014 CE panels. The first step in preparing the final project analysis file required the construction of small extracts of several data items from seven of the 43 detailed annual expenditure files. The seven items extracted and later merged were: 1. Presence of and expenditure on homeowner and tenant insurance 2. Parking expenses and local tolls paid 3. Presence of and amount of alimony contributions 4. Presence of and amount of a list of detailed education expenses 5. Presence of and amount of child support contributions 6. Presence of anyone in the consumer unit enrolled in Medicare or Medicaid 7. Presence of and expense of unreimbursed uniform purchases for those age 16 or older. It is important to note that uniform expenditures are reported only when uniforms are the first of several items purchased in a single expenditure. In addition, the age of the person for whom clothing was purchased is reported only for the transaction as a whole. School and work uniforms cannot be differentiated. Next, we extracted consumer unit-level income and expenditure data from the Consumer Unit Characteristics and Income Files for 2013 and 2014. Given that the first quarter of 2014 is included with the 2013 data files, we excluded those data in order to avoid duplication. Thus we use five quarters of data from the 2013 CE and the last four quarters of the 2014 CE. Consumer units in the fifth ‘quarter’ of the 2013 CE also appear in the first quarter of the 2014. Not all reported values are identical as new topcodes are introduced with the first quarter data that may differ from the previous year. Once we extracted and annualized the relevant analysis variables, we created several variables to customize the summary measure, such as a sum of housing costs A-6 http:\/\/www.bls.gov\/cex\/pumd_data.htm AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A excluding the costs of domestic services. We also calculated other expenditures by subtracting the detailed expenditure categories presented in the analysis tables from total expenditures. We created and defined the labor force status of the consumer unit heads as follows: Employed. The unit head was employed if the number of hours usually worked per week was greater than zero. Unemployed. The unit head was unemployed if the reason for not working in the past 12 months was the inability to find work. Not in labor force. The unit head was not in the labor force if he or she was age 18 to 59 and indicated that he or she was retired, taking care of the home, enrolled in school, ill, disabled or unable to work, or doing something else. We assigned all unit heads age 18 to 59 to one of the three labor force status categories. However, we assigned an employment status to children under age 18 and adults older than age 60 only if they were employed. Otherwise, we excluded children and elderly adults from the employment panels in our tables. Next, for 2013 and 2014, we read the individual consumer unit member files. Again, we did not include records for the first quarter of 2014 from the 2014 files, as those data are part of the 2013 data files. We calculated several consumer unit level summary measures by scanning through each individual record to determine the composition or type of consumer unit. In this manner, we determined the presence and counts of consumer unit members by age, employment status, disability status, and unit composition such as presence of children. We defined a consumer unit as including children if it included an individual younger than age 18; as including an elderly member if it included an individual age 60 or older; and as including a nonelderly disabled individual if an individual indicated that the main reason for not working in the past 12 months was due to being ill, disabled, or unable to work. 3 After development of this consumer unit summary data file, we merged these consumer characteristics onto the consumer unit level expenditure file. In addition, at this stage, we merged to the full analysis file the seven small extract files containing additional data on items such as insurance, parking and tolls, alimony, Medicare, and so forth. With all the data gathered into a unified file, the final step was the creation of binary variables identifying membership in each summary row subgroup to be shown in the analysis tables. This single summary analysis data file was the input for all CE-based data tables presented in this report. C. Overview of the SNAP QC data The SNAP QC data file is derived from SNAP’s QC system that measures the accuracy of State eligibility and benefit determinations. It contains detailed demographic, economic, and SNAP eligibility information, in addition to information on deduction use and amounts of deductions, for a nationally representative sample of approximately 48,000 SNAP households 3 This definition of disability differs from the SNAP definition which is based on receipt of disability-based income. A-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A (Filion et al., 2014; Vigil et al. 2015). The data are weighted to ensure that the weighted totals match three adjusted SNAP Program Operations totals: the monthly number of SNAP households by State and stratum, the monthly number of SNAP participants by State, and the monthly total benefit amounts issued by State. The totals are adjusted by removing benefits issued in error and benefits issued through the SNAP disaster assistance program because the SNAP QC data do not include cases with either of these conditions. We used the adjusted data to address most topics under Objective 3. The SNAP unit (also called the SNAP household in the tables and in our description of the findings) was the unit of observation and the unit of analysis. SNAP units comprise individuals who purchase and prepare food together and who are together certified for and receive SNAP benefits. For all QC-based analyses, we stacked the fiscal year 2013 and 2014 SNAP QC data files so that the combined data cover October 2012 through September 2014. There were no substantial changes in the structure or content of the fiscal year 2014 file relative to the fiscal year 2013 file. We multiplied the sample weights by one-half to make the findings representative of an average month in the combined fiscal year 2013 and 2014 period. The combined data contain observations for 97,819 SNAP households. We excluded from most analyses all SNAP households participating in State programs for which income is not used in their SNAP benefit determinations. These include households eligible for SNAP through the Minnesota Family Investment Program (MFIP) or a Supplemental Security Income-Combined Application Project (SSI-CAP). 4 We imposed some additional restrictions in the tables that compare SNAP QC based findings with CE findings, thereby increasing the comparability of the two groups of households (discussed in more detail in Section F). D. QC-based analyses of deduction usage We used the stacked fiscal year 2013 2014 SNAP QC data for descriptive and multivariate regression analyses to address two research questions: 1. Are the rates of deduction use for excess shelter costs, medical costs, and transportation costs maintained at recertification? 2. Do households with similar circumstances that do not deduct certain medical, shelter, or transportation costs have comparably similar SNAP allotments?5 Each SNAP unit record includes information on the amount of the total deduction and each deduction type, along with the marginal effectiveness of each deduction. The marginal effectiveness of each deduction measures the amount of the increase in net income if the deduction type were not used. The data also include a variable (ACTNTYPE) that identifies 4 One exception is for the multivariate analysis of the excess shelter expense deduction. In Florida, Massachusetts, and Washington, SSI-CAP units have standard rent or mortgage allowances. Therefore, for the excess shelter expense deduction regressions, we did not exclude SSI-CAP units with positive shelter deductions. 5 We do not discuss this analysis in the text but present results in Appendix Table F.3. A-8 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A whether the most recent action on a case was a new certification or a recertification. In the multivariate analysis files used to address both research questions, we included all units with nonmissing information on all outcome measures (deduction usage and SNAP benefit amounts). To address the question about whether deduction usage is maintained at recertification, we conducted a multivariate regression analysis that compared households that were most recently newly certified to those that were most recently recertified across three measures of deduction use: (1) whether a SNAP household has a specific deduction type, (2) the deduction amount for deductions without standard amounts, and (3) the marginal effectiveness of each deduction type. We estimated separate regression models for each of the three measures of deduction use; in each model, the main independent variable was whether the most recent certification was the initial certification or a recertification (based on the variable ACTNTYPE). Other explanatory variables included some or all of the following demographic and economic characteristics of SNAP households, varying slightly by specification: unit size; separate indicators for whether the unit contained children, an elderly individual, or a disabled nonelderly individual; an indicator for whether several adults resided in the household; unit-level earned income; unit-level unearned income; indicators for whether the unit had Temporary Assistance for Needy Families (TANF), General Assistance (GA), SSI, or Social Security income; an indicator for whether the unit contained a noncitizen; an indicator for whether the unit was categorically eligible for SNAP; locality (metropolitan, micropolitan, or rural); and Census region. We measured the three dependent variables (presence of a deduction, deduction amount, and marginal effectiveness) by using the following six measures of deductions, resulting in 18 regressions: Total deductions (one variable) Earned income, child support payment, dependent care, medical expense, and excess shelter expense deductions (five variables) The regression analyses that examined the presence of a deduction used the full SNAP QC sample, including units with positive or zero deduction amounts. However, we restricted the samples for the analyses examining the amount of the deduction or marginal effectiveness to those units with positive values for those deductions. This allowed us to examine differences in deduction amounts at initial certification and recertification for deductions with low take-up rates. We estimated logistic regression models that relate the probability of receipt of a specific type of deduction to whether the unit was initially certified or recertified and the set of unit characteristics described above. We estimated ordinary least squares (linear) regression models for the analyses examining the amount of the deduction or marginal effectiveness. To address the question about whether SNAP benefit amounts are higher for otherwise similar units that take deductions (presented only in Appendix Table F.3), we estimated three separate regressions for the medical expense, excess shelter expense, and earned income deductions. In each regression, the SNAP allotment was the dependent variable, and the main A-9 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A independent variable was a measure of whether the SNAP household took the deduction. Each ordinary least squares regression included the same set of explanatory variables listed above. To construct the tables, we transformed the raw regression coefficient of the recertification variable into a regression-adjusted value of the dependent variable to measure the association of recertification with the probability of having a deduction (or, in alternate specifications, the mean amount of the deduction or marginal effectiveness amount). We obtained the regression-adjusted percentages of households with a deduction type, for example, by performing the following steps: i. Obtain the percentage for units at recertification. We evaluated the regression equation by using the regression coefficient estimates, setting the recertification variable equal to 1 for all households and using the means of all other explanatory variables calculated over all households in the sample. The process generated a single predicted probability that a household whose last action was recertification receives a deduction. ii. Obtain the percentage for units at certification. We evaluated the regression equation by using the regression coefficient estimates, setting the recertification variable equal to 0 for all units and using the means of all other explanatory variables calculated over all households in the sample. The process generated a single predicted probability of a unit whose last action was certification having a deduction. iii. Obtain the difference in percentages. We calculated the difference in the two predicted probabilities to obtain the estimate of whether deduction use is maintained at recertification. We performed an analogous set of steps for deduction amounts by estimating mean amounts of deductions in place of obtaining percentages of units with each deduction in the three steps above. E. Overview of the microsimulation models The QC Minimodel uses SNAP QC data to simulate the impact of various policy changes to SNAP on current SNAP participants. The 2013 and 2014 QC Minimodels use the fiscal year 2013 and 2014 SNAP QC data files, respectively.6 We used the 2013 and 2014 QC Minimodels to assess the effect of removing the shelter cap for SNAP households without elderly or disabled individuals (introduced in Chapter IV and discussed further in Section H of this appendix). The simulation results represent combined information from both the 2013 and 2014 models. With all results presented as percentages, we did not need to use weighting adjustments to account for the use of two years of data. Vigil et al. (2015) present more information on the QC Minimodel. Some research questions discussed in Chapters IV and V required the calculation of expenditures in the CE as a percentage of net income. Given that we did not have sufficient 6 The 2014 QC Minimodel simulates benefits that were in place after the sunset of the American Recovery and Reinvestment Act (ARRA) benefit amounts. With the ARRA benefits in place for only one month during the fiscal year (October 2013), the QC file used with the model does not differ substantially from the original fiscal year 2014 SNAP QC data file. A-10 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A information to derive net income in the CE, we used a microsimulation model database, the fiscal year 2015 Baseline of the 2011 MATH SIPP+ model, to obtain additional information. The model uses SIPP and CPS Annual Social and Economic Supplement (ASEC) data from 2011 and SNAP rules from fiscal year 2015 to simulate SNAP eligibility and participation, weighted to recent FNS Program Operations data. The model allows FNS to simulate existing SNAP policies (the baseline simulation), simulate alternative policies (the policy change simulation), and measure the difference between the baseline and policy change simulations. We present additional details of the analysis methods involving the MATH SIPP+ model in Section G. F. Analyses using both CE and SNAP QC data We compared expenditures for low-income consumer units in the CE data with expenditure or deduction amounts for SNAP participants in the SNAP QC data. In this section, we describe the methods used for those analyses. In Chapter IV, we compared mean monthly utility amounts used for low-income SNAP participants in the SNAP excess shelter expense deduction calculation with mean monthly utility expenditures in the CE data. We restricted participants in the SNAP QC data to those with gross income at or below 200 percent of the poverty guidelines, to better-align the SNAP QC data with the CE sample. We used the UTIL variable in the SNAP QC data to identify the utility amount used in the excess shelter expense deduction and used the SUA1 variable to identify the type of standard utility allowance that the unit received. In Chapter VI, we compared the percentage of consumer units with gross income at or below 130 percent of poverty guidelines that reported certain expenditures in the CE data with the percentage of participating units in the SNAP QC data with that expenditure or deduction type, by subgroup. We restricted units in the SNAP QC file to those with gross income at or below 130 percent of poverty so that both data sources used the same income cut-off. We also removed cases from Guam and the Virgin Islands from the SNAP QC data because the CE sample does not include units in those territories. Consumer units in the CE with income at or below 130 percent of poverty guidelines represent a different population than SNAP participants in the SNAP QC data. For two reasons, we focused our primary analysis in the CE on all consumer units meeting the income requirements regardless of whether they reported SNAP receipt. First, we were concerned about the underreporting of SNAP receipt in the CE. Second, we intended to include in our analysis net income ineligible units that might have been eligible if they had reported certain expenditures and thus had taken an additional or higher deduction. G. Analyses using both CE data and microsimulation modeling Two analyses discussed in this report required the calculation of expenditures as a percentage of net income: an examination of shelter expenditures and an examination of food expenditures. First, in Chapter IV, we examined whether a typical low-income consumer unit would have expenditures high enough to take an excess shelter expense deduction based on its rent or mortgage and actual utility expenditures. Expenditures are high enough if they exceed 50 percent A-11 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A of adjusted net income, defined as gross income minus all deductions excluding the excess shelter expense deduction. To obtain the share of adjusted net income spent on housing and utility costs, we used the following approach: i. Using the 2015 Baseline of the 2011 MATH SIPP+ model, estimate the ratio of mean gross income to mean adjusted net income (the sum of net income plus the excess shelter expense deduction) among simulated participating SNAP units in the model, with income at or below 200 percent of poverty guidelines. Given that the CE data do not include sufficient information to calculate adjusted net income, we obtained additional information from the MATH SIPP+ model. It simulates gross income, allowable deductions, and net income using SNAP program rules. We used the data to calculate the ratio of mean simulated weighted gross income to mean simulated weighted adjusted net income. In other words, it is the ratio of mean gross income to mean net income before inclusion of the excess shelter expense deduction, obtained by summing weighted gross income by the sum of weighted adjusted net income. ii. Using the CE, calculate the aggregated mean monthly share of gross income that low- income households spend on shelter. Countable shelter expenses include rent or mortgage payments, utility expenses, property taxes, and insurance.7 We used the appropriate housing expense variables in the CE (including those for mortgage, rent, utilities, property taxes, and insurance) to calculate the average monthly expenditures as a share of average monthly gross income. We calculated separate shares for all low-income households and for those with and without elderly or disabled individuals. iii. Using the mean monthly share of gross income that low-income households spend on shelter in the CE (derived in step ii) and the ratio from the MATH SIPP+ derived in step i, estimate the mean monthly share of adjusted net income (San) that low-income households spend on shelter. We calculated separate shares for all low-income households and for those with and without elderly or disabled individuals. In a separate analysis in Chapter V, we calculated expenditures on food as a percentage of SNAP net income by using variations (discussed in the chapter) of a similar method. The general method was as follows: i. Using the 2011 MATH SIPP+ model, estimate the ratio of gross income to net income. Using a process similar to that used for the analysis of the excess shelter expense deduction, we calculated the ratio of mean gross income to mean net income for key subgroups, including units of various sizes, units with children, units with elderly or nonelderly disabled individuals, and units with various ranges of income as a percentage of poverty. The difference for this analysis and the one for the excess shelter expense 7 They also include housing maintenance or repair costs incurred due to disasters, but these expenditures cannot be identified in the CE. A-12 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix A deduction is that we calculated the ratio of gross income to net income rather than to adjusted net income. ii. Using the CE, calculate the share of after-tax gross income that low-income households spend on food by subgroup. iii. Use the subgroup-specific MATH SIPP+ ratios and the subgroup after-tax gross income food expenditure shares to calculate the share of net income that low-income households spend on food. iv. Compare the net income food expenditure share to the 30 percent benefit reduction rate. H. Analysis using both SNAP QC data and microsimulation modeling For one analysis (Appendix Table D.4), we used SNAP QC data to assess how often excess shelter expenses (rent or mortgage amount plus utility amount) exceeded the shelter cap among participating SNAP units without elderly or disabled individuals. For units with shelter expenses above the shelter cap, we examined by how much expenses exceeded the cap (for example, $1 to $200 above the cap, $201 to $400 above the cap, and so forth). Then, for each category presented in the table, we used the QC Minimodel to determine how often households without elderly or disabled individuals had an effective shelter deduction that was constrained (or limited) by the shelter cap. That is, we estimated the percentage of households that would have received a higher SNAP benefit in the absence of a shelter cap. To do so, we simulated the elimination of the shelter cap and observed how many households in each category would have seen an increase in their SNAP benefit. In Chapter IV of the report, we discuss simulation results among all households without elderly or disabled individuals and among all households (1) without elderly or disabled individuals and (2) with an excess shelter expense deduction. However, we do not discuss the extent to which total shelter expenditures exceed the shelter cap; those findings only appear in the appendix table. A-13 Page intentionally blank AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix B Appendix B: Chapter III Analysis Tables (Research Objective 1) No. Title B.1 Mean monthly expenditure amounts for all consumer units and low-income consumer units, 2013 2014 B.2 Distribution of annual expenditure amounts and mean income for all consumer units and low- income consumer units, 2013 2014 B.3a Mean expenditure shares for all consumer units and low-income consumer units, 2013 2014 B.3b Mean expenditure shares for all consumer units and consumer units with expenditures at or below 200 percent of poverty guidelines Mean expenditure shares for all consumer units and units with both income at or below 200 B.3c percent of the poverty guidelines and expenditures below 200 percent of median expenditures, 2013 2014 B.4 Mean expenditure shares as a percentage of total annual income for all consumer units and low- income consumer units, 2013 2014 Mean expenditure shares as a percentage of total annual income for all consumer units and low- B.5a income consumer units, by whether expenditures equals or exceeds 120 percent of income and whether income equals or exceeds 120 percent of expenditures, 2013 2014 B.5b Mean expenditure shares as a percentage of total annual income for all consumer units and low- income consumer units, for units with savings or debt, 2013 2014 B.6 Presence of expenditure types for all consumer units and low-income consumer units, 2013 2014 B.7 Mean monthly expenditure amounts among units with that expenditure type for all consumer units and low-income consumer units, 2013 2014 B-1 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table B.1. Mean monthly expenditure amounts for all consumer units and low-income consumer units, 2013 2014 All consumer units Low-income consumer units Mean monthly expenditure amounts Dollars (weighted) Dollars (weighted) Total expenditures 4,128 2,319 Food at home 425 347 Decision Demographics Final Report: Appendix B Food away from home Food away, excluding meals as pay Meals as pay Housing (excluding domestic services) 198 196 2 1,314 101 100 2 851 Shelter 852 537 Owned dwelling 505 197 Rented dwelling 289 326 Utilities 319 240 Domestic services including child care a 56 21 Child care 28 9 Apparel 76 44 Uniforms (for which cost is not reimbursed) 0 0 Health care 314 184 Health insurance 213 126 Medical services 66 35 Prescription drugs and medical supplies 36 23 Transportation 720 389 Sum of vehicle expenses 673 371 Public transportation 47 18 Local 8 7 Non-local 38 11 Other goods and services 1,025 381 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. Mean expenditure amounts include contributions from CUs that report zero expenditures of that type unless otherwise noted. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.2. Distribution of annual expenditure amounts and mean income for all consumer units and low-income consumer units, 2013 2014 All consumer units Low-income consumer units Consumer units with: Column percent (weighted) Mean annual income Column percent (weighted) Mean annual income Annual expenditures of: Any amount 100.0 $64,310 100.0 $18,680 $0 to $12,000 $12,001 to $24,000 $24,001 to $36,000 $36,000 to $48,000 $48,001 or more 5.9 19.6 21.4 16.2 36.9 $10,256 $21,550 $39,604 $58,454 $112,259 15.1 38.8 24.7 11.2 10.1 $8,853 $15,023 $22,842 $27,988 $26,641 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. The mean income amounts include contributions from CUs with zero income. Expenditure groupings are equivalent to $0 to $1,000 per month, $1,000 to $2,000 per month, and so forth. B-3 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.3a. Mean expenditure shares for all consumer units and low-income consumer units, 2013 2014 Low-income All consumer units consumer units Mean expenditure shares as a percentage of Column percent Column percent total annual expenditures (weighted) (weighted) Total expenditures 100.0 100.0 Food at home 10.3 15.0 Food away from home 4.8 4.4 Food away, excluding meals as pay 4.8 4.3 Meals as pay 0.1 0.1 Housing (excluding domestic services) 31.8 36.7 Shelter 20.6 23.2 Owned dwelling 12.2 8.5 Rented dwelling 7.0 14.1 Utilities 7.7 10.4 Domestic services including child care a 1.4 0.9 Child care 0.7 0.4 Apparel 1.8 1.9 Uniforms (for which cost is not reimbursed) 0.0 0.0 Health care 7.6 7.9 Health insurance 5.1 5.4 Medical services 1.6 1.5 Prescription drugs and medical supplies 0.9 1.0 Transportation 17.4 16.8 Sum of vehicle expenses 16.3 16.0 Public transportation 1.1 0.8 Local 0.2 0.3 Non-local 0.9 0.5 Other goods and services 24.8 16.4 Mean value of total expenditures $49,530 $27,828 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. The shares of each broad expenditure category (e.g., food at home, food away from home, housing, apparel, health care, transportation; and other goods and services) sum to 100 percent. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-4 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.3b. Mean expenditure shares for all consumer units and consumer units with expenditures at or below 200 percent of poverty guidelines Mean expenditure shares as a percentage of total annual expenditures All consumer units Column percent (weighted) Consumer units with expenditures at or below 200 percent of poverty guidelines Column percent (weighted) Total expenditures 100.0 100.0 Food at home 10.3 17.5 Food away from home Food away, excluding meals as pay Meals as pay 4.8 4.8 0.1 4.6 4.6 0.1 Housing (excluding domestic services) 31.8 38.0 Shelter 20.6 23.0 Owned dwelling 12.2 8.5 Rented dwelling 7.0 14.1 Utilities 7.7 12.4 Domestic services including child care a 1.4 0.7 Child care 0.7 0.4 Apparel 1.8 1.8 Uniforms (for which cost is not reimbursed) 0.0 0.0 Health care 7.6 7.2 Health insurance 5.1 5.5 Medical services 1.6 0.8 Prescription drugs and medical supplies 0.9 0.9 Transportation 17.4 12.3 Sum of vehicle expenses 16.3 11.7 Public transportation 1.1 0.5 Local 0.2 0.3 Non-local 0.9 0.2 Other goods and services 24.8 17.9 Mean value of total expenditures $49,530 $23,487 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. The shares of each broad expenditure category (e.g., food at home, food away from home, housing, apparel, health care, transportation; and other goods and services) sum to 100 percent. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-5 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.3c. Mean expenditure shares for all consumer units and units with both income at or below 200 percent of the poverty guidelines and expenditures below 200 percent of median expenditures, 2013 2014 Mean expenditure shares as a percentage of total annual expenditures All consumer units Column percent (weighted) Consumer units with both income at or below 200 percent of the poverty guidelines and expenditures below 200 percent of median expenditures Column percent (weighted) Total expenditures 100.0 100.0 Food at home 10.3 16.3 Food away from home Food away, excluding meals as pay Meals as pay 4.8 4.8 0.1 4.6 4.5 0.1 Housing (excluding domestic services) 31.8 39.2 Shelter 20.6 24.7 Owned dwelling 12.2 8.6 Rented dwelling 7.0 15.6 Utilities 7.7 11.3 Domestic services including child care a 1.4 0.8 Child care 0.7 0.4 Apparel 1.8 2.0 Uniforms (for which cost is not reimbursed) 0.0 0.0 Health care 7.6 8.1 Health insurance 5.1 5.8 Medical services 1.6 1.3 Prescription drugs and medical supplies 0.9 1.0 Transportation 17.4 13.2 Sum of vehicle expenses 16.3 12.5 Public transportation 1.1 0.7 Local 0.2 0.3 Non-local 0.9 0.4 Other goods and services 24.8 15.7 Mean value of total expenditures $49,530 $25,019 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. The shares of each broad expenditure category (e.g., food at home, food away from home, housing, apparel, health care, transportation; and other goods and services) sum to 100 percent. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-6 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.4. Mean expenditure shares as a percentage of total annual income for all consumer units and low-income consumer units, 2013 2014 Low-income All consumer units consumer units Mean expenditure shares as a percentage of Column percent Column percent total annual income (weighted) (weighted) Total expenditures 77.1 149.0 Food at home 7.9 22.3 Food away from home 3.7 6.5 Food away, excluding meals as pay 3.7 6.4 Meals as pay 0.0 0.1 Housing (excluding domestic services) 24.5 54.7 Shelter 15.9 34.6 Owned dwelling 9.4 12.7 Rented dwelling 5.4 20.9 Utilities 5.9 15.4 Domestic services including child care a 1.0 1.3 Child care 0.5 0.6 Apparel 1.4 2.9 Uniforms (for which cost is not reimbursed) 0.0 0.0 Health care 5.9 11.9 Health insurance 4.0 8.2 Medical services 1.2 2.3 Prescription drugs and medical supplies 0.7 1.5 Transportation 13.5 25.0 Sum of vehicle expenses 12.6 23.9 Public transportation 0.9 1.1 Local 0.2 0.4 Non-local 0.7 0.7 Other goods and services 19.1 24.4 Mean value of total expenditures $49,530 $27,828 Mean annual income $64,310 $18,680 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure and total income amounts (excluding SNAP benefits) are for all members of the consumer unit (CU) as reported in the CE. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. The shares of each broad expenditure category (e.g., food at home, food away from home, housing) do not necessarily sum to 100 percent because expenditures may fall short of or exceed total reported income. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.5a. Mean expenditure shares as a percentage of total annual income for all consumer units and low- income consumer units, by whether expenditures equals or exceeds 120 percent of income and whether income equals or exceeds 120 percent of expenditures,a 2013 2014 Percent of all consumer units regardless of income to expenditure ratio b Mean expenditure shares as a percentage of total annual income for consumer units Consumer units with annual expenditures that are greater than or equal to annual income All consumer units Low-income consumer units 30.3% 56.8% Column percent (weighted) Column percent (weighted) Consumer units with annual income that is greater than annual expenditures All consumer units Low-income consumer units 49.0% 19.0% Column percent (weighted) Column percent (weighted) All expenditures 237.1 269.0 52.9 66.0 Food at home 22.0 35.9 5.7 13.0 Food away from home Food away, excluding meals as pay Meals as pay Housing (excluding domestic services) 9.6 9.5 0.1 70.1 11.7 11.5 0.2 96.5 2.8 2.8 0.0 17.4 3.0 2.9 0.1 25.0 Shelter 45.6 62.6 11.2 14.2 Owned dwelling 23.7 24.0 7.4 5.0 Rented dwelling 18.7 36.4 3.1 9.0 Utilities 16.0 24.5 4.4 9.4 Domestic services including child care c 2.7 2.7 0.8 0.3 Child care 1.0 1.0 0.4 0.2 Apparel 4.0 5.1 1.0 1.2 Uniforms (for which cost is not reimbursed) 0.0 0.0 0.0 0.0 Health care 17.2 21.4 3.9 4.5 Health insurance 10.8 13.7 2.8 3.6 Medical services 4.2 4.7 0.7 0.5 Prescription drugs and medical supplies 2.2 2.9 0.4 0.5 Transportation 62.7 51.1 6.4 7.8 Sum of vehicle expenses 59.9 48.7 5.9 7.5 Public transportation 2.7 2.4 0.6 0.3 Local 0.4 0.8 0.1 0.2 Non-local 2.3 1.6 0.5 0.1 Other goods and services 48.8 44.6 14.9 11.2 Mean annual expenditures $52,101 $32,572 $48,450 $18,303 Mean annual income $25,443 $12,993 $91,390 $27,708 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Both income (excluding SNAP benefits) and expenditure shares are for all members of the consumer unit (CU), and the data may be subject to misreporting. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Both income and expenditure data may be subject to misreporting. b Percent of total consumer units within the column universes of all consumer units or low-income consumer units regardless of expenditure to income ratio. The two column sets do not sum to 100 percent because two types of consumer units are not include: those where expenditures are less than 120 percent of income and units where income is less than 120 percent of expenditures. c The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-8 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.5b. Mean expenditure shares as a percentage of total annual income for all consumer units and low-income consumer units, for units with savings or debt,a 2013 2014 Mean expenditure shares as a percentage of total annual income for consumer units Consumer units with positive savings or checking account balances All consumer units Low-income consumer units Column percent (weighted) Column percent (weighted) Consumer units with debt All consumer units Low-income consumer units Column percent (weighted) Column percent (weighted) All expenditures 78.0 160.2 78.3 155.0 Food at home 7.1 20.6 7.2 20.0 Food away from home Food away, excluding meals as pay Meals as pay 3.8 3.7 0.1 7.0 6.8 0.2 3.7 3.6 0.1 6.2 6.1 0.1 Housing (excluding domestic services) 24.2 57.5 24.4 54.0 Shelter 15.8 36.4 15.8 33.3 Owned dwelling 9.9 14.9 9.7 12.8 Rented dwelling 4.6 20.0 5.0 19.2 Utilities 5.5 14.9 5.7 14.4 Domestic services including child care b 1.1 1.6 1.0 1.3 Child care 0.5 0.6 0.6 0.8 Apparel 1.5 2.9 1.5 3.1 Uniforms (for which cost is not reimbursed) 0.0 0.0 0.0 0.0 Health care 5.9 14.0 5.7 11.7 Health insurance 3.9 9.2 3.8 7.7 Medical services 1.3 3.1 1.3 2.6 Prescription drugs and medical supplies 0.7 1.7 0.7 1.4 Transportation 13.4 27.9 14.4 30.9 Sum of vehicle expenses 12.4 26.5 13.5 29.8 Public transportation 1.0 1.4 0.9 1.1 Local 0.1 0.4 0.2 0.4 Non-local 0.8 1.0 0.7 0.7 Other goods and services 21.0 28.7 20.4 27.8 Mean annual expenditures $55,428 $30,698 $56,903 $32,984 Mean annual income $71,055 $19,179 $72,727 $21,262 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Both income (excluding SNAP benefits) and expenditure shares are for all members of the consumer unit, and the data may be subject to misreporting. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. Units with positive savings or checking account balances and those with debt are not mutually exclusive. a Units with savings are those with checking, savings, money market accounts, or certificates of deposit with a positive account balance. Debt includes that on all major credit cards including store cards and gas cards, as well as student, medical, personal, or other loans. Debt is not considered in the SNAP income or asset eligibility determination. b The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-9 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.6. Presence of expenditure types for all consumer units and low-income consumer units, 2013 2014 Percent of all Percent of low-income Consumer units with expenditures on: consumer units consumer units At least one type 100.0 100.0 Food at home 98.9 97.8 Food away from home 81.1 67.1 Food away, excluding meals as pay 80.8 66.6 Meals as pay 1.9 1.9 Housing (excluding domestic services) 99.7 99.2 Shelter 98.0 95.7 Owned dwelling 63.5 45.2 Rented dwelling 35.6 51.2 Utilities 97.5 94.6 Domestic services including child care a 29.4 19.4 Child care 6.0 3.4 Apparel 69.9 61.9 Uniforms (for which cost is not reimbursed) 1.4 0.9 Health care 79.0 65.3 Health insurance 66.7 50.2 Medical services 40.5 26.4 Prescription drugs and medical supplies 43.7 35.7 Transportation 94.6 88.0 Sum of vehicle expenses 90.9 80.8 Public transportation 19.7 15.9 Local 10.6 11.7 Non-local 11.2 5.1 Other goods and services 99.0 97.4 Total weighted number of consumer units (000s) 252,676 92,895 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Presence of expenditures types is reported for all members of the consumer unit, and the data may be subject to misreporting. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-10 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix B Table B.7. Mean monthly expenditure amounts among units with that expenditure type for all consumer units and low-income consumer units, 2013 2014 Mean monthly expenditure amounts ($) for that category of expenditure among those with that expenditure type All consumer units Dollars (weighted) Number (unweighted) Low-income consumer units Dollars (weighted) Number (unweighted) At least one type $4,128 12,943 $2,320 4,755 Food at home $430 12,802 $354 4,652 Food away from home Food away, excluding meals as pay Meals as pay $245 $243 $110 10,483 10,445 220 $151 $149 $100 3,169 3,146 78 Housing (excluding domestic services) Shelter Owned dwelling Rented dwelling Utilities $1,318 $870 $796 $812 $327 12,905 12,688 8,163 4,674 12,614 $858 $561 $436 $637 $254 4,721 4,558 2,124 2,460 4,496 Domestic services including child care a Child care $190 $465 3,902 773 $106 $258 953 162 Apparel Uniforms (for which cost is not reimbursed) $108 $10 9,084 182 $72 $9 2,962 40 Health care Health insurance Medical services Prescription drugs and medical supplies $398 $318 $163 $81 10,195 8,637 5,205 5,606 $282 $251 $133 $66 3,094 2,397 1,239 1,682 Transportation Sum of vehicle expenses Public transportation Local Non-local $761 $741 $236 $80 $340 12,228 11,701 2,658 1,470 1,476 $442 $460 $112 $59 $210 4,167 3,790 794 602 239 Other goods and services $1,036 12,813 $391 4,632 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure amounts are for all members of the consumer unit (CU) as reported in the CE. a The CE includes domestic services including child care as a component of total housing expenditures. Here we categorize these domestic services expenses separately. B-11 Page intentionally blank AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix C Appendix C: Chapter III Analysis Tables (Research Objective 2) No. Title C.1a Mean expenditure shares for low-income consumer units by demographic subgroup and broad expenditure type, 2013 2014 C.1b Mean expenditure shares for low-income consumer units by economic and geographic subgroup and broad expenditure type, 2013 2014 C.2a Mean expenditure shares for low-income consumer units by demographic subgroup and detailed food expenditure category, 2013 2014 C.2b Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed food expenditure category, 2013 2014 C.3a Mean expenditure shares for low-income consumer units by demographic subgroup and detailed housing expenditure category, 2013 2014 C.3b Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed housing expenditure category, 2013 2014 C.3c Mean expenditure shares for low-income consumer units by demographic subgroup and detailed utilities expenditure category, 2013 2014 C.3d Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed utilities expenditure category, 2013 2014 C.4a Mean expenditure shares for low-income consumer units by demographic subgroup and detailed health care expenditure category, 2013 2014 C.4b Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed health care expenditure category, 2013 2014 C.5a Mean expenditure shares for low-income consumer units by demographic subgroup and other detailed expenditure categories of interest, 2013 2014 C.5b Mean expenditure shares for low-income consumer units by economic and geographic subgroup and other detailed expenditure categories of interest, 2013 2014 C-1 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.1a. Mean expenditure shares for low-income consumer units by demographic subgroup and broad expenditure type, 2013 2014 Mean expenditure share for broad categories (weighted) Number (unweighted) Food Housing, excluding domestic services Apparel Health care Trans- portation Other goods and services All low-income consumer units Low-Income Consumer units with: Household size 4,756 19.3 36.7 1.9 7.9 16.8 17.3 1 person 1,985 17.8 39.8 1.6 9.3 13.1 18.6 2 people 1,094 18.4 34.6 1.4 10.7 17.5 17.4 3 people 581 20.0 37.3 2.3 6.3 18.6 15.7 4 people 518 21.0 36.1 2.4 5.4 18.5 16.6 5 or more people 578 21.5 34.7 2.6 5.0 19.3 16.9 Children a 1,597 20.8 36.2 2.6 4.9 19.1 16.3 And one adult 431 21.8 39.8 3.1 3.1 18.2 14.1 Only preschool age children (age 0 to 4) 60 21.5 38.9 3.6 2.9 15.9 17.2 Only school age children (age 5 to 17) 279 20.7 40.1 2.7 3.4 19.3 13.8 Both preschool and school age children 92 25.4 39.1 4.1 2.5 15.7 13.3 And multiple adults 1,164 20.6 35.2 2.5 5.4 19.3 17.0 Only preschool age children (age 0 to 4) 229 20.4 34.9 3.2 4.2 19.7 17.5 Only school age children (age 5 to 17) 584 20.6 36.2 2.1 5.9 19.2 16.0 Both preschool and school age children 351 20.6 33.9 2.8 5.2 19.3 18.2 No children 3,159 18.2 37.1 1.4 10.1 15.1 18.0 Nonelderly adults 3,275 20.0 36.7 2.2 5.5 18.0 17.8 Only nonelderly adults Nonelderly adults and others 1,362 1,913 18.8 20.5 38.5 35.8 1.6 2.4 4.6 5.9 15.8 19.0 20.7 16.3 No nonelderly adults 1,482 17.6 36.8 1.2 14.9 13.5 16.0 Elderly individuals 1,977 18.4 36.1 1.3 13.4 14.9 15.9 Only elderly individuals Elderly and nonelderly individuals 1,457 520 17.5 20.3 36.7 34.8 1.2 1.6 15.0 10.0 13.5 17.6 16.0 15.7 No elderly individuals 2,779 19.9 37.1 2.3 4.5 18.0 18.2 See notes at end of table. C-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.1a. continued Mean expenditure share for broad categories (weighted) Housing, Other excluding goods Number domestic Health Trans- and (unweighted) Food services Apparel care portation services Presence of disabled individuals b Nonelderly disabled individuals 615 20.7 38.6 1.7 7.8 16.7 14.5 And elderly individuals 128 19.8 35.8 1.1 11.2 17.5 14.7 And no elderly individuals 486 21.1 39.7 1.9 6.6 16.4 14.4 Only elderly individuals or nonelderly disabled individuals 2,072 18.5 37.3 1.4 12.8 14.5 15.5 No nonelderly disabled individuals 4,142 19.1 36.5 1.9 8.0 16.8 17.7 And elderly individuals 1,849 18.3 36.1 1.4 13.6 14.6 16.0 And no elderly individuals 2,293 19.7 36.7 2.3 4.2 18.3 18.8 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-3 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.1b. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and broad expenditure type, 2013 2014 Mean expenditure share for broad categories (weighted) Number (unweighted) Food Housing, excluding domestic services Apparel Health care Trans- portation Other goods and services All low-income consumer units Low-income Consumer units with: Income as a percentage of poverty guidelines 4,756 19.3 36.7 1.9 7.9 16.8 17.3 0 to under 50 percent 915 21.1 39.6 2.3 5.5 15.6 15.8 50 to under 100 percent 1,101 21.1 38.7 2.1 6.4 14.9 16.8 100 to 130 percent 802 18.9 36.7 1.8 8.4 16.9 17.2 More than 130 percent to 200 percent 1,938 18.2 35.0 1.7 9.2 17.9 18.1 Receipt of income or federal assistance types Earnings 2,656 19.7 36.0 2.2 5.5 18.7 17.9 TANF income 151 24.6 40.5 3.2 3.3 13.1 15.3 Social Security income 1,838 18.4 36.3 1.3 13.5 15.3 15.2 SSI 507 22.4 41.7 2.1 6.3 13.4 14.1 SNAP benefits 1,025 22.1 39.3 2.6 4.7 16.2 15.1 Income from other sources a 351 18.5 36.9 2.3 5.0 19.5 17.7 Medicare 1,723 18.6 36.2 1.4 14.1 14.2 15.5 Medicaid 1,392 22.0 39.4 2.4 4.0 16.8 15.2 Employment status of unit head b Employed 2,127 19.5 36.2 2.2 5.0 18.7 18.3 Unemployed 114 23.1 45.5 1.8 5.0 13.5 11.2 Not in labor force 976 20.3 37.2 2.1 6.0 16.6 17.8 Geography Northeast 747 18.0 39.8 2.2 7.5 14.4 18.1 Midwest 990 18.3 35.4 1.8 9.1 16.3 19.1 South 1,920 21.0 35.5 1.8 7.9 17.9 15.9 West 1,071 18.4 37.8 2.0 7.3 16.9 17.6 Urban 4,406 19.2 37.4 1.9 7.7 16.5 17.2 Rural 350 20.2 30.4 1.7 10.1 19.3 18.3 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Other sources include VA payments, Unemployment Compensation, child support, or alimony. b Children and elderly adults are excluded from those not in the labor force. C-4 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.2a. Mean expenditure shares for low-income consumer units by demographic subgroup and detailed food expenditure category, 2013 2014 Mean expenditure share for food categories (weighted) Food away from home Number (unweighted) Total Food at home Total Excluding meals as pay Meals as pay All low-income consumer units 4,756 19.3 15.0 4.4 4.3 0.1 Low-income Consumer units with: Household size 1 person 1,985 17.8 13.0 4.7 4.6 0.1 2 people 1,094 18.4 13.9 4.5 4.5 0.1 3 people 581 20.0 15.9 4.1 4.0 0.1 4 people 518 21.0 16.7 4.3 4.2 0.1 5 or more people 578 21.5 17.7 3.8 3.8 0.0 Children a 1,597 20.8 16.8 4.0 4.0 0.1 And one adult 431 21.8 17.7 4.1 4.0 0.1 Only preschool age children (age 0 to 4) 60 21.5 17.5 4.1 4.0 0.1 Only school age children (age 5 to 17) 279 20.7 16.5 4.1 4.1 0.1 Both preschool and school age children 92 25.4 21.6 3.8 3.7 0.0 And multiple adults 1,164 20.6 16.6 4.0 4.0 0.1 Only preschool age children (age 0 to 4) 229 20.4 16.2 4.2 4.1 0.1 Only school age children (age 5 to 17) 584 20.6 16.6 4.1 4.0 0.1 Both preschool and school age children 351 20.6 16.8 3.8 3.8 0.1 No children 3,159 18.2 13.6 4.6 4.5 0.1 Nonelderly adults 3,275 20.0 15.6 4.4 4.3 0.1 Only nonelderly adults 1,362 18.8 13.6 5.2 5.0 0.2 Nonelderly adults and others 1,913 20.5 16.5 4.0 4.0 0.1 No nonelderly adults 1,482 17.6 13.3 4.3 4.3 0.0 Elderly individuals 1,977 18.4 14.2 4.2 4.2 0.0 Only elderly individuals 1,457 17.5 13.2 4.3 4.3 0.0 Elderly and nonelderly individuals 520 20.3 16.3 4.0 3.9 0.1 No elderly individuals 2,779 19.9 15.4 4.5 4.4 0.1 See notes at end of table. C-5 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.2a. continued Number (unweighted) Decision Demographics Final Report: Appendix C Mean expenditure share for food categories (weighted) Food away from home Total Food at home Total Excluding meals as pay Meals as pay Presence of disabled individuals b Nonelderly disabled individuals 615 20.7 17.6 3.1 3.1 0.0 And elderly individuals 128 19.8 17.1 2.7 2.7 0.0 And no elderly individuals 486 21.1 17.8 3.3 3.3 0.0 Only elderly individuals or nonelderly disabled individuals 2,072 18.5 14.6 3.9 3.9 0.0 No nonelderly disabled individuals 4,142 19.1 14.6 4.5 4.4 0.1 And elderly individuals 1,849 18.3 14.0 4.3 4.3 0.0 And no elderly individuals 2,293 19.7 15.0 4.7 4.6 0.1 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-6 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.2b. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed food expenditure category, 2013 2014 Mean expenditure share for food categories (weighted) Food away from home Number (unweighted) Total Food at home Total Excluding meals as pay Meals as pay All low-income consumer units 4,756 19.3 15.0 4.4 4.3 0.1 Low-income Consumer units with: Income as a percentage of poverty guidelines 0 to under 50 percent 915 21.1 17.0 4.2 4.1 0.1 50 to under 100 percent 1,101 21.1 16.7 4.3 4.3 0.1 100 to 130 percent 802 18.9 14.7 4.3 4.2 0.1 More than 130 percent to 200 percent 1,938 18.2 13.7 4.5 4.4 0.1 Receipt of income or federal assistance types Earnings 2,656 19.7 15.1 4.5 4.4 0.1 TANF income 151 24.6 20.9 3.7 3.7 0.0 Social Security income 1,838 18.4 14.2 4.1 4.1 0.0 SSI 507 22.4 19.0 3.4 3.4 0.1 SNAP benefits 1,025 22.1 18.9 3.2 3.1 0.1 Income from other sources a 351 18.5 14.6 4.0 3.9 0.1 Medicare 1,723 18.6 14.5 4.1 4.0 0.0 Medicaid 1,392 22.0 18.4 3.6 3.5 0.1 Employment status of unit head b Employed 2,127 19.5 14.8 4.8 4.6 0.1 Unemployed 114 23.1 19.9 3.2 3.2 0.0 Not in labor force 976 20.3 16.3 3.9 3.9 0.0 Geography Northeast 747 18.0 13.9 4.1 4.1 0.1 Midwest 990 18.3 14.0 4.2 4.1 0.1 South 1,920 21.0 16.5 4.5 4.4 0.1 West 1,071 18.4 13.9 4.5 4.4 0.1 Urban 4,406 19.2 14.8 4.4 4.3 0.1 Rural 350 20.2 16.2 4.1 3.9 0.1 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Other sources include VA payments, Unemployment Compensation, child support, or alimony. b Children and elderly adults are excluded from those not in the labor force. C-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.3a. Mean expenditure shares for low-income consumer units by demographic subgroup and detailed housing expenditure category, 2013 2014 All low-income consumer units Low-income Consumer units with: Household size Mean expenditure share for housing categories (weighted) Shelter Number (unweighted) Utilities Total Owned dwelling Rented dwelling 4,756 10.4 23.2 8.5 14.1 1 person 1,985 9.8 27.1 8.9 17.5 2 people 1,094 10.3 21.0 9.7 10.3 3 people 581 10.9 22.9 7.2 15.2 4 people 518 10.5 22.5 7.7 14.3 5 or more people 578 10.9 20.5 7.6 12.7 Children a 1,597 10.5 22.4 7.1 15.0 And one adult 431 10.7 25.9 6.1 19.5 Only preschool age children (age 0 to 4) 60 10.0 26.3 2.9 23.3 Only school age children (age 5 to 17) 279 10.7 26.2 7.0 18.9 Both preschool and school age children 92 10.8 24.6 4.9 19.5 And multiple adults 1,164 10.5 21.5 7.3 13.8 Only preschool age children (age 0 to 4) 229 9.6 22.1 4.7 17.0 Only school age children (age 5 to 17) 584 11.1 22.0 8.4 13.2 Both preschool and school age children 351 10.0 20.4 7.1 13.0 No children 3,159 10.2 23.7 9.5 13.4 Nonelderly adults 3,275 10.1 23.4 7.0 15.9 Only nonelderly adults 1,362 8.9 26.5 5.5 20.3 Nonelderly adults and others 1,913 10.7 21.8 7.7 13.7 No nonelderly adults 1,482 11.0 22.6 12.7 8.9 Elderly individuals 1,977 11.4 21.5 12.0 8.7 Only elderly individuals 1,457 11.0 22.6 12.7 8.9 Elderly and nonelderly individuals 520 12.1 19.4 10.4 8.2 No elderly individuals 2,779 9.7 24.2 6.3 17.4 See notes at end of table. C-8 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.3a. continued Number (unweighted) Decision Demographics Final Report: Appendix C Mean expenditure share for housing categories (weighted) Shelter Utilities Total Owned dwelling Rented dwelling Presence of disabled individuals b Nonelderly disabled individuals 615 12.4 22.7 7.4 14.9 And elderly individuals 128 12.5 19.6 10.8 8.3 And no elderly individuals 486 12.4 23.7 6.3 17.2 Only elderly individuals or nonelderly disabled individuals 2,072 11.4 22.6 11.1 10.8 No nonelderly disabled individuals 4,142 10.1 23.2 8.6 13.9 And elderly individuals 1,849 11.3 21.7 12.1 8.7 And no elderly individuals 2,293 9.3 24.3 6.3 17.5 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-9 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.3b. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed housing expenditure category, 2013 2014 All low-income consumer units Low-income Consumer units with: Income as a percentage of poverty guidelines Mean expenditure share for housing categories (weighted) Shelter Number (unweighted) Utilities Total Owned dwelling Rented dwelling 4,756 10.4 23.2 8.5 14.1 0 to under 50 percent 915 10.4 25.8 7.8 17.4 50 to under 100 percent 1,101 10.8 24.8 6.8 17.5 100 to 130 percent 802 10.5 23.0 8.4 13.9 More than 130 percent to 200 percent 1,938 10.1 21.7 9.5 11.6 Receipt of income or federal assistance types Earnings 2,656 10.0 22.9 7.1 15.3 TANF income 151 10.9 26.4 4.7 21.6 Social Security income 1,838 11.6 21.4 11.5 9.0 SSI 507 12.7 25.7 5.6 19.7 SNAP benefits 1,025 11.6 24.4 4.4 19.8 Income from other sources a 351 10.3 23.0 7.6 14.8 Medicare 1,723 11.5 21.5 11.1 9.6 Medicaid 1,392 11.8 24.4 5.6 18.6 Employment status of unit head b Employed 2,127 9.7 23.3 6.8 16.0 Unemployed 114 12.9 29.4 9.0 20.2 Not in labor force 976 10.4 23.6 7.1 16.1 Geography Northeast 747 9.7 26.9 9.3 16.8 Midwest 990 9.9 22.1 8.6 12.9 South 1,920 12.0 20.3 8.1 11.8 West 1,071 8.4 26.1 8.3 17.0 Urban 4,406 10.2 24.1 8.6 14.9 Rural 350 11.9 14.9 7.4 6.8 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Other sources include VA payments, Unemployment Compensation, child support, or alimony. b Children and elderly adults are excluded from those not in the labor force. C-10 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.3c. Mean expenditure shares for low-income consumer units by demographic subgroup and detailed utilities expenditure category, 2013 2014 Number (unweighted) Total Mean expenditure share for utilities categories (weighted) Natural gas Electricity Fuel oil and other fuels Telephone services Water and other public services All low-income consumer units 4,756 10.4 1.0 4.4 0.3 3.2 1.3 Low-income Consumer units with: Household size 1 person 1,985 9.8 1.0 4.2 0.5 2.8 1.3 2 people 1,094 10.3 1.0 4.4 0.5 3.1 1.4 3 people 581 10.9 1.0 4.8 0.2 3.5 1.4 4 people 518 10.5 0.9 4.5 0.2 3.6 1.3 5 or more people 578 10.9 1.1 4.6 0.2 3.5 1.5 Children a 1,597 10.5 1.0 4.5 0.2 3.5 1.3 And one adult 431 10.7 1.0 4.9 0.1 3.4 1.3 Only preschool age children (age 0 to 4) 60 10.0 0.9 4.7 0.0 3.3 1.0 Only school age children (age 5 to 17) 279 10.7 0.9 4.8 0.1 3.6 1.3 Both preschool and school age children 92 10.8 1.2 5.3 0.0 3.1 1.3 And multiple adults 1,164 10.5 1.0 4.4 0.2 3.5 1.4 Only preschool age children (age 0 to 4) 229 9.6 0.8 4.1 0.1 3.4 1.1 Only school age children (age 5 to 17) 584 11.1 1.1 4.6 0.2 3.8 1.5 Both preschool and school age children 351 10.0 1.1 4.3 0.2 3.1 1.3 No children 3,159 10.2 1.0 4.4 0.5 3.0 1.4 See notes at end of table. C-11 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.3c. continued Number (unweighted) Total Decision Demographics Final Report: Appendix C Mean expenditure share for utilities categories (weighted) Natural gas Electricity Fuel oil and other fuels Telephone services Water and other public services Nonelderly adults 3,275 10.1 1.0 4.4 0.2 3.3 1.3 Only nonelderly adults Nonelderly adults and others 1,362 1,913 8.9 10.7 0.8 1.0 3.9 4.6 0.2 0.2 2.9 3.5 1.0 1.4 No nonelderly adults 1,482 11.0 1.2 4.6 0.7 2.9 1.6 Elderly individuals 1,977 11.4 1.2 4.8 0.6 3.1 1.6 Only elderly individuals Elderly and nonelderly individuals 1,457 520 11.0 12.1 1.2 1.2 4.6 5.2 0.7 0.4 2.9 3.6 1.6 1.7 No elderly individuals 2,779 9.7 0.9 4.2 0.2 3.3 1.2 Presence of disabled individuals b Nonelderly disabled individuals 615 12.4 1.2 5.7 0.3 3.6 1.6 And elderly individuals 128 12.5 1.1 5.5 0.5 3.5 1.9 And no elderly individuals 486 12.4 1.2 5.8 0.2 3.7 1.5 Only elderly individuals or nonelderly disabled individuals 2,072 11.4 1.2 5.0 0.5 3.1 1.6 No nonelderly disabled individuals 4,142 10.1 1.0 4.3 0.3 3.2 1.3 And elderly individuals 1,849 11.3 1.2 4.8 0.6 3.1 1.6 And no elderly individuals 2,293 9.3 0.9 3.9 0.2 3.2 1.1 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-12 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.3d. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed utilities expenditure category, 2013 2014 Number (unweighted) Total Mean expenditure share for utilities categories (weighted) Natural gas Electricity Fuel oil and other fuels Telephone services Water and other public services All low-income consumer units 4,756 10.4 1.0 4.4 0.3 3.2 1.3 Low-income Consumer units with: Income as a percentage of poverty guidelines 0 to under 50 percent 915 10.4 1.0 4.8 0.2 3.1 1.3 50 to under 100 percent 1,101 10.8 1.0 4.7 0.3 3.3 1.4 100 to 130 percent 802 10.5 1.0 4.6 0.3 3.2 1.4 More than 130 percent to 200 percent 1,938 10.1 1.0 4.2 0.4 3.2 1.3 Receipt of income or federal assistance types Earnings 2,656 10.0 0.9 4.2 0.2 3.4 1.2 TANF income 151 10.9 1.4 4.8 0.2 3.4 1.1 Social Security income 1,838 11.6 1.2 5.0 0.6 3.2 1.6 SSI 507 12.7 1.3 5.7 0.2 3.9 1.6 SNAP benefits 1,025 11.6 1.2 5.3 0.2 3.5 1.4 Income from other sources a 351 10.3 1.0 4.2 0.3 3.3 1.4 Medicare 1,723 11.5 1.2 5.0 0.6 3.1 1.6 Medicaid 1,392 11.8 1.1 5.4 0.2 3.6 1.5 Employment status of unit head b Employed 2,127 9.7 0.9 4.1 0.2 3.3 1.2 Unemployed 114 12.9 1.3 6.2 0.2 3.6 1.6 Not in labor force 976 10.4 1.0 4.8 0.2 3.2 1.3 See notes at end of table. C-13 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.3d. continued Number (unweighted) Total Decision Demographics Final Report: Appendix C Mean expenditure share for utilities categories (weighted) Natural gas Electricity Fuel oil and other fuels Telephone services Water and other public services Geography Northeast 747 9.7 1.4 3.4 1.0 3.0 0.9 Midwest 990 9.9 1.7 3.9 0.2 3.0 1.1 South 1,920 12.0 0.6 6.0 0.2 3.6 1.6 West 1,071 8.4 0.8 3.1 0.1 3.0 1.4 Urban 4,406 10.2 1.1 4.3 0.3 3.2 1.3 Rural 350 11.9 0.7 5.7 1.0 3.1 1.3 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Other sources include VA payments, Unemployment Compensation, child support, or alimony. b Children and elderly adults are excluded from those not in the labor force. C-14 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.4a. Mean expenditure shares for low-income consumer units by demographic subgroup and detailed health care expenditure category, 2013 2014 All low-income consumer units Low-income Consumer units with: Household size Mean expenditure share for health care categories (weighted) Number (unweighted) Total Health insurance Medical services Prescription drugs and medical supplies 4,756 7.9 5.4 1.5 1.0 1 person 1,985 9.3 6.0 1.9 1.3 2 people 1,094 10.7 7.6 1.6 1.5 3 people 581 6.3 4.5 1.0 0.7 4 people 518 5.4 3.7 1.1 0.5 5 or more people 578 5.0 3.3 1.3 0.5 Children a 1,597 4.9 3.3 1.1 And one adult 431 3.1 2.1 0.6 0.4 Only preschool age children (age 0 to 4) 60 2.9 2.0 0.6 0.3 Only school age children (age 5 to 17) 279 3.4 2.2 0.7 0.5 Both preschool and school age children 92 2.5 1.9 0.4 0.2 And multiple adults 1,164 5.4 3.6 1.3 0.5 Only preschool age children (age 0 to 4) 229 4.2 2.7 1.0 0.4 Only school age children (age 5 to 17) 584 5.9 4.1 1.2 0.6 Both preschool and school age children 351 5.2 3.2 1.6 0.4 No children 3,159 10.1 7.0 1.8 1.4 Nonelderly adults 3,275 5.5 3.6 1.2 0.7 Only nonelderly adults 1,362 4.6 3.0 1.0 0.6 Nonelderly adults and others 1,913 5.9 4.0 1.2 0.7 No nonelderly adults 1,482 14.9 10.4 2.5 2.0 Elderly individuals 1,977 13.4 9.4 2.2 1.8 Only elderly individuals 1,457 15.0 10.5 2.5 2.0 Elderly and nonelderly individuals 520 10.0 7.1 1.6 1.4 No elderly individuals 2,779 4.5 3.0 1.1 0.5 See notes at end of table. C-15 0.5 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.4a. continued Number (unweighted) Decision Demographics Final Report: Appendix C Mean expenditure share for health care categories (weighted) Total Health insurance Medical services Prescription drugs and medical supplies Presence of disabled individuals b Nonelderly disabled individuals 615 7.8 5.1 1.4 1.3 And elderly individuals 128 11.2 7.8 1.8 1.6 And no elderly individuals 486 6.6 4.2 1.2 1.2 Only elderly individuals or nonelderly disabled individuals 2,072 12.8 8.8 2.2 1.8 No nonelderly disabled individuals 4,142 8.0 5.5 1.5 1.0 And elderly individuals 1,849 13.6 9.5 2.2 1.8 And no elderly individuals 2,293 4.2 2.8 1.0 0.4 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-16 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.4b. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and detailed health care expenditure category, 2013 2014 All low-income consumer units Low-income Consumer units with: Income as a percentage of poverty guidelines Mean expenditure share for health care categories (weighted) Number (unweighted) Total Health insurance Medical services Prescription drugs and medical supplies 4,756 7.9 5.4 1.5 1.0 0 to under 50 percent 915 5.5 3.7 1.1 0.7 50 to under 100 percent 1,101 6.4 4.5 1.1 0.9 100 to 130 percent 802 8.4 5.5 1.9 1.0 More than 130 percent to 200 percent 1,938 9.2 6.4 1.7 1.2 Receipt of income or federal assistance types Earnings 2,656 5.5 3.7 1.2 0.6 TANF income 151 3.3 2.3 0.5 0.4 Social Security income 1,838 13.5 9.7 2.0 1.9 SSI 507 6.3 4.4 0.9 1.1 SNAP benefits 1,025 4.7 3.1 0.9 0.7 Income from other sources a 351 5.0 3.2 1.1 0.8 Medicare 1,723 14.1 10.3 1.9 1.9 Medicaid 1,392 4.0 2.6 0.8 0.6 Employment status of unit head b Employed 2,127 5.0 3.3 1.2 0.6 Unemployed 114 5.0 3.5 0.9 0.6 Not in labor force 976 6.0 3.9 1.2 0.8 Geography Northeast 747 7.5 5.3 1.3 0.9 Midwest 990 9.1 6.1 1.9 1.1 South 1,920 7.9 5.6 1.2 1.1 West 1,071 7.3 4.7 1.9 0.8 Urban 4,406 7.7 5.3 1.5 1.0 Rural 350 10.1 6.9 1.8 1.4 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. a Other sources include VA payments, Unemployment Compensation, child support, or alimony. b Children and elderly adults are excluded from those not in the labor force. C-17 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.5a. Mean expenditure shares for low-income consumer units by demographic subgroup and other detailed expenditure categories of interest, 2013 2014 Number (unweighted) Mean expenditure share for other categories of interest (weighted) Uniforms Child care Vehicle expenses (excluding gasoline and motor oil) Gasoline and motor oil Public transportation Payroll taxes All low-income consumer units Low-income Consumer units with: Household size 4,756 0.0 0.4 10.0 6.0 0.8 3.1 1 person 1,985 0.0 0.0 7.7 4.6 0.8 1.4 2 people 1,094 0.0 0.2 10.7 5.9 0.9 2.0 3 people 581 0.0 0.7 11.3 6.6 0.7 4.0 4 people 518 0.0 0.9 10.8 7.0 0.7 4.7 5 or more people 578 0.0 0.6 11.6 7.0 0.6 5.7 Children a 1,597 0.0 0.9 11.6 6.8 0.6 4.9 And one adult 431 0.0 1.4 11.5 6.0 0.6 3.5 Only preschool age children (age 0 to 4) 60 0.0 4.9 9.5 5.8 0.6 3.7 Only school age children (age 5 to 17) 279 0.0 0.6 12.7 6.0 0.6 3.5 Both preschool and school age children 92 0.0 2.1 8.9 6.1 0.7 3.1 And multiple adults 1,164 0.0 0.7 11.7 7.0 0.6 5.3 Only preschool age children (age 0 to 4) 229 0.0 1.6 11.8 7.3 0.6 5.4 Only school age children (age 5 to 17) 584 0.0 0.2 11.5 7.0 0.7 5.0 Both preschool and school age children 351 0.0 1.1 11.9 6.9 0.5 5.8 No children 3,159 0.0 0.0 8.9 5.4 0.9 1.8 Nonelderly adults 3,275 0.0 0.5 10.8 6.5 0.7 4.0 Only nonelderly adults 1,362 0.0 0.0 9.0 5.9 0.9 3.1 Nonelderly adults and others 1,913 0.0 0.7 11.6 6.7 0.7 4.5 See notes at end of table. C-18 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix C Table C.5a. continued Number (unweighted) Uniforms Mean expenditure share for other categories of interest (weighted) Child care Vehicle expenses (excluding gasoline and motor oil) Gasoline and motor oil Public transportation Payroll taxes No nonelderly adults 1,482 0.0 0.0 8.0 4.6 0.9 0.5 Elderly individuals 1,977 0.0 0.1 8.8 5.2 0.8 1.2 Only elderly individuals 1,457 0.0 0.0 8.1 4.6 0.9 0.4 Elderly and nonelderly individuals 520 0.0 0.1 10.3 6.5 0.8 2.8 No elderly individuals 2,779 0.0 0.6 10.8 6.5 0.7 4.3 Presence of disabled individuals b Nonelderly disabled individuals 615 0.0 0.1 10.0 6.2 0.5 1.9 And elderly individuals 128 0.0 0.1 10.6 6.5 0.4 1.6 And no elderly individuals 486 0.0 0.1 9.8 6.1 0.5 2.0 Only elderly individuals or nonelderly disabled individuals 2,072 0.0 0.1 8.7 5.1 0.8 0.9 No nonelderly disabled individuals 4,142 0.0 0.4 10.0 5.9 0.8 3.3 And elderly individuals 1,849 0.0 0.1 8.6 5.1 0.9 1.2 And no elderly individuals 2,293 0.0 0.7 11.0 6.5 0.7 4.7 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. Payroll taxes are estimated as 7.65 percent of earnings. a Subgroups (children living with one adult and children living with multiple adults) do not add up to the total number of CUs with children because a small number of CUs are comprised only of children under age 18. b We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. C-19 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix C Table C.5b. Mean expenditure shares for low-income consumer units by economic and geographic subgroup and other detailed expenditure categories of interest, 2013 2014 Mean expenditure share for other categories of interest (weighted) Number (unweighted) Uniforms Child care Vehicle expenses (excluding gasoline and motor oil) Gasoline and motor oil Public transportation Payroll taxes All low-income consumer units Low-income Consumer units with: Income as a percentage of poverty guidelines 4,756 0.0 0.4 10.0 6.0 0.8 3.1 0 to under 50 percent 915 0.0 0.4 9.1 5.6 0.9 0.6 50 to under 100 percent 1,101 0.0 0.3 8.1 6.0 0.8 2.4 100 to 130 percent 802 0.0 0.4 10.1 6.0 0.8 3.1 More than 130 percent to 200 percent 1,938 0.0 0.4 11.1 6.1 0.7 4.2 Receipt of income or federal assistance types Earnings 2,656 0.0 0.5 11.2 6.8 0.7 4.9 TANF income 151 0.0 0.6 7.0 4.9 1.2 1.9 Social Security income 1,838 0.0 0.1 9.3 5.2 0.8 0.7 SSI 507 0.0 0.1 7.2 5.3 0.9 1.5 SNAP benefits 1,025 0.0 0.6 9.3 6.1 0.8 3.2 Income from other sources a 351 0.0 0.6 12.6 6.3 0.6 2.6 Medicare 1,723 0.0 0.1 8.4 5.1 0.7 1.0 Medicaid 1,392 0.0 0.7 9.7 6.5 0.7 3.8 Employment status of unit head b Employed 2,127 0.0 0.6 11.3 6.7 0.7 5.0 Unemployed 114 0.0 0.2 6.6 6.1 0.8 1.9 Not in labor force 976 0.0 0.2 9.9 5.9 0.7 2.5 See notes at end of table. C-20 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table C.5b. continued Number (unweighted) Uniforms Decision Demographics Final Report: Appendix C Mean expenditure share for other categories of interest (weighted) Child care Vehicle expenses (excluding gasoline and motor oil) Gasoline and motor oil Public transportation Payroll taxes Geography Northeast 747 0.0 0.4 8.5 4.3 1.6 2.4 Midwest 990 0.0 0.4 9.9 5.7 0.7 3.2 South 1,920 0.0 0.4 10.5 7.0 0.4 3.3 West 1,071 0.0 0.4 10.3 5.8 0.8 3.3 Urban 4,406 0.0 0.4 9.9 5.8 0.8 3.1 Rural 350 0.0 0.2 11.6 7.4 0.4 3.0 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Expenditure shares are for all consumer unit (CU) members and are defined as annual expenditures of a certain type divided by total annual expenditures. Mean expenditure shares include contributions from CUs that report zero expenditures of that type unless otherwise noted. Payroll taxes are estimated as 7.65 percent of earnings. a Other sources include VA payments, Unemployment Compensation, child support, or alimony b Children and elderly adults are excluded from those not in the labor force. C-21 Page intentionally blank AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix D Appendix D: Chapter IV Analysis Tables (Research Objective 3) No. Title D.1 Prevalence and dollar amounts of gasoline and motor oil, parking and tolls, and uniform expenditures by level of earned income for low-income consumer units, 2013 2014 D.2 Prevalence and amount of out-of-pocket medical expenditures for low-income consumer units with and without elderly or disabled individuals, 2013 2014 Average monthly deductible out-of-pocket medical expenditures relative to standard medical D.3 deduction demonstration amounts among consumer units with out-of-pocket medical expenditures, 2013 2014 Shelter expense amounts for SNAP households relative to the shelter cap for SNAP households D.4 without elderly or disabled individuals, and percentage of households with benefits constrained by the shelter cap, 2013 2014 Shelter expenditures as a share of gross income and adjusted net income in the Consumer D.5 Expenditure Survey (CE) using ratios of gross income to adjusted net income in the 2015 Baseline of the 2011 MATH SIPP+ model, 2013 2014 Mean utility amounts in the SNAP QC data file by type of standard utility allowance (SUA) D.6 receipt, compared with utility expenditures for low-income consumer units in the Consumer Expenditure Survey (CE) by geographic region, 2013 2014 D.7 Prevalence and dollar amounts of expenditure types associated with deductions prior to the 1977 Farm Bill by consumer unit size for low-income consumer units, 2013 2014 D-1 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.1. Prevalence and dollar amounts of gasoline and motor oil, parking and tolls, and uniform expenditures by level of earned income for low-income consumer units, 2013 2014 Annual earned income Positive earned income $0 Any amount More than $0 to $15,000 More than $15,000 to $30,000 More than $30,000 All low-income consumer units by level of earnings Row percentage Mean earnings amount 43.0 $0 57.0 $19,839 24.4 $7,118 20.3 $22,093 12.3 $41,293 Percentage of low-income consumer units with expenditures on Gasoline and motor oil 70.3 86.4 80.8 89.0 93.2 Parking and tolls Uniforms a Estimated payroll taxes b 5.6 0.2 0.0 11.9 1.4 100.0 12.2 1.1 100.0 11.3 1.3 100.0 12.1 2.0 100.0 Mean annualized expenditures on Gasoline and motor oil Among all units Among units with expenditures on gasoline and motor oil Parking and tolls Among all units Among units with expenditures on parking and tolls Uniforms a $1,097 $1,561 $40 $715 $2,089 $2,418 $81 $683 $1,650 $2,042 $84 $689 $2,050 $2,305 $70 $619 $3,023 $3,242 $93 $771 Among all units Among units with expenditures on uniforms Estimated payroll taxes Among all units Among units with payroll taxes b $0 $116 n.a. n.a. $1 $102 $1,518 $1,518 $1 $105 $545 $545 $1 $90 $1,690 $1,690 $2 $111 $3,159 $3,159 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. A consumer unit with one individual working full-time at the 2014 federal minimum wage of $7.25 would earn approximately $15,000 annually. Units with negative earnings from self-employment are categorized as having $0 of earnings in this table. For the Among all units rows, mean expenditure amounts include contributions from CUs that report zero expenditures of that type. n.a.: Consumer units without earning do not incur payroll taxes. a For this table, uniform expenses are restricted to those purchased for individuals age 16 and over. b Payroll taxes are estimated as 7.65 percent of earnings, or the sum of 6.20 percent for Social Security and 1.45 percent for Medicare. D-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.2. Prevalence and amount of out-of-pocket medical expenditures for low-income consumer units with and without elderly or disabled individuals, 2013 2014 Low-income consumer units Low-income Consumer units with With elderly or Without elderly or out-of-pocket medical expenses All disabled individuals a disabled individuals Percentage 65.3 83.1 46.9 Mean (among those with positive out-of-pocket medical expenses) $285 $318 $224 Percentage with average monthly expenditures Greater than $0 to $35 14.5 9.6 23.3 $36 to $100 11.7 7.0 20.3 $101 to $500 59.0 66.1 46.0 $501 to $1,000 11.3 13.2 7.8 $1,001 or more 3.6 4.1 2.6 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Due to the design of the CE, the expenditure amounts that contribute to unit-level distributions cannot be restricted to those that occur within the 2013 and 2014 calendar years. Some are representative of the fourth quarter of 2012 or the first quarter of 2015. Medical expenses are for all members of the consumer unit and cannot be disaggregated into only those for members who are elderly or disabled. a We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. D-3 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.3. Average monthly deductible out-of-pocket medical expenditures relative to standard medical deduction demonstration amounts among low-income consumer units with out-of-pocket medical expenditures, 2013 2014 Percentage among low- income consumer units with elderly or disabled individuals a Low-income consumer units with average monthly out-of-pocket medical expenses too low to deduct b 9.6 Low-income consumer units with deductible average monthly out-of- pocket medical expenses Greater than $0 to $83 (the lowest FY 2013\/FY 2014 SMD amount) 19.4 $84 to $140 (the median FY 2013\/FY 2014 SMD amount) 13.0 $141 to $210 (the highest FY 2013\/FY 2014 SMD amount) 15.2 $211 or higher 42.8 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey Interview data files. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. SMD = Standard medical deduction demonstration. In FY 2013, 14 States (AR, IL, IA, KS, MA, MO, NH, ND, RI, SD, TX, VT, VA, and WY) had SMDs for medical expenditures less than or equal to the SMD plus $35. In FY 2014, 15 States (the same 14 States listed above, plus ID) had SMDs. MA increased its standard medical deduction demonstration amount in March 2014 from $90 to $155. When calculating the median amounts for all States, we use the mean amount of $123 for MA. a We define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. b Deductible out-of-pocket medical expenses are those in excess of $35 per month. D-4 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.4. Shelter expense amounts for SNAP households relative to the shelter cap for SNAP households without elderly or disabled individuals, and percentage of households with benefits constrained by the shelter cap, 2013 2014 SNAP households without elderly or Percentage of households in category where benefits are disabled individuals (percent) a constrained by the shelter cap Households without elderly or disabled individuals Total 100.0 13.9 With excess shelter expenses and deduction 68.5 20.2 Shelter expenses are at or below the shelter cap 17.5 0.0 Shelter expenses are above the shelter cap 51.0 27.2 By $1 to $200 13.7 0.0 By $201 to $400 12.7 11.1 By $401 to $600 11.0 36.9 By $601 to $800 7.1 53.8 By $801 to $1,000 3.4 64.4 By more than $1,000 3.2 75.7 Sources: Tabulations of FY 2013 and 2014 SNAP QC data files and simulations using the 2013 and 2014 QC Minimodels. Notes: Only households without elderly or disabled individuals are subject to a shelter cap. a We define SNAP households with nonelderly disabled individuals as those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. D-5 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.5. Shelter expenditures as a share of gross income and adjusted net income in the Consumer Expenditure Survey (CE) using ratios of gross income to adjusted net income in the 2015 Baseline of the 2011 MATH SIPP+ model, 2013 2014 Subgroup Countable shelter expenditures As a percentage of gross income As a percentage of adjusted net income, using MATH SIPP+- based ratio Ratio of gross income to adjusted net income, MATH SIPP+ model a All low-income consumer units 47.4 55.5 1.17 Household composition Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 46.2 48.5 53.6 57.2 1.16 1.18 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. Countable shelter expenditures include those for owned dwellings, rental dwellings, utilities, property taxes, and insurance. Adjusted net income is the sum of net income plus the excess shelter expense deduction. In other words, it is equal to countable income after all other potential deductions except for the excess shelter expense deduction are subtracted from gross income. a These ratios were applied to expenditures as a percentage of gross income (excluding SNAP benefits) in the CE to derive expenditures as a percentage of adjusted net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. D-6 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.6. Mean utility amounts in the SNAP QC data file by type of standard utility allowance (SUA) receipt, compared with utility expenditures for low-income consumer units in the Consumer Expenditure Survey (CE) by geographic region, 2013 2014 Low-income units Geographic region of residence All Northeast Midwest South West Mean utility amount ($) used in SNAP shelter deduction calculation (SNAP QC) a 302.35 540.58 314.14 200.74 289.57 Among units with positive utility amount (SNAP QC) 396.06 571.66 417.92 304.32 348.25 Receiving a heating\/cooling SUA 418.11 598.85 447.12 329.63 363.42 Receiving the lower utility standard (LUA) 250.89 271.71 238.35 244.68 254.76 Receiving only a telephone allowance or individual standard 50.99 48.44 50.44 37.97 87.22 Receiving an allowance for actual expenditures 280.33 606.38 331.21 240.07 164.25 With unknown utility type 535.72 646.25 564.05 322.51 386.84 Low-income consumer units Mean monthly utility expenditures ($) (CE) 240.30 241.60 216.80 263.17 219.90 Among low-income consumer units with positive utility expenditures (CE) 254.09 260.02 236.30 272.36 232.47 Sources: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: We define low-income units in the SNAP QC data file as SNAP households with gross income at or below 200 percent of the poverty guidelines. Low-income units in the CE are consumer units with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. a SNAP households in States with mandatory SUA policies receive a standard utility allowance for their shelter deduction if they incur heating or cooling expenses and have two or more utility expenses. SNAP households in States with non-mandatory SUA policies receive a utility amount equal to either an SUA or actual monthly utility expenses (including $0 if no expenses were incurred). D-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix D Table D.7 Prevalence and dollar amounts of expenditure types associated with deductions prior to the 1977 Farm Bill by consumer unit size for low-income consumer units, 2013 2014 Mean monthly expenditures All low-income consumer units Consumer unit size 1 3 4 5 6+ Alimony contributions Among all low-income consumer units Among all low-income consumer units with expense a Percentage of low-income consumer units with alimony contributions $0 $38 0.1 $0 $0 $0 $0 $41 $27 $10 n.a. 0.1 0.1 0.1 0.0 Education expenses Among all low-income consumer units Among all low-income consumer units with expense Percentage of low-income consumer units with education expenses $54 $500 10.8 $57 $44 $32 $47 $668 $278 $166 $230 8.6 15.9 19.4 20.3 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. Note: n.a.: not applicable. a The numbers for Alimony contributions\u2014Among all consumer units with expense are based on very small sample sizes and are not presented in the report. D-8 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix E Appendix E: Chapter V Analysis Tables (Research Objective 3) No. Title E.1 Ratios of gross income to net income by subgroup in the 2015 Baseline of the 2011 MATH SIPP+ model Food expenditures as a share of after-tax gross income and net income in the Consumer E.2a Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from after-tax gross income, 2013 2014 Food expenditures as a share of after-tax gross income and net income in the Consumer E.2b Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from both food at home expenditures and after-tax gross income, 2013 2014 Food expenditures as a share of after-tax gross income and net income in the Consumer E.2c Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and including SNAP benefits in both food expenditures and after-tax gross income, 2013 2014 Food at home expenditures as a share of after-tax gross income and net income in the E.2d Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from after-tax gross income, 2013 2014 Food at home expenditures as a share of after-tax gross income and net income in the E.2e Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from both food at home expenditures and after-tax gross income, 2013 2014 Food at home expenditures as a share of after-tax gross income and net income in the E.2f Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and including SNAP benefits in both food expenditures and after-tax gross income, 2013 2014 E-1 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.1. Ratios of gross income to net income by subgroup in the 2015 Baseline of the 2011 MATH SIPP+ model Subgroup Low-income simulated SNAP participating households Mean gross income ($) Mean net income ($) Ratio a All simulated SNAP households 739.69 339.73 2.18 Household size 1 person 2 people 3 people 4 people 5 or more people 568.98 698.85 890.64 1,041.82 1,342.12 229.36 310.59 429.03 535.75 749.36 2.48 2.25 2.08 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals No elderly or nonelderly disabled individuals 902.12 620.66 930.41 618.86 447.47 260.77 463.56 261.27 2.02 2.38 2.01 2.37 Income as a percentage of poverty guidelines 0 percent Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 0.00 362.88 958.79 1448.61 1732.36 0.00 90.73 446.76 734.23 938.92 n.a. 4.00 2.15 1.97 1.85 Source: Simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Note: Low-income SNAP households are defined as those simulated to participate in SNAP with gross income at or below 200 percent of poverty guidelines. n.a. = undefined. a These ratios are applied, as shown in Tables E.2a through E.2f, to gross income amounts in the Consumer Expenditure Survey. E-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2a. Food expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from CE after-tax gross income, 2013 2014 Subgroup Food expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 28.8 62.8 2.18 Household size 1 person 2 people 3 people 4 people 5 or more people 31.4 31.8 27.5 27.5 24.5 77.9 71.6 57.3 53.3 43.9 2.48 2.25 2.08 1.94 1.79 Household composition Children 26.7 54.0 2.02 No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 30.7 29.3 28.4 73.1 58.8 67.3 2.38 2.01 2.37 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 122.9 36.5 26.3 20.8 491.7 78.5 51.8 38.4 4.00 2.15 1.97 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-3 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2b. Food expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from both food at home expenditures and after-tax gross income, 2013 2014 Subgroup Food expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 25.5 55.5 2.18 Household size 1 person 2 people 3 people 4 people 5 or more people 29.5 29.6 23.0 22.9 20.3 73.1 66.6 47.8 44.5 36.3 2.48 2.25 2.08 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 21.8 28.9 26.4 24.7 44.0 68.8 53.0 58.4 2.02 2.38 2.01 2.36 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 92.0 29.6 24.0 19.9 368.1 63.7 47.4 36.8 4.00 2.15 1.98 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. In this table, we subtract the reported household SNAP benefit from both after-tax gross income and expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for 6 percent of low-income units to zero because food at home expenditures were lower than the SNAP benefit. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-4 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2c. Food expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and including SNAP benefits in both food expenditures and after- tax gross income, 2013 2014 Subgroup Food expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 27.8 60.7 2.18 Household size 1 person 2 people 3 people 4 people 5 or more people 30.8 31.1 26.3 26.3 23.6 76.5 69.9 54.7 50.9 42.2 2.48 2.25 2.08 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 25.4 30.2 28.4 27.3 51.4 71.8 57.1 64.8 2.02 2.38 2.01 2.37 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 94.1 34.2 25.7 20.6 376.3 73.5 50.7 38.1 4.00 2.15 1.97 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-5 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2d. Food at home expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from after-tax gross income, 2013 2014 Subgroup Food at home expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 22.3 48.6 2.18 Household size 1 person 2 people 3 people 4 people 5 or more people 23.0 24.0 21.9 21.9 20.2 57.1 54.0 45.6 42.4 36.1 2.48 2.25 2.08 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 21.6 22.9 23.0 21.6 43.5 54.6 46.3 51.3 2.01 2.38 2.01 2.38 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 98.9 29.0 20.4 15.6 395.6 62.3 40.1 28.9 4.00 2.15 1.97 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-6 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2e. Food at home expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and excluding SNAP benefits from both food at home expenditures and after-tax gross income, 2013 2014 Subgroup Food at home expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 19.5 42.4 2.17 Household size 1 person 2 people 3 people 4 people 5 or more people 21.4 22.1 18.2 18.0 16.4 53.1 49.6 37.9 35.0 29.4 2.48 2.24 2.08 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 17.4 21.4 20.5 18.5 35.1 50.9 41.3 43.9 2.02 2.38 2.01 2.37 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 73.8 23.1 18.4 14.9 295.1 49.7 36.2 27.5 4.00 2.15 1.97 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. In this table, we subtract the reported household SNAP benefit from both after-tax gross income and expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for 6 percent of low-income units to zero because food at home expenditures were lower than the SNAP benefit. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix E Table E.2.f. Food at home expenditures as a share of after-tax gross income and net income in the Consumer Expenditure Survey (CE) using ratios of gross income to net income in the 2015 Baseline of the 2011 MATH SIPP+ model and including SNAP benefits in both food expenditures and after-tax gross income, 2013 2014 Subgroup Food at home expenditures As a percentage of after-tax gross income (CE) As a percentage of net income, using MATH SIPP+-based ratio Ratio of gross income to net income, MATH SIPP+ model a All low-income consumer units 21.5 47.0 2.19 Household size 1 person 2 people 3 people 4 people 5 or more people 22.6 23.4 20.9 20.9 19.4 56.1 52.7 43.6 40.5 34.7 2.48 2.25 2.09 1.94 1.79 Household composition Children No children Elderly or nonelderly disabled individuals b No elderly or nonelderly disabled individuals 20.5 22.5 22.4 20.8 41.4 53.6 45.0 49.4 2.02 2.38 2.01 2.38 Income as a percentage of poverty guidelines Greater than 0 percent to 50 percent Greater than 50 percent to 100 percent Greater than 100 percent to 130 percent Greater than 130 percent to 200 percent 75.7 27.2 19.9 15.5 302.7 58.4 39.3 28.7 4.00 2.15 1.97 1.85 Sources: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Notes: Low-income consumer units are defined as those with gross income (excluding SNAP benefits) at or below 200 percent of poverty guidelines. a These ratios, derived in Table E.1, were applied to expenditures as a percentage of after-tax gross income in the CE to derive expenditures as a percentage of net income. b In the CE we define disabled individuals as those who list illness, disability, or inability to work as their reason for not working. E-8 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Decision Demographics Final Report: Appendix F Appendix F: Chapter VI Analysis Tables (Research Objective 3) No. Title F.1 Prevalence and dollar amounts of expenditures that could be considered for a new deduction for low-income consumer units, 2013 2014 Percentage of SNAP households with deduction, mean amount of deduction, and marginal F.2 effectiveness of deduction by deduction type and whether the last SNAP certification was a new certification or recertification, 2013 2014 F.3 Mean SNAP allotments, by household deduction use, 2013 2014 Percentage of proxy eligible consumer units (CUs) with average monthly out-of-pocket medical F.4 expenses greater than $0 or greater than $35 in the Consumer Expenditure Survey (CE) and percentage of SNAP households with a medical deduction in the SNAP QC data file by subgroup, 2013-2014 Percentage of proxy eligible consumer units (CUs) with earnings in the Consumer Expenditure F.5 Survey (CE) and percentage of SNAP households with earnings in the SNAP QC data file by subgroup, 2013-2014 Percentage of proxy eligible consumer units (CUs) with reported child care expenses in the F.6 Consumer Expenditure Survey (CE) and percentage of SNAP households with a dependent care deduction in the SNAP QC data file by subgroup of units with children, 2013-2014 Percentage of proxy eligible consumer units (CUs) with reported child support payments in the F.7 Consumer Expenditure Survey (CE) and SNAP households with a child support payment deduction in the SNAP QC data file by subgroup, 2013-2014 Percentage of proxy eligible consumer units (CUs) with reported rent or mortgage expenses in F.8 the Consumer Expenditure Survey (CE) and SNAP households with positive rent expenses in the SNAP QC data file by subgroup, 2013-2014 F-1 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.1. Prevalence and dollar amounts of expenditures that could be considered for a new deduction for low-income consumer units, 2013 2014 Amount of Amount of Percentage of expense among expense among units with all consumer units with Mean monthly expenditures expenditure type units expenditure type Housing or property repairs and maintenance 19.9 $43.97 $221.90 Finance, late charges, and interest for all student loans in the last month a 20.7 $14.39 $69.42 Apparel expenses 61.9 $44.40 $71.72 Personal care b 41.6 $11.85 $28.46 Vehicle finance charges 14.9 $7.46 $50.08 Vehicle maintenance and repair expenses 39.5 $33.36 $84.57 Vehicle insurance 39.9 $44.48 $111.45 New car or truck 0.5 $39.48 $8,525.61 Used car or truck 3.3 $92.64 $2,811.53 Vehicle rental, leases, licenses, and other charges 22.4 $14.62 $65.15 Source: Weighted tabulations of the 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files. a This information is only available in the fifth-quarter CE interview. b Personal care expenses as shown include only wigs, personal care appliances, and personal care services. F-2 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.2. Percentage of SNAP households with deduction, mean amount of deduction, and marginal effectiveness of deduction by deduction type and whether the last SNAP certification was a new certification or recertification, 2013 2014 Percentage of SNAP households with deduction Mean amount of deduction among households with deduction Marginal effectiveness of deduction Deduction type Households after recertification Households after initial certification Difference Households after recertification Households after initial certification Difference Households after recertification Households after initial certification Difference Total deductions 100.0 100.0 0.0 $526 $533 $6* $531 $544 $13* Child support payment 2.3 2.1 -0.2 $251 $225 -$26* $292 $285 -$7 Dependent care 3.3 3.9 0.6* $281 $251 -$31* $346 $311 -$35* Medical expense 5.7 4.8 -0.9* $149 $158 $9 $197 $208 $11 Excess shelter expense 72.2 75.3 3.1* $389 $382 -$7* $333 $335 $2 Sources: Regression-adjusted output from the fiscal year 2013 and 2014 SNAP QC data files. Notes: Percentages of SNAP households with deductions and mean amounts of deductions are adjusted for SNAP household size; presence of children, an elderly individual, or a disabled nonelderly individual in the household; an indicator of whether there are multiple adults in the household; SNAP household-level gross income; an indicator of whether the household has earned income; an indicator of whether the household has unearned income; indicators of whether the household has TANF, GA, SSI, or Social Security income; and locality (metropolitan, micropolitan, or rural). The analysis excluded MFIP and SSI-CAP households, for which deductions are not applicable. * Difference between outcome at recertification and certification is statistically significant at the 0.05 level, two-tailed test. F-3 AG-3198-C-15-0015 SNAP Benefit and Eligibility Parameters Table F.3. Mean SNAP allotments, by household deduction use, 2013 2014 Mean SNAP allotment Deduction type Households with deduction Households without deduction Difference Decision Demographics Final Report: Appendix F Medical expense Excess shelter expense Earned income $307.25 $281.83 $300.62 $263.68 $217.07 $249.69 $43.57* $64.75* $50.93* Sources: Regression-adjusted output from the 2013 and 2014 SNAP QC data files. Notes: Percentages of SNAP households with deductions and mean amounts of deductions are adjusted for SNAP household size; presence of children, an elderly individual, or a disabled nonelderly individual in the household; an indicator of whether there are multiple adults in the household; SNAP household-level gross income; an indicator of whether the household has earned income; an indicator of whether the household has unearned income; indicators of whether the household has TANF, GA, SSI, or Social Security income; and locality (metropolitan, micropolitan, or rural). The analysis excluded MFIP and SSI-CAP households, for which deductions are not applicable. * Difference between outcome at recertification and certification is statistically significant at the 0.05 level, two-tailed test. F-4 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.4. Percentage of proxy eligible consumer units (CUs) with average monthly out-of-pocket medical expenses greater than $0 or greater than $35 in the Consumer Expenditure Survey (CE) and percentage of SNAP households with a medical deduction in the SNAP QC data file by subgroup, 2013-2014 Percent of CUs with Percent of CUs with out-of-pocket medical expenditures out-of-pocket medical expenditures greater than $35 per Percent of units with medical deduction Characteristic of any amount (CE) month (CE) (SNAP QC) All units 57.9 46.0 3.6 All units with elderly or nonelderly disabled individuals a 76.2 64.2 9.7 Unit composition Nonelderly disabled individuals 65.3 48.5 7.6 And elderly individuals 83.5 77.7 14.4 And no elderly individuals 61.7 42.8 7.4 Elderly individuals 82.2 73.0 12.3 And no disabled individuals 83.7 74.9 12.2 Age of unit head Nonelderly 46.6 33.6 7.7 Age 60 to 69 75.5 65.0 10.8 Age 70 to 79 88.3 78.3 13.0 Age 80 or older 90.6 84.7 15.1 Age of any household member in the unit Under age 18 48.4 36.2 7.1 Age 18 to 59 50.0 37.7 7.9 Age 60 to 69 90.1 85.7 11.1 Age 70 to 79 94.4 90.6 13.7 Age 80 or older 90.9 85.4 15.6 Employment status of unit head Employed 46.7 34.9 9.0 Unemployed 35.8 26.4 5.6 Not in labor force 51.9 37.2 9.9 Unknown n.a. n.a. 0.0 Receipt of assistance from SNAP 51.8 34.2 9.7 Social Security 83.6 74.2 15.6 SSI 61.1 40.2 2.7 Source: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to units with gross income (excluding SNAP benefits in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any units in Guam or the Virgin Islands because these units are not included in the CE. CUs in the CE with income at or below 130 percent of poverty guidelines are considered proxy eligible. Medical expenses are for all members of the consumer unit and cannot be disaggregated into only those for members who are elderly or disabled. n.a.: not applicable. a In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. F-5 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.5. Percentage of proxy eligible consumer units (CUs) with earnings in the Consumer Expenditure Survey (CE) and percentage of SNAP households with earnings in the SNAP QC data file by subgroup, 2013-2014 Percent of units with Percent of CUs with earnings Characteristic earnings (CE) (SNAP QC) All units 53.1 29.9 Unit composition With children 77.3 50.4 And one adult 63.5 41.1 And multiple adults 84.3 61.8 With nonelderly adults 66.4 32.3 And children 77.9 48.0 And no children 56.6 17.0 With elderly individuals 24.0 5.6 With nonelderly disabled individuals a 25.8 9.1 Age of unit head Under age 18 70.2 68.2 Age 18 to 49 74.1 36.4 Age 50 to 59 50.3 17.0 Age 60 to 69 28.3 7.7 Age 70 or older 10.4 1.2 Income as a percentage of poverty guidelines 0 percent to 50 percent 46.6 18.0 Greater than 50 percent to 100 percent 56.4 35.7 Greater than 100 percent to 130 percent 55.8 54.0 Employment status of unit head Employed 99.0 100.0 Unemployed 22.6 7.8 Not in labor force 29.5 12.8 Unknown n.a. 35.9 Receipt of assistance from SNAP 49.4 29.9 Social Security 15.5 6.2 SSI 23.0 7.4 TANF 35.7 21.7 Source: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to units with gross income (excluding SNAP benefits in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any units in Guam or the Virgin Islands because these units are not included in the CE. CUs in the CE with income at or below 130 percent of poverty guidelines are considered proxy eligible. n.a.: not applicable. a In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. F-6 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.6. Percentage of proxy eligible consumer units (CUs) with reported child care expenses in the Consumer Expenditure Survey (CE) and percentage of SNAP households with a dependent care deduction in the SNAP QC data file by subgroup of units with children, 2013-2014 Characteristic Percent of CUs with child care expenditures (CE) Percent of units with dependent care deduction (SNAP QC) All units with children 8.6 6.9 Unit size 1 person 0.0 6.1 2 people 11.2 6.9 3 people 8.6 7.8 4 people 8.2 6.6 5 or more people 7.9 6.1 Unit composition One adult 11.7 9.0 Only preschool age children (age 0 to 4) 30.3 13.0 Only school age children (age 5 to 17) 5.5 5.1 Both preschool and school age children 17.3 13.8 Multiple adults 7.1 3.1 Only preschool age children (age 0 to 4) 12.8 3.4 Only school age children (age 5 to 17) 2.2 2.4 Both preschool and school age children 11.3 4.2 Income as a percentage of poverty guidelines 0 percent to 50 percent 8.2 2.0 Greater than 50 percent to 100 percent 8.1 9.4 Greater than 100 percent to 130 percent 9.8 18.5 Employment status of unit head Employed 12.3 17.1 Unemployed 2.7 1.4 Not in labor force 4.2 2.5 Unknown n.a. 0.0 Receipt of assistance from SNAP 9.3 6.9 Social Security 2.4 3.0 SSI 2.4 3.0 TANF 7.3 1.7 Source: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to units with gross income (excluding SNAP benefits in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any units in Guam or the Virgin Islands because these units are not included in the CE. CUs in the CE with income at or below 130 percent of poverty guidelines are considered proxy eligible. n.a.: not applicable. F-7 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.7. Percentage of proxy eligible consumer units (CUs) with reported child support payments in the Consumer Expenditure Survey (CE) and percentage of SNAP households with a child support payment deduction in the SNAP QC data file by subgroup, 2013-2014 Percent of units with child Percent of CUs with child support payment Characteristic support payments (CE) deduction a (SNAP QC) All units 1.9 2.0 Unit size 1 person 1.5 1.8 2-3 people 1.7 1.8 4-5 people 3.0 2.8 6 or more people 3.1 3.2 Unit composition With children 2.6 2.2 And one adult 1.5 1.4 And multiple adults 3.1 4.5 With nonelderly adults 2.4 2.3 And children 2.6 2.4 And no children 2.2 2.3 With elderly individuals 0.9 0.9 With nonelderly disabled individuals b 2.8 3.0 Income as a percentage of poverty guidelines 0 to 50 percent 1.8 0.9 Greater than 50 to 100 percent 2.0 2.6 Greater than 100 to 130 percent 1.9 3.8 Earnings as a percentage of poverty guidelines 0 percent to 50 percent 1.5 1.6 Greater than 50 percent to 100 percent 2.6 3.4 Greater than 100 percent to 130 percent 3.2 5.0 Employment status of unit head c Employed 2.8 3.3 Unemployed 1.5 1.3 Not in labor force 1.8 1.8 Unknown n.a. 0.0 Receipt of assistance from SNAP 2.3 2.0 Source: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to units with gross income (excluding SNAP benefits in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any units in Guam or the Virgin Islands because these units are not included in the CE. CUs in the CE with income at or below 130 percent of poverty guidelines are considered proxy eligible. n.a.: not applicable. a We excluded, from both the numerator and denominator, SNAP households living in the eighteen States that, as of September 2013, took the option to treat child support payments as an income exclusion rather than a deduction for some units. Implicit in this method is the assumption that the percentage of units with child support expenditures is similar across both the group of States that treat some child support payments as exclusions and the group of States that treat them exclusively as deductions. b In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. c Children and elderly adults are excluded from those not in the labor force. F-8 AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix F Table F.8. Percentage of proxy eligible consumer units (CUs) with reported rent or mortgage expenses in the Consumer Expenditure Survey (CE) and percentage of SNAP households with positive rent expenses in the SNAP QC data file by subgroup, 2013-2014 Percent of CUs with Percent of units with rent or mortgage rent expenses a Characteristic expenses (CE) (SNAP QC) All units 94.6 67.3 Unit size 1 person 93.5 59.5 2 people 95.7 72.0 3 people 94.4 75.6 4 people 95.4 78.2 5 or more people 96.8 81.8 Unit composition With children 95.3 75.1 And one adult 93.5 69.2 And multiple adults 96.2 83.0 With nonelderly adults 94.1 62.5 And children 95.3 73.2 And no children 93.2 52.2 With elderly individuals 96.3 82.3 With nonelderly disabled individuals b 94.8 88.5 With no elderly individuals or nonelderly disabled individuals 93.5 56.6 Income as a percentage of poverty guidelines 0 percent to 50 percent 91.4 40.5 Greater than 50 percent to 100 percent 95.6 88.3 Greater than 100 percent to 130 percent 97.1 93.2 Receipt of assistance from SNAP 95.0 67.3 Geography Northeast 94.7 77.9 Midwest 95.6 66.2 South 93.8 62.8 West 95.3 69.2 Urban c 94.9 67.5 Rural 92.7 62.7 Unknown status n.a. 79.6 Source: Weighted tabulations of 2013 and 2014 Consumer Expenditure Survey (CE) Interview data files and tabulations of FY 2013 and 2014 SNAP QC data files. Notes: Both CE and SNAP QC files are restricted to units with gross income (excluding SNAP benefits in the CE) at or below 130 percent of poverty guidelines. We also remove from the SNAP QC sample any units in Guam or the Virgin Islands because these units are not included in the CE. CUs in the CE with income at or below 130 percent of poverty guidelines are considered proxy eligible. n.a.: not applicable. a We used the RENT variable from the SNAP QC data file, which is defined as rent or mortgage amount. b In the SNAP QC, SNAP households with disabled individuals are those with a disability-based assistance payment (the SNAP criteria) or with a reported medical expense deduction. Disabled individuals in the CE list illness, disability, or inability to work as their reason for not working. c In the SNAP QC data, we classify units in metropolitan and micropolitan areas as urban. F-9 Page intentionally blank AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix G G-1 Appendix G: Summary of food expenditure estimates for low-income households To examine overall spending patterns for low-income households and to assess the 30 percent benefit reduction rate, this study used data from the CE to generate several estimates of food expenditures as a percentage of total expenditures, after-tax gross income, and net income. This appendix summarizes these estimates and explains the differences between them. A. Shares of total expenditures spent on food This report includes two measures of the shares of total expenditures spent on food: one in Chapter III that includes SNAP benefits in both food at home expenditures and total expenditures and one in Chapter V that excludes SNAP benefits from both food at home and total expenditures. The estimation method used in Chapter III is more conventional in studies describing how households allocate total expenditures across major categories of goods and services. The estimation method used in Chapter V is more consistent with the income-based measures presented in that chapter, where SNAP benefits are excluded from both after-tax gross income and food at home expenditures. Table G.1 presents these estimates. Table G.1. Percentage of total expenditures spent on food at home and food away from home, by whether SNAP benefits were included in food spending and total expenditure measures, 2013 2014 Whether SNAP benefits are included in food spending and total expenditures Food at home Food away from home b Included in both food at home and total expenditures 15.0 4.4 Removed from both food at home and total expenditures a 13.4 4.5 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a We subtract the reported household SNAP benefit from expenditures on food at home and total expenditures. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. b These estimates were unaffected by the inclusion or exclusion of SNAP benefits in food at home expenditures. However, they were affected by the decision to include or exclude SNAP benefits from total expenditures. B. Shares of after-tax gross income spent on food The analysis of the SNAP benefit reduction rate, presented in Chapter V of this report, included three estimates of the percentage of after-tax gross income spent on food at home. The first estimate excluded SNAP benefits from both food at home and after-tax gross income; the second included SNAP benefits in both food at home and after-tax gross income; and the third included SNAP benefits in food at home but excluded them from after-tax gross income. The approach used for this third estimate is the same one used for the estimates presented in Chapter III of food at home and other expenditures as a percentage of after-tax gross income. Table G.2 presents these estimates. AG-3198-C-15-0015 Decision Demographics SNAP Benefit and Eligibility Parameters Final Report: Appendix G G-2 Table G.2. Percentage of after-tax gross income spent on food at home, by whether SNAP benefits were included in food spending and income measures, 2013 2014 Whether SNAP benefits are included in food spending and income measures Food at home expenditures as a percentage of after-tax income Removed from both food at home and income a 19.5 Included in both food at home and income 21.5 Included in food at home; removed from income 22.3 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. C. Shares of net income spent on food Chapter V presents estimates of the share of net income spent on food at home. Because we did not have sufficient information to derive net income in the CE, we used a microsimulation model database, the fiscal year 2015 Baseline of the 2011 MATH SIPP+ model, to obtain the needed information. We calculated net income as a percentage of gross income for certain household types that have income at or below 200 percent of poverty and that were simulated as eligible for and participating in SNAP. We then applied the ratios of net income to gross income to after-tax gross income of the same groups in the CE. As with the estimates of food at home expenditures as a percentage of after-tax gross income presented in Table G.2, we obtained three estimates that differed according to whether SNAP benefits were excluded from food at home expenditures and after-tax gross income. Table G.3 provides these estimates. More information on the approach is provided in Chapter II and Appendix A. Table G.3. Percentage of net income spent on food at home, by whether SNAP benefits were included in food spending and income measures, 2013 2014 Whether SNAP benefits are included in food spending and income measures Food at home expenditures as a percentage of net income Removed from both food at home and income a 42.4 Included in both food at home and income 47.0 Included in food at home; removed from income 48.6 Sources: Weighted tabulations of the 2013 and 2014 CE Interview data files and simulations using the 2015 Baseline of the 2011 MATH SIPP+ model. Note: Low-income households are defined as those with gross income (excluding SNAP benefit amounts) at or below 200 percent of poverty guidelines. a We subtract the reported household SNAP benefit from expenditures on food at home. If food at home minus the SNAP benefit was less than $0, we set the food at home amount to zero. We adjusted food at home expenditures for about 6 percent of low-income households to zero because food at home expenditures were lower than the SNAP benefit. ”

” Facilitating CalFresh Eligibility and Enrollment for SSI Recipients January 2017 Coalition of California Welfare Rights Organizations County Welfare Directors Association of California Social Interest Solutions Acknowledgements The authors express gratitude to staff from the following organizations who generously shared their time and contributed information and insights to this project: Alabama Department of Human Resources, California Department of Health Care Services, California Department of Social Services, California Food Policy Advocates, California Office of Systems Integration, California Statewide Automated Welfare System Consortium IV (C-IV), CalWIN Consortium, Center on Budget and Policy Priorities, Community Legal Services of Philadelphia, Hunger Solutions New York, Kone Consulting, Los Angeles County Department of Public Social Services, Massachusetts Law Reform Institute, and National Council on Aging. About the Coalition of California Welfare Rights Organizations The Coalition of California Welfare Rights Organizations (CCWRO) is a state- wide nonprofit organization that has been providing advocacy in the public benefits field since the early 1980s. CCWRO provides public assistance training, consultation and information services, and serves as co-counsel on hearings and administrative procedures related to public benefit programs. www.ccwro.org About the County Welfare Directors Association The County Welfare Directors Association of California (CWDA) is a non- profit association representing the human services directors from each of California’s 58 counties. The association’s mission is to promote a human services system that encourages self-sufficiency of families and commu- nities and protects vulnerable children and adults from abuse and neglect. www.cwda.org About Social Interest Solutions Social Interest Solutions (SIS) is a national nonprofit organization dedicated to improving access to quality health and social services through technol- ogy and policy solutions. SIS has worked to advance federal, state and local policies to streamline and modernize eligibility and enrollment processes, and has developed pioneering technology solutions that have impacted the quality of life for more than 20 million of the nation’s underserved population. www.socialinterest.org http:\/\/www.ccwro.org http:\/\/www.cwda.org https:\/\/www.socialinterest.org Contents 1 Executive Summary Streamlined CalFresh Enrollment Options for SSI Recipients Additional Considerations 2 Introduction 3 Background 4 Current California Landscape SSI CalFresh 9 Streamlined Enrollment Models SSA Role in SNAP Enrollment Simplified SNAP Enrollment Pilots Streamlined Enrollment Based on Eligibility for Other Programs Options for Streamlining Enrollment 13 Facilitating CalFresh Enrollment for SSI Recipients CalFresh Eligibility and Enrollment for Current SSI Recipients CalFresh Eligibility and Enrollment for New SSI Applicants Ongoing CalFresh Case Management for SSI Recipients CalFresh Recertification for SSI Recipients 21 Additional Considerations Planning and Phased Rollout Working with Trusted Partners Multiple Communication Channels Training and Customer Support 22 Conclusion 23 Endnotes FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 1 CalFresh case management; and managing CalFresh recer- tification. These options are discussed briefly below. Facilitating CalFresh for Current SSI Recipients: Fast Track Given the large number of SSI recipients in California, the state could identify a fast track population that is highly likely to be eligible for CalFresh and implement a one-time simplified enrollment process for this group. The fast track population could be defined as single individuals or couples whose only income comes from SSI, a group that is consid- ered categorically eligible for SNAP in all other states. Once the fast track population has been identified, a stream- lined approach for initial CalFresh enrollment for this group could be implemented. A potential approach could include the following high-level steps: calculate a standard benefit amount; issue a notice of eligibility, EBT card, PIN number and instructions on how to accept and use the benefits to recipients; allow use of the EBT card to serve as con- sent or collect consent by electronic\/telephonic signature, in person, or by mail, and conduct interviews by phone or waive the interview requirement. This approach would re- quire a number of policy and procedural changes, some of which would require federal waivers, including modified data sharing agreements between federal and state agencies, the application of standard allowances to CalFresh income calculations, changes to current consent policies and\/or the ability to collect signatures telephonically, and the potential waiving of the CalFresh interview requirement. The tradeoffs of these changes would need to be weighed against the usability of the process for SSI recipients and the potential efficiencies for program administrators. Enrollment of Current SSI Recipients: Non-Fast Track SSI recipients who are not identified as fast track, meaning those with additional sources of income and\/or additional household members, would likely require a full eligibility de- termination process to obtain an accurate CalFresh benefit amount. However, potential options for streamlining this ap- proach could include leveraging existing SSI data to initiate enrollment and verify household information, utilizing a sim- plified CalFresh application, disregarding non-SSI income and resources, and exploring treating all SSI recipients as individual households. In order to mitigate the impact of ending cash-out on existing CalFresh households with SSI members, the state could also delay recertification of these Executive Summary Supplemental Security Income (SSI) recipients in California are not currently eligible for CalFresh (California’s version of the Supplemental Nutrition Assistance Program SNAP, formerly known as Food Stamps). Instead, California has historically opted to support food expenses for the SSI pop- ulation through the state share of the SSI payment, a policy decision known as cash-out. California is now reexamining this policy and considering changes to allow SSI recipients who meet income and other requirements to be eligible for CalFresh benefits. If California decides to end cash-out, it will be important to consider how existing processes and systems can be leveraged and streamlined to facilitate CalFresh eligibility de- termination and enrollment for as many as 1.3 million existing SSI recipients. California counties have well-established sys- tems and processes used to determine CalFresh eligibility and manage ongoing caseload using their State Automated Welfare System (SAWS). Furthermore, the state has existing access to a rich data file on SSI recipients through the Social Security Administration (SSA) State Data Exchange (SDX), and a subset of that data is already captured by state and county systems. However, given California’s current number of SSI recipients, it will be challenging from a workload perspective to collect CalFresh applications for the entire population and expedi- ently process them all at once. Therefore, California may want to assess opportunities to streamline the application and en- rollment process. Existing models in other states targeted at facilitating SNAP participation for elderly and disabled pop- ulations, such as the Combined Application Project (CAP) and the Elderly Simplified Application Project (ESAP), may provide lessons for California. California may also want to examine the role that SSA currently plays in other states to help facilitate SNAP applications for SSI applicants. These models have utilized a range of options that may be useful to California for streamlining enrollment if it decides to end cash-out. Streamlined CalFresh Enrollment Options for SSI Recipients Facilitating CalFresh enrollment for SSI recipients will in- clude: assessing eligibility for, and conducting enrollment in, CalFresh for current SSI recipients; facilitating CalFresh applications for new SSI applicants; providing ongoing FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 2 approach; working with trusted community partners to ef- fectively communicate with SSI recipients; providing multiple communication channels for recipients, including in-person, web, phone and mail; and ensuring adequate training and specialized customer support. Evaluating options for streamlining enrollment in CalFresh for SSI recipients will require discussions about the potential need for state policy changes (including federal waivers), the ability to leverage existing technology, and one-time versus ongoing process and program changes. Furthermore, the state will want to consider the importance of planning, train- ing, and building partnerships with county eligibility staff as well as community-based organizations. These decisions will ultimately determine whether seniors and people with disabilities in California are able to obtain the nutrition as- sistance they need in a manner that is least burdensome for them as well as most efficient for the state. Introduction Supplemental Security Income (SSI) recipients in California are not currently eligible for CalFresh (California’s version of the Supplemental Nutrition Assistance Program SNAP, formerly known as Food Stamps). Today, California is reexamining this policy, referred to as cash-out. State pol- icymakers are considering changes to allow SSI recipients who meet income and other requirements to be eligible for CalFresh benefits. If this policy change is realized, 1.3 mil- lion elderly and disabled Californians receiving SSI today, as well as future SSI recipients in California, could potentially become eligible for CalFresh. The purpose of this policy paper is to assess solutions for maximizing enrollment of el- igible SSI recipients into CalFresh, should California decide to end cash-out. The paper discusses: \u25b6\u25b6 The California cash-out policy \u25b6\u25b6 Current enrollment processes and systems for SSI and CalFresh \u25b6\u25b6 Models for streamlining enrollment across programs \u25b6\u25b6 Options for facilitating CalFresh enrollment for SSI recipients in California \u25b6\u25b6 Key policy, technology and other considerations households until the next regularly scheduled CalFresh rede- termination date. Facilitating CalFresh for New SSI Applicants On an ongoing basis, individuals who are newly applying to SSI could also benefit from a streamlined connection to CalFresh. A potential approach would be to leverage SSA’s existing obligation to assist SSI applicants with SNAP ap- plications. In some states, the SSI application has been modified to ask applicants about their interest in applying for SNAP (and collect consent), and in some cases to collect additional required information for SNAP eligibility determi- nation purposes. The SSI interview could also be deemed to satisfy the initial CalFresh interview requirement. Ongoing CalFresh Case Management for SSI Recipients Ongoing CalFresh case management for SSI recipients, which will be managed by county human services offices as it is for current CalFresh recipients, can benefit by ensuring specialized training for staff on providing customer support for elderly and disabled individuals. Furthermore, careful ad- vance planning will be required to ensure adequate staffing levels to support the expanded caseload. CalFresh Recertification for SSI Recipients CalFresh currently requires recertification every 12 months for most households, and every 24 months for elderly and disabled recipients. An interview is required at the time of re- certification, and interim reporting is required within 10 days of a change. This process could be simplified for fast track SSI recipients, for example, by extending the CalFresh re- certification timeline, waiving interim reporting requirements, aligning the CalFresh recertification process with the SSI or Medi-Cal redetermination processes, or allowing SSA’s redetermination process for SSI to fulfill the CalFresh recer- tification requirements. Non-fast track households could use the current CalFresh recertification process, but additional efficiencies could be achieved, such as if CalFresh were able to conduct an ex-parte recertification of SSI recipients using the most current data from SSA. These and other ideas should be more formally considered and fleshed out by the state, counties, advocates and other stakeholders. Additional Considerations Lessons from other states provide additional consider- ations for California to weigh if it ends cash-out, including: the importance of planning and the possibility of a phased FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 3 the California Assembly enacted a measure Assembly Joint Resolution 35 calling on the federal government to allow California to end cash-out in a way that would maxi- mize participation among those newly eligible for CalFresh and mitigate the impact on those determined to be ineligible for CalFresh for income or other reasons. One of the stated drivers behind the current reconsideration of cash-out is a concern that many low-income seniors and people with disabilities in California have difficulties obtaining suffi- cient food. 4 Data support this concern. One in seven seniors over the age of 60 and half of individuals with disabilities over the age of 40 in the United States have experienced food insecurity, or inadequate access to a sufficient quantity of affordable, nutritious food.5 Food insecurity is also widespread among those with low incomes: 38% of those between zero and 50% of FPL and 45.5% of those between 50% and 100% of FPL struggle with food insecurity.6 In California, food in- security has increased among low-income seniors in recent years, increasing from 21% of California seniors with in- comes under 200% of FPL in 2009\/10, to 27% in 2013\/14.7 Food insecurity can compromise health, particularly among vulnerable populations such as those eligible for the SSI pro- gram: One study found that food insecure seniors were more than twice as likely to report fair or poor health status as their food secure counterparts.8 As California contemplates ending cash-out, a number of procedural, policy and system issues will need to be thought through in order to maximize enrollment for newly eligi- ble SSI recipients. One of the challenges the state faces is how to optimally enroll seniors and people with disabil- ities in CalFresh, an issue with which California and many other states have struggled. In 2012, with only 18% of eligi- ble Californians over the age of 60 (excluding SSI recipients) enrolled in SNAP, California ranked last in enrollment com- pared to other states and was nearly seven percentage points lower than the next lowest state.9 To set the context for, and provide insights into, the decisions California faces if it decides to end cash-out, the next two sections describe the current California landscape for SSI and CalFresh, and examine a range of potential models for streamlining eligibility and enrollment of SSI recipients into CalFresh. The findings were informed by interviews and workgroup sessions with more than 30 California state and county program officials, national and state advocates, and rep- resentatives from efforts in other states to connect the SSI population with nutrition assistance. Background SSI, a federal income support program administered by the Social Security Administration (SSA), was created in 1974 to help aged, blind and disabled individuals with little or no income pay for basic needs. States can choose to supple- ment the federal SSI benefit using state funds. This additional payment is called the State Supplementary Payment (SSP). SSI recipients in California are not currently eligible for CalFresh, a state-federal program that provides nutrition assistance to low-income individuals and families. Instead, California has opted to support nutrition assistance for the SSI population through its SSP benefit, a policy decision commonly referred to as cash-out. California’s cash-out policy dates back to the creation of the SSI program in 1974. States that provided a SSP pay- ment were allowed to increase the amount of that payment in lieu of allowing SSI recipients to be eligible for food stamps (now called SNAP, known as CalFresh in California). To save on the administrative costs of administering both SSI and food stamps benefits to SSI recipients, California chose to utilize the cash-out policy option.1 While four other states implemented cash-out initially (Massachusetts, Nevada, New York and Wisconsin), California is the only state that has maintained cash-out to the present day. However, SSI\/ SSP payments (hereafter referred to simply as SSI ) have not kept pace with inflation over time. In 1980, a year of SSI payments for an individual equated to about 128% of the federal poverty level (FPL); by 2002, the annual value of SSI payments had decreased to about 102% of FPL.2 In 2016, SSI recipients are living below the federal poverty level. A year of SSI payments in California for an individual resid- ing in their own home ($10,672.80) equates to about 90% of FPL ($11,880 annually).3 As a result, spending on food must compete with scarce resources for living expenses and other basic necessities. For this and other reasons, California has contemplated ending cash-out several times since 1974. Most recently, FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 4 2. The local SSA office determines financial eligibility and conducts an interview.13,14 The applicant may need to submit additional documentation. If the applicant is not determined to be financially eligible, SSA issues a denial notice. 3. If the applicant is determined to be financially eligible, a disability determination is conducted, unless the ap- plicant is over age 65 or legally blind, in which case a separate disability determination is not required. \u25b6\u25b6 SSA contracts with the California Department of Social Services’ Disability Determination Service Division (DDSD) to conduct the disability determi- nation and report the result back to SSA. \u25b6\u25b6 This process can take several months and often requires multiple medical evaluations. 4. If the applicant is determined to be disabled accord- ing to the SSI program rules, SSA sends the applicant an approval notice and the applicant begins to receive a monthly benefit amount from SSA, either via direct de- posit into a bank account or into a debit card account. 5. Once approved for SSI, individuals are automatically eligi- ble for Medi-Cal. Information about the newly eligible SSI recipient is sent electronically from SSA in a regular batch file via the State Data Exchange (SDX) and captured by the state Medi-Cal Eligibility Data System (MEDS). (See sidebars below and on page 5.) Current California Landscape California’s existing processes and systems for administering SSI and CalFresh will need to be leveraged and may require adjustments if cash-out ends. This section provides a high- level overview of the steps and systems currently involved in determining eligibility for each program in California. SSI Supplemental Security Income (SSI) is income assistance for people who are disabled, blind, or age 65 or older with lim- ited income and resources.10 Of SSI recipients in California, 43% are age 65 or older, 48% are non-elderly adults and 9% are children.11 Some 72% of SSI recipients qualify for the program on the basis of a disability, including a portion of the group age 65 and older.12 The program is both federally (SSI) and state (SSP) funded. The Social Security Administration (SSA) administers SSI at the federal level. Although some states administer the SSP portion of the program, California has opted to have SSA administer its SSP program as well. However, SSA has del- egated a portion of the SSI eligibility determination process to the state via the California Department of Social Services (CDSS). This process is described in more detail below. SSI recipients in California are categorically eligible for Medi-Cal (the state Medicaid program), referred to as SSI- linked Medi-Cal. Because the process and systems used to administer SSI-linked Medi-Cal might inform facilitating CalFresh enrollment for SSI recipients, the steps involved in this process are included in the description of the SSI eligi- bility and enrollment process below. SSI and SSI-Linked Medi-Cal Eligibility and Enrollment Process In California, the steps to enroll in SSI and SSI-linked Medi-Cal are: 1. An individual goes in person to a local SSA office to com- plete an application and interview for SSI. The application can be started online, but must be completed in person at the SSA office. In California, and other states with an automatic linkage between SSI and Medicaid, the SSA application also serves as an application for Medi-Cal. State Data Exchange (SDX) SDX is a batch data exchange that provides data from the Social Security Administration (SSA) on SSI applicants and recipients to states that administer federally funded income and\/or health programs such as Medicaid. Each state receives a flat file from SDX and uses its state eligibility system to extract data needed to conduct eligi- bility for various means-tested programs from the SDX record.15 States must have a data shar- ing agreement with SSA that clearly indicates for which programs the state may use the SDX data.16 FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 5 8. The SSA office provides ongoing case management for SSI and SSI-linked Medi-Cal. SSA is responsible for in- forming SSI recipients about their SSI and Medi-Cal benefits, handling benefits questions or problems (includ- ing any issues related to Medi-Cal BIC cards), receiving and processing recipient reports of changes in eligibil- ity, and managing the SSI redetermination process. If the SSI recipient calls or goes to the county human services office for assistance with Medi-Cal, the county can record a change of address or reissue a BIC card, but SSA han- dles all other case management. The SSI recipient must report any changes in eligibility (e.g., change of address, household, or income) directly to SSA within 10 days and must undergo redetermination annually if changes are likely.17 As long as the recipient retains SSI eligibility, they remain enrolled in Medi-Cal. 6. MEDS identifies the newly eligible SSI recipient based on SDX records, assigns an aid code designating each individual as an SSI-linked Medi-Cal recipient, and this in- formation is sent to the California Medicaid Management Information System (CA-MMIS) to complete Medi-Cal en- rollment for the SSI recipient. Note, that unlike for all other Medi-Cal recipients, SSI-linked Medi-Cal cases are not managed at the county level and therefore do not have a record in the county eligibility and enrollment system unless it is from a case that existed prior to the individu- al’s enrollment in SSI. 7. CA-MMIS electronically notifies the state vendor (Xerox) to issue and mail a Medi-Cal Beneficiary Identification Card (BIC) to the recipient. The BIC serves as proof of enrollment for the SSI-linked Medi-Cal recipient to use when receiving Medi-Cal covered health care services from a provider. Medi-Cal Eligibility Data System (MEDS) California’s MEDS provides a repository for en- rollment data about multiple benefits programs, including Medi-Cal, CalFresh, CalWORKs, and other cash and nutrition assistance programs. MEDS captures data on SSI applicants and re- cipients, including demographics and program eligibility and enrollment. MEDS also interfaces with all three Statewide Automated Welfare Systems (SAWS), California’s county-managed elibility and enrollment system of record for public programs (see next section for more information on SAWS). FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 6 CalFresh Eligibility and Enrollment Process The steps to enroll in CalFresh are: 1. An individual or family applies online, by phone, by mail, or in person at the local county human services office. The applicant must sign the application to certify the in- formation provided is accurate and to provide consent to use the information for an eligibility determination for CalFresh. 2. A county eligibility worker checks to see if the applicant has a prior or existing case in MEDS (known as file clear- ance; see sidebar on page 7). MEDS is also checked to determine whether the applicant has SSI, which would, under today’s cash-out policy, make them ineligible for CalFresh. CalFresh CalFresh, California’s SNAP program, assists low-income in- dividuals and households in purchasing food. The program issues monthly electronic benefits via an Electronic Benefits Transfer (EBT) card that can be used to buy most foods at many markets and grocery stores. (See sidebar on page 7.) CalFresh benefits are federally funded, while program ad- ministrative costs are shared between the federal (50%), state (35%) and county (15%) governments. The program is administered at the federal level by the U.S. Department of Agriculture, under the Food and Nutrition Service (FNS), and at the state level by CDSS. Under California’s county-ad- ministered public benefit system, 58 county human services departments are responsible for CalFresh eligibility determi- nations and case management. Figure 1. SSI and SSI-Linked Medi-Cal Eligibility and Enrollment Process APPLICATION DETERMINE SSI MEDI-CAL DELIVER BENEFIT MANAGE CASE DETERMINE ELIGIBILITY To determine financial eligibility, local SSA office conducts in-person interview MEDS sends data to CA-MMIS MEDS receives SSI recipient data via SDX and creates SSI-Linked Medi-Cal case To determine disability eligibility, DDSD conducts a disability determination New SSI recipient receives notice of SSI Medi-Cal eligibility Local SSA offices provide ongoing case management services to SSI recipients Applicant Agency\/worker Applicant goes to local SSA office to complete an application CA-MMIS sends data to BIC vendor to print and mail BIC New SSI recipient receives Medi-Cal BIC in the mail New SSI recipient receives SSI payments via either direct deposit or debit card FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 7 3. If a case does not already exist, the county eligibility worker opens a new case in the Statewide Automated Welfare System (see sidebar). If a SAWS case does exist, the county eligibility worker adds information from the new CalFresh application to the existing case. 4. The county eligibility worker interviews the applicant, either in-person or by phone.18 In the interview, the eli- gibility worker reviews the application and explains the program. If any additional documents are needed from the applicant, the eligibility worker asks the applicant to send that information to the county. 5. Once the applicant has completed the interview and pro- vided all necessary information and documentation, the eligibility worker uses SAWS to determine eligibility and calculate the CalFresh benefit amount for the household. (See details below.) 6. SAWS then sends the new CalFresh recipient data to MEDS and to the EBT system, whose vendor (Xerox) generates and mails an EBT card with the correct ben- efit amount. The recipient separately receives a Personal Identification Number (PIN) to use when making pur- chases with the EBT card. The CalFresh recipient can immediately use the EBT card, like a debit card, to pur- chase food at most grocery stores and many other locations. Alternatively, if the CalFresh recipient applied in person at a county office, the county staff can print an EBT card on the spot and help the recipient set a PIN before they leave the office. Statewide Automated Welfare System (SAWS) SAWS is California’s county-managed eligibility and enrollment system and is the state’s system of record for public programs including CalFresh, Medi-Cal, and CalWORKs (cash assistance). SAWS supports eligibility determination, benefit calculation, benefit issuance, case management and reporting. All of California’s 58 counties are organized into one of three SAWS consortia : CalWIN, C-IV, and LRS (C-IV and LRS will consolidate into a single consortia over the next several years). Electronic Benefits Transfer (EBT) EBT cards are used by states to provide an easy way for public program recipients to access benefits. EBT cards are similar to bank debit cards and can be used at any point of sale (POS) system that accepts the card, for example, a card reader at a grocery check-out. States were required to start using EBT cards for SNAP in 2002. In California, an EBT card is issued by default to the adult designated as the head of household in the CalFresh benefits case. The head of household may authorize other adults in the household, as well as one additional adult outside the house- hold, to be issued an EBT card as well, all linked to the same CalFresh benefits case. Those who are issued an EBT card are also assigned or are prompted to choose a personal identification number (PIN) that allows them to use the EBT card and access the CalFresh benefits. California’s EBT vendor, Xerox, is responsible for issuing CalFresh EBT cards and tracking spending against recipients’ benefit amounts. File Clearance Currently, before a CalFresh case can be created in SAWS, county workers must first go through a file clearance process to avoid creating a duplicate record for the same individual. The county worker searches for an existing record in MEDS using the individu- al’s information (name, date of birth, address, and Social Security number). If the individual is known to MEDS, the county worker selects the existing Client Index Number (CIN) and links the new application to an existing SAWS case in that county, or creates a new SAWS case, as appropriate. If the individual is not already known to MEDS, a new CIN is created in MEDS, and a new case is created in SAWS. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 8 CalFresh Calculation of Income and Benefit Amount An individualized assessment is required to determine eli- gibility and the monthly amount of CalFresh benefits for the applicant’s household. Anyone in the household, whether re- lated or not, who purchases and prepares meals together, is counted as part of the CalFresh household, as is their income. To qualify for the program: \u25b6\u25b6 Total gross household income must be below 200% of FPL; and \u25b6\u25b6 Net income (gross income minus deductions and standard allowances) must be at or below 100% of FPL.19 7. County human services offices provide initial and ongo- ing case management for CalFresh cases. In addition to processing all mandatory periodic reports submitted by recipient households and annual recertifications, el- igibility workers respond to all changes in household circumstances, address changes, lost EBT card, and other reports and changes communicated by house- holds. In addition, county staff explains program rules, answer questions, and assist households with securing necessary documents and verifications required by fed- eral and state regulations. Figure 2. CalFresh Eligibility and Enrollment Process Applicant Agency\/worker DETERMINE ELIGIBILITY APPLICATION DELIVER BENEFIT MANAGE CASE County worker performs file clearance in MEDS and SAWS County worker runs CalFresh eligibility in SAWS SAWS sends CalFresh information to EBT vendor County worker opens a new case (or updates existing case) in SAWS SAWS sends CalFresh information to MEDS EBT vendor generates and mails EBT card and PIN (or counties can generate locally) County workers provide ongoing case management services County worker interviews applicant Applicant completes and submits application New CalFresh recipient receives notice of eligibility from SAWS New CalFresh recipient receives EBT card and PIN FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 9 Streamlined Enrollment Models Existing models targeted at increasing SNAP participation for elderly and disabled populations or for facilitating stream- lined enrollment across other public benefit programs can provide lessons to California as it contemplates ending cash-out. This section highlights some of those models and identifies a range of potential options for streamlining eligi- bility and enrollment. SSA Role in SNAP Enrollment In all states other than California, SSI recipients are eligi- ble to apply for SNAP. Under federal law, the Social Security Administration (SSA) is required to assist SSI applicants in applying for SNAP benefits.22 Specifically, for all households consisting of only SSI applicants and\/or recipients, SSA must: \u25b6\u25b6 Help to fill out the state SNAP application at the time applicants register for SSI, if they are not already receiving SNAP benefits; \u25b6\u25b6 Deliver the completed SNAP application to the state or county agency responsible for facilitating SNAP benefits. That agency must process the SNAP application within 30 days.23 – 25 For individuals applying for SSI who have other household members or other income, SSA must inform applicants of potential eligibility for SNAP and refer them to the appropri- ate state or county agency to apply.26 Simplified SNAP Enrollment Pilots SNAP enrollment challenges related to the senior popula- tion are well documented. Nationally, in fiscal year 2014 just 42% of eligible elderly individuals were enrolled in SNAP, compared to 83% of all eligible individuals.27 FNS has at- tempted to approve various pilot projects over the years to test various enrollment strategies to help increase SNAP participation among seniors through a variety of demon- stration pilots, including the Combined Application Project (CAP) and the Elderly Simplified Application Project (ESAP). Combined Application Project (CAP) CAP is an FNS demonstration project established 21 years ago that has allowed 18 states to streamline enrollment of SSI recipients into SNAP. 28, 29 The primary goal of CAP is to Net income is determined by applying deductions and stan- dard allowances to gross income. Deductions are based on actual costs incurred by a household for certain expenses, such as housing and dependent care, up to a maximum amount. For example, the actual amount paid for housing (up to the capped amount) is deducted from the household’s gross income; thus, the amount deducted will vary by house- hold. In California, medical expenses greater than $35 per month can also be deducted from gross income.20 Standard allowances are a pre-set amount, determined by the state, and deducted from gross income for certain living costs, regardless of the amount spent by the household on that item. For example, households that have earned income, such as wages or salaries, are automatically given a $20 al- lowance, regardless of the actual amount of their earned income. This allowance is referred to as an earned income deduction. CalFresh households that incur a utility cost sep- arately from their rent or mortgage also receive a Standard Utility Allowance (SUA) for utility expenses that is deducted from gross income. After all deductions and standard allowances have been applied to the gross household income, an individualized as- sessment is made to determine the amount of the CalFresh benefit for all eligible members of the household. Under SNAP program rules, households are generally expected to contribute 30% of their net income to food expenses. That amount is subtracted from the CalFresh program maximum benefit amount for that household size, which is tied to the cost of the Department of Agriculture’s Thrifty Food Plan.21 For example, if a household has no income, it would receive the maximum CalFresh benefit amount. If a household has a net income of $400 per month, it would be expected to con- tribute 30% ($120) to food; that amount would be deducted from the maximum CalFresh benefit amount for that house- hold size, and the resulting difference would be the amount received each month by that household from CalFresh. Based on these program rules, CalFresh households must submit documentation of income and relevant expenses and undergo an individualized assessment in order to calculate eligibility and benefit amount. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 10 Streamlined Enrollment Based on Eligibility for Other Programs Another model for streamlined enrollment is direct certifica- tion of eligibility from one program to another. For example, under the Affordable Care Act (ACA), states are permitted to find certain SNAP recipients automatically eligible for Medicaid based on the SNAP eligibility determination.32 In 2014, California initiated an Express Lane Eligibility (ELE) program to provide a streamlined process to enroll new and existing CalFresh recipients into Medi-Cal.33 Specifically, the California Medi-Cal agency identified ex- isting CalFresh recipients in MEDS who were not already enrolled in Medi-Cal and notified them by mail that they could affirmatively opt in to Medi-Cal without completing a new application. Those opting in could respond by mail, phone, web portal, or in person using a provided PIN. The response rate to the initial mailing was estimated to be about 30%, with responses primarily from mail and phone. On an ongoing basis, the CalFresh application is altered so new applicants for CalFresh can be evaluated for Medi-Cal if they meet the ELE requirements. Options for Streamlining Enrollment The models described utilize a range of options for stream- lining enrollment either for target populations or across programs that may be useful to California if it decides to end cash-out. Some of these options could be utilized to stream- line the eligibility and enrollment process for SSI recipients in CalFresh, and are described briefly below. Population Identification Targeted outreach using existing data sources can be an ef- ficient way to identify recipients of one public program who may be eligible for another, despite some differences in pro- gram eligibility rules. For example, in CAP states the SNAP agency identifies newly eligible SSI recipients from the SDX data periodically sent by SSA and initiates the CAP SNAP en- rollment process so that only a few additional questions have to be answered to complete the CAP SNAP determination. Similarly, for its CalFresh\/Medi-Cal ELE program, California queried MEDS to identify existing CalFresh recipients who were not already enrolled in Medi-Cal and sent notices to those individuals informing them of their eligibility for Medi- Cal without requiring they complete a separate application. If California ends cash-out, it can identify and reach out to existing SSI recipients who are most likely to be eligible for CalFresh using only data available through SDX and MEDS. increase SNAP participation among SSI recipients by simpli- fying the process for receiving SNAP benefits in conjunction with SSI benefits. The standard CAP model builds on the existing SSA ob- ligation to screen and help enroll new SSI applicants into SNAP. Under this model, people applying for SSI bene- fits are asked if they would also like to apply for state CAP SNAP benefits; if yes, they only need answer a few additional questions on their SSI application, rather than completing a separate SNAP application, in order for the state or county SNAP agency to determine eligibility for the CAP SNAP ben- efits. In contrast, under the modified CAP model, the state or county SNAP agency affirmatively reviews the SDX data to identify SSI recipients who live alone or only with a spouse and are thus more likely to be eligible for CAP SNAP benefits. The SNAP agency then notifies these individuals of eligibility for CAP SNAP benefits and provides instructions on how to opt in. With both CAP models, the SSI interview satisfies the SNAP interview requirement. Elderly Simplified Application Project (ESAP) ESAP is an FNS demonstration project that as of November 2016 has allowed eight states (Alabama, Florida, Georgia, Maryland, Mississippi, Pennsylvania, South Carolina, and Washington) to streamline application and recertification for eligible elderly (and in some states, disabled) individuals.30 The primary goal of ESAP is to increase SNAP participa- tion among the elderly low-income population, and in some states, the disabled low-income population as well, by sim- plifying the existing SNAP application and certification requirements for those most likely to be eligible for SNAP. Typically, individuals are eligible for ESAP if all household members are disabled or over 60 years of age and have no earned income. While ESAPs are not limited to SSI re- cipients, those who are eligible greatly overlap with the SSI population. The ESAP pilots streamline the SNAP application and certi- fication process by using a shorter application, eliminating the interview requirement at recertification (early ESAP pilots were also able to offer SNAP eligibility without conducting an initial interview), making use of data matches to eliminate the need for applicants and recipients to provider paper docu- ments, and extending the SNAP certification period from 12 to 36 months.31 FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 11 to them was considered as consent to receive SNAP benefits. If the EBT card is not used within a set period, the individual’s case is closed. CAP recipients in New York have 90 days to begin using the EBT card to purchase food. Recipients are mailed a reminder if they have not used the card within 60 days, and the state SNAP agency closes the case if not used it within 90 days. Interview Another potential area for streamlining is around the SNAP program requirement for an interview at initial application and annual recertification. The purpose of the interview is to gather or confirm additional information to determine eligibility, and to provide information to applicants about the program, including their rights and responsibilities. States can conduct interviews by phone for some populations. However, requiring an interview as an eligibility criterion can create a barrier to enrollment for some, preventing or delay- ing otherwise eligible individuals from completing enrollment for failing to complete the interview. The CAP and ESAP pilots have explored alternative approaches to the SNAP interview requirement: \u25b6\u25b6 In CAP states, FNS allowed the SSA in-person interview for SSI to fulfill the state SNAP agency’s interview requirement, both at initial application and at SSI recertification. \u25b6\u25b6 In ESAP states, the SNAP interview requirement at recertification is waived. In some of the initial ESAP pilots, the interview requirement for SNAP was also waived. Waiving the interview requirement, however, would require finding another channel for providing SNAP education to new recipients and giving them opportunities to ask ques- tions about their new benefits. The value of this can be seen in Washington’s specialized call center for its CAP. Since CAP allows the initial interview by SSA to satisfy the SNAP interview requirement, Washington’s CAP call center could be dedicated to providing education and support to recipi- ents once they received their SNAP benefits. The specialized call center staff are trained to handle a variety of questions, ranging from questions about data matching errors to how to use an EBT card, which also helps reduce call volume in Washington’s other human services call centers and county offices. However, waiving the initial interviews for SNAP eligi- bility may be difficult; FNS will permit states to postpone but Simplified Application Implementing a simplified application can be a core compo- nent of streamlining program enrollment. ESAP states have provided individuals who they have identified as being likely eligible for SNAP with a simplified two-page SNAP applica- tion. CAP states with a standard CAP model have built on the SSA existing obligation to facilitate enrollment of SSI recipi- ents into SNAP by adding a small number of SNAP-specific eligibility questions to the existing SSI application, in lieu of a separate SNAP application. If California opts to adopt this approach, state oversight of the SSA obligation may initially be needed to ensure that staff at the local SSA offices ask the additional SNAP questions, capture and record the an- swers, and ensure that the SDX records are sent on a timely basis. Consent Under federal law, individuals seeking SNAP must affirma- tively agree or consent to apply. Typically, the SNAP agency collects an applicant’s consent through a signature on the initial application prior to conducting an eligibility de- termination. Streamlined options for collecting consent from SSI recipients to apply for CalFresh that California might con- sider include: \u25b6\u25b6 Allowing electronic signatures. FNS recently provided states instruction on using electronic signatures for SNAP, which requires the consent to be recorded and be available for review in the individual’s case file.34 \u25b6\u25b6 Providing multiple channels. Individuals enrolled in one program who may be eligible for a second program may need to provide consent prior to being automatically enrolled. Once these indi- viduals are notified of potential eligibility, providing multiple channels of communicating their consent could help increase the response rate for auto enrollment. For example, the California CalFresh\/ Medi-Cal ELE program allowed SNAP recipients to provide consent for Medi-Cal by mail, phone, web portal, or in person. \u25b6\u25b6 Usage of EBT card as proxy for consent. In lieu of providing consent through a signature, some states have allowed an individual’s use of the EBT card to purchase food to indicate consent to be enrolled in SNAP. In New York and Pennsylvania, an individual’s use of an EBT card and PIN mailed FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 12 consist of only those who receive SSI benefits.40 The SNAP agency can deem these individuals eligible for SNAP based on their receipt of SSI and only request any additional in- formation that the SNAP agency needs that SSA does not collect, such as housing costs.41 Benefit Calculation Developing a standard SNAP benefit amount is another way to streamline the SNAP enrollment process. As discussed earlier, an individualized assessment of income and ex- penses for each CalFresh applicant is currently performed to determine eligibility and CalFresh benefit amount. One key difference in the CAP and ESAP models that allows SNAP determination to be simplified is that instead of going through the regular SNAP calculation process to determine a SNAP benefit amount, CAP SNAP recipients receive a standardized SNAP benefit amount. It may be lower than if the recipient went through the regular SNAP eligibility pro- cess, but the advantage of ensuring that more SSI recipients successfully enroll in SNAP benefits is perceived to outweigh this disadvantage. One specific method used by some CAP and ESAP states is to apply standard allowances for living expenses (such as housing, utilities and medical expenses), rather than requesting documentation of actual expenses. For example, most CAP states applied one or more stan- dard allowances to each CAP participant’s reported gross income. The levels of the standard allowances vary in an effort to account for the different levels of housing and other costs actually paid by participants. Individuals who self-re- port high housing or utility costs have their gross income reduced by a higher standard allowance amount than those with smaller costs. The tradeoff of this approach is that some households may receive more or less SNAP benefits than they would if they had provided documentation and were individually assessed based on their actual income and expenses. For example, those who spend less in actual housing expenses than the standard housing allowance re- ceive a higher level of SNAP benefits than if they had gone through an individualized assessment, while those with higher housing costs receive a smaller SNAP benefit amount than they would have under an individualized eligibility de- termination. In the latter cases, however, states report that recipients who received less SNAP benefits than they might have otherwise often remained in CAP (rather than opt to apply through the regular SNAP process and potentially re- ceive more in SNAP benefits) and accepted the lower benefit amount as a tradeoff for the benefit of a more streamlined not waive the initial interview for expedited SNAP applicants and Alabama’s request to continue waiver of the initial inter- view in its ESAP renewal was recently denied by FNS.35 Verification Some SNAP eligibility data, including income and medical deductions, must be verified, often through documentation supplied by the applicant. This can delay the application process if an applicant does not have all of the required information on hand at the time of initial application. Data matching using reliable, external data sources can assist with verification of most eligibility criteria e.g., income, citizenship status, births and deaths so that the appli- cant need only supply information and documentation for a few eligibility criteria rather than all. For example, the U.S. Government Accountability Office (GAO) recently found that SSA data on unearned income is particularly reliable for data matching purposes because the data is current, accessible in real time, and relies on a primary data source.36 One of the key features of ESAP pilots is to leverage this data matching capability to verify certain eligibility criteria, including income and household size, without relying on the applicant to provide information or documentation.37 SSI recipients are already required to report changes to SSA, providing the CalFresh program an opportunity to use SDX data to fulfill at least some CalFresh data verification require- ments as states participating in ESAP do. Eligibility Determination One way to streamline enrollment across public programs is to allow one program’s eligibility determination to serve as the determination for a second program. This is referred to as categorical or deemed eligibility or direct certification. For example, once an applicant has been enrolled in SSI, states have the option to automatically determine them eligible for, and enroll them in, Medicaid.38 More recently, CMS encour- aged states to streamline Medicaid enrollment by directly certifying an individual for Medicaid using existing SNAP eli- gibility determination, without requiring a separate Medicaid application or resubmission of documents that were already provided to the SNAP agency.39 Another option is to apply some of the eligibility calculations for one program to satisfy a second program’s requirement, and to then only collect whatever required information is still needed. Currently, in non-cash-out states, SSI recipients are considered income eligible for SNAP if their households FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 13 Facilitating CalFresh Enrollment for SSI Recipients In the event that California decides to end cash-out, plans will need to be in place to address the following processes: \u25b6\u25b6 Conduct CalFresh eligibility and enrollment for current SSI recipients \u25b6\u25b6 Facilitate CalFresh eligibility and enrollment for new SSI applicants \u25b6\u25b6 Provide ongoing CalFresh case management for SSI recipients \u25b6\u25b6 Manage CalFresh recertification for SSI recipients This section discusses streamlining options for each of these processes to help maximize enrollment of eligible se- niors and disabled individuals into CalFresh based on their linkage to the SSI program, should California end cash-out. CalFresh Eligibility and Enrollment for Current SSI Recipients If California changes its cash-out policy, 1.3 million elderly and disabled SSI recipients will become potentially eligible for CalFresh. Given the size of this population, CDSS and county human services agencies could face capacity and efficiency challenges in expediently processing applications if a large volume of CalFresh applications from existing SSI recipients are submitted all at once. One option is to do a phased rollout, by county or by SSI sub-population (for ex- ample, process individuals first, followed by more complex households), using the current CalFresh eligibility and enroll- ment process. A second option is to use available SSI data to identify a subset of the SSI population that is highly likely to be eligible for CalFresh, and implement a one-time simplified enroll- ment process a fast track for this group. Households with more complex situations, the non-fast track popula- tion, could be assessed using a process more similar to the current CalFresh eligibility determination process. This section outlines options and considerations for CalFresh el- igibility and enrollment for both the fast track and non-fast track groups. enrollment process, including a longer recertification period and no interim reporting requirements. The CalFresh benefit calculation could be further simplified by assuming the same gross income for all SSI recipients as well as applying the same deductions and standard al- lowances for some groups of SSI recipients. Applying a standard allowance to a standard gross income results in the same amount of SNAP benefits, thereby effectively cre- ating a standard benefit amount. Because SSI recipients with no income other than their SSI benefit have generally the same level of gross income (as defined by the federal pov- erty level), CAP states are able to predetermine the SNAP benefit amount by applying a few standard allowances to the same gross SSI income. By creating a standard bene- fit amount, applicants do not have to provide documentation of their income and expenses, the administrative costs for the SNAP agency to follow up with applicants who failed to submit documents are reduced, and more eligible appli- cants are likely to receive benefits rather than being denied for lack of documents. Recertification Once an individual successfully completes the application process and is enrolled in the program, a streamlined re- certification process can improve continuity of benefits. One option for streamlining CalFresh recertification of SSI recip- ients is to extend the time between recertification. In ESAP states, the SNAP recertification period is extended from 12 months to 36 months. Many CAP states have also opted to extend the recertification period beyond 12 months, either to 24 months or 36 months. Another potential option for streamlining recertification would be to waive or reduce the frequency of SNAP interim report- ing requirements for SSI recipients, which could also help reduce administrative costs for the SNAP agency. In some ESAP states, interim reporting during the 36-month recertifi- cation period was not required, based on the relative stability of residence, income, and disability status among the el- derly and disabled participants. Alternatively, rather than waiving interim reporting altogether, data matching could be used to satisfy the interim reporting requirements. For example, ESAP states are required to leverage data match- ing capabilities at recertification to verify certain eligibility criteria, including income and household size, only asking program participants to provide information or documenta- tion, if needed.42 FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 14 b. Notify recipients that use of their EBT card will indicate their consent to accept the CalFresh benefits. 6. Conduct interviews by phone, or waive the interview requirement. 7. Conduct outreach to recipients who fail to respond to the initial notice (5a) or fail to use their EBT card (5b). Send individuals who fail to respond or use their EBT card a notice of discontinuance and provide information on how to apply for CalFresh benefits if they choose to do so in the future. 8. Provide ongoing case management by leveraging data reported to SSA by SSI recipients wherever possible. Implementing this streamlined approach for the fast track population would require the following: \u25b6\u25b6 Modify the existing SSA-CDSS data sharing agree- ment to allow CDSS to use SDX data to determine CalFresh eligibility, currently not identified in the agreement because of cash-out. \u25b6\u25b6 Develop and apply pre-set standard allowances, including housing and medical. If the same gross income is assumed for all fast track individuals, a policy option discussed below, determine and apply a standard benefit amount. \u25b6\u25b6 Allow electronic or telephonic signature to serve as consent for CalFresh and establish a mechanism to collect and store electronic\/telephonic signatures per FNS guidance; or allow initial use of the EBT card to establish consent. \u25b6\u25b6 Potentially waive the interview requirement. \u25b6\u25b6 Provide a point of contact for SSI recipients to ask questions, conduct interviews, and provide con- sent as needed during the initial enrollment period. The implementation details for many of the steps above will depend on key policy decisions, some of which may require a federal waiver, including: \u25b6\u25b6 Create standard deductions for housing allowance and medical expenses for only the fast track popula- tion to allow simplified enrollment. (This would require a federal waiver.) Fast Track Identifying the Fast Track Population The fast track population could be defined as single indi- viduals or couples whose only income comes from SSI. This group has also been referred to as pure SSI households, and is considered categorically eligible for SNAP in all other states.43 The fast track population can be identified using available SSI data, either directly from the SDX data set, or possibly via the subset of SDX data fields that are delivered to MEDS. One caveat is that this group might include SSI recipients who purchase and prepare meals with non-spousal room- mates or other family members who are included in the CalFresh definition of household, but are not part of the SSI program’s household definition. However, for purposes of identifying a fast track population in order to streamline initial enrollment of current SSI recipients, the state might explore allowing the SSI definition of household to meet the CalFresh household definition in this specific circumstance (poten- tially requiring a federal waiver). Potential Streamlined Enrollment Process A potential streamlined approach for initial CalFresh enroll- ment for the fast track population could include the following steps: 1. Generate a data file of the fast track population from SDX, using a pre-determined set of data elements and criteria. 2. Calculate the initial CalFresh benefit amount for the entire fast track population using standard allowances (includ- ing housing and medical) for everyone in this population and assuming the same gross income. 3. Issue notice of eligibility to recipients. 4. Send the data file electronically to the EBT vendor (Xerox) with recipient information and benefit amount so that Xerox can generate the EBT cards. 5. Issue and mail to recipients an EBT card, PIN number, and instructions on how to accept and use the benefits. a. Notify recipients that they need to contact the program via phone, web portal, in person, or by mail to accept their CalFresh benefits and get additional information. Collect their consent to enroll by electronic\/telephonic signature, in person, or by mail; or FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 15 Considerations and Tradeoffs Benefit calculation. Establishing a standard CalFresh benefit amount using predetermined housing and utility allowances, regardless of actual housing costs, would help to avoid the need for collecting additional information and documentation from the fast track population before making a CalFresh determination. As housing costs vary greatly in California, those in the fast track population with high housing costs might receive a smaller level of CalFresh ben- efits than they would have if they went through the existing CalFresh determination process, while those with less costly housing (including the homeless) would receive more than they would otherwise qualify. The tradeoff for these recipi- ents opting for the fast track streamlined enrollment process over the existing individualized CalFresh process, however, would be to obtain CalFresh benefits more quickly and easily. A standard utility allowance (SUA) already exists in CalFresh. The state could explore creating a new standard housing allowance to establish a standard benefit amount for enroll- ment of the fast track population. The state could allow fast track recipients to opt out of the standard benefit at any point after the initial enrollment and request a full CalFresh eligibility determination, likely requir- ing the collection of additional information. The county could conduct an individualized CalFresh determination and re- calculate the benefit amount if the SSI recipient provides \u25b6\u25b6 Determine which method to use to calculate the monthly benefit amount using only SDX data. Potential options include: Option 1. Calculate the benefit amount for every individual assuming the same income and deductions for all recip- ients, regardless of income data in SDX, resulting in the same benefit amount for everyone. Using California’s cur- rent average benefit amount as an example, all individuals in the fast track population would receive $200 per month regardless of how much they spend on housing.44 Option 2. Apply standard deductions to each individual’s actual income reported in SDX. May result in minimal vari- ances to the benefit amount. Option 3. Like option 1, but instead of assuming the same income and deductions for all, assume no income outside of SSI or deductions and provide the minimum CalFresh benefit amount, which is currently $17 per month. \u25b6\u25b6 Permit use of a simplified interview requirement for the fast track population or use the SSA interview of the SSI recipient to satisfy the CalFresh interview re- quirement. (This would require a federal waiver.) Figure 3. Potential Streamlined Enrollment Process for Fast Track Population Applicant Agency\/worker DETERMINE BENEFIT DELIVER BENEFIT FINALIZE ELIGIBILITY IDENTIFY POPULATION Generate fast track list from SDX Apply CalFresh benefit amount Send fast track list to EBT vendor EBT vendor mails EBT card, PIN, and instructions to accept the benefits Recipient completes steps to accept the benefit FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 16 Non-Fast Track Identifying the Non-Fast Track Population By definition, SSI recipients who are not identified as fast track would be considered non-fast track. In general, non- fast track recipients would have additional sources of income and\/or additional members in their households than those in the fast track population. This greater level of complexity would make it difficult to assess CalFresh eligibility without additional information about who else is in their household or the sources and amounts of their other income. Because the eligibility rules for what income is counted and who is part of the household are different in SSI and CalFresh, the county human services agencies would likely need to conduct a full eligibility determination to get an accurate CalFresh benefit amount for the non-fast track population. Moreover, additional household members who reside with the SSI recipient may already receive CalFresh, or may have received CalFresh benefits in the past. If so, there would be an existing case in SAWS containing information that may allow for a preliminary recertification of everyone in the cur- rent CalFresh household, including the SSI recipient. Given these differences within the non-fast track population and to help streamline enrollment, California may want to identify different types of SSI households within the non-fast track population solely using SDX data and process each group into CalFresh separately as a batch at different times. The enrollment of the non-fast track population could be phased in as follows: \u25b6\u25b6 Group 1. SSI recipients who live alone or with their spouse only, but are not fast track due to having sources of income other than SSI; \u25b6\u25b6 Group 2. SSI recipients who live with additional household members who do not currently receive CalFresh benefits; \u25b6\u25b6 Group 3. SSI recipients who live with additional household members who currently receive CalFresh. Group 1 could be identified using only SDX data. The re- maining population would need to be assessed, using SAWS, to determine whether or not their household has an existing CalFresh case in order to classify them into either Group 2 or Group 3. documentation of actual housing or medical costs and complies with other requirements. The ability to opt out is available in some CAP pilots, thus allowing the eligible SNAP recipient to choose between enrolling in SNAP through the standard application and recertification process with an in- dividualized benefit amount, or enrolling through the CAP with a more streamlined process with fewer reporting and recertification requirements and a standard benefit amount. California could consider a similar approach. Case creation. As discussed earlier, county human services offices conduct the CalFresh case creation process. Under the current CalFresh enrollment process, county workers conduct file clearance and enter applicant information into SAWS before a new case can be created (or an existing case can be modified) in SAWS and the enrollment process can proceed. Streamlining this step could help to expedite the initial enrollment of fast track recipients. For example, the state could implement technology solutions to better support the clearance process, and use those to identify and clean up existing duplicate records. Alternatively, the timeline for this effort must provide sufficient lead time and funding for staff to complete this step prior to the target date for the first benefits to be issued. Communication with recipients. If SSI recipients in California become newly eligible for CalFresh they will need educa- tion to help them understand and use their new benefits. In addition, SSI recipients who are notified of their new eligibil- ity for CalFresh will need an easy way to give their consent and complete the required CalFresh interview, if not waived. Providing multiple pathways for recipients to communicate with the program, including phone, web portal, in-person, and mail can help increase participation. Based on successful models in the CAP and ESAP pilots, California could designate one or more call centers with staff trained to support the SSI population to handle incoming re- quests, conduct phone interviews and obtain telephonic consent (if needed), provide education about CalFresh and use of the EBT card, and make outbound calls to fast track individuals who do not respond within a certain time frame. Given the magnitude of the potential policy change, pro- viding specialized training to call center staff will be vital. Providing one example, Washington’s CAP set up a des- ignated call center staffed by a small number of specially trained workers, allowing it to more efficiently process about 60,000 new SNAP cases created through CAP. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 17 send a notice and a simplified CalFresh application to collect needed information for all household members. c. Allow a set number of days for the SSI recipient to respond via multiple channels and follow up with non-responders. d. Use the information received from the simplified ap- plication to determine if the SSI recipient is eligible for CalFresh and what the benefit amount should be. Send notice of eligibility and EBT card. 3. For Group 3: a. Determine the next recertification date for the CalFresh household. Potential Streamlined Enrollment Process A potential streamlined approach for the initial CalFresh en- rollment for the non-fast track population could include the following steps: 1. Identify the non-fast track individuals in each of the three groups (identified above) using SDX and SAWS. 2. For Groups 1 and 2: a. Determine what information is still missing to deter- mine CalFresh eligibility. b. For Group 1, send a notice to the SSI recipient asking for any additional information needed to clarify income and complete the eligibility determination. For Group 2, Figure 4. Potential Streamlined Enrollment Process for Non-Fast Track Population COLLECT REMAINING INFORMATION DELIVER BENEFIT AND\/OR NOTICE FINALIZE ELIGIBILITY IDENTIFY POPULATION Generate fast track list from SDX Send fast track list to EBT vendor Determine eligibility Send an application Send CalFresh EBT card and PIN Check if recipient already has a MEDS record For those not known to MEDS For those known to MEDS Recipient completes application For those who live in a household already receiving CalFresh Send notice explaining that the SSI household member (and his\/her income) will be included in the CalFresh household at recertification Applicant Agency\/worker For those who live alone or in a household not receiving CalFresh FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 18 \u25b6\u25b6 Consider treating all SSI recipients as individual households (see sidebar). In simplifying CalFresh enrollment for non-fast track SSI re- cipients, California could also facilitate enrollment for non-SSI individuals in those households who are potentially eligible for, but not enrolled in, CalFresh, thereby further reducing food insecurity in California and increasing the CalFresh par- ticipation rate. However, some existing CalFresh households that have an SSI household member could see a reduction in their CalFresh benefit amount or become ineligible for CalFresh altogether. Under existing CalFresh eligibility rules, a SSI recipient is not counted as part of the CalFresh house- hold and the SSI income is not included in the CalFresh benefit calculation. If cash-out ends, the SSI recipient and corresponding income would be counted in the CalFresh eligibility and benefit calculation, and would change the income of the overall household. b. Send a notice to explain the policy change and that the SSI household member will need to be included as part of the next CalFresh recertification. c. Recertify CalFresh eligibility for the entire household at that next recertification date. Considerations and Tradeoffs Non-fast track SSI recipients would likely require an individ- ualized assessment before they could be found eligible for CalFresh. However, changes to the existing CalFresh enroll- ment process could help streamline this process. Potential options include: \u25b6\u25b6 Leverage existing SDX and MEDS data to the greatest extent possible to initiate CalFresh enroll- ment, and if needed for consent and\/or additional information, ask non-fast track households to complete a pre-populated form or simplified ap- plication rather than requiring submission of a full CalFresh application (the potential costs of this ap- proach would need to be assessed). \u25b6\u25b6 Send an individualized notice, preferably from SSA, to all non-fast track SSI recipients in California to explain the change in CalFresh policy and to alert them that they will be contacted with information about any required next steps needed to assess their eligibility for, or complete their en- rollment in, CalFresh. \u25b6\u25b6 Provide a list of non-fast track SSI recipients to county human services agencies for purposes of outreach and follow-up. The following policy changes could support a streamlined process: \u25b6\u25b6 Require use of electronic data sources (such as SAWS, SDX and MEDS) to conduct ex-parte review of eligibility for all non-fast track individuals, includ- ing those living with other household members; do not request documentation for information that can be verified electronically. \u25b6\u25b6 Postpone any change in eligibility or benefit amount for existing CalFresh households until the next scheduled CalFresh recertification date. \u25b6\u25b6 Consider potential disregard of non-SSI income and resources for initial enrollment of the non-fast track population. Treating All SSI Recipients as Their Own Households A policy option that California previously explored and may want to consider again is to seek a fed- eral waiver to treat all SSI recipients as their own households. This would alleviate the need for the state to analyze the household composition of current SSI recipients during the initial enrollment into CalFresh and to more easily recertify existing CalFresh households that have SSI household members. Under this approach, all SSI recipients could be treated as fast track, so long as they do not have non-SSI income. A separate CalFresh case could be created for every SSI recipient, and any existing CalFresh cases for households with SSI recipients would continue to exclude the SSI individual and SSI income as part of the house- hold. However, if California opts to consider this option, it should be explored in more detail with counties and SAWS to determine optimal admin- istration structure to minimize workload impacts and automation costs. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 19 4. The state could further simplify CalFresh enrollment for new SSI fast track applicants by: \u25b6\u25b6 Deeming the SSI interview to satisfy the initial CalFresh phone interview, via a waiver; \u25b6\u25b6 Allowing SSA to collect an individual’s consent to apply for CalFresh via the SSI application process, if use of the EBT card is not sufficient for consent. 5. CDSS could also regularly review the SDX record to iden- tify new fast track individuals by: \u25b6\u25b6 Using the same eligibility criteria as those used in the initial enrollment of fast track individuals; or \u25b6\u25b6 Looking for new applicants who indicated on their SSI applications that they currently do not have, but would like to apply for, CalFresh.45, 46 Best practices from other states related to streamlining SNAP enrollment for new SSI applicants can also inform California’s approach, including: 1. Training for staff in California SSA offices about the change in policy and new procedures for CalFresh enroll- ment for SSI applicants and recipients, such as: \u25b6\u25b6 How to help SSI applicants complete and submit CalFresh applications \u25b6\u25b6 Potentially adding questions to the SSI application to ensure there is sufficient information in the SDX record to screen for CalFresh eligibility 2. Creating liaisons between SSA, CDSS and the California county agencies 3. Providing one or more designated call centers where SSA staff can refer SSI applicants and recipients for individual assistance with CalFresh Ongoing CalFresh Case Management for SSI Recipients County human services offices will manage ongoing CalFresh case management for the SSI population, as they do for current CalFresh recipients. County staff will support SSI recipients with a wide range of tasks including benefits questions, EBT card replacements and PIN changes, and changes in address, household composition, and income. These processes could be supported by ensuring spe- cialized training for staff on providing customer support for elderly and disabled individuals. Counties may opt to One way to help temporarily mitigate this issue would be to delay any recertification of SSI recipients in households with existing CalFresh cases until the next scheduled CalFresh recertification date. California could also consider using po- tential cost savings from streamlined enrollment for the fast track and other non-fast track groups to offset potential re- ductions in or loss of benefits for affected households. CalFresh Eligibility and Enrollment for New SSI Applicants Following the initial enrollment of existing SSI recipients into CalFresh, individuals who are newly applying for SSI could also benefit from a streamlined CalFresh enrollment process. Leveraging the existing SSA obligation to assist SSI appli- cants with CalFresh applications, a potential streamlined approach could involve the following steps: 1. Individual applies for SSI. The current SSI application could be modified to ask applicants if they currently receive CalFresh or would like to apply for CalFresh. This is a similar approach to the one used in the standard CAP model. That information is recorded in the SDX record, as it currently is in CAP pilot states. 2. At the initial SSI interview, SSA notifies every SSI applicant regarding eligibility status for CalFresh. SSA conducts a preliminary screen to determine if applicants currently receive CalFresh and whether they could be classified as fast track for CalFresh purposes. For those not already receiving CalFresh benefits: \u25b6\u25b6 If not fast track, SSA provides applicants with a CalFresh application and refers them to the appro- priate state or county agency to apply for CalFresh. \u25b6\u25b6 If fast track, SSA assists with expediting enrollment into CalFresh as described in steps 3 to 4. 3. SSA assists fast track applicants with enrollment into CalFresh by: \u25b6\u25b6 Providing a streamlined CalFresh application, sim- ilar to the simplified applications used in the CAP and ESAP pilots, and delivers the application to the appropriate state or county agency for expedited processing. Under existing federal rules, CDSS must ensure an eligibility determination is com- pleted within 30 days. \u25b6\u25b6 Or, facilitating submission of an online CalFresh application through the county SAWS portal. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 20 Based on lessons from other states, California could simplify and streamline CalFresh recertification for the SSI fast track population by making the following policy changes: 1. Depending on state policy decisions and federal require- ments of budget neutrality, individualized assessments of CalFresh eligibility for fast track individuals who re- ceived a standard benefit amount at initial enrollment, could be done at the first recertification date. This could allow verification of the CalFresh household and permit a change in the monthly benefit for those with high housing costs. However, this could result in a large number of in- dividualized assessments coming due at the same time, potentially resulting in significant caseload management issues. To alleviate a potential backlog, a phased recerti- fication approach could be considered. 2. Allow fast track SSI recipients to extend CalFresh recertifi- cation to three years with a waiver from FNS. Alternatively, the state could apply the existing CalFresh two-year re- certification period, currently available only to aged and disabled individuals, to all SSI recipients. 3. Waive interim reporting requirements between recerti- fication periods (which could be accomplished through an ESAP pilot). Alternatively, allow changes reported to SSA between CalFresh recertification periods that are reflected in the SDX data to meet interim reporting re- quirements. This would still require some county action to update SAWS with the new information, but would require recipients to report a change only once. 4. Explore data-matching policies and procedures that could initiate a CalFresh redetermination in SAWS if data from SDX indicates an SSI recipient loses SSI eligibility before the next CalFresh recertification period, and request ad- ditional information from the recipient only if needed. 5. Allow use of the SSA periodic redetermination of SSI eli- gibility to automatically serve as a CalFresh recertification for fast track individuals. California could recertify using the same or a new standard CalFresh benefit amount. Non-fast track households would use the current CalFresh re- certification process. However, efficiencies could be achieved if CalFresh is able to conduct an ex-parte recertification of SSI recipients using the most current data from the SDX record, only requesting that SSI recipients provide additional information if not otherwise available (similar to the stream- lined process for fast track households outlined above). provide this training broadly, or to designate specific staff or units to provide support to the SSI population. In fact, some counties already designate specific units to support elderly public program recipients. Regardless of the approach, careful planning will be required to ensure adequate staffing levels to support the expanded caseload. CalFresh Recertification for SSI Recipients The current recertification process for CalFresh is: 1. A 12-month recertification period for most households and 24-month recertification period for the elderly and disabled.47 2. Interview required at recertification phone interview is permitted unless the CalFresh recipient requests an in-person interview.48 3. Interim reporting for the elderly and disabled is required at 6, 12 and 18 months for households with earned income, and at 12 months for households with no earned income. This process could be simplified for fast track SSI recipients by leveraging the SSA redetermination process for SSI. For individuals whose SSI is based on disability, SSA conducts a disability review annually or every three years, depending on the severity of the disability.49 For all other SSI eligibil- ity criteria, SSI recipients must report changes to SSA no later than 10 days after the end of the month in which the change occurred.50 In order to minimize the recipient having to report the same changes multiple times, California could explore policy and technology changes that would permit data matching from SDX to meet CalFresh interim reporting requirements. Because CalFresh and SSI have similar financial eligibil- ity criteria and deadlines for reporting changes, California could choose to rely on SDX data for CalFresh recertifica- tion and interim reporting to lessen the burden on recipients, avoid duplication of SSA processes for verification and rede- termination of new information, and help reduce the churn that occurs when individuals fail to provide requested docu- mentation at renewal, but are otherwise eligible for continued enrollment. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 21 senior centers, independent living centers, and other com- munity-based organizations and human services agencies. Alabama’s ESAP, for example, has succeeded in enrolling more than 60,000 elderly individuals into SNAP due, in part, to coordinated outreach efforts between the Department of Human Resources and community-based organizations. In California, community partners could provide individu- alized support, answer questions and provide education about the CalFresh program and how to use the benefits. State and county agencies could help increase recipient satisfaction and increase CalFresh participation rates by in- volving all community resources and trusted partners. The state could also send a joint notice with SSA or a general notice about the CalFresh program, followed by a person- alized notice explaining next steps, based on whether the individual is identified as fast track or non-fast track. Multiple Communication Channels The SSI population in California is diverse and is likely to have a range of customer support needs that will require a flexible and multi-channel enrollment and communications approach. For example, technology solutions, such as use of a web-portal to provide information or enabling communi- cations solely by email or text, could greatly help streamline enrollment and communications with SSI recipients and may be the preferred method of communication for some. However, other SSI recipients who do not feel comfortable with technology or prefer face-to-face interactions will need alternative ways to ask questions and communicate with the state about their new CalFresh options. For example, low-in- come seniors tend to have lower adoption of technology than the broader population; only 39% of surveyed seniors with incomes below $30,000 reported that they go online com- pared to 59% of all seniors and 86% of all adults. Even fewer low-income seniors have access to broadband services at home 25% compared to 47% of all seniors and 70% of all adults.51 Similarly, adults with disabilities are as a group less likely than non-disabled adults to use the Internet (54% com- pared to 81%) or have broadband at home (41% compared to 69%), though that gap has been narrowing over time.52 An optimal solution for supporting the transition of SSI recip- ients into CalFresh would therefore encompass a range of enrollment and customer support channels, including phone support, in-person assistance, web-based solutions, and mail. Additional Considerations Along with the suggestions discussed above, there are ad- ditional lessons learned from other states that California can take into consideration. Based on positive results from ESAP states, for example, FNS has recommended that new ESAP pilots adopt best practices such as collaboration with com- munity partners on outreach, specialized call centers for handling ESAP cases and questions, and the development of targeted communications materials such as resource guides to support recipients. Some of these considerations are described briefly below. Planning and Phased Rollout Given the size and diversity of the SSI population in California and the complexity of the process involved in eligibility de- termination for, and enrollment in, CalFresh, which includes outreach and education, it will be critical for California to plan carefully for the roll-out. CDSS, counties, and other stakeholders can work in partnership to plan and determine the best business process flow for enrollment and recertifi- cation of SSI recipients in CalFresh based on the adopted streamlining options. County human services agencies may have their own relationships with local SSA offices that can be leveraged as part of the transition, or may have spe- cialized units that have experience working with aged and disabled populations. California may also want to consider a phased approach to implementation, rolling out the ex- isting SSI population in different subgroups to reduce the simultaneous volume of new CalFresh cases. This approach would give county human services agencies the opportunity to test and refine the enrollment process with a smaller pop- ulation, ensuring those individuals receive and understand how to use their CalFresh benefits before opening up enroll- ment more broadly. It would also allow for careful planning and adjustments as needed for training relevant staff, antic- ipating workload changes, and otherwise ensuring efficient operations. Working with Trusted Partners Early communication with SSI recipients will be particularly important. Many existing SSI recipients in California may not have interacted with the state or county agencies that admin- ister CalFresh. Initial communications coming directly from these agencies, therefore, may be met with confusion or mis- trust. As California plans its education and outreach strategy, it may want to consider partnering with organizations that are known to and trusted by the SSI population SSA, FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 22 Conclusion If California ends cash-out, it can consider a range of options for streamlining enrollment in CalFresh for SSI re- cipients. Evaluating these options will require decisions about the respective roles of federal, state and county agencies, the potential need for state policy changes, the ability to leverage existing technology, and one-time verses ongoing process and program changes. These decisions will ultimately determine whether seniors and people with disabilities in California are able to obtain the nutrition as- sistance they need in a manner that is least burdensome for them and most efficient for the state. Training and Customer Support Based on lessons learned from states with CAP and ESAP states, putting in place a dedicated call center with staff who have been trained specifically to support the SSI popu- lation can help increase SNAP program enrollment. Training staff to understand the preferences and perceived barri- ers of seniors and people with disabilities can lead to better interactions and a greater likelihood that they will want to provide additional information that may be needed to help them apply for or use their SNAP benefits. In California, the state could work with county human services agencies to leverage or create designated call centers that are trained to assist not only with initial CalFresh enrollment for this popu- lation but with ongoing determinations, recertification, and\/ or case management. For example, after the initial rollout of the pilot did not go as smoothly as planned, Alabama established a dedicated call center for its ESAP pilot and today that call center remains a central part of the ESAP pilot for new enrollments and recer- tification. Washington’s WASHCAP set up a dedicated call center at the start of the pilot, which was staffed by a small number of specially trained call center workers (six eligibility workers and one supervisor) that and took calls exclusively from SSI recipients enrolled in WASHCAP. Washington found that many seniors preferred to use the phone as a way to seek information and ask questions. Because WASHCAP staff were trained specifically for, and dedicated solely to, WASHCAP SNAP cases, they were able to process their caseloads efficiently. Moreover, staff in SSA offices will need to be trained on the change in policy and whatever process California estab- lishes to enroll existing and newly eligible SSI individuals. Creating materials like FAQs, fact sheets, and scripts for the SSA call center staff could also help make the transition easier for SSI recipients. FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 23 16. State Agreements , Social Security Administration, www.ssa.gov. 17. Recertification every six years may be permitted if changes are not likely. POMS Section SI 02301.005, secure.ssa.gov. 18. See 7 Code of Federal Regulations (CFR) 273.2(e) for the Supplemental Nutrition Assistance Program (SNAP) require- ments for initial applicant interview. See 7 CFR 273.14(3) for SNAP recertification interview requirements. Initial interview for SNAP applicants can be done by phone rather than in-person for households without earned income or whose members are el- derly or disabled. 19. CalFresh Eligibility and Issuance Requirements, California Department of Social Services, www.dss.cahwnet.gov. 20. California is considering developing a standard medical deduc- tion rather than applying actual costs, which is currently done in 16 other states. See for example, Ty Jones, SNAP’s Excess Medical Expense Deduction: Targeting Food Assistance to Low- Income Seniors and Individuals with Disabilities, (Center for Budget Policy and Priorities, August 2014), www.cbpp.org. 21. A Quick Guide to SNAP Eligibility and Benefits, Center on Budget Policy and Priorities, November 5, 2015, www.cbpp.org. 22. See 7 CFR 273.2(e), 273.2(k). Additional details of SSA’ ob- ligation are included in the Memorandum of Understanding (MOU) between U.S. Department of Agriculture (USDA) and SSA. 23. 7 CFR 273.2(k) POMS Section SI 01801.005, secure.ssa.gov. 24. Understanding Supplemental Security Income (SSI) and Other Government Programs: 2016 Edition, Social Security Administration, www.ssa.gov. 25. Social Security: Nutrition Assistance Programs, Social Security Administration, www.ssa.gov (PDF). 26. 7 CFR 273.2(m) and 7 CFR 273.2(k)(1)(i)(H). 27. Senior SNAP Participation Visualization, National Council on Aging, www.ncoa.org. 28. State Trends in Supplemental Nutrition Assistance Program Eligibility and Participation Among Elderly Individuals, Fiscal Year 2008 to Fiscal Year 2013, Mathematica Policy Research, July 2015, www.mathematica-mpr.com (PDF). 29. Combined Application Projects: Guidance for States Developing Projects, U.S. Department of Agriculture, Food and Nutrition Services, March 2005, www.fns.usda.gov (PDF). 30. Fact Sheet: USDA Support for Older Americans, U.S. Department of Agriculture, Food and Nutrition Services, July 2015, www.fns.usda.gov. 31. Elderly Simplified Application Project Guidance, U.S. Department of Agriculture, Food and Nutrition Services, Program Development Division, Fiscal Year 2015-2016, www.fns.usda.gov (PDF). Endnotes 1. Autumn Arnold and Amy Marinacci, Cash-Out in California: A History of Help and Harm, California Food Policy Advocates, August 2003, cfpa.net (PDF). 2. Ibid. 3. SSI\/SSP Payment Standards, California Department of Social Services, January 2016, caassistedliving.org (PDF); Poverty Guidelines, Office of the Assistant Secretary for Planning and Evaluation, U.S. Department of Health & Human Services, January 2016, aspe.hhs.gov. 4. AJR-35 Supplemental Nutrition Assistance Program: cash-out policy, California Legislative Information, U.S. Senate, August 16, 2016, leginfo.legislature.ca.gov. 5. Sarah Strickhouser, James D. Wright, and Amy M. Donley, Food Insecurity Among Older Adults, AARP Foundation, September 2014, www.aarp.org (PDF). 6. Ibid. 7. Marisa Agha, Fighting poor nutrition among California seniors with a food truck, Tales From The Field, California Department for Food and Agriculture, blogs.cdfa.ca.gov. 8. Jung Sun Lee and Edward A. Frongillo Jr., Nutritional and Health Consequences Are Associated with Food Insecurity among U.S. Elderly Persons, The Journal of Nutrition, 131(5), American Society for Nutritional Sciences, May 2001, jn.nutrition.org. 9. Senior SNAP Participation Visualization, National Council on Aging, Retrieved September 8, 2016, www.ncoa.org. 10. SSI does not depend on prior work history, and individuals can receive SSI if they live alone, with others, or in an eligible institu- tion. Living arrangements may affect the amount of SSI received if others are paying for housing and other basic necessities. SSA permits and encourages SSI recipients to work if possi- ble so they can receive earned income while also receiving SSI. Supplemental Security Income (SSI) Living Arrangements, Social Security Administration, www.ssa.gov. 11. SSI Recipients by State and County, 2014, Social Security Administration, Office of Retirement and Disability Policy, 2015, www.ssa.gov (PDF). 12. Ibid. 13. Individual is income eligible as long as countable income is less than the federal benefit amounts and resources are beneath certain thresholds. For 2016, the maximum SSI federal benefit amount is $733 for an individual and $1,100 for a couple (www.ssa.gov). This amount decreases if a SSI recipient re- ceives any countable income by subtracting the amount of the countable income from the maximum SSI federal benefit amount (www.ssa.gov). Countable resources must be less than $2,000 for an individual and $3,000 for a couple (www.ssa.gov). 14. Social Security Administration Program Operations Manual (POMS), Sections GN 00203.001 and SI 00601.060, secure.ssa.gov and secure.ssa.gov. 15. List of data elements and their descriptions, Social Security Administration, www.ssa.gov (PDF). https:\/\/www.ssa.gov\/dataexchange\/stateagreements.html https:\/\/secure.ssa.gov\/apps10\/poms.nsf\/lnx\/0502301005 http:\/\/www.dss.cahwnet.gov\/foodstamps\/PG841.htm#inc http:\/\/www.cbpp.org\/research\/snaps-excess-medical-expense-deduction?fa=view&id=4189 http:\/\/www.cbpp.org\/research\/a-quick-guide-to-snap-eligibility-and-benefits https:\/\/secure.ssa.gov\/apps10\/poms.nsf\/lnx\/0501801005 https:\/\/www.ssa.gov\/ssi\/text-other-ussi.htm https:\/\/www.ssa.gov\/pubs\/EN-05-10100.pdf https:\/\/www.ncoa.org\/economic-security\/benefits\/visualizations\/senior-snap-participation\/ https:\/\/www.mathematica-mpr.com\/our-publications-and-findings\/publications\/state-trends-in-supplemental-nutrition-assistance-program-eligibility-and-participation-among-elderly-individuals http:\/\/www.fns.usda.gov\/sites\/default\/files\/CAPsDevelopmentGuidance.pdf http:\/\/www.fns.usda.gov\/pressrelease\/2015\/020215 http:\/\/www.fns.usda.gov\/sites\/default\/files\/snap\/ESAP_Guidance.pdf http:\/\/cfpa.net\/CalFresh\/CFPAPublications\/CalFresh-CashOutHelpHarm-2003.pdf https:\/\/caassistedliving.org\/pdf\/resources\/ssi-ssp.pdf https:\/\/aspe.hhs.gov\/poverty-guidelines https:\/\/leginfo.legislature.ca.gov\/faces\/billTextClient.xhtml?bill_id=201520160AJR35 http:\/\/www.aarp.org\/content\/dam\/aarp\/aarp_foundation\/2015-PDFs\/AF-Food-Insecurity-2015Update-Final-Report.pdf http:\/\/blogs.cdfa.ca.gov\/TalesFromTheField\/?p=754 http:\/\/jn.nutrition.org\/content\/131\/5\/1503.abstract https:\/\/www.ncoa.org\/economic-security\/benefits\/visualizations\/senior-snap-participation\/ https:\/\/www.ssa.gov\/ssi\/text-living-ussi.htm https:\/\/www.ssa.gov\/policy\/docs\/statcomps\/ssi_sc\/2014\/ca.pdf https:\/\/www.ssa.gov\/ssi\/text-benefits-ussi.htm https:\/\/www.ssa.gov\/oact\/cola\/countableincome.html https:\/\/www.ssa.gov\/ssi\/text-resources-ussi.htm https:\/\/secure.ssa.gov\/apps10\/poms.nsf\/lnx\/0200203001 https:\/\/secure.ssa.gov\/apps10\/poms.nsf\/lnx\/0500601060 https:\/\/www.ssa.gov\/dataexchange\/documents\/SDX%20record.pdf FACILITATING CALFRESH ELIGIBILITY AND ENROLLMENT FOR SSI RECIPIENTS 24 42. Elderly Simplified Application Project Guidance, U.S. Department of Agriculture, Food and Nutrition Services, Program Development Division, Fiscal Year 2015-2016, www.fns.usda.gov (PDF). 43. See 7 CFR 273.2(j)(1)(iv); 273.2(j)(2)(i)(D); 273.2(j)(2)(i)(E). 44. For CalFresh’s average benefit amount to all households, see www.dss.cahwnet.gov. 45. Understanding Supplemental Security Income (SSI) and Other Government Programs: 2016 Edition, Social Security Administration, www.ssa.gov. 46. POMS Section EN-05-10100, www.ssa.gov (PDF). 47. CalFresh recertification periods can vary from one month to two years, depending on whether there are expected changes in the household; see California Manual of Policies and Procedures (MPP) 63-504.141(a) and 63-504.1 for details. Households who only include elderly or disabled individuals are re-certified every two years. See 7 CFR 273.10(f)(1); California MPP 63-504.142. 48. 7 CFR 273.14(b)(3); All County Letter 12-26, California Department of Social Services, May 31, 2012, www.dss.cahwnet.gov (PDF). 49. Continuing Disability Reviews (CDRs) are generally done every 3 years but can be earlier if the underlying medical condi- tion could improve sooner or every 6-7 years if improvement is not expected. Continuing Disability Reviews, Social Security Administration, www.ssa.gov. 50. POMS Section SI 02301.005. For a list of changes that must be reported to SSA, see www.ssa.gov. 51. Aaron Smith, Older Adults and Technology Use, April 3, 2014, www.pewinternet.org. 52. Susannah Fox, Americans Living with Disability and Their Technology Use, Pew Research Center, January 21, 2011, www.pewinternet.org. 32. Policy Options for Using SNAP to Determine Medicaid Eligibility and an Update on Targeted Enrollment Strategies, Centers for Medicare and Medicaid Services, State Health Official Letter 15-001, August 13, 2015, www.medicaid.gov (PDF); Strategies to Enroll and Retain Eligible Children in Medicaid and CHIP, Centers for Medicare and Medicaid Services Informational Bulletin, June 13, 2016, www.medicaid.gov (PDF); Facilitating Medicaid and CHIP Enrollment and Renewal in 2014, Centers for Medicare and Medicaid Services State Health Official Letter 13-03, May 17, 2013, www.medicaid.gov (PDF). 33. Express Lane Enrollment For CalFresh Eligible Adults And Children, All County Welfare Directors’ Letter 14-06, California Department of Health Care Services, February 21, 2014, www.dhcs.ca.gov (PDF). 34. See Accepting SNAP Applicant and Client Signatures Electronically, U.S. Department of Agriculture, April 21, 2016, available at: www.fns.usda.gov (PDF). Also see SNAP Telephonic Signature Guidance, U.S. Department of Agriculture, May 12, 2014, available at: www.fns.usda.gov (PDF). 35. Supplemental Nutrition Assistance Program: Guidance for State Agencies on Novel Waivers, U.S. Department of Agriculture, May 13, 2014, www.fns.usda.gov. 36. Supplemental Nutrition Assistance Program:: More Information on Promising Practices Could Enhance States’ Use of Data Matching for Eligibility, U.S. Government Accountability Office, October 19, 2016, www.gao.gov. 37. Elderly Simplified Application Project Guidance, U.S. Department of Agriculture, Food and Nutrition Services, Program Development Division, Fiscal Year 2015-2016, www.fns.usda.gov (PDF). 38. 42 United States Code 1902(a)(10)(A)(i)(II)(aa) (Section 1634 of the Social Security Act). Section 209(b) of the Social Security Amendments of 1972 gave states the option of using their own criteria for eligibility for Medicaid for SSI recipients rather than provide categorical linkage. For a current list of states that do and do not automatically deem Medicaid eligibility to SSI recipients, see List of State Medicaid Programs for the Aged, Blind and Disabled, SSA POMS Section SI 01715.020, secure.ssa.gov. 39. Policy Options for Using SNAP to Determine Medicaid Eligibility and an Update on Targeted Enrollment Strategies, Centers for Medicare and Medicaid Services, State Health Official Letter 15-001, August 13, 2015, www.medicaid.gov (PDF). 40. See 7 CFR 273.2(j)(1)(iv); 273.2(j)(2)(i)(D); 273.2(j)(2)(i)(E). 41. 7 CFR 273.2(j)(2)(v). SNAP eligibility criteria that are similar to SSI’s include resource, gross and net income limits; Social Security Number; citizenship or immigration status; and resi- dency. The SNAP agency must verify other eligibility factors not collected by SSA, such as determining which SSI household members purchase and prepare food together. 7 CFR 273.2(j) (2)(v)(C). http:\/\/www.fns.usda.gov\/sites\/default\/files\/snap\/ESAP_Guidance.pdf http:\/\/www.dss.cahwnet.gov\/foodstamps\/PG846.htm https:\/\/www.ssa.gov\/ssi\/text-other-ussi.htm https:\/\/www.ssa.gov\/pubs\/EN-05-10100.pdf http:\/\/www.dss.cahwnet.gov\/lettersnotices\/entres\/getinfo\/acl\/2012\/12-26.pdf https:\/\/www.ssa.gov\/ssi\/text-cdrs-ussi.htm https:\/\/www.ssa.gov\/ssi\/text-report-ussi.htm http:\/\/www.pewinternet.org\/2014\/04\/03\/older-adults-and-technology-use\/ http:\/\/www.pewinternet.org\/2011\/01\/21\/americans-living-with-disability-and-their-technology-profile\/ https:\/\/www.medicaid.gov\/Federal-Policy-Guidance\/downloads\/SHO-15-001.pdf https:\/\/www.medicaid.gov\/federal-policy-guidance\/downloads\/cib061316.pdf https:\/\/www.medicaid.gov\/Federal-Policy-Guidance\/downloads\/SHO-13-003.pdf http:\/\/www.dhcs.ca.gov\/services\/medi-cal\/eligibility\/Documents\/ACWDL2014\/14-06.pdf http:\/\/www.fns.usda.gov\/sites\/default\/files\/snap\/Electronic_Signatures_Memo.pdf http:\/\/www.fns.usda.gov\/sites\/default\/files\/SNAP%20Telephonic%20Signatures%20Policy%20Memo.pdf http:\/\/www.fns.usda.gov\/snap\/snap-guidance-state-agencies-novel-waivers http:\/\/www.gao.gov\/products\/GAO-17-111 http:\/\/www.fns.usda.gov\/sites\/default\/files\/snap\/ESAP_Guidance.pdf https:\/\/secure.ssa.gov\/poms.nsf\/lnx\/0501715020 https:\/\/www.medicaid.gov\/Federal-Policy-Guidance\/downloads\/SHO-15-001.pdf Executive Summary Streamlined CalFresh Enrollment Options for SSI Recipients Additional Considerations Introduction Background Current California Landscape SSI CalFresh Streamlined Enrollment Models SSA Role in SNAP Enrollment Simplified SNAP Enrollment Pilots Streamlined Enrollment Based on Eligibility for Other Programs Options for Streamlining Enrollment Facilitating CalFresh Enrollment for SSI Recipients CalFresh Eligibility and Enrollment for Current SSI Recipients CalFresh Eligibility and Enrollment for New SSI Applicants Ongoing CalFresh Case Management for SSI Recipients CalFresh Recertification for SSI Recipients Additional Considerations Planning and Phased Rollout Working with Trusted Partners Multiple Communication Channels Training and Customer Support Conclusion Endnotes ”

” W elfare R u les D atab o o k Welfare Rules Databook: State TANF Policies as of July 2017 OPRE Report 2018-109 Welfare Rules Databook: State TANF Policies as of July 2017 FINAL REPORT OPRE Report 2018-109 October 2018 Christine Heffernan, Benjamin Goehring, Ian Hecker, Linda Giannarelli, and Sarah Minton The Urban Institute Submitted to: Girley Wright, Project Officer Office of Planning, Research, and Evaluation Administration for Children and Families U.S. Department of Health and Human Services Contract Number: HHSP23320095654WC; Task Order Number: HHSP23337044T Project Directors: Linda Giannarelli and Sarah Minton The Urban Institute 2100 M Street NW Washington, DC 20037 This report is in the public domain. Permission to reproduce is not necessary. Suggested citation: Heffernan, Christine, Benjamin Goehring, Ian Hecker, Linda Giannarelli, and Sarah Minton (2018). Welfare Rules Databook: State TANF Policies as of July 2017, OPRE Report 2018- 109, Washington, DC: Office of Planning, Research, and Evaluation, Administration for Children and Families, U.S. Department of Health and Human Services. Disclaimer The views expressed in this publication do not necessarily reflect the views or policies of the Office of Planning, Research, and Evaluation, the Administration for Children and Families, the U.S. Department of Health and Human Services, the Urban Institute, or the Urban Institute’s trustees or funders. This report and other reports sponsored by the Office of Planning, Research, and Evaluation are available at https:\/\/www.acf.hhs.gov\/opre. https:\/\/www.acf.hhs.gov\/opre ABOUT ACF\/OPRE The Administration for Children & Families (ACF) is a division of the U.S. Department of Health & Human Services (HHS). ACF promotes the economic and social well-being of families, children, individuals and communities. The Office of Planning, Research, and Evaluation (OPRE) studies ACF programs and the populations they serve through rigorous research and evaluation projects. These include evaluations of existing programs, evaluations of innovative approaches to helping low-income children and families, research syntheses, and descriptive and exploratory studies. ABOUT THE WELFARE RULES DATABASE The Welfare Rules Database is maintained by the Urban Institute under funding from the Administration for Children and Families, Office of Planning, Research, and Evaluation. This project produces a comprehensive, up-to-date database of TANF policies for the 50 states and the District of Columbia. The database contains hundreds of variables and is designed to capture TANF policies across time. The data are made available for public use; for more information visit https:\/\/wrd.urban.org. ABOUT THE URBAN INSTITUTE The nonprofit Urban Institute is dedicated to elevating the debate on social and economic policy. For nearly five decades, Urban scholars have conducted research and offered evidence-based solutions that improve lives and strengthen communities across a rapidly urbanizing world. Their objective research helps expand opportunities for all, reduce hardship among the most vulnerable, and strengthen the effectiveness of the public sector. https:\/\/wrd.urban.org\/ Acknowledgments The authors owe thanks to all the individuals who helped to design the project and these tables, who provided and verified the data, and who assisted in carrying out the project tasks. Particular thanks are owed to the ACF project officer Girley Wright and other HHS staff for their continued guidance on the project and their review of this report. We also greatly appreciate the many state administrators and staff who provided the detailed policy documents on which these tables are based, and conducted often time-consuming reviews of draft tables to improve their accuracy and relevance. The project would not be possible without their substantial involvement. We are grateful to Kara Harkins for her ongoing technical support as the lead programmer for the project. We also recognize the contributions of numerous past Urban Institute colleagues\u2014too numerous to name here\u2014who collectively assisted in the development, coding, and verification of the earlier policy materials. Table of Contents Introduction and Background …………………………………………………………………………………… 1 The Welfare Rules Database ……………………………………………………………………………………….. 3 The Databook ……………………………………………………………………………………………………………. 8 I. Initial Eligibility ……………………………………………………………………………………………….. 11 A. Does the state try to divert some families from becoming recipients? ……………………….. 11 B. How does family composition or individual status affect eligibility? …………………………… 13 C. What level of assets can a family have and still be eligible? ………………………………………. 24 D. How is income counted in determining eligibility? …………………………………………………… 25 E. How much income can a family have and still be eligible? ………………………………………… 30 II. Benefits ……………………………………………………………………………………………………… 107 A. If a family passes all eligibility tests, what is received? ……………………………………………. 107 III. Requirements ……………………………………………………………………………………………… 130 A. Once determined eligible, what must a recipient family do to maintain benefits? …….. 130 B. What work activities are required? ………………………………………………………………………. 131 IV. Ongoing Eligibility ………………………………………………………………………………………… 170 A. What eligibility tests must recipient families pass for continuing eligibility? ……………… 170 B. Are children eligible if born while the family receives benefits? ………………………………. 175 C. How long can a family receive benefits? ……………………………………………………………….. 176 D. Can families receive transitional cash assistance? ………………………………………………….. 179 V. Policies across Time, 1996 2017 ……………………………………………………………………… 236 Appendix 1: Component Descriptions …………………………………………………………………….. 286 Welfare Rules Databook: State TANF Policies as of July 2017 i Table of Tables Table I.A.1 Formal Diversion Payments ……………………………………………………………………. 35 Table I.A.2 Mandatory Job Search at Application ………………………………………………………. 42 Table I.B.1 Eligibility of Pregnant Women with No Other Children ……………………………… 47 Table I.B.2 Eligibility Rules for Two-Parent, Nondisabled Applicant Units …………………….. 50 Table I.B.3 Special Rules Imposed on Minor Parent Eligibility …………………………………….. 53 Table I.B.4 Inclusion of Stepparents in the Assistance Unit ………………………………………… 56 Table I.B.5 Eligibility of Nonexempt, Pre-PRWORA, Qualified Aliens ……………………………. 58 Table I.B.6 Use of State Funds to Help Noncitizens Who Entered after Enactment and Are Ineligible for Federal TANF Assistance …………………………………………. 60 Table I.B.7 Eligibility of Post-PRWORA Qualified Aliens after Five Years ………………………. 63 Table I.B.8 Treatment of Non-caretaker Adults in Household …………………………………….. 65 Table I.B.9 Eligibility Requirements for Children ……………………………………………………….. 70 Table I.B.10 Inclusion of SSI Recipients in the Assistance Unit………………………………………. 73 Table I.B.11 Inclusion of Nonparent Caretakers in the Assistance Unit ………………………….. 75 Table I.C.1 Asset Limits for Applicants ……………………………………………………………………… 79 Table I.D.1 Treatment of Grandparent Income …………………………………………………………. 82 Table I.D.2 Treatment of Stepparent Income ……………………………………………………………. 86 Table I.D.3 Treatment of Income and Assets of Nonparent Caretakers ………………………… 90 Table I.D.4 Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status ………………………………………………………………………………. 92 Table I.E.1 Income Eligibility Test for Applicants ……………………………………………………….. 98 Table I.E.2 Earned Income Disregards for Initial Income Eligibility Purposes ………………. 100 Table I.E.3 Standards for Determining Eligibility ……………………………………………………… 102 Table I.E.4 Maximum Income for Initial Eligibility for a Family of Three …………………….. 105 Table II.A.1 Earned Income Disregards for Benefit Computation ……………………………….. 113 Table II.A.2 Benefit Determination Policies ……………………………………………………………… 116 Table II.A.3 Standards for Determining Benefits ………………………………………………………. 119 Table II.A.4 Maximum Monthly Benefit for a Family with No Income …………………………. 122 ii Welfare Rules Databook: State TANF Policies as of July 2017 Table of Tables (continued) Table II.A.5 Maximum Monthly Benefit for a Child-Only Unit with One Child, No Income ………………………………………………………………………………………….. 124 Table II.A.6 Benefit Issuance Policies ………………………………………………………………………. 126 Table III.A.1 Behavioral Requirements and Bonuses ………………………………………………….. 136 Table III.B.1 Work-Related Activity Exemptions for Single-Parent Head of Unit ……………. 138 Table III.B.2 Work-Related Activity Requirements for Single-Parent Head of Unit…………. 146 Table III.B.3 Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit …………………………………………………………………… 162 Table III.B.4 Work-Related Activity Requirements for Parents Outside the Unit and Nonparent Caretakers………………………………………………………………………….. 168 Table IV.A.1 Eligibility Rules for Two-Parent, Nondisabled Recipient Units …………………… 181 Table IV.A.2 Treatment of Child Support Income for Recipients ………………………………….. 183 Table IV.A.3 Asset Limits for Recipients and Related Assets Policies ……………………………. 186 Table IV.A.4 Income Eligibility Tests for Recipients ……………………………………………………. 194 Table IV.A.5 Earned Income Disregards for Continuing Income Eligibility Purposes ………. 196 Table IV.A.6 Maximum Income for Ongoing Eligibility for a Family of Three …………………. 198 Table IV.B.1 Family Cap Policies ………………………………………………………………………………. 200 Table IV.C.1 Time Limit Policies ………………………………………………………………………………. 203 Table IV.C.2(a) Time Limit Exemption Policies ………………………………………………………………. 208 Table IV.C.2(b) Time Limit Exemption Policies (continued) …………………………………………….. 213 Table IV.C.3(a) Time Limit Extension Policies ………………………………………………………………… 220 Table IV.C.3(b) Time Limit Extension Policies (continued) ………………………………………………. 225 Table IV.D.1 Transitional Cash Benefits …………………………………………………………………….. 233 Table L1 Formal Diversion Payments, 1996-2017 …………………………………………………. 239 Table L2 Types of Special Restrictions on Two-Parent, Nondisabled Units’ Eligibility, 1996-2017 …………………………………………………………………………… 243 Table L3 Maximum Income for Initial Eligibility for a Family of Three, 1996-2017 ……. 246 Table L4 Earned Income Disregards for Benefit Computation, 1996-2017 ………………. 249 Table L5 Maximum Monthly Benefit for a Family of Three with No Income, 1996-2017 ………………………………………………………………………………………….. 259 Welfare Rules Databook: State TANF Policies as of July 2017 iii Table of Tables (continued) Table L6 Work-Related Exemption When Caring for a Child under X Months, 1996-2017 ………………………………………………………………………………………….. 261 Table L7 Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 …………………………………. 265 Table L8 Asset Limits for Recipients, 1996-2017 …………………………………………………… 275 Table L9 Asset Limit Vehicle Exemptions for Recipients, 1996-2017 ………………………. 278 Table L10 Family Cap Policies, 1996-2017 …………………………………………………………….. 284 Appendix 1 Component Description ……………………………………………………………………….. 287 iv Welfare Rules Databook: State TANF Policies as of July 2017 Introduction and Background The purpose of this publication\u2014the Welfare Rules Database’s annual Databook\u2014is to provide researchers and policymakers with easy access to detailed information on how states provide cash assistance under the Temporary Assistance for Needy Families (TANF) program.1 The dozens of tables in this book collectively describe how states determine eligibility for TANF benefits, how they compute program benefits for eligible families, and the work requirements and time limits that they impose. In Federal Fiscal Year (FFY) 2017, 1.095 million families received cash aid from TANF in the average month.2 TANF cash assistance policies vary widely across states due to the nature of the TANF program and funding. TANF is a block grant, providing federal money that states combine with their own funding (there is a maintenance of effort or MOE requirement) to meet the goals of the program.3 The four purposes of the program are: to (1) Provide assistance to needy families so that children can be cared for in their own homes; (2) Reduce the dependency of needy parents by promoting job preparation, work, and marriage; (3) Prevent and reduce the incidence of out-of-wedlock pregnancies; and (4) Encourage the formation and maintenance of two-parent families.4 Some requirements are established at the federal level. However, states are allowed to determine how much of their block grant funds to spend on cash assistance compared with various other services, and to establish most of the specific policies used in providing those benefits. State policies\u2014ranging from initial eligibility determination to benefit computation to ongoing eligibility requirements\u2014can vary greatly. For example, a family eligible for several hundred dollars of cash aid each month in one state may be eligible for much less in another state and completely ineligible in a third state. Thus, while TANF is a single program from the perspective of federal law, in practice the program operates differently in every state. 1 Throughout the Databook, the term states refers to the 50 states and the District of Columbia. 2 The policies shown in this Databook are for July 2017, and fall within FFY 2017, which covers the period of October 2016 through September 2017. For information about the number of families receiving TANF in FFY 2017, as well as other caseload data, see the Office of Family Assistance website: https:\/\/www.acf.hhs.gov\/ofa\/resource\/tanf-caseload-data-2017. 3 States are required to maintain specified levels of funding, based in part on historical spending levels in each state. The requirement for state expenditures is referred to as the maintenance of effort (MOE) requirement; additional detail about MOE requirements can be found on the Office of Family Assistance website: https:\/\/www.acf.hhs.gov\/programs\/ofa\/resource\/policy\/pi-ofa\/1996\/pi9602. 4 Additional detail about the TANF program can be found on the Office of Family Assistance website: https:\/\/www.acf.hhs.gov\/programs\/ofa\/programs\/tanf\/about. Welfare Rules Databook: State TANF Policies as of July 2017 1 https:\/\/www.acf.hhs.gov\/ofa\/resource\/tanf-caseload-data-2017 https:\/\/www.acf.hhs.gov\/programs\/ofa\/resource\/policy\/pi-ofa\/1996\/pi9602 https:\/\/www.acf.hhs.gov\/programs\/ofa\/programs\/tanf\/about This publication presents the key policies that each state used to determine cash aid under the TANF program as of July 2017. The Databook also provides longitudinal tables describing various state policies for selected years between 1996 and 2017. All the tables in this publication are based on the information in the Welfare Rules Database (WRD), a publicly available, online database funded by the Department of Health and Human Services and developed and maintained by the Urban Institute. The Databook summarizes the more detailed information in the WRD. Users interested in more information than is provided in this Databook are encouraged to use the full database, available at https:\/\/wrd.urban.org. This site includes a point-and-click interface, as well as extensive documentation. The focus of this publication, and the underlying database, is on the cash aid that is provided under TANF. During FFY 2016 (the most recent year for which financial data are available), 23.9 percent of combined federal TANF funds and state maintenance-of-effort (MOE) funds were spent on basic assistance (cash aid). Other TANF block grant funds were spent on work, education, and training activities; child care; refundable tax credits; child welfare services; pre-kindergarten\/Head Start; out-of-wedlock pregnancy prevention; program management; and other activities.5 The WRD covers only the policies for TANF cash aid and related policies such as work requirements for aid recipients; it does not cover policies for other programs that may be provided through TANF block grant funds. The tables in this Databook are presented in five groups: 1. Initial eligibility in 2017 2. Benefits in 2017 3. Requirements in 2017 4. Ongoing eligibility and transitional benefits in 2017 5. Policies across time, 1996 2017 Each chapter begins with an overview of the policies, followed by information relating to specific tables. The following sections first discuss the background and structure of the WRD, and then describe the contents and structure of the tables in this book. 5 See table A.1 Federal TANF and State MOE Expenditures Summary by ACF-196 Spending Category, FY 2016 on the ACF website, https:\/\/www.acf.hhs.gov\/ofa\/resource\/tanf-financial-data-fy-2016. 2 Welfare Rules Databook: State TANF Policies as of July 2017 https:\/\/wrd.urban.org\/ https:\/\/www.acf.hhs.gov\/ofa\/resource\/tanf-financial-data-fy-2016 The Welfare Rules Database The Welfare Rules Database is a comprehensive resource for comparing cash assistance programs across all 50 states and the District of Columbia, researching changes across time in cash assistance rules within a single state, or determining the rules governing cash assistance in one state at a point in time. The WRD is longitudinal and currently provides information on state Aid to Families with Dependent Children (AFDC) and TANF policies from 1996 through 2017. The WRD was initially developed in the mid-1990s to meet the needs of researchers under the Urban Institute’s Assessing the New Federalism project and was made publicly available in August 1999. The Department of Health and Human Services, Administration for Children and Families (HHS\/ACF) currently funds the maintenance and development of the WRD. The Development of the WRD The WRD was developed in response to the increasing difficulty since the early 1990s of tracking how states operate their cash assistance programs for needy families. Under AFDC, the structure of eligibility and benefit computation was mostly determined at the federal level. States were allowed to set certain policies\u2014such as the standards used to establish eligibility and benefits, and the rules for two-parent families\u2014but those choices were detailed in the State Plans submitted to HHS\/ACF and in annual reports issued by HHS\/ACF summarizing the State Plans. In the early to mid-1990s, as more states received waivers to experiment with welfare rules, it became increasingly difficult to research states’ policies. The waiver terms and conditions agreed to by the states and the federal government often did not provide full implementation details, and the implementation schedules often changed after the agreement was reached. The August 1996 passage of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), replacing AFDC with the TANF block grant, further increased both the degree of variation across state programs and the difficulty of tracking program rules. In addition, the Deficit Reduction Act of 2005, which reauthorized the TANF program in 2006, modified work participation requirements and further altered state TANF policies. Currently, each state is required to submit a TANF State Plan to the federal government every two years. TANF State Plans provide an overview of states’ choices under the block grant; however, the plans’ level of detail varies considerably across states, and alone, the plans generally offer insufficient information to completely understand the details of eligibility, benefit computation, and client requirements. Furthermore, although states are expected to Welfare Rules Databook: State TANF Policies as of July 2017 3 notify the federal government if any of their choices change after the plan is submitted, they are not required to do so. The WRD was developed to provide detailed information about states’ TANF policies, going beyond the level of detail in most states’ official State Plans and capturing changes in policies that occur between the submissions of those plans. The WRD focuses on cash assistance policies and some closely tied transitional benefits; it does not attempt to capture other uses of federal TANF funds (such as state earned income tax credits and child care programs). Although in general the Welfare Rules Database and Databook can be thought of as tracking TANF policies, the state cash assistance programs tracked by the WRD are not always exclusively funded with TANF dollars. Some states’ cash assistance policies incorporate a state separate program (SSP), and other states use a solely state funded (SSF) program.6 States may choose to use different types of funding for families in different situations, although the materials used by caseworkers\u2014which are generally the source materials for this project\u2014 do not generally indicate what funding is used in what circumstance. Thus, if a state funds benefits to two-parent units under an SSF program, or funds benefits to certain immigrant units under SSP funding, those benefits policies are included in the WRD to the extent they are described in the TANF caseworker materials, but the WRD does not separately identify which policies use SSP or SSF funds. This is particularly relevant for readers examining both the eligibility and benefit policies in the Databook and information on TANF spending or caseloads. The federal government’s administrative data sources do capture information on SSP programs (it is usually shown separately from information on TANF programs); but information on SSF programs is not collected or disseminated by the federal government. Sources of Information for the WRD, and Verification of the Data The primary sources of information for the WRD (and thus for the tables in the Databook) are the caseworker manuals and regulations used in each state and the District of Columbia.7 The Urban Institute has a subscription or other arrangement with each state to obtain the manuals or regulations as well as the ongoing updates to those manuals or regulations. These 6 See Falk, Gene. The Temporary Assistance for Needy Families (TANF) Block Grant: A Primer on TANF Financing and Federal Requirements. Congressional Research Service. December 14, 2017. https:\/\/www.fas.org\/sgp\/crs\/misc\/RL32748.pdf. 7 Owing to the difficulty of obtaining caseworker manuals during the transition from AFDC to TANF, the 1996 data in the WRD are coded using several different sources, including (a) caseworker manuals, when available; (b) AFDC State Plans submitted by states to the federal government; (c) waiver terms and conditions; and (d) telephone calls to states to clarify the implementation dates of waivers. 4 Welfare Rules Databook: State TANF Policies as of July 2017 https:\/\/www.fas.org\/sgp\/crs\/misc\/RL32748.pdf documents provide a consistent source of detailed information on policy changes and implementation dates across states and time. After reviewing and coding the documents describing 2017 procedures, project staff conducted a verification process with the states. The draft 2017 tables were submitted to program administrators who were asked to identify incorrect information and to indicate where project staff could locate missing information not initially identified in the policy materials used for coding.8 The verification response rate was 96 percent. In 48 states and the District of Columbia, all issues that were raised by project staff or state staff were fully resolved. In two states (Arizona and Maine), most but not all issues were resolved. A similar verification process has been performed in each year since the first WRD Databook, which described policy variations in 1999. Portions of the 1996 98 data in the WRD have been verified against selected secondary sources but have not been fully reviewed by state TANF staff. Contents of the WRD The WRD provides in-depth information on a wide range of policy topics. These topics are currently organized into 32 categories that together describe most significant dimensions of state policies regarding cash assistance to needy families. It is useful to consider the rules in the sequence in which individuals seeking and receiving assistance will likely encounter them. The 32 categories are listed below, organized into five sections, beginning with initial eligibility. (The organization of the tables in this report is similar to the organization of the database, but with slightly different categorizations.) I. Initial Eligibility A. Does the state try to divert some families from becoming recipients? Diversion B. How does family composition or individual status affect eligibility? Eligibility by Number\/Type of Parents Eligibility of Units Headed by a Minor Parent Eligibility of Pregnant Women Employment-Related Eligibility of Two-Parent Families 8 In most cases, adjustments to initial coding were made after documentation was obtained in the form of an updated policy or supplemental policy document. In the few cases where a particular policy was not documented in any written form, initial coding was adjusted based on discussion with the state contact. Welfare Rules Databook: State TANF Policies as of July 2017 5 Eligibility of Individual Family Members Inclusion of Noncitizens in the Unit Treatment of Additional Adults in the Household9 Other Nonparent Caretaker Policies C. What level of assets can a family have and still be eligible? Asset Test D. How is income counted in determining eligibility? Countable Income Income and Assets of Children In-Kind Income Deemed Income Child Support Earned Income Disregards E. How much income can a family have and still be eligible? Income Eligibility Tests Dollar Amounts10 II. Benefits A. If a family passes all eligibility tests, what is received? Benefit Computation11 Benefit Issuance III. Requirements A. Once determined eligible, what must a recipient family do to maintain benefits? Contracts and Agreements School Policies for Dependent Children Immunization and Health Screening Requirements Child Support Sanctions12 B. What work activities are required? Activities Exemptions 9 Treatment of Additional Adults in the Household includes policies related to both financial and nonfinancial eligibility, as well as benefit computation. Therefore, the category could be included under sections I.A, I.D, and II.A. 10 Information in Dollar Amounts is also relevant to other categories, including Deemed Income, Income Eligibility Tests, and Benefit Computation. 11 Most states base benefits on the net income of the recipient. Net income is calculated by determining the gross income of a recipient and subtracting any earned income disregards the state may allow. Therefore, the Earned Income Disregard category is also relevant for section II.A. 12 The child support requirements for which a recipient may be sanctioned are included in the Child Support category listed under section I.D. 6 Welfare Rules Databook: State TANF Policies as of July 2017 Activities Requirements Activities Sanctions Minor Parent Activities Requirements and Bonuses Components IV. Ongoing Eligibility13 A. How long can a family receive benefits? Time Limits B. Are children eligible if born while the family receives benefits? Family Cap V. Transition to Self-Support A. What happens after cash assistance ends? Transitional Benefits General Points about the WRD In using the Databook and full database, it is helpful to keep in mind the following aspects of the WRD. \u25aa The WRD contains information on the cash assistance rules in effect in each state across time. It does not include information on proposed legislation or on policies that have been agreed-upon but not yet implemented. \u25aa The WRD focuses on the rules applied in determining families’ eligibility, benefits, and requirements. The database does not contain information regarding caseloads, budgets, outcomes, or administrative practices. \u25aa The database contains at least one record (a set of coded variables) for each state, year, and category of rules. \u25aa The database contains additional records when the state changes a policy during the year or when the state’s policy varies by geographic regions of the state, demographic characteristics of the assistance units, or component groups across the state. (The term component is used when the state’s caseload is divided into mutually exclusive 13 The categories under sections I.B I.E and II.A may also be relevant to ongoing eligibility. In most states, recipients are also required to pass nonfinancial and financial tests to continue receiving benefits. These tests may differ for initial and ongoing eligibility. Welfare Rules Databook: State TANF Policies as of July 2017 7 groups based on multiple characteristics. Appendix 1 provides additional information about components.) \u25aa The WRD indicates when states vary policies either by sub-state regions or by county. When eligibility or benefit levels vary by sub-state regions, those amounts are generally captured for all regions. However, when policies vary at the county level, data are recorded only for the largest county in the state.14 \u25aa The database contains for every year, state, and category of rules one record designated the majority rule record. This record represents the policy that affected the majority of the caseload for the majority of the year. It is important to note that neither the WRD nor the Databook addresses the issue of how rules may be implemented in practice. As noted above, the WRD is based on caseworker manuals and regulations, which typically do not include information on the likelihood of various outcomes. For instance, if a particular type of recipient may be assigned to one of several work activities, the manuals do not typically address which activity is most likely to be assigned. Thus, for certain policies, two states may look similar in the database and yet in practice be different, and other states’ policies may look different and yet be similar in practice. The Databook The descriptions of the policies in this Databook are focused on what is relevant to the individuals and families to whom the policies apply. The book describes the rules that affect individuals and families in each state, but it generally does not specify whether those policies are imposed as a result of federal or state requirements. Thus, this book does not exhaustively describe federal requirements or prohibitions. Federal TANF policies are fully described in resources available from the Administration for Children and Families.15 The tables included in this book are designed to provide readers with easy access to key TANF policies across states as of July 2017. The first four chapters of the Databook provide 14 The states that allow counties to vary policies (that are included in this book) are California and Colorado. The largest counties in each state are Los Angeles County in California and Denver County in Colorado. The WRD provides additional information on states that allow counties to vary other policies (that are not included in this book). 15 For an index of TANF-related laws and regulations compiled by the Administration for Children and Families, Office of Financial Assistance, see the Office of Family Assistance website: https:\/\/www.acf.hhs.gov\/programs\/ofa\/programs\/tanf\/laws-regulations. 8 Welfare Rules Databook: State TANF Policies as of July 2017 https:\/\/www.acf.hhs.gov\/programs\/ofa\/programs\/tanf\/laws-regulations information as of July 2017 across four broad policy areas: initial eligibility, benefits, requirements, and ongoing eligibility and transitional benefits. The last chapter provides longitudinal tables for selected policies with data from 1996 through 2017. The data for the tables are extracted from the WRD and represent only a portion of the information in the database. Even for the policy areas addressed in this book, further details are available online in the WRD. In general, the Databook tables focus on the majority rule for an aspect of policy, while the full online database allows exploration of policy variations across months of the year and different subsets of the caseload.16 Each table follows the same general structure. Typically, the body of each table includes one row per state, which represents the policies in place as of July 2017. If different policies were used for different types of families, the tables show the policies for the predominant type of family in the state\u2014generally, single-parent units with children. If a state’s policies in a category vary by geographic area, the policies for the largest area in the state are shown. Some tables include more information than just the rules for the majority of the caseload. In some cases, additional information is included in an additional row for the state; in other cases, additional information is included in footnotes. \u25aa Additional data as a second row: A second row is added to the body of the table if a state divides its entire caseload into mutually exclusive groups that are treated differently across more than one policy. These groups\u2014called components in the WRD\u2014are usually defined by more than one characteristic, such as units either meeting any one of a number of work-exemption criteria or not meeting any of those criteria. Descriptions of states’ components are located in Appendix 1. \u25aa Additional data as a footnote: Several types of variations may appear as footnotes in the tables. These include variation by type of assistance unit (two-parent units versus one- parent units, or applicants versus recipients) or geographic areas. These types of policies are footnoted in some, but not all, tables. The tables do not capture all the variation in policies across regions and types of units, but the full database contains this information. In addition, states with county variations in policy are footnoted. The footnote indicates the name of the county (the largest in population in the state) to which the policy applies. 16 In the tables regarding eligibility and benefits, states that vary dollar amounts used for eligibility or benefit standards are denoted. Welfare Rules Databook: State TANF Policies as of July 2017 9 Each 2017 table is numbered by chapter and section. For example, table III.A.1 refers to the first table in chapter III, section A. The longitudinal tables are numbered L1 through L10. The tables in this book and their numbering are the same as in the Databook describing the July 2016 policies with the exception of the addition of a new Table, I.D.4 (Immigrant Parent Deeming Policies). 10 Welfare Rules Databook: State TANF Policies as of July 2017 I. Initial Eligibility The tables in this chapter of the Databook describe key aspects of the rules imposed on families and individuals to determine initial eligibility for TANF cash assistance as of July 2017. Rules for initial eligibility apply to individuals who are applying for the first time or who are reapplying for assistance after a period of not receiving assistance. To be eligible, an applicant family must pass both nonfinancial tests, based on the characteristics of the family and its members, and financial tests, based on the income and asset holdings available to the family. This chapter is divided into five sections covering initial eligibility rules related to diversion, family composition, assets, income definitions, and income tests. A. Does the state try to divert some families from becoming recipients? Many states have policies that attempt to divert from assistance applicants who may be able to become self-sufficient with some type of state help other than regular monthly cash aid. These types of policies were developed during the 1990s, first under state waivers and then after the passage of PRWORA. Some states use a formal diversion program (described below), while others require job search at application, and some states use both approaches. Formal Diversion Payments (Table I.A.1) Under formal diversion programs, families may choose to receive a lump-sum cash payment to address immediate needs instead of receiving a monthly TANF benefit. Generally, states provide benefits to families to alleviate short-term problems that interfere with either keeping or finding employment. Many states require recipients of diversion assistance to be currently employed or seeking employment. Families that accept diversion payments typically are barred from applying for monthly TANF benefits for some period, but the period of ineligibility may be reduced by approaches such as deducting a portion of the diversion payment from future TANF benefits. Most diversion programs are voluntary; however, states may require certain families to enroll in a diversion program and participate in job search or job-related activities before applying for monthly TANF benefits. For the purposes of the WRD, a formal diversion program is defined as diverting eligible applicants or recipients from ongoing TANF receipt by providing a lump-sum cash payment Welfare Rules Databook: State TANF Policies as of July 2017 11 directly to the family or to a vendor for expenses incurred by the family. Other strategies states may use to divert applicants from ongoing receipt of cash benefits (such as requiring an applicant to participate in job search or resource and referral services) are not identified as formal diversion programs in the WRD. The maximum diversion payment is either a flat payment, regardless of the family’s size and the state’s maximum benefit (represented in table I.A.1 by a dollar amount), or a multiple of the maximum benefit the family would have received in monthly TANF benefits (represented in the table by a number of months of benefits). If the state provides diversion payments based on a multiple of the maximum monthly benefit, the amount will vary by the family size and the level of the state’s maximum benefits. Table I.A.1 describes whether a state provides a diversion payment, the maximum payment, the form of the payment, how often a recipient may receive the maximum payment, the period of TANF ineligibility after receiving a diversion payment, and whether the months that a family is diverted count toward the state’s time limit. Highlights for 2017 include: \u25aa Thirty-two states have formal diversion programs. \u25aa Of the states with formal diversion programs, nine states provide families the same diversion payment regardless of the family’s size. These payments range from $1,000 in Florida, Kansas, and Texas to $2,500 in Colorado. An additional two states provide families a fixed amount that does depend on the family’s size. For a family of three, these payments range from $750 in New Jersey to $1,500 in New Mexico. \u25aa Sixteen states and DC pay diverted families an amount equal to a multiple of the maximum monthly benefit for the family’s size; the multiple ranges from 1 to 12, but is most commonly three times the maximum benefit. Additionally, California pays either $2,000 or three times the maximum aid payment for the family size, whichever is greater. \u25aa Among the states with diversion programs, six count the payments toward the TANF time limit in some or all cases. Families applying for a diversion payment must still be eligible for assistance using the state’s eligibility rules (see sections I.B I.E). The rules generally are the same for families that apply for diversion and those that apply for monthly assistance. 12 Welfare Rules Databook: State TANF Policies as of July 2017 Related tables: For information on diversion programs for selected years between 1996 and 2017, see table L1. Mandatory Job Search at Application (Table I.A.2) In states requiring job search at application, applicants must look for jobs either before or while their applications are processed. To be eligible for aid, applicants must prove they have searched for jobs at a set number of businesses or participated in the state’s job-related programs. The goal of these requirements is for applicants to find jobs and no longer need assistance, or at least be employed by the time they begin receiving assistance. States may exempt some applicants from searching for a job at the time of application. Exempt groups often include applicants who are ill or incapacitated, caring for someone who is ill or incapacitated, over a certain age, or pregnant. Table I.A.2 indicates which states require applicants to search for a job at application as a condition of eligibility, what kinds of activities are required, who is exempt from the activities, and what happens to individuals who do not comply with the requirement. Findings for 2017 include: \u25aa Nineteen states require the applicant to seek employment either before or while the application is processed. \u25aa Of the states that require job search, 17 may deny the application if the individual fails to meet the job search requirements. B. How does family composition or individual status affect eligibility? To be eligible for either a diversion payment or monthly benefits, a family must pass several nonfinancial tests based on the demographic characteristics of the overall family or individuals within the family. Families generally include at least one eligible child, but states may also allow TANF eligibility for pregnant women with no other children. States vary in whether they allow TANF for children living with caretakers who are not relatives; further, some states do not offer TANF to families that include two non-disabled parents. When a family passes a state’s initial tests, the next step in the eligibility process is to determine what many states refer to as the assistance unit \u2014the group of people whose Welfare Rules Databook: State TANF Policies as of July 2017 13 needs are considered in establishing the benefit. The definition of the assistance unit can have substantial implications for a unit’s eligibility. In states that increase eligibility limits with unit size, a larger assistance unit might increase the family’s chance of eligibility. In some cases, however, including an individual in the unit and including his or her income in the unit’s countable income might lower the chance of eligibility. In most states, the size of the assistance unit also determines the maximum benefit that will be paid. In general terms, the assistance unit consists of the dependent children and their parents\u2014 including any parents in the household, even if those parents are not married. However, states vary in the treatment of stepparents, immigrant parents, a parent’s nonparent partner, and parents and children who receive benefits from the Supplemental Security Income (SSI) program. When the only adults in the family are prohibited from being in the assistance unit (due to immigrant status, receipt of SSI, certain time limits or sanctions, or nonparent caretaker status in some states and circumstances), or when they choose not to be in the unit (nonparent caretakers in other states and circumstances), a child-only assistance unit is formed.17 Eligibility of Pregnant Women with No Other Children (Table I.B.1) At the most basic level, to be eligible for TANF, the family must include a child or, in some states, a pregnant woman. Table I.B.1 indicates whether units with pregnant women who have no other children are eligible to receive TANF cash assistance. The table also indicates whether the father and unborn child are also eligible for benefits\u2014usually meaning they are included in the assistance unit. For states that provide TANF benefits to pregnant women with no other children, the table also indicates the month of pregnancy in which benefits may begin. Key findings for 2017 include: \u25aa In cases when a woman is pregnant but has no other children, 32 states consider her potentially eligible for benefits for at least a portion of her pregnancy. \u25aa Among the states that allow eligibility for a pregnant woman with no other children, nine states also consider the father eligible, and one state counts the unborn child in the size of the assistance unit. 17 In some states, reaching a time limit results in removing the needs of the adult from the assistance unit. 14 Welfare Rules Databook: State TANF Policies as of July 2017 Eligibility Rules for Two-Parent, Nondisabled Applicant Units (Table I.B.2) Some states have different eligibility rules for families that include two parents compared with families with one parent or no parents.18 If the family includes two parents, and neither parent has a disability, the family is ineligible for TANF in some states. In other states, a family with two nondisabled parents must pass additional eligibility tests (not imposed on other families) based on the parents’ current or prior labor force status.19 These additional requirements may include an hours test, a work history test, or a waiting period. Under an hours test, the unit is ineligible if the parent who is the principal wage earner is working more than a specified number of hours per month.20 States may apply this rule when determining the initial or continuing eligibility of two-parent families. Under a work history test, the eligibility of two-parent units is restricted to those in which the principal wage earner worked during a certain number of calendar quarters over a specified number of years, or in which the principal wage earner satisfies other criteria related to labor force attachment.21 Waiting periods restrict the eligibility of two-parent families until a certain number of days or weeks after the family would otherwise have been eligible.22 For example, under a 30-day waiting period, if the principal wage earner becomes unemployed and the family would not have been eligible when the parent was working, the family would not become eligible to apply for assistance until one month after the parent loses his or her job. 18 The policies discussed here apply to both married or unmarried parents. 19 In some states, benefits are provided to two-parent units under solely state-funded or separate state programs (SSFs or SSPs) funded by state monies rather than the TANF block grant. Table I.B.2 includes those states as providing benefits to two-parent families regardless of the funding source as long as these provisions are specified in each state’s TANF policy manual. 20 Under AFDC, the principal earner could be working no more than 100 hours per month in order for the family to be potentially eligible for aid. 21 Under AFDC, the principal earner was required to have worked at least six of the last 13 quarters in order to be found eligible for benefits. The 13-quarter period must have ended within one year of applying for assistance. Generally, work history could also be established if one of the following applied: (1) the applicant received unemployment compensation (UC) benefits within 12 months of the date of application or (2) the applicant would have been eligible for UC benefits within the previous 12 months but did not apply or his or her employment was not covered by UC laws. 22 Under AFDC, waiting periods were imposed only on two-parent units. However, under TANF, some states have begun to apply waiting periods to all types of units. The WRD does not currently capture waiting periods that apply to all units. Welfare Rules Databook: State TANF Policies as of July 2017 15 Table I.B.2 presents the eligibility rules for families with two nondisabled parents at application. Highlights for 2017 include: \u25aa Three states (Louisiana, New Hampshire, and North Dakota) do not allow two-parent families in which neither parent has a disability to receive TANF. \u25aa In seven states, two-parent families are potentially eligible, but face additional tests not imposed on single-parent families (i.e., a work hours test, work history test, or application waiting period). Related tables: For information about the hours test for two-parent non-disabled families who are already receiving benefits (as compared to those who are applying for benefits), see table IV.A.1. Table L2 provides information on the rules for two-parent units in selected years from 1996 through 2017. Special Rules Imposed on Minor Parent Eligibility (Table I.B.3) Parents who are teenagers may or may not be eligible to receive a benefit on their own, and in most cases they are eligible only if they are living with their adult parents or in another state- approved setting.23 Table I.B.3 describes special eligibility rules for families where the parent is a minor (usually defined as under age 18 and never married). The first column indicates whether a minor parent can ever head a TANF unit and receive the benefit in his or her own name. The second column indicates whether the state requires the minor parent to live with a parent or in another state-approved setting (referred to in the table as a living arrangement restriction). Findings from 2017 include: \u25aa Forty-one states allow minor parents to apply for TANF as the head of a unit. \u25aa Two states (Hawaii and Nebraska) do not require the minor parent to live with a guardian or in an approved setting.24 Related table: Table I.D.1 provides information on the treatment of the grandparents’ income in cases when a minor parent is living with one or both of his or her parents and also heading his or her own assistance unit. 23 In general, states may not provide federally-funded assistance to minor parents who are not living in an adult- supervised setting. However, there are some exceptions to this requirement. 24 Benefits for assistance units that do not qualify for federal funding are provided with state funding. 16 Welfare Rules Databook: State TANF Policies as of July 2017 Inclusion of Stepparents in the Assistance Unit (Table I.B.4) State rules vary for whether a stepparent (i.e., a person who has married the children’s biological\/adoptive parent, but who has not legally adopted the children) is included in the assistance unit. Stepparents may be required to be part of the unit, may be prohibited from being part of the unit, or may be included in the unit at the option of the family. Table I.B.4 focuses on rules for stepparents who have no child in common with their spouses, have no biological children of their own in the assistance unit, are living in the home, and are not incapacitated. Policy highlights from 2017 include: \u25aa Twenty-two states require that stepparents be included in the assistance unit. \u25aa Fourteen states allow the unit head to choose whether to include the stepparent. \u25aa Fifteen states prohibit the stepparent from being included in the assistance unit. State rules for stepparents not meeting the criteria outlined for table I.B.4 may vary and are addressed in further detail in the WRD. Related table: Information about the treatment of income from a stepparent who is not included in the assistance unit can be found in table I.D.2. Eligibility of Noncitizens (Tables I.B.5, I.B.6, and I.B.7) If a family is potentially eligible for aid, but one or more members of the family is not a citizen, complex rules govern whether the noncitizens can be included in an assistance unit. The eligibility of noncitizens depends on several factors, including when they arrived in the country, how long they have resided in the country, the specific status that allows them to be in the country (e.g., lawful permanent resident, refugee, etc.), and the extent to which they have worked since arriving in the country. The federal rules require that some groups of noncitizens be considered potentially eligible for TANF in all states, but states retain wide discretion regarding the eligibility of most noncitizens. Under the AFDC program, the only noncitizens categorically ineligible for aid were unauthorized immigrants and noncitizens in the country temporarily (under student visas or temporary work visas). Further, the income of a legal immigrant’s sponsor could be treated as available to the immigrant (a process known as deeming ) for a limited time; however, most legal immigrants were potentially eligible for benefits. Welfare Rules Databook: State TANF Policies as of July 2017 17 After the passage of PRWORA, noncitizens’ access to federal TANF benefits was significantly restricted. PRWORA created the qualified alien distinction, which more narrowly defined the group of noncitizens potentially eligible for most federally-funded TANF assistance.25 The federal law also extended sponsor deeming and further limited qualified aliens’ access to assistance based on their date of entry into the country. Qualified aliens who entered the United States before August 22, 1996 (the date PRWORA was passed), are potentially eligible for federally-funded assistance without any waiting period, whereas most qualified aliens who arrived in the country on or after August 22, 1996 are subject to a five-year bar on federal TANF assistance.26 After the five-year bar, qualified aliens are again potentially eligible for federally- funded TANF assistance. Some immigrants are exempt from the various restrictions, and must be potentially eligible for TANF. Refugees and asylees must be considered potentially eligible in all states for their first five years in the country. Also, military personnel and veterans and their families can never be denied eligibility due to their immigrant status (regardless of how long they have been in the country).27 Finally, noncitizens who arrived in the U.S. prior to the passage of PRWORA who 25 Qualified aliens include lawful permanent residents, asylees, refugees, aliens paroled into the United States for at least one year, aliens whose deportations are being withheld, aliens granted conditional entry before April 1, 1980, certain battered alien spouses and their children, battered alien children and their parents, and Cuban\/Haitian entrants. 26 The five-year bar applies only to those aliens who entered the United States\u2014whether legally or illegally\u2014on or after August 22, 1996. Therefore, a person may have entered illegally in 1994 and become a lawful permanent resident in 2000. As long as that person has been continuously present in the United States, the bar would not apply to him or her. See the Department of Justice’s Interim Guidance on Verification of Citizenship, Qualified Alien Status and Eligibility under Title IV of PRWORA at 62 Federal Regulation 61415 (November 17, 1997). Further, if the noncitizen enters the United States on or after August 22, 1996, but is not qualified when he or she enters, the five-year clock begins on the date his or her immigrant status becomes qualified. 27 States must permit the following qualified aliens who meet the state’s eligibility criteria to receive TANF benefits for five years after the date of entry into the United States or the date asylum or withholding of deportation was granted: refugees (and victims of severe forms of trafficking and certain family members), asylees, aliens whose deportation has been withheld, Amerasians, and Cuban\/Haitian entrants. Also, states may never deny eligibility to veterans or individuals on active duty along with their spouses and unmarried dependent children. Under the 2008 Consolidated Appropriations Act (P.L. 110-161, 101(a)(27)) and the 2008 National Defense Authorization Act (P.L. 110-181, 8120(b)), Iraqi and Afghani aliens gained special immigrant status and became eligible to receive benefits available to refugees, including resettlement assistance and access to other public benefit programs. The Afghani and Iraqi aliens, while eligible for a time-limited exemption, are still otherwise subject to the federal five- year bar on benefit assistance. Afghani special immigrants became eligible for a six-month time-limited exemption from the federal five-year bar, while Iraqi special immigrants became eligible for an eight-month time-limited exemption from the federal five-year bar. The time-limited exemption from the federal five-year bar begins on the date the noncitizen enters the United States. 18 Welfare Rules Databook: State TANF Policies as of July 2017 have accumulated 40 quarters of work history cannot be denied TANF eligibility due to their immigrant status in any state.28 Although federal law determines which noncitizens are potentially eligible for federally- funded benefits and the periods in which they may be eligible, states have substantial flexibility. States can choose to provide or deny assistance to certain qualified aliens the federal government has indicated are potentially eligible for federally-funded benefits. States can also provide state-funded assistance to certain aliens ineligible for federally-funded assistance, such as qualified aliens during the five-year bar or certain nonqualified aliens.29 States have made three types of decisions about the eligibility of noncitizens: 1. Will some or all qualified aliens who arrived before PRWORA (pre-PRWORA) be eligible for benefits? 2. Will some or all noncitizens who arrived on or after the date of the PRWORA legislation (post-PRWORA) be eligible for benefits during the five-year bar? 3. Will some or all post-PRWORA noncitizens be eligible for benefits after the five-year bar? Tables I.B.5, I.B.6, and I.B.7 describe the variation in state policies concerning pre-PRWORA and post-PRWORA noncitizens.30 Table I.B.5 describes selected state policies regarding pre-PRWORA qualified noncitizens who are potentially eligible for federally-funded assistance, but who do not fall into groups required to be covered (in other words, they are nonexempt ). Since PRWORA was passed more than 20 years prior to the policies covered by this Databook, the policies regarding pre- PRWORA entrants do not affect a large number of applicants; however, there are still some families applying for TANF in which the adults entered the country prior to August 1996 and have not obtained citizenship. The table provides eligibility rules for two groups of pre-PRWORA 28 Forty quarters is approximately 10 years for one person; however, a noncitizen may be credited with quarters of coverage worked by a parent or a spouse under certain circumstances. 29 Two groups of non-qualified aliens\u2014those who are in the country on a temporary basis (student visas, work visas, and so on) and those who are in the country without authorization\u2014are not eligible for benefits in any state. However, there are other groups of nonqualified aliens, such as persons residing under color of law (PRUCOL), who are eligible in some states. 30 These state rules must be viewed in the context of the federal prohibitions and requirements affecting the eligibility of noncitizens for federally funded assistance. The eligibility rules for noncitizens are very complex. This discussion is a summary intended for researchers and should not be used for assessing the policy options available to a state under federal law or whether a state’s policies fully comport with federal law. Welfare Rules Databook: State TANF Policies as of July 2017 19 noncitizens\u2014lawful permanent residents and asylees.31 As mentioned above, even if a state does not provide assistance to all pre-PRWORA qualified aliens, those qualifying for special exceptions based on work history (having accumulated 40 quarters) or veteran or military status are still potentially eligible for federally-funded benefits in all states. Highlights from 2017 include: \u25aa Forty-nine states consider all pre-PRWORA qualified aliens who are lawful permanent residents eligible for assistance. \u25aa Forty-nine states consider all pre-PRWORA qualified aliens who are asylees eligible for assistance. \u25aa One state (Mississippi) does not consider any pre-PRWORA lawful permanent residents or asylees eligible for assistance (with the exception of those who must be considered potentially eligible based on federal rules). Table I.B.6 shows whether states use their own funding to provide assistance to post- PRWORA noncitizens who are ineligible for federal TANF assistance. The first three columns of the table focus on three groups of qualified noncitizens during their first five years, when they are ineligible for federally-funded TANF due to the five-year bar (unless they qualify for a military or veteran exemption). The three groups of qualified noncitizens shown in the table are lawful permanent residents, parolees, and people who meet the specific definition of battered non-citizen. (Several other groups of qualified aliens\u2014including refugees, asylees, and people with deportation withheld\u2014are not shown in this table because they must be considered potentially eligible for federally-funded TANF in every state during their first five years.) The last column of the table describes whether any nonqualified aliens, other than those who are temporary or unauthorized, are potentially eligible for benefits using state funds. Key policies for 2017 include: \u25aa Thirteen states fund benefits for all three categories of qualified aliens shown in the table (lawful permanent residents, parolees, and battered noncitizens) during their first five years. \u25aa Nine states fund benefits for at least some nonqualified aliens. 31 Versions of this table for 2014 and earlier years showed policies for additional categories of noncitizens. However, due to the diminishing numbers of pre-PRWORA entrants in the population applying for TANF, many states’ caseworker manuals do not provide explicit policies for this group. Thus, this table focuses on the two statuses that are likely the most prevalent among noncitizens who entered prior to PRWORA. 20 Welfare Rules Databook: State TANF Policies as of July 2017 Table I.B.7 shows whether post-PRWORA noncitizens are eligible for assistance after they have resided in the United States with qualified alien status for at least five years. After the five- year bar, qualified aliens may be provided with TANF using federal funds, but the state is not required to provide aid. The table provides eligibility rules for several categories of qualified aliens: lawful permanent residents, asylees\/refugees, noncitizens with deportation withheld, noncitizens paroled in the country for at least one year, and battered noncitizens. Even if a state does not provide assistance to all qualified aliens following the five-year bar, those qualifying for special exceptions based on veteran or military status are still eligible for federally-funded benefits in all states. Further, some states provide aid only to some subgroups, for example only those who have attained 40 quarters of work history. Policies from 2017 include: \u25aa Forty-five states consider all post-PRWORA qualified aliens who are lawful permanent residents and who are beyond the five-year bar to be potentially eligible for assistance. \u25aa Four states only consider a lawful permanent resident past the five-year bar to be potentially eligible for assistance if that person can be credited with 40 quarters of work (or if federal rules require eligibility based on military or veteran status). \u25aa Forty-two states consider post-PRWORA qualified aliens to be potentially eligible for assistance if they are past the five-year bar and if they fall into any of the other four groups shown in the table\u2014asylees\/refugees, deportees, parolees, or battered non- citizens. \u25aa For post-PRWORA qualified aliens after the five-year bar who fall into any of the other four groups shown in the table\u2014asylees\/refugees, deportees, parolees, or battered non-citizens\u2014three states do not provide any eligibility (unless federal rules require eligibility based on military or veteran status). Two points are important to note for all three tables concerning the treatment of noncitizens. First, even if a state will potentially fund cash aid to an immigrant in a particular circumstance, that immigrant might still be ineligible if the immigrant has a sponsor whose income is deemed available for the immigrant’s support. Policies related to sponsor deeming are not shown in the tables but are included in the WRD. Second, all noncitizen rules discussed here apply to individuals, not to entire families. Within a family, some individuals may be ineligible based on immigrant status, while others may remain eligible. Related table: Information about the treatment of income from immigrant parents who are not eligible to be in the assistance unit can be found in table I.D.4. Welfare Rules Databook: State TANF Policies as of July 2017 21 Treatment of Non-Caretaker Adults in Household (Table I.B.8) When a child’s household includes adults who are neither the child’s parents nor caretakers, state rules vary on whether those non-caretaker adults may be considered to be members of the assistance unit. For the purposes of the WRD, a non-caretaker adult is defined as an adult living in the household who is neither the primary caretaker of the children nor a parent of any children in the household. A non-caretaker adult could be an adult who is related to the parent or children (for instance, the children’s aunt), the unmarried partner of the parent, or a friend of the parent who is not a relative or in a relationship with the parent. Table I.B.8 describes whether these individuals are eligible to be included in the TANF unit. Additionally, the table provides information about how states count income and calculate benefits when these individuals are not included in the assistance unit. The table also details whether shared living costs affect eligibility or benefits. Key policies from 2017 include: \u25aa Thirty-three states always exclude all non-caretaker adults in the household from the assistance unit. \u25aa Four states (Hawaii, New York, Vermont, and Virginia) potentially allow any adult in the household to be included in the unit. Eligibility Requirements for Children (Table I.B.9) States define the maximum age of a child for purposes of TANF and may require that a child lives with either a parent or another relative to be potentially eligible for TANF. Table I.B.9 addresses these basic criteria for determining the potential eligibility of a family (as opposed to individuals within the family). The first two columns of the table show the maximum age at which a child can be TANF-eligible; the first column provides the maximum age for children who are not in school, and the second column gives the maximum that applies for children who are still enrolled in school. The last column of table I.B.9 addresses a second issue related to overall family eligibility\u2014whether a child whose caretaker is a nonrelative is potentially eligible for TANF.32 Policies from 2017 include: \u25aa A teenager who is not attending school is still considered a child for purposes of TANF through age 17 (until reaching his or her 18th birthday) in 47 states, and through age 15 in two states. In addition, Michigan and Virginia require all school-age children to be in 32 AFDC did not cover children with nonrelative caretakers. 22 Welfare Rules Databook: State TANF Policies as of July 2017 school full-time as a condition of eligibility for either the child (in Virginia) or the entire family (in Michigan). \u25aa In 48 states, the maximum age to be considered a child for purposes of TANF is slightly higher (generally through age 18) for those who are attending school. \u25aa Eighteen states consider children living with nonrelative caretakers potentially eligible for TANF. Inclusion of SSI Recipients in the Assistance Unit (Table I.B.10) States also vary in the treatment of parents and children who receive benefits from the Supplemental Security Income (SSI) program. SSI provides cash aid to low-income individuals who are age 65 or over and low-income individuals under age 65\u2014including children\u2014who are determined by the program to have a disability. Table I.B.10 shows whether SSI recipients are included in the TANF assistance unit and when counted in the unit, how their income is treated. SSI benefits are typically higher than TANF benefits, so including an SSI recipient in the unit and counting his or her SSI income might reduce a family’s likelihood of eligibility. Highlights for 2017 include: \u25aa Four states (Idaho, New Hampshire, West Virginia, and Wisconsin) include SSI recipients in the TANF assistance unit. Idaho, New Hampshire, and Wisconsin include both child and adult SSI recipients, whereas West Virginia includes SSI recipients who are children. Related table: For additional detail about SSI recipients, table II.A.5 gives the maximum benefit paid to a child-only TANF case with one child when the parents have been excluded due to SSI receipt. Inclusion of Nonparent Caretakers in the Assistance Unit (Table I.B.11) Many children live with caretakers who are not their parents\u2014often a grandparent or another relative. Nonparent caretakers may or may not be considered part of the TANF assistance unit, depending on their characteristics and, in some cases, their own choice. Being included in the unit could increase the TANF benefit (depending on the caretaker’s income), but it could also lead to additional requirements that would not be placed on a child-only unit (related to time limits and work requirements). Welfare Rules Databook: State TANF Policies as of July 2017 23 Table I.B.11 shows the state policies regarding nonparent caretakers. The first four columns of the table address whether nonparent caretakers are included in the unit, and under what circumstances caretakers are included when inclusion is optional. The final column of the table provides information as to whether a caretaker’s spouse is included in the unit when the caretaker is included. This column is relevant in the situation when a child’s caretakers are a married couple\u2014for example, his or her grandmother and grandfather. Key policies from 2017 include: \u25aa Four states never allow nonparent caretakers to be included in the assistance unit. \u25aa Twenty-four states allow nonparent caretakers to choose whether to be included in the assistance unit. \u25aa Twenty-two states allow for the inclusion of some nonparent caretakers (e.g., those with lower incomes, or those who are relatives), but do not allow others to be included in the unit. \u25aa The remaining state (North Dakota) requires the inclusion of some nonparent caretakers, allows for the inclusion of other nonparent caretakers, and does not allow others to be included in the unit. Related tables: For additional information about cases with nonparent caretakers, see table I.B.9 for whether the state ever provides TANF to a child living with a caretaker who is not a relative. Additionally, table I.D.3 describes the treatment of the income and assets of nonparent caretakers, table II.A.5 gives the maximum benefits paid to child-only units with a single child living with a nonparent caretaker, and table III.B.4 describes work-related activity requirements for nonparent caretakers. C. What level of assets can a family have and still be eligible? If the family passes the nonfinancial eligibility tests, the next step in determining TANF eligibility may be an assets test. Most states restrict the amount of assets a family may hold and still be eligible for assistance; however, these amounts vary greatly by state and by type of asset. If the family’s total assets exceed the amounts established by the state, the family is ineligible for assistance. 24 Welfare Rules Databook: State TANF Policies as of July 2017 Asset Limits for Applicants (Table I.C.1) States determine the maximum value of assets\u2014including vehicles\u2014an applicant family may hold and still remain eligible for benefits. Table I.C.1 describes each state’s asset tests for applicants. The first column of the table provides the limit on the value of countable assets a family may hold and still be eligible for assistance. The second column describes whether some or all of the value of a vehicle is excluded in determining the amount of a family’s assets for eligibility purposes; any portion not excluded is counted as part of the family’s total asset value, which is then compared to the asset limit. When a portion of the vehicle’s value is exempted, the value may be given in terms of equity or fair-market value. The fair-market value is the amount for which the vehicle could be sold, while the equity value is the fair-market value minus any amount still owed on the vehicle. When a family still owes money on a vehicle, the equity value will be less than the fair-market value, so this distinction is important when comparing vehicle exemption amounts across states. Policy highlights for 2017 include: \u25aa Forty-three states have asset limits for applicants. \u25aa In states with assets tests, the limits range from $1,000 in nine states to $10,000 in Delaware and Minnesota. Related tables: Asset limits may be different for determining the initial eligibility of applicants compared to the continuing eligibility of recipients. For information on the asset test for recipients, see table IV.A.3. Tables L8 and L9 provide information on asset limits for recipients and the vehicle exemption for recipients, respectively, for selected years from 1996 through 2017. D. How is income counted in determining eligibility? Once a family has passed any asset test imposed by the state, its available income is computed for eligibility purposes. States have discretion in determining what portion and types of earned and unearned income are counted, in addition to whose income is counted, for eligibility purposes.33 33 While there are many types of unearned income, this book only addresses unearned income in the form of child support payments (in chapter IV, Ongoing Eligibility). The WRD captures more details on the treatment of other types of unearned income, including interest income and lump-sum income. Welfare Rules Databook: State TANF Policies as of July 2017 25 Generally, if a person is considered part of the assistance unit, his or her earned and unearned income is counted as part of the unit’s total ( gross ) income. Many states also count a portion of or all income from certain individuals who are not part of the assistance unit but who have an obligation to support a member of the assistance unit. Typically, states view a portion of the income of these individuals as being required for their own needs; they allocate that portion to the individual and any remaining income is deemed available to the assistance unit as unearned income. This income may or may not actually be available to the unit, but the state assumes the individual bears some financial responsibility and therefore requires that a portion of the individual’s income count as income of the unit. In particular, when a stepparent or a grandparent (the parent of a minor parent) lives in the same home as the applicant but is not considered part of the assistance unit, a portion of that person’s income is sometimes counted against the applicant for eligibility and benefit computation purposes. Other groups of individuals whose income may receive special treatment are nonparent caretakers and immigrant parents who are members of the household but not included in the assistance unit. Treatment of Grandparent Income (Table I.D.1) When a minor parent is potentially eligible to head his or her own assistance unit, a portion of his or her parents’ income may be deemed available to the minor’s unit when determining eligibility and benefits. When the grandparents’ (the parents of the minor parent) income is deemed available to the unit, the state may allow grandparents to disregard a portion of their earned income, similar to the earned income disregards available to applicants. States may also allow for an additional disregard approximating the amount of the grandparents’ basic needs and the needs of their dependents outside the TANF assistance unit. The remaining income is deemed available to the minor parent’s TANF unit and is counted as unearned income for eligibility and benefit computation purposes. Table I.D.1 describes the treatment of grandparent income for applicants. The first column indicates if the state deems income in this situation, the second column indicates the initial earned income disregard available to the grandparents, and the third column describes any other disregards available to the grandparents (most often referred to as the need-based disregard). The table also indicates the income standards used by states to determine the disregard. Key policies from 2017 include: \u25aa Thirty-nine states require a portion of the grandparent’s income be deemed available to the minor parent. 26 Welfare Rules Databook: State TANF Policies as of July 2017 \u25aa Two states (Arkansas and Vermont) do not require deeming of income from the grandparent. \u25aa In the remaining 10 states, there is no policy regarding deeming since the minor parent is considered to be in an assistance unit that also includes the grandparent (the minor parent’s adult parent). Information pertaining to disregards for child support payments for dependents outside the home or alimony is not captured in the table, but can be found in the WRD. Related tables: For the income standards listed in the final column, to determine the value for a family size of three, see table I.E.3 (Standards for Estimating Eligibility). For more information about minor parents, see table I.B.3, which describes whether minor parents are potentially eligible to head their own TANF units. Treatment of Stepparent Income (Table I.D.2) In states where a stepparent is either always excluded from the assistance unit or given the option to be excluded from the assistance unit, a portion of the stepparent’s income may be deemed available to the unit. As with their policies for grandparent deeming, states generally allow the stepparent to disregard a portion of his or her earned income, similar to the earned income disregards available to applicants. States may also allow the stepparent to subtract from his or her income a second disregard approximating the amount of his or her basic needs and the needs of his or her dependents outside the TANF assistance unit. The remaining income after these disregards is deemed available to the stepparent’s spouse and the spouse’s dependents and is counted as unearned income for eligibility and benefit computation purposes. Table I.D.2 describes the deeming process for stepparents’ income. The first column indicates if the state deems income, the second column indicates the initial earned income disregard available to the stepparent, and the third column describes any other disregards available to the stepparent (most often referred to as the need-based disregard). The table also indicates the income standards used by states to determine the disregard. Policy highlights for 2017 include: \u25aa Twenty-eight states require that some of the stepparent’s income be deemed to the unit. \u25aa DC does not require deeming of income from the stepparents. Welfare Rules Databook: State TANF Policies as of July 2017 27 \u25aa In the remaining 22 states, there is no policy regarding deeming since the stepparents must be included in the unit. As noted for table I.D.1, information pertaining to disregards for child support payments for dependents outside the home or alimony is not captured in the table, but can be found in the WRD. Related tables: For the standards listed in the final column, to determine the value for a family size of three, see table I.E.3. For additional information on whether stepparents are potentially eligible to be included in the assistance unit, see table I.B.4. Treatment of Income and Assets of Nonparent Caretakers (Table I.D.3) In general, the treatment of a nonparent caretaker’s income and assets depends on whether that person has been included in the assistance unit. Typically, if the caretaker is included in the unit, then his or her income and assets are counted; if the caretaker is not included in the unit, then his or her income and assets are not counted. This means that a unit that is child only because the child lives with a nonparent caretaker often has a countable income of $0. However, states may establish different policies, such as treating income differently for eligibility determination versus benefit computation. Table I.D.3 describes the state policies regarding the income of nonparent caretakers. Key highlights from 2017 include: \u25aa For caretakers who are not in the assistance unit, five states include at least a portion of their income for eligibility and\/or benefit computation. \u25aa All 47 states that include at least some caretakers in the assistance unit count at least a portion of the included caretaker’s income for eligibility and benefit calculations. Related table: For information on whether nonparent caretakers are included in the assistance unit, see table I.B.11. Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status (Table I.D.4) In many cases, the restrictions placed on immigrants’ eligibility for TANF (see Tables I.B.5 through I.B.7) result in a parent not being eligible to be in the assistance unit, while one or more children are potentially eligible. For example, in the case of two lawful permanent residents who have been in the U.S. for three years, and who have a baby who was born in the U.S., the baby is potentially eligible for TANF (because he or she is a citizen) while the parents 28 Welfare Rules Databook: State TANF Policies as of July 2017 are still within the five-year bar, and therefore ineligible in many states. In all cases when a parent is in the household but is not included in the assistance unit, either all or a portion of the parent’s income is considered available to the potentially-eligible children for purposes of determining their eligibility and benefits. As with grandparent and stepparent deeming, states often allow the immigrant parent to disregard a portion of his or her earned income, similar to the earned income disregards available to applicants. States may also allow additional disregards, and some states only count a prorated portion of the parent’s income. Table I.D.4 describes state policies that apply to units in which a child has a parent who is living in the household but not eligible to be part of the assistance unit due to immigrant status. The first column indicates if the state deems income from immigrant parents in this situation, the second column shows the initial earned income disregards available to the immigrant parent, the third column reflects any additional income disregards provided, and the fourth column conveys the computation methods used in determining both eligibility and benefits. Key highlights from 2017 include: \u25aa Five states deem all the excluded parent’s income available to the unit for both eligibility and benefit calculations. \u25aa In 45 states, some portion of the ineligible immigrant parent’s income is disregarded, with different disregards sometimes used for eligibility determination and for benefit computation. \u25aa A large majority of states (47) utilize the standard method of computation–adding deemed income to the unit’s other income, and then performing the eligibility and benefit computations with the unit size of the eligible members. Other states use other formulas. California computes eligibility and benefits using the family size that includes the family members who are ineligible due to immigrant status, but caps the benefit at the maximum payment for the family size that includes only the eligible members. \u25aa One state\u2014Wisconsin\u2014does not allow eligibility for families in which all parents in the household are ineligible due to their immigrant status. Related tables: Tables I.B.5, I.B.6, and I.B.7 describe the variation in state policies concerning the eligibility of pre-PRWORA and post-PRWORA noncitizens. Welfare Rules Databook: State TANF Policies as of July 2017 29 E. How much income can a family have and still be eligible? To determine initial eligibility for benefits, many states use income eligibility tests–that is, tests that compare the unit’s gross or net income amount to a specified income threshold. If the applicant’s countable income (for purposes of that test) exceeds the threshold, the applicant is not eligible to receive benefits. Income eligibility tests and the calculation of countable income vary greatly across states. This section of the Databook describes the types of eligibility tests in the states, the earned income disregards used for the net income tests, and the income eligibility standards used for the various tests, and also presents a calculation of the maximum income for initial eligibility at application. The first three tables in this section must be used together to fully understand the income eligibility tests in each state. Income Eligibility Test for Applicants (Table I.E.1) To determine initial eligibility for benefits, most states impose income eligibility tests on applicants. States use the total gross income calculated from the unit’s earned and unearned income as a starting point for these tests. States may impose one income test on applicants or use a combination of tests, which might include a gross income test, a gross earnings test, an unearned income test, and\/or a net income test. A gross income test compares the unit’s total income (earned and unearned, including any deemed income) with a state-determined standard. If the unit’s income is less than the standard, the next test is applied (if applicable) or the unit is considered eligible and a benefit is computed. A gross earnings test and an unearned income test operate similarly, but only the unit’s earned income is used for a gross earnings test and only the unit’s unearned income is used for an unearned income test. States may also impose net income tests, either after a gross income test or in lieu of it. Net income is calculated by subtracting the state’s earned income disregards from the unit’s gross earned income and then adding the unit’s unearned income to this amount. The net income is then compared to an income standard determined by the state. If the net income is less than the standard, the next test is applied (if applicable) or the unit is considered eligible and a benefit is computed. Table I.E.1 describes states’ income eligibility tests for determining whether an applicant can begin receiving benefits. The table indicates the state income standard used for each test. 30 Welfare Rules Databook: State TANF Policies as of July 2017 \”No explicit tests\” indicates that either the state imposes no income tests on applicants (other than the implicit test inherent in the benefit computation formula) or the state imposes an income test, but the calculation of the test and disregards allowed for the test are no different from those used to calculate the benefit. Policies from 2017 include: \u25aa Forty-four states have explicit net or gross income tests for applicants. \u25aa Twenty-one states require applicants to pass two or more income eligibility tests. \u25aa Seven states have no explicit income eligibility tests for applicants. Related tables: Table I.E.3 provides the eligibility standards used to determine eligibility for a three-person family. Tables I.D.1, I.D.2, and I.D.4 describe policies concerning the deeming of income from grandparents, stepparents, and immigrant parents, respectively, that may be used when determining gross income for income eligibility tests. Table I.E.2 describes the earned income disregards that may be used for net income tests. Table I.E.4 combines information on the income eligibility tests applied to applicants with information on the earned income disregards and eligibility standards to show the maximum earnings a family can have and still be eligible for TANF. Table L3, in the last section of this book, provides the same information as in table I.E.4 for selected years from 1996 through 2017. Earned Income Disregards for Initial Income Eligibility Purposes (Table I.E.2) States that impose a net income test generally disregard a portion of the unit’s earned income before comparing the income to the state’s income standard. The amount of disregarded earned income varies greatly across states. Table I.E.2 describes the earned income disregards applied to applicants’ income in determining net income for the income eligibility tests. When a state has more than one net income test and imposes different disregards for the tests, the table will show two rows for the state describing both the disregard and for which net income test the disregard applies. When a state has no explicit net income tests, the table indicates No explicit net income test. Some states have net income tests but do not apply a general earned income disregard; instead, they may disregard earnings only for specific expenses, such as child care. In those cases, No disregards allowed appears in the table. Key policies from 2017 include: \u25aa Fifteen states have no explicit net income test, and therefore, do not have any earned income disregards for eligibility. An additional state, Virginia, imposes a net income test Welfare Rules Databook: State TANF Policies as of July 2017 31 with disregards for applicants who are not in the VIEW component, but does not have an explicit net income test for applicants to the VIEW component. \u25aa One state (Ohio) has a net income test that allows applicants to deduct dependent care expenses, but they do not disregard any other earnings in applying the net income test. \u25aa Two states (California and Texas) have two different net income tests, which use different disregards. Related tables: In some cases, states also use net income tests to determine a recipient’s continuing eligibility. The earned income disregards used in applying net income tests for recipients’ ongoing eligibility are captured in table IV.A.5. When a state has established different earned income disregards for applicants and recipients, the disregards are generally lower for applicants and higher for recipients. Additional disregards for child care expenses paid by a family or special disregards for units affected by a family cap or time limit are not included in the Databook; however, this information is included in the WRD. Standards for Determining Eligibility (Table I.E.3) As described earlier, most income tests involve state-established income amounts that vary by the size of the assistance unit. The WRD includes the standards for each family size from 1 through 12. Table I.E.3 provides the standards for a three-person assistance unit. Table I.E.3 identifies the standard by the name used in the caseworker manual. Under the former AFDC program, the standard for income eligibility tests was called the need standard. Currently, because of the complexity of state programs, there is no longer a single need standard concept. States may compare an assistance unit’s income against multiple standards, depending on the type or amount of income. Therefore, the term need standard is not used in the table unless the state explicitly uses it to refer to its eligibility standard. Key policies from 2017 include: \u25aa Standards for determining eligibility vary significantly across states. The values for a family of three range from a $188 Recognizable Needs standard in Texas to a $4,002 Standard of Need in New Hampshire. These values must be interpreted in conjunction with the information in other tables. The numbers do not by themselves indicate the maximum income at which a family may be eligible. That maximum depends on multiple policies, and on whether a family’s income is earned or unearned. 32 Welfare Rules Databook: State TANF Policies as of July 2017 Some details concerning eligibility standards are not included in table I.E.3. In some states, different dollar amounts are used in different regions of the state; in those cases, table I.E.3 includes the amounts for the most populous area of the state. In other states, the amounts may be higher for families with certain types of special needs, such as a pregnancy; the amounts in table I.E.3 assume no special needs. Also, a few states vary standards for one-parent families, two-parent families, and child-only units; table I.E.3 includes values for a one-parent family with two children. Some states prorate the eligibility or benefit standards depending on whether a unit pays for shelter; the amounts in the table assume the unit pays all shelter costs and does not live in public housing or have a housing voucher. Related tables: These standards by themselves are not comparable across states, since the income tests differ. To determine how the standards are used in practice, see tables I.D.1, I.D.2, I.D.4, I.E.1, and IV.A.4. Maximum Income for Initial Eligibility for a Family of Three (Table I.E.4) Table I.E.4 synthesizes the various financial rules related to initial eligibility to provide information on the maximum amount of income a family of three can earn and still be eligible for assistance. The calculation incorporates information on the income eligibility rules for applicants, earned income disregards for eligibility and benefit computation, benefit computation policies, and the eligibility and payment standards. The calculation determines the maximum amount of earnings an applicant can have and still be technically eligible for assistance in each state. Technical eligibility does not mean the unit will necessarily receive a cash benefit, but the unit will have passed all eligibility tests and will be eligible for some positive amount. Most states distribute a cash benefit only if it is greater than $10. The calculation assumes the assistance unit includes one parent and two children, has only earned income, has no child care expenses, contains no children subject to a family cap, has no special needs, pays for all shelter costs with no subsidies, and is subject to the benefit standard that applies to the majority of the state’s caseload. Key findings for 2017 include: \u25aa The maximum monthly earnings a family of three can have at application and be eligible for TANF varies significantly across states. The values for a family of three range from $268 in Alabama to $2,243 in Minnesota. \u25aa Across the states, the average (mean) earnings level that is the maximum possible amount allowing TANF eligibility is $881. The median figure is slightly lower, at $828. Welfare Rules Databook: State TANF Policies as of July 2017 33 Related tables: Table L3 provides the maximum income for initial eligibility for selected years from 1996 through 2017. Table IV.A.6 provides information on the amount of earnings a recipient may have and remain eligible for assistance. (The figures for recipients may differ from those for applicants due to differences in income eligibility tests and earnings disregards.) 34 Welfare Rules Databook: State TANF Policies as of July 2017 State Diversion program Maximum diversion payment 2 Form of payment How often recipient can receive maximum payment Period of TANF ineligibility after receiving diversion payment Payment counts toward the time limit Alabama No n.a. n.a. n.a. n.a. n.a. Alaska No 3 n.a. n.a. n.a. n.a. n.a. Arizona Yes 4 3 months of benefits Cash payment Once every 12 month period Period used in computing maximum diversion payment No Arkansas Yes 3 months of benefits Cash loan Once in a lifetime 100 days 5 Yes California 6 Yes Greater of $2,000 or 3 months of benefits 7 Cash or vendor payment As often as needed, up to maximums 7 No ineligibility period 8 Varies 8 Colorado 9 Yes $2,500 10 Cash payment Twice in a 12 month period up to 3 times in a lifetime 12 months 11 No Connecticut Yes 3 months of benefits Cash payment Once in a 12 month period up to 3 times in a lifetime Period used in computing maximum diversion payment Yes Delaware Yes 12 $1,500 Vendor payment Once every 12 month period Period used in computing maximum diversion payment 13 No D.C. Yes 3 months of benefits Cash or vendor payment Once every 12 month period Period used in computing maximum diversion payment 14 No Florida 15 Yes 16 $1,000 Cash payment Once in a lifetime 17 Period used in computing maximum diversion payment 18 No Georgia No n.a. n.a. n.a. n.a. n.a. Hawaii No n.a. n.a. n.a. n.a. n.a. Idaho Yes 3 months of benefits Cash payment Once in a lifetime Twice the number of months included in the payment Yes Illinois Yes 19 $1,200 20 Cash or vendor payment As often as needed, up to maximums 21 No ineligibility period No Indiana No n.a. n.a. n.a. n.a. n.a. Iowa No n.a. n.a. n.a. n.a. n.a. Kansas Yes $1,000 Cash payment Once in a lifetime 12 months Yes 22 Kentucky Yes $1,300 Vendor payment Once in a 24 month period up to 2 times in a lifetime 12 months No Louisiana No n.a. n.a. n.a. n.a. n.a. Table I.A.1. Formal Diversion Payments, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 35 State Diversion program Maximum diversion payment 2 Form of payment How often recipient can receive maximum payment Period of TANF ineligibility after receiving diversion payment Payment counts toward the time limit Maine Yes 3 months of benefits Vendor payment Once every 12 month period No ineligibility period 23 No Maryland Yes 3 months of benefits Cash or vendor payment As often as needed Period used in computing maximum diversion payment No Massachusetts No n.a. n.a. n.a. n.a. n.a. Michigan No n.a. n.a. n.a. n.a. n.a. Minnesota Yes 24 1 month of benefits 25 Cash or vendor payment Once every 12 month period 4 months 26 No Mississippi No n.a. n.a. n.a. n.a. n.a. Missouri Yes 3 months of benefits Cash payment Once every 12 month period Period used in computing maximum diversion payment No Montana No n.a. n.a. n.a. n.a. n.a. Nebraska No n.a. n.a. n.a. n.a. n.a. Nevada Yes Case-by-case Cash payment Once in a lifetime Period used in computing maximum diversion payment 27 No New Hampshire No n.a. n.a. n.a. n.a. n.a. New Jersey Yes 28 $750 29 Cash payment As often as needed 29 No ineligibility period 30 No New Mexico Yes 31 $1,500 32 Cash payment Twice in a lifetime 12 months 33 No New York Yes 34 Case-by-case 35 Cash or vendor payment Case-by-case No ineligibility period No North Carolina Yes 3 months of benefits Cash payment Once every 12 month period No ineligibility period No North Dakota Yes Case-by-case 36 Cash payment Up to 4 months in a 12 month period No ineligibility period No Ohio No n.a. n.a. n.a. n.a. n.a. Oklahoma No n.a. n.a. n.a. n.a. n.a. Oregon No n.a. n.a. n.a. n.a. n.a. Pennsylvania Yes 3 months of benefits 37 Cash payment Once every 12 month period Period used in computing diversion payment No Rhode Island No n.a. n.a. n.a. n.a. n.a. South Carolina No n.a. n.a. n.a. n.a. n.a. Table I.A.1. Formal Diversion Payments, July 2017 1 36 Welfare Rules Databook: State TANF Policies as of July 2017 State Diversion program Maximum diversion payment 2 Form of payment How often recipient can receive maximum payment Period of TANF ineligibility after receiving diversion payment Payment counts toward the time limit South Dakota Yes 2 months of benefits Cash or vendor payment As often as needed 3 months 38 No Tennessee Yes 39 12 months of benefits Cash payment As often as needed No ineligibility period Yes Texas Yes 40 $1,000 Cash payment Once every 12 month period 12 months No Utah Yes 3 months of benefits Cash payment Once every 12 month period 3 months No Vermont Yes 41 4 months of benefits Cash payment Once every 12 month period No ineligibility period 42 No Virginia Yes 4 months of benefits Cash or vendor payment Once every 12 month period Up to 160 days 43 No Washington Yes $1,250 Cash or vendor payment Once every 12 month period 12 months 44 No West Virginia Yes 3 months of benefits Cash payment Once in a lifetime 3 months No 45 Wisconsin Yes $1,600 Cash loan 46 As often as needed, up to maximums 47 No ineligibility period No Wyoming No n.a. n.a. n.a. n.a. n.a. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Many states require recipients of diversion assistance to be currently employed or seeking employment. Eligibility and diversion payment decisions often are made case by case. Receipt of diversion often precludes TANF applicants from being eligible for a certain period, but the degree of ineligibility may be decreased subject to a penalty such as prorating and deducting the diversion payment from initial TANF benefits. For more information on eligibility and payment calculations related to diversion assistance, see the \”Diversion\” category in the full Welfare Rules Database available online at https:\/\/wrd.urban.org\/wrd\/Query\/query.cfm. 2 The maximum diversion payment is either a flat payment, regardless of the family’s size and the state’s maximum benefit (represented in the table by a dollar amount), or a multiple of the maximum benefit the family would have received if it were receiving monthly TANF benefits (represented in the table by a number of months of benefits the family could receive). If the state provides diversion payments based on a multiple of the maximum benefit, the amount will vary by the family size and the generosity of the state’s maximum benefits. Table I.A.1. Formal Diversion Payments, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 37 3 Alaska’s TANF program is not currently implementing the diversion payment option due to systematic and program integrity reasons. Alaska may re-implement the payment option when its new eligibility software is fully launched and state statutes\/regulations have been updated to better define diversion-eligible households. According to the legislation authorizing the program, a recipient can receive a cash payment worth up to three months of TANF benefits. If a family applies for assistance during the three-month ineligibility period, the entire amount of the diversion payment is treated as unearned income to the family. The diversion payment is prorated equally over the three months, and the prorated amount is counted as monthly income. An individual can receive diversion payments up to four times in a lifetime but no more than once every 12 months. 4 To be eligible, applicants must have employment or self-employment history in the application month or within the 12 months prior to the application month, have successfully completed an educational, vocational, or job training program in the application month or within the six months prior to the application month, or have a job offer for full-time employment that will begin within three calendar months of the grant diversion period. 5 If the diversion loan is repaid, then it does not count toward the time limit. If it is not repaid, then it does count toward the time limit. 6 Counties have the option to vary their diversion programs. These policies refer to Los Angeles County. 7 The maximum diversion cash payment is the greater of $2,000 or three times the maximum aid payment for the family size. In cases where an applicant has a one- time expense that exceeds the standard maximum diversion payment, payments up to $4,000 may be issued if necessary to retain self-sufficiency. Recipients may receive only $4,000 or three times the maximum aid payment for the family, whichever is greater, annually and no more than $10,000 in a lifetime. 8 If the unit applies for monthly TANF benefits after the diversion period (diversion amount divided by the maximum aid payment) ends, the state counts one month toward the time limit. If the unit applies during the diversion period, it can choose to count the diversion payment toward the time limit or to repay the diversion amount at a rate of 10 percent of the monthly benefit each month until the diversion is repaid. The number of months counted toward the 48-month time limit is calculated by dividing the total diversion payment by the maximum aid payment for the apparently eligible assistance unit at the time the diversion payment was made. The months resulting from the calculation less any partial month, are counted toward the 48-month time limit. 14 The diversion payment is divided by the maximum benefit for the family size in order to get the period of ineligibility. The period is rounded down to the nearest month. 13 The period of ineligibility depends on the amount of the diversion payment. Units receiving $1 $500.99 are ineligible for one month, units receiving $501 $1,000.99 are ineligible for two months, and units receiving $1,001 $1,500 are ineligible for three months. 15 Florida has three separate diversion programs. An assistance unit may receive a one-time payment of up to $1,000 in up-front diversion or cash severance diversion, or up to the amount needed to relocate in relocation assistance. Cash severance diversion is also available to employed TANF recipients. Up-front diversion and relocation assistance do not count toward time limits. Cash severance diversion does not count toward time limits if the payment is made in a month in which the unit also receives a TANF payment. If the payment is made in a month in which the unit does not receive a TANF payment, the cash severance diversion payment counts as a month toward the time limit. 9 Counties have the option to vary their diversion programs. These policies refer to Denver County. 10 The amount of the payment is determined case by case. If assistance greater than $1,500 is requested, it must be approved by a designated staffing team. 11 The period of ineligibility is no more than four consecutive calendar months, unless good cause exists. The client may apply for the diversion assistance during the period of ineligibility if circumstances beyond his or her control exist. Such circumstances include but are not limited to: serious or terminal illness of an immediate family member; natural disaster such as fire, flood, etc.; child protection case involvement with activities that are incompatible with the Individual Responsibility Contract; a lack of child care; job lay-off; domestic violence; homelessness; and severe mental or physical disabilities. 12 The state’s diversion program is related to retaining or obtaining employment and is only for parents living with natural or adopted children. 38 Welfare Rules Databook: State TANF Policies as of July 2017 16 Florida has three separate diversion programs. Up-front diversion is for individuals in need of assistance because of unexpected circumstances or emergency situations. Relocation assistance is available for individuals who reside in an area with limited employment opportunities and experience one of the following: geographic isolation, formidable transportation barriers, isolation from extended family, or domestic violence that threatens the ability of a parent to maintain self- sufficiency. Cash severance is available to TANF recipients if they meet the following criteria: they are employed and receiving earnings, they are able to verify their earnings, they will remain employed for at least six months, they have received cash assistance for at least six consecutive months since October 1996, and they are eligible for at least one more month of TANF. 17 There is no limit on the number of times relocation assistance services are needed. 18 The client is ineligible for three months for up-front diversion and six months for relocation assistance. If an up-front diversion recipient reapplies for TANF within the three-month period and the Regional Workforce Board confirms an emergency exists, TANF benefits are approved and the diversion benefit is prorated over the next eight months of eligibility. For relocation assistance, if the family applies for cash assistance before the six-month period ends for emergency reasons other than domestic abuse, the relocation payment will be prorated and subtracted from any cash assistance payments received. 19 Illinois operates its diversion program through local community partners. Payments are provided when funding is available. 20 Some of these expenses have individual limits. 21 Clients cannot receive more than the maximum payment in any 12-month period without additional approval. 22 Recipients of diversion payments have their lifetime limit for TANF benefits reduced by six months. 23 Units that apply for benefits during the three-month ineligibility period must repay any diversion payment received for any period that was covered by both diversion and TANF. 24 Minnesota’s four-month Diversionary Work Program (DWP) is mandatory for all TANF applicants, unless exempt. Recipients receive financial assistance and must participate in four months of intensive employment services focused on helping the participant obtain an unsubsidized job before entering regular TANF. Failure to comply with the employment services, which may include a structured job search, results in ineligibility for both DWP and TANF until compliance. After completing the four-month program, participants who still require assistance may apply for TANF as applicants. 25 DWP benefits are provided monthly and are equal to the difference between the unit’s countable income and the sum of its actual housing costs, utility costs, $35 a month for telephone services, and up to $70 per unit member for personal needs. The total monthly grant amount cannot exceed the cash portion of the TANF transitional standard. DWP recipients are eligible to receive SNAP benefits in addition to their diversion benefits (unlike the TANF calculation, which combines the cash and SNAP benefits). The unit is generally not required to assign child support payments over to the state while participating in DWP, but child support must be signed over to the state if the family receives child care assistance. 26 The unit may apply for TANF at the completion of the four-month diversion program. If a unit applies for TANF any time within 12 months of receiving either TANF or DWP assistance, it moves directly into TANF and is not eligible to participate in diversion. 27 A recipient is ineligible to receive TANF for the number of months determined by dividing the Self-Sufficiency Grant (SSG) payment by the maximum TANF grant for the family size at the time of payment. Any part of a month counts as a full month. 28 New Jersey’s diversion program, the Early Employment Initiative (EEI), is mandatory for applicants who have a work history that equals or exceeds four months of full-time employment in the past 12 months, appear to meet TANF eligibility requirements, are not in immediate need, and do not meet criteria for a deferral from work requirements. Participants receive a one-time, lump-sum payment and are required to pursue an intensive job search for 15 to 30 days while their application is processed. If participants obtain employment and withdraw their application, they are eligible to receive a second lump-sum payment to assist in the transition to employment. If no employment is secured, the applicant is referred back to the Work First New Jersey (WFNJ)\/TANF agency for cash assistance. Welfare Rules Databook: State TANF Policies as of July 2017 39 32 The grant amount is $1,500 for a family of one to three people and $2,500 for a family of four or more. 33 Good cause may include loss of employment, but not a voluntary quit or dismissal due to poor job performance or failure to meet a condition of employment, use of an illegal substance or other drug, catastrophic illness or accident of a family member which requires an employed participant to leave employment, a victim of domestic violence, or another situation or emergency that renders an employed family member unable to care for the basic needs of the family. 34 New York has three types of diversion payments: diversion payments (for crisis needs such as moving expenses, storage fees, or household structural or equipment repairs), diversion transportation payments (for employment-related transportation expenses), and diversion rental payments (for rental housing). 35 Eligible individuals include cash assistance applicants or re-applicants who meet eligibility criteria for cash assistance, but are deemed unable to meet the work requirements. The value of the payment is determined case by case depending on the specific needs of the family. 29 The maximum amount a family would receive is relative to the number of people in the unit. The amount included in the table is for a unit of three. The maximum diversion payment for a unit of eight or more people is $1,550. If the agency believes an individual may benefit, he or she may be considered suitable for repeated participation in the Early Employment Initiative (EEI) when determining subsequent eligibility for the program. 30 If a participant is unable to find a job through the diversion program or loses employment and reapplies for TANF benefits within 60 days of the original application, TANF benefits will be retroactive to the date of application. 31 The diversion payment is intended to assist the benefit group in accepting or retaining employment, remedying an emergency situation, or alleviating an unexpected short-term need. 36 Cash payment for emergency needs is limited to $430 a month for up to four months. Additional supportive services can include: Housing\/shelter costs; $1,000 maximum for the cost of books, tuition, and fees relating to a work activity; $1,000 maximum for moving expenses relating to a job offer; $500 maximum for vehicle repairs; $250 maximum for employment related clothing; $150 maximum for cost for tools or equipment required for employment; and $150 maximum for monthly transportation expenses. 38 If the unit applies for benefits before the three months have passed, the individual must repay the diversion payment. The payment will be prorated over a three- month period and the amount of the repayment will be deducted from the unit’s monthly assistance payment. 39 To be eligible, the applicant must have an identifiable one-time financial need, have been a resident of Tennessee for six months, have no identifiable barriers to employment, have earned a high school diploma or GED, and either be currently employed or have been steadily employed in six of the last 12 months, with at least three being consecutive. In two-parent units, both parents must meet the eligibility criteria to qualify for a diversion payment. 40 To qualify for the state’s diversion program, the assistance unit must meet one of the crisis criteria, including (1) the caretaker or second parent lost employment in the process month, application month, or two months before application; (2) a dependent child experienced a loss of financial support from the legal parent or stepparent within the past 12 months as a result of death, divorce, separation, abandonment, or termination of child support and the caretaker was employed within 12 months of the application or process month; (3) the caretaker or second parent graduated from a university, college, junior college, or technical training school within 12 months of the application or process month and was underemployed or unemployed; or (4) the caretaker or second parent is currently employed but still meets TANF requirements and is facing the loss or potential loss of transportation or shelter or has a medical emergency temporarily preventing him or her from continuing to work. If the unit has an open TANF activity requirement sanction and fails to demonstrate cooperation within the allowed time or is not eligible for a TANF grant of at least $10, the unit is ineligible for diversion assistance. 37 The payment equals one, two, or three months of the family size allowance. 40 Welfare Rules Databook: State TANF Policies as of July 2017 45 For units that received diversion assistance before July 2000, three months are counted toward the lifetime limit. 47 In a 12-month period, a unit may receive several loans, but it may not receive more than $1,600 in total loans or have an outstanding loan balance of more than $1,600. 46 Repayments are expected within 12 months but may be extended to 24 months. The loan may be paid back in cash or through a combination of cash and volunteer community service (valued at the higher of the state or federal minimum wage). 41 To be eligible for diversion assistance, an applicant family must meet cash assistance financial eligibility and diversion eligibility criteria and, if it has no members who are mandatory applicants, must choose to participate in the diversion program. Families who meet the following criteria are mandatory applicants: (1) at least one member of the family is work eligible, (2) work-eligible individuals in the family are neither disregarded from nor meeting their cash assistance work requirement, (3) none of the work-eligible individuals have received a diversion assistance payment in the 12 months before the application month, and (4) at least one work-eligible adult is part of a two-parent family, has recent and stable employment with earnings of at least 150 percent of the federal poverty guidelines, or has a marketable college degree or vocational education certificate. 42 The unit may be transferred into regular TANF (Reach Up) at any time after the four-month period of diversion (Reach First) payments. It is at the caseworker’s discretion to move a family into regular TANF during the four-month diversion period. However, should the unit need to apply for Reach Up in the months attributed to the Reach First payments, the payment will reduce dollar for dollar any Reach Up financial assistance in the months covered by the payment. 44 If a unit requests monthly benefits before 12 months have passed, the diversion payment becomes a loan. The amount of the loan is calculated by dividing the diversion payment by 12 and multiplying the quotient by the number of months remaining of the 12-month period since the diversion payment was received. The unit’s monthly benefit is decreased by 5 percent each month until the loan is paid off. 43 The period of ineligibility is 160 days when the diversion payment equals four times the monthly TANF benefit the unit could have received. The period may be shorter. The number of days of ineligibility is computed through these steps: (1) divide the diversion payment by 1\/30th of the monthly TANF benefit the unit could have received; (2) round up to the higher whole number; (3) multiply by 1.33; (4) round up to the higher whole number. Welfare Rules Databook: State TANF Policies as of July 2017 41 State Job search required? Description of job search requirement Who is exempt from job search at application? What is the penalty for noncompliance? Alabama Yes Apply to 3 jobs at businesses with job openings Individuals who are non-parent caretakers not included in the assistance unit, receive SSI, are ill or incapacitated, are aged 60 years or older, are providing full-time care for a child under 12 weeks of age, are full-time volunteers in the VISTA program, or are working more than 30 hours per week earning minimum wage Application is denied Alaska Yes Participate in a 4-week job search program, which may include group or individual job search and job readiness activities Individuals who are not job-ready, are ill or incapacitated, are caring for an ill or incapacitated family member, are caring for a child under 12 months old, or lack access to adequate child care 2 Benefit is reduced Arizona No n.a. n.a. n.a. Arkansas No n.a. n.a. n.a. California 3 No n.a. n.a. n.a. Colorado 4 No n.a. n.a. n.a. Connecticut No n.a. n.a. n.a. Delaware No n.a. n.a. n.a. D.C. No 5 n.a. n.a. n.a. Florida No 6 n.a. n.a. n.a. Georgia Yes Within 6 weeks of application review, make 12-24 job contacts Individuals who are not job-ready, are ill or incapacitated, or are providing full-time care for a child under 12 months of age Application is denied Hawaii Yes Complete orientation and intake within 1 week of application; complete 1 full week of job readiness training within 21 days from intake Individuals who are non-needy caretakers, are receiving SSI, are caring for an ill or incapacitated family member, are aged 65 or older, are single-custodial parents providing full-time care for a child under 6 months of age, or are exempt from work requirements due to temporary disability, substance abuse treatment, or crisis due to domestic violence situation Application is denied Table I.A.2. Mandatory Job Search at Application, July 2017 1 42 Welfare Rules Databook: State TANF Policies as of July 2017 State Job search required? Description of job search requirement Who is exempt from job search at application? What is the penalty for noncompliance? Idaho Yes Participate in a job search program, which may include group or individual job search and job readiness activities Individuals who are providing full-time care for a child under 12 weeks of age Application is denied Illinois No n.a. n.a. n.a. Indiana Yes Participate in job search for 4 hours per day for 20 days within the 60 day application period 7 Individuals who receive Medicaid as Blind or Disabled, SSDI or other disability benefit, are aged 60 years or older, are providing full-time care for a child under 12 weeks of age or an incapacitated household member, or are refugees (or other alien with refugee equivalent status) and within 6 months of their date of arrival Application is denied Iowa No n.a. n.a. n.a. Kansas No 8 n.a. n.a. n.a. Kentucky No n.a. n.a. n.a. Louisiana No n.a. n.a. n.a. Maine No n.a. n.a. n.a. Maryland Yes For 2 weeks, search for jobs for at least 20 hours per week Individuals who are non-parent caretakers not included in the assistance unit, are ill or incapacitated, are providing full-time care for a child under 12 months of age for a maximum of 12 months in the parent’s lifetime, or are working more than 30 hours per week earning minimum wage Application is denied Massachusetts Yes Within first 30 days, 3 job contacts (one of which is a mandatory orientation session), 3 job contacts within second 30 days Individuals who are under age 18, not subject to work requirements, currently enrolled in an education or training activity, or participating in inpatient substance abuse treatment Work Ready Job Search: Unit’s application is denied; Initial Job Search Program: Noncompliant adult is removed from unit Table I.A.2. Mandatory Job Search at Application, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 43 State Job search required? Description of job search requirement Who is exempt from job search at application? What is the penalty for noncompliance? Michigan Yes For a minimum of 21 days up to a maximum of 30, participate in work activities including job search Individuals who are ill or incapacitated, are caring for someone ill or incapacitated, are aged 65 or older, are providing full-time care for a child under 2 months of age, are experiencing pregnancy complications, or are victims of domestic violence Application is denied Minnesota Yes 9 For 4 months, participate in work activities program including job search 9 Individuals who are aged 60 or older, are single parents providing full-time care for a child under 12 months of age, have received Diversion or TANF benefits within the last 12 months, or are in units with either refugee or asylee caregivers granted such status within the last 12 months Ineligible until in compliance 10 Mississippi Yes Within 30 days, make at least 3 job search contacts Individuals who are exempt from work requirements Application is denied Missouri Yes Register\/login to jobs.mo.gov to start job search Individuals who are exempt or temporarily excluded from work activities Application is denied Montana No n.a. n.a. n.a. Nebraska No n.a. n.a. n.a. Nevada Yes Determined by local office Individuals who are non-head-of-household minor parents, are undocumented non-citizens, receive SSI\/SSDI, are parents caring for a disabled family member, or are non-recipient non-parent relatives Application is denied New Hampshire No n.a. n.a. n.a. New Jersey Yes 11 For a minimum of 15 days up to a maximum of 30, participate in required job search placement plan Individuals who are ill or incapacitated, are caring for a newborn or for someone ill or incapacitated, are aged 62 or older, are pregnant, lack access to adequate child care, are victims of domestic violence, or are in drug, alcohol, or mental health treatment 12 Application is denied New Mexico No n.a. n.a. n.a. New York Yes Determined by local office Individuals who are ill or incapacitated, are aged 60 or older, are providing full-time care for a child under 3 months of age, or are pregnant within 30 days of expected delivery date 13 Application is denied Table I.A.2. Mandatory Job Search at Application, July 2017 1 44 Welfare Rules Databook: State TANF Policies as of July 2017 State Job search required? Description of job search requirement Who is exempt from job search at application? What is the penalty for noncompliance? North Carolina No n.a. n.a. n.a. North Dakota No n.a. n.a. n.a. Ohio No n.a. n.a. n.a. Oklahoma No n.a. n.a. n.a. Oregon No n.a. n.a. n.a. Pennsylvania Yes 14 While application pends, apply to 3 jobs per week 14 Individuals who are employed, are participating in the Diversion program, are participating in the Department of Human Services’ employment and training program, or meet a work requirement exemption Application may be denied Rhode Island No n.a. n.a. n.a. South Carolina Yes Within 2 weeks, contact at least 5 employer contacts Individuals who are ineligible aliens, are ill or incapacitated, are caring for someone ill or incapacitated, are single parents providing full-time care for a child under 12 months of age, are at least seven months pregnant, are victims of domestic violence, are reapplying to cure a sanction within 60 days after the closure, or are refugees Application is denied South Dakota No n.a. n.a. n.a. Tennessee No n.a. n.a. n.a. Texas No n.a. n.a. n.a. Utah No n.a. n.a. n.a. Vermont Yes Report to the Department of Labor within two working days following eligibility interview Individuals who face barriers to work or do not have any recent or stable work history Application is denied Virginia No n.a. n.a. n.a. Washington No n.a. n.a. n.a. West Virginia No n.a. n.a. n.a. Wisconsin Yes Participate in a job search program, which may include job orientation or other job search activities Individuals who are not job-ready Application may be denied Wyoming No n.a. n.a. n.a. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table I.A.2. Mandatory Job Search at Application, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 45 4 Counties have the option to vary their diversion programs. These policies refer to Denver County. 1 This table refers to single-parent unit heads over 21 years old. 2 The unit’s benefit is reduced by the difference between the adult-based need standard for a two-person unit and the child-only need standard for a one-person unit. 3 Counties have the option to vary their diversion programs. These policies refer to Los Angeles County. 5 Job search is not required, but families may be referred for job search assistance based on their needs. 6 Applicants are required to engage in work activities, which may include job search, as determined by the local workforce board. 7 Job search training and job readiness activities are allowed for up to 20 hours of the 80 total hours. 8 As a condition of eligibility, applicants are required to complete an on-line assessment and an on-line employment services orientation tutorial. 14 As a condition of eligibility, applicants who are not employed a minimum of 20 hours per week are required to document that they applied for at least three jobs per week while the application is pending authorization for benefits. 9 Most families who have not used cash assistance in the last 12 months must first participate in the Diversionary Work Program (DWP). The participant and caseworker develop an employment plan, including hours of job search, before receiving DWP benefits; the participant must report job search activity and accept any offer of suitable employment. If the participant is a victim of domestic violence, the employment plan is developed in association with a family violence advocate. After the DWP, participants may apply for TANF assistance, without a requirement for job search at application. 10 During the four-month DWP eligibility period, the case is closed until the family comes into compliance with employment services, at which point the benefit is prorated from the date of compliance. There is no minimum amount of time the case must be closed. 11 Job search is a mandatory part of the state’s diversion program. Once in the program, participants receive an activity payment and are required to search for a job during the TANF application process. If no employment is secured, the applicant is referred back for traditional cash assistance. 12 Pregnant women are deferred from work requirements if they are in the third trimester, or earlier in the pregnancy with a medical reason. 13 The exemption for a caretaker of a child under 3 months may last for no more than 12 months in a recipient’s lifetime, and it may not last for more than three months for any one child unless the social services official makes a determination to extend the exemption for up to the total of 12 months. 46 Welfare Rules Databook: State TANF Policies as of July 2017 State Mother Father 1 Unborn Child Eligible in what month of pregnancy? Alabama No No No n.a. Alaska Yes 2 No No 7 Arizona No No No n.a. Arkansas No No No n.a. California Yes 3 No No 4 4 Colorado Yes No No 1 5 Connecticut Yes 6 No No 1 Delaware Yes 7 No No 9 8 D.C. Yes No No 5 Florida Yes No No 9 9 Georgia No No No n.a. Hawaii Yes No No 9 Idaho Yes No No 7 10 Illinois Yes Yes 11 No 1 Indiana No No No n.a. Iowa No No No n.a. Kansas Yes Yes No 1 Kentucky No No No n.a. Louisiana Yes 6 No 12 No 6 Maine Yes No No 7 Maryland Yes Yes No 1 Massachusetts Yes No No 6 13 Michigan Yes Yes 14 No 1 Minnesota Yes No 15 No 1 16 Mississippi No No No n.a. Missouri No No No n.a. Montana Yes No No 7 Nebraska Yes Yes 17 Yes 7 Nevada Yes No No 6 New Hampshire No No 12 No n.a. New Jersey No No No n.a. New Mexico Yes Yes 18 No 7 New York Yes Yes No 1 5 North Carolina No No No n.a. North Dakota Yes No 19 No 6 Ohio Yes No No 6 Oklahoma No No No n.a. Oregon Yes Yes No 8 20 Pennsylvania Yes 21 No No 1 5 Rhode Island Yes 6 No No 7 22 South Carolina No No No n.a. South Dakota No No No n.a. Table I.B.1. Eligibility of Pregnant Women with No Other Children, July 2017 Eligible for Benefits Welfare Rules Databook: State TANF Policies as of July 2017 47 State Mother Father 1 Unborn Child Eligible in what month of pregnancy? Tennessee Yes No No 6 Texas No No No n.a. Utah Yes Yes No 7 Vermont Yes No No 9 23 Virginia No No No n.a. Washington Yes No No 1 24 West Virginia No No No n.a. Wisconsin Yes 25 No No 6 26 Wyoming No No No n.a. Total states providing benefits 32 9 1 n.a. 3 A pregnant woman must meet the eligibility requirements as if her child were already born and living with her. If the father of the unborn child is living in the home, his income, resources, and needs are counted to determine her eligibility and benefits. After the child is born, the father and child will be added to the assistance unit if eligible. 4 A pregnant woman age 19 or older, with no other eligible children in the home, may be eligible beginning in the second trimester of pregnancy. 5 A pregnant woman is eligible upon verification of pregnancy. 6 A pregnant woman must meet the eligibility requirements as if her child were already born and living with her. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 If a state’s policies vary for same-sex couples, the policy for same-sex couples is described in the notes. 2 The needs, resources, and income of all household members who would be required to be in the mandatory filing unit must be considered in determining eligibility. If the woman is eligible, the payment is based solely on the pregnant woman’s income and needs. Table I.B.1. Eligibility of Pregnant Women with No Other Children, July 2017 Eligible for Benefits 7 A pregnant woman’s financial eligibility in the month that her child is due is determined by comparing her gross income to 185 percent of the standard of need for one person. If she lives with the father of her unborn child, financial eligibility is determined by comparing the sum of the pregnant woman’s income and the father’s income to the standard of need for three people (the number of people who would be included in the family unit when the child is born). If income exceeds the standard, the application is denied. If income is less than the standard, only the mother’s income and needs are considered in determining the amount of the grant. 14 The father must be married to the mother to be eligible. 15 The income and assets of both the mother and father are used to determine eligibility and benefits if the mother and the father live together and are married. 9 A pregnant woman is eligible in the ninth month, unless her doctor verifies that she is unable to work; then she is eligible in the seventh month. The ninth month is defined as the calendar month in which the due date falls. 10 A pregnant woman is eligible only if she is in her last trimester and unable to work for medical reasons. 11 A pregnant woman and her spouse or civil union partner, if living with her, are eligible for assistance. 12 This state does not provide benefits to two-parent, nondisabled families. If the father of the child is disabled, incapacitated, or caring for a disabled family member living in the home, he may be included. 13 A pregnant woman may only receive benefits after a licensed medical practitioner has verified the pregnancy and determined the expected date of delivery. A pregnant woman age 18 or younger is eligible from the date the pregnancy is verified and if she is otherwise meeting her school’s attendance requirements. 8 A pregnant woman is eligible on the first day of the month in which the child is expected. 48 Welfare Rules Databook: State TANF Policies as of July 2017 19 This state does not provide benefits to two-parent, nondisabled families. If the pregnant woman resides with her spouse and either the woman or spouse is incapacitated, aged, or disabled, they may both be included. 16 A pregnant woman is eligible the first day of the month in which the pregnancy is confirmed, or the application date, whichever is later. 17 When the parents of the unborn child are married, the father’s needs are included when determining the benefit. 18 The father of the unborn child may be in the assistance unit if living in the home. Additionally, to be considered, the father must sign a sworn statement attesting to paternity of the child. 24 A pregnant woman may only receive benefits after a licensed medical practitioner has verified the pregnancy and determined the expected date of delivery. 25 A pregnant woman is eligible in the third trimester of pregnancy if she is unmarried, unable to work due to a medically- verified at-risk pregnancy, and the at-risk pregnancy is verified no earlier than 30 days prior to the beginning of the third trimester. 26 Pregnant women are eligible for cash assistance beginning in the sixth month of pregnancy. Prior to the sixth month of pregnancy, if a pregnant woman does not qualify for cash assistance, she may receive other support services (i.e., employment or child care related services) upon medical verification of the pregnancy. 20 A pregnant woman may apply in the month prior to her due date. A pregnant woman who is at risk or has a safety concern due to domestic violence may apply for TANF at any point during her pregnancy. 21 A pregnant woman must meet the eligibility requirements as if her child were already born and living with her. If the pregnant woman’s spouse is living in the home, his income, resources, and needs are included in this calculation. If she is not married, the income, resources, and needs of the father will not be included in the eligibility calculation until the child is born and paternity has been established. 22 A pregnant woman can begin to receive assistance within three months of her medically-verified due date. 23 A pregnant woman may be eligible in the seventh month if she is a minor or is documented as having a high-risk pregnancy. Welfare Rules Databook: State TANF Policies as of July 2017 49 State Upper limit on monthly work hours 2 Work history test 3 Application waiting period after employment ends Alabama No limit No None Alaska No limit No None Arizona No limit No None Arkansas No limit No None California 100 4 No None Colorado No limit No None Connecticut No limit No None Delaware No limit No None D.C. No limit No None Florida No limit No None Georgia No limit Must be connected to the work force 5 None Hawaii No limit No None Idaho No limit No None Illinois No limit No None Indiana No limit No None Iowa No limit No None Kansas No limit No None Kentucky 100 6 Must have earned at least $1,000 in the last 2 year period 7 30 days Louisiana 8 n.a. n.a. n.a. Maine 100 6 out of 13 quarters 30 days Maryland No limit No None Massachusetts No limit No None Michigan No limit No None 9 Minnesota No limit No None Mississippi 100 6 out of 13 quarters 30 days Missouri 10 No limit No None Montana No limit No None Nebraska No limit No None Nevada No limit No None New Hampshire 8 n.a. n.a. n.a. New Jersey No limit No None New Mexico No limit No None New York No limit No None North Carolina No limit No None 11 North Dakota 8 n.a. n.a. n.a. Ohio No limit No None Oklahoma No limit 6 out of 13 quarters 30 days Oregon No limit No None Pennsylvania No limit No None Rhode Island No limit No None South Carolina No limit No None Table I.B.2. Eligibility Rules for Two-Parent, Nondisabled Applicant Units, July 2017 1 50 Welfare Rules Databook: State TANF Policies as of July 2017 State Upper limit on monthly work hours 2 Work history test 3 Application waiting period after employment ends South Dakota 100 Must have earned at least $1,500 in the last 6 month period 12 None Tennessee No limit No None Texas No limit No None Utah No limit No None Vermont No limit No None Virginia No limit No None Washington No limit No None West Virginia No limit No None Wisconsin No limit No None Wyoming No limit No None 5 Applicants must have been connected to the workforce, which includes one of the following: (1) currently working at least 20 hours a week, (2) receiving Unemployment Compensation, or received UC benefits within 12 months prior to the application date, (3) unemployed or working less than 20 hours a week and earned $500 within the six months before application, (4) receiving retirement benefits or received retirement benefits in any of the six months prior to the application month, or (5) has received disability benefits based on 100 percent disability in any of the last six months. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 In some states, benefits are provided to two-parent units under a state-funded program instead of through federal TANF. This table describes the treatment of two-parent units regardless of the funding source. Eligibility rules for two-parent, nondisabled families are special categorical rules in addition to the other state rules that all units must pass. Under the AFDC program, states imposed rules on two-parent families’ work effort, including limits on hours of work, work history tests, and waiting periods. Some states have continued to impose these policies under TANF. 3 Applicants have to demonstrate previous attachment to the workforce; under AFDC, the principal earners was required to work at least six of the last 13 quarters. The 13-quarter period must have ended within one year of applying for assistance. Generally, work history could also be established if one of the following applied: (1) the applicant received unemployment compensation (UC) benefits within 12 months of the date of application or (2) the applicant would have been eligible for UC benefits within the previous 12 months but did not apply or his or her employment was not covered by UC laws. 4 To be eligible for cash assistance, the individual has to have been employed less than 100 hours during the four-week period before the date of eligibility for cash aid. 2 States with this policy generally allow eligibility for units with two nondisabled parents only if the principal earner in the couple works no more than a certain number of hours per month. However, in most states with this policy, eligibility may still be allowed when hours exceed the maximum, if work hours are usually at or below the maximum. See the full database for details. Table I.B.2. Eligibility Rules for Two-Parent, Nondisabled Applicant Units, July 2017 1 6 The applicant may not have turned down a bona fide offer of training or employment without good cause, and must be available for full-time labor. 7 Applicants must have earned at least $1,000 during the 24-month period before the month of application. Two semesters of full-time attendance in a postsecondary institution may be substituted for $500 of the $1,000. 8 The state does not provide benefits to two-parent, nondisabled units. 9 Applicants who refuse suitable employment without good cause while their application is pending, or up to 30 days before their application date, are not eligible for benefits until the 30th day after the refusal of employment. Welfare Rules Databook: State TANF Policies as of July 2017 51 11 While there is no waiting period for newly unemployed families, these families cannot receive benefits in a given month during which the family receives verified wages that make them ineligible. 12 The parents in the unit must have a combined gross income in the past six months of at least $1,500 and must not have voluntarily terminated employment, reduced hours worked, or refused a job offer within the previous six months without good cause. 10 Policies shown are for all areas of the state, with the exception of Kansas City. 52 Welfare Rules Databook: State TANF Policies as of July 2017 State Can be head of unit Living arrangement restriction 2 Alabama Yes Yes Alaska Yes Yes Arizona Yes Yes Arkansas Yes Yes California Yes Yes 3 Colorado Yes Yes Connecticut Yes Yes Delaware No 4 Yes D.C. Yes Yes Florida Yes Yes Georgia Yes Yes Hawaii Yes No Idaho No 5 Yes 6 Illinois Yes Yes 7 Indiana Yes Yes Iowa Yes Yes Kansas No 8 Yes Kentucky Yes Yes Louisiana No 9 Yes Maine Yes 10 Yes Maryland No Yes Massachusetts Yes Yes 11 Michigan No 12 Yes Minnesota Yes 13 Yes Mississippi Yes Yes Missouri Yes Yes 14 Montana No 15 Yes Nebraska Yes No Nevada Yes Yes New Hampshire Yes Yes New Jersey Yes Yes New Mexico Yes Yes New York Yes 16 Yes North Carolina No Yes North Dakota Yes Yes 17 Ohio Yes Yes 18 Oklahoma Yes Yes Oregon Yes Yes 19 Pennsylvania Yes Yes Rhode Island Yes Yes 20 South Carolina Yes Yes South Dakota Yes Yes 21 Tennessee Yes Yes Texas Yes Yes Utah Yes Yes Table I.B.3. Special Rules Imposed on Minor Parent Eligibility, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 53 State Can be head of unit Living arrangement restriction 2 Vermont Yes Yes 22 Virginia Yes 23 Yes Washington Yes Yes West Virginia No Yes Wisconsin No Yes Wyoming Yes Yes Total states with policy 41 49 7 Minor parents may receive benefits for up to six nonconsecutive months without complying with the residency requirement. 4 Children born to teenage parents are ineligible for cash assistance unless the parent is married. The minor parent may receive noncash assistance services in the form of vouchers for their children upon request; however, vouchers are not automatically distributed each month. Voucher payments are distributed through a protective payee to the minor parent’s parent or the adult in the supervised living arrangement. 6 An unmarried parent under age 18 must live with his or her parents, unless good cause is established. Two unmarried parents under the age of 18, with a child in common, can choose to live with the parents of the unmarried father or the unmarried mother. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This table provides policies for parents under 18 years old. States may have a different age cutoff for treating parents as minors for at least some purposes. 2 This column describes whether the state requires unmarried minor parents, who have not been legally emancipated, to live with their parents or in another state-approved setting. If \”Yes\” is coded, a minor is not eligible to receive assistance unless living with a parent or in an approved setting. Under federal policy, minors may be exempt from this requirement under the following circumstances: the minor has no parent, legal guardian, or other appropriate relative who is living or whose whereabouts are known; the minor or his or her child has been subjected to, or faces an imminent risk of, serious physical or emotional harm in the residence of the minor’s parent or legal guardian; or the state agency determines it is in the best interest of the minor’s child to waive the requirement. 3 A minor parent is exempt from living with his or her parents if he or she does not have a living parent or legal guardian, there is no a state-licensed living arrangement available, a child protection services worker determines that such a living arrangement would be physically or emotionally unsafe, or the minor parent has lived apart from his or her parents for more than 12 months. 5 A minor parent may be the head of an assistance unit if the minor parent is married. Table I.B.3. Special Rules Imposed on Minor Parent Eligibility, July 2017 1 8 Minor parents may be the head of the unit if they are 16 or 17 and have been married, have been placed in independent living by the department of children and families, are in an approved transitional living program, or are in Job Corps. 9 A minor parent can head his or her own unit if he or she meets an exemption to the residency requirement. 11 A minor parent may live on his or her own when the Department of Children and Families determines that he or she has acquired sufficient independent living and parenting skills. 10 If the minor lives with his or her parents and the grandparents are parenting the child, the grandparents must be included in the TANF unit. If the minor is parenting the child and the grandparents are not receiving TANF for other children, the grandparents may or may not be included, at the option of the family. 12 A minor parent can head his or her own unit when the adult relative or legal guardian is not receiving assistance. In these cases, the supervising adult must serve as the protective payee. 54 Welfare Rules Databook: State TANF Policies as of July 2017 14 A minor parent is exempt from living with his or her parents if he or she does not have a living parent or guardian (or if the whereabouts of the parent or guardian is unknown), the minor parent’s legal living parent or guardian will not allow the minor parent to live in his or her home, the state determines that such a living arrangement would be physically or emotionally unsafe, the minor parent lived apart from any parent or legal guardian for at least a year prior to either the birth of the dependent child or applying for benefits, or the state determines good cause to live apart from a parent, adult relative, or other approved setting. 15 Individuals under the age of 18 can head their own units if they have been emancipated by court action or a previous marriage. 17 Minor parents are exempt from living with a parent, legal guardian or a legally responsible caretaker relative, or in an adult-supervised supportive living arrangement if they have a marital status of separated, divorced, or widowed, or are active duty in the uniformed service. 16 The minor parent must be at least 16 years old to receive assistance as the head of the assistance unit. 13 When two unmarried minor caregivers live together with their minor child, at least one minor caregiver must meet the living arrangement requirements in order for the minor child, along with the minor caregiver, to be eligible. 18 If the minor lives with a parent, guardian, or relative, the benefit is generally paid to that person as a protective payee. A protective payment is not required if the minor lives in a supervised supportive living arrangement such as a group home. 19 A minor parent may be exempt from the residency requirement if it is unsafe or impractical for the minor parent to live with his or her parents, legal guardian, or other adult relative. 20 Minors who are at least six months pregnant are subject to the residency requirements. 23 A minor parent may form his or her own unit provided none of the minor parent’s siblings receive benefits. 22 Minor parents may be exempt if they are 17 years old and have lived independently for at least six months, live with their child’s other parent and both parents are age 16 or older, or lack an appropriate living arrangement. 21 A minor parent is exempt from living with his or her parents if no adult relative or legal guardian will allow the minor parent and child to live with them. Welfare Rules Databook: State TANF Policies as of July 2017 55 State Inclusion in the assistance unit Alabama Mandatory Alaska Prohibited Arizona Prohibited Arkansas Mandatory California Optional Colorado Prohibited Connecticut Prohibited Delaware Optional 2 D.C. Optional Florida Prohibited Georgia Optional Hawaii Optional Idaho Mandatory Illinois Optional Indiana Optional 3 Iowa Prohibited Kansas Mandatory Kentucky Prohibited Louisiana Mandatory 4 Maine Optional Maryland Optional Massachusetts Prohibited Michigan Mandatory Minnesota Mandatory Mississippi Prohibited Missouri Prohibited Montana Mandatory Nebraska Mandatory Nevada Optional New Hampshire Mandatory New Jersey Optional 5 New Mexico Mandatory New York Optional North Carolina Mandatory North Dakota Mandatory Ohio Prohibited Oklahoma Prohibited Oregon Mandatory Pennsylvania Optional 6 Rhode Island Mandatory South Carolina Mandatory South Dakota Mandatory 7 Tennessee Prohibited 8 Texas Optional Utah Mandatory Vermont Mandatory Virginia Prohibited Washington Mandatory Table I.B.4. Inclusion of Stepparents in the Assistance Unit, July 2017 1 56 Welfare Rules Databook: State TANF Policies as of July 2017 State Inclusion in the assistance unit West Virginia Mandatory Wisconsin Mandatory 9 Wyoming Prohibited Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The table describes policies for units in which the stepparent has no child in common with the spouse (the head of unit and the parent of the child or children), the stepparent has no dependents of his or her own living in the household, the spouse is living in the home, and the spouse is not incapacitated. States may have different policies that apply when these conditions are not true (e.g. if the natural parent is incapacitated). 4 If both the parent and the stepparent are able bodied, then the unit is considered a two-parent unit and is not eligible for assistance. 3 The stepparent is included only if he or she is a specified relative with care and control of the child. 2 The needy legal spouse or civil union partner of a child’s natural or adoptive parent can be included in the unit if the parent is the principal wage earner and qualifies as an unemployed parent. Table I.B.4. Inclusion of Stepparents in the Assistance Unit, July 2017 1 9 The stepparent is included in the W-2 group for income purposes but cannot be the mandatory work program participant. 8 The stepparent is not allowed to be included in the unit unless he or she is the only relative in the home who meets the caretaker requirements. 7 If the stepparent is an Indian in Indian country who is under the exclusive jurisdiction of a tribe for purposes of determining the domestic relations rights of the family, the stepparent has the option of being included in the assistance unit. 6 If the stepparent is a specified relative or essential person (i.e., a relative who lives with the child and cares for the dependent), the stepparent may be included in the assistance unit. 5 The stepparent is a mandatory participant in the unit unless the stepparent’s income causes the assistance unit to become ineligible, in which case the stepparent is not required to be included in the unit. If the stepparent chooses not to receive assistance, the unit becomes a child-only unit (the spouse is also excluded from the unit) and his or her income is used to determine eligibility but not the benefit amount. Welfare Rules Databook: State TANF Policies as of July 2017 57 State Lawful permanent residents 2 Asylees 3 Alabama All All Alaska All All Arizona Some 4 All Arkansas All All California All All Colorado All All Connecticut All All Delaware All All D.C. All All Florida All All Georgia All All Hawaii 5 All All Idaho All All Illinois All All Indiana All All Iowa All All Kansas All All Kentucky All 6 All Louisiana All All Maine All All Maryland All All Massachusetts All All Michigan All All Minnesota All All Mississippi None None Missouri All All Montana All Some 7 Nebraska All All Nevada All All New Hampshire All All New Jersey All All New Mexico All All New York All All North Carolina All All North Dakota All All Ohio All All Oklahoma All All Oregon All All Pennsylvania All All Rhode Island All All South Carolina All All South Dakota All All Tennessee All All Texas All All Table I.B.5. Eligibility of Non-exempt, Pre-PRWORA, Qualified Aliens, July 2017 1 58 Welfare Rules Databook: State TANF Policies as of July 2017 State Lawful permanent residents 2 Asylees 3 Utah All All Vermont All All Virginia All All Washington All All West Virginia All All Wisconsin All All Wyoming All All 4 The LPR must meet one of the following to be potentially eligible: 1) five years lawful residency, 2) prior qualified status, 3) military connection, and 4) continuous residency. 6 Obtaining permanent residency does not negate the person’s original entry status for TANF eligibility in the state. 7 Qualified immigrants are only eligible for benefits for seven years beginning on the date they attained qualified immigrant status. 5 All immigrant units are funded through a state program with the same eligibility rules as TANF. No immigrant units, however, are eligible for federal TANF funding. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This table describes the eligibility of a subset of people who entered the United States before August 22, 1996\u2014those whose current status is either legal permanent resident or asylee, and who are nonexempt as federally-defined. For example, non-citizens who entered the U.S. prior to August 22, 1996 are exempt from special eligibility restrictions if they are legal permanent residents who can claim 40 quarters of work history; people who satisfy a federal exemption criterion are potentially eligible in all states. This table does not cover the eligibility of individuals who entered prior to August 22, 1996 and currently have other qualified immigrant statuses, or who are nonqualified immigrants. 2 Lawful permanent residents are individuals who have been granted authorization to permanently live and work in the United States. Pre-PRWORA LPRs with 40 quarters of work are exempt from eligibility restrictions by federal law and are therefore potentially eligible in all states. 3 Asylees are immigrants who flee their countries owing to persecution because of race, religion, nationality, political opinion, or membership in a social group, and who request permission to remain in the U.S. Asylees are permitted to apply for LPR status after one year of asylee status but are not required to do so. (Refugees, not shown in this table, are similar to asylees but receive their status before coming to the U.S.; they are required to apply for LPR status after one year.) Table I.B.5. Eligibility of Non-exempt, Pre-PRWORA, Qualified Aliens, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 59 Lawful permanent residents 3 Parolees 4 Battered noncitizens 5 Alabama No No No No Alaska No 7 No No No Arizona No Yes No No Arkansas No No No No California Yes Yes Yes Some 8 Colorado No No No No Connecticut Yes 9 Yes 9 Yes 9 No Delaware No No Yes No D.C. No No No No Florida No No No No Georgia Yes Yes Yes No Hawaii 10 Yes Yes Yes Yes Idaho No No No No Illinois No 7 Yes Yes No Indiana No No No No Iowa No No Yes No Kansas No No No No Kentucky No 7 No No No Louisiana No 7 No No No Maine Some 11 Some 11 Some 11 Some 11 Maryland 10 Yes Yes Yes No Massachusetts No No No No Michigan No No No No Minnesota Some 12 Yes Yes Some 13 Mississippi No No No No Missouri No No No No Montana No No No No Nebraska No No No No Nevada No No Yes No New Hampshire No No No No New Jersey No No Yes No New Mexico Yes Yes Yes No New York Yes Yes Yes Some 14 North Carolina No No No No North Dakota No No No No Ohio No No No No Oklahoma No No No No Oregon Yes Yes Yes Some 15 Pennsylvania Yes Yes Yes Some 16 Rhode Island No No Yes No South Carolina No No No No Table I.B.6. State Practices Regarding Eligibility of Noncitizens Who Entered after Enactment and Are Ineligible for Federal TANF Assistance, July 2017 1 State Qualified aliens during their first five years 2 Nonqualified aliens 6 60 Welfare Rules Databook: State TANF Policies as of July 2017 Lawful permanent residents 3 Parolees 4 Battered noncitizens 5 South Dakota No No No No Tennessee No No No No Texas No 7 No No No Utah Yes Yes Yes No Vermont No 7 No No No Virginia No No No No Washington Yes Yes Yes Some 16 West Virginia No No No No Wisconsin Yes Yes Yes Some 17 Wyoming Yes Yes Yes No 6 Two groups of non-qualified aliens–those who are in the country on a temporary basis (student visas, work visas, and so on), and those who are in the country without authorization–are not eligible for benefits in any state. However, there are other groups of nonqualified aliens, such as persons residing under color of law (PRUCOL). This column describes whether any nonqualified aliens other than those who are temporary or unauthorized are potentially eligible for benefits using state funds. 7 Certain American Indians born in Canada may be regarded as lawful permanent residents for purposes of eligibility and are therefore qualified aliens. These individuals are eligible for benefits during the five-year bar. 8 All nonqualified aliens who are legally in the country and were not on a temporary basis are eligible for assistance. 9 To be eligible, all noncitizens must pursue citizenship to the maximum extent allowed by law, unless incapable owing to mental incapacity, a medical condition, a language barrier, or a domestic violence situation. 1 This table refers only to noncitizens that have entered the United States on or after August 22, 1996, and are ineligible for federally funded TANF assistance because of the five-year bar or nonqualified status. Refugees, asylees, and deportees are eligible for federal funding for the first five years after obtaining that status, and therefore are not included in this table. 2 Qualified aliens are defined under PRWORA as lawful permanent residents (includes Amerasians), refugees, asylees, individuals who have had their deportation withheld, parolees admitted for one or more years, certain battered aliens, Cuban\/Haitian entrants, and aliens granted conditional entry before April 1, 1980. 3 Lawful permanent residents are individuals who have been granted authorization to permanently live and work in the United States. 4 Parolees are individuals permitted entry into the United States in cases of emergency or because of an overriding public interest. The table only discusses the eligibility of aliens paroled into the United States for at least one year. Aliens paroled into the United States for less than a year are not \”qualified\” aliens according to the immigrant definition in PRWORA. 5 Battered noncitizens refer to those individuals who have been battered or subjected to extreme cruelty in the U.S. by a spouse or parent who is a U.S. citizen or LPR. To be eligible for benefits, individuals must no longer be living in the same household as the abuser and there must be a connection between the abuse and the need for benefits. See 8 USC 1641 (c). 10 All immigrant units are funded through a state program with the same eligibility rules as TANF. 11 A noncitizen who is not eligible for federal funding may receive state-funded cash assistance if the noncitizen received (or was applying for) TANF on December 1, 2012; is elderly or disabled; is a victim of domestic violence; or is suffering from a hardship while waiting for proper work documentation. In addition, asylum seekers with work documentation who are unemployed may be eligible if funding is available. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Qualified aliens during their first five years 2 Nonqualified aliens 6 Table I.B.6. State Practices Regarding Eligibility of Noncitizens Who Entered after Enactment and Are Ineligible for Federal TANF Assistance, July 2017 1 State Welfare Rules Databook: State TANF Policies as of July 2017 61 17 Individuals with employment authorization by the US Citizenship and Immigration Services are eligible for assistance. 12 Lawful permanent residents age 18-70 who have lived in the US for at least four years and whose benefits are funded entirely with state money must either be participating in a literacy or citizenship class, on a waiting list, applying for a waiver, or applying for citizenship to remain eligible for state-funded assistance. This requirement does not apply to legal permanent residents in the country less than four years. 13 All non-citizens who are legally in the country and who were not admitted on a temporary basis are eligible for assistance. 14 Individuals permanently residing in the United States under color of law as defined by the state and parolees in the country for less than one year are eligible for assistance. 15 Victims of trafficking and noncitizens at risk of domestic violence are eligible for assistance. 16 Individuals permanently residing in the United States under color of law are potentially eligible. 62 Welfare Rules Databook: State TANF Policies as of July 2017 State Lawful permanent residents 2 Asylees\/ Refugees 3 Deportees 4 Parolees 5 Battered noncitizens 6 Alabama All None None None All Alaska All All All All All Arizona All All All All All Arkansas All All All All None California All All All All All Colorado All All All All All Connecticut All All All All All Delaware All All All All All D.C. All All All All All Florida All All All All All Georgia All All All All All Hawaii 7 All All All All All Idaho All All All All All Illinois All All All All All Indiana Some 8 All All None None Iowa All All All All All Kansas All All All All All Kentucky All All All All All Louisiana All All All All All Maine All All All All All Maryland All All All All All Massachusetts All All All All All Michigan All All None All All Minnesota Some 9 All All All All Mississippi Some 10 None None None None Missouri All All All All All Montana All Some 11 Some 11 All Some 10 Nebraska All All All All All Nevada All All All All All New Hampshire All All All All All New Jersey All 12 All All All All New Mexico All All All All All New York All All All All All North Carolina All All All All All North Dakota All All All All All Ohio Some 10 Some 10 Some 10 None None Oklahoma All All All All All Oregon All All All All All Pennsylvania All All All All All Rhode Island All All All All All South Carolina Some 10 None None None None South Dakota All All All All All Table I.B.7. Eligibility of Post-PRWORA Qualified Aliens after Five Years, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 63 State Lawful permanent residents 2 Asylees\/ Refugees 3 Deportees 4 Parolees 5 Battered noncitizens 6 Tennessee All All All All None Texas Some 10 None None None None Utah All All All All All Vermont All All All All All Virginia All All All All All Washington All All All All All West Virginia All All All All All Wisconsin All All All All All Wyoming All All All All All 4 Deportees are individuals granted a stay of deportation or who have had their deportation withheld. 5 Parolees are individuals permitted entry into the United States in cases of emergency or because of an overriding public interest. The table only discusses the eligibility of aliens paroled into the United States for at least one year. Aliens paroled into the United States for less than a year are not \”qualified\” aliens according to the immigrant definition in PRWORA. 6 Battered noncitizens refer to those individuals who have been battered or subjected to extreme cruelty in the U.S. by a spouse or parent who is a U.S. citizen or LPR. To be eligible for benefits, individuals must no longer be living in the same household as the abuser and there must be a connection between the abuse and the need for benefits. See 8 USC 1641 (c). 7 All immigrant units are funded through a state program with the same eligibility rules as TANF. No immigrant units, however, are eligible for federal TANF funding. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This table identifies the eligibility for federally-funded TANF assistance of certain groups of qualified aliens. In general, the table captures potential eligibility five years after the point when a person obtains the specified status, which may be later than the date of entry to the U.S. (e.g., if a person initially enters the country in a non-qualified status but later obtains asylee status). Post-PRWORA entrants who are military personnel or veterans (and their families) are potentially eligible in every state. Aliens are categorized by their current immigrant status (rather than their initial status upon entry into the United States, if different). 2 Lawful permanent residents are individuals who have been granted authorization to permanently live and work in the United States. 3 Asylees and refugees are immigrants who flee their countries owing to persecution because of race, religion, nationality, political opinion, or membership in a social group. Refugees request permission to enter the country, while asylees are already in the United States and request permission to stay. Table I.B.7. Eligibility of Post-PRWORA Qualified Aliens after Five Years, July 2017 1 8 Only lawful permanent residents who have previously been refugees are eligible. 10 Forty qualifying quarters of work are required. 11 Qualified aliens with this status are only eligible for benefits for seven years beginning on the date they entered the United States. 12 Aliens who were not continuous residents of the United States (meaning they left the United States for 30 days or more) before becoming lawful permanent residents are ineligible for benefits. 9 Lawful permanent residents age 18-70 who have lived in the US for at least four years and whose benefits are funded entirely with state money must either be participating in a literacy or citizenship class, on a waiting list, applying for a waiver, or applying for citizenship to remain eligible for state-funded assistance. This requirement does not apply to legal permanent residents in the country less than four years. 64 Welfare Rules Databook: State TANF Policies as of July 2017 Is the income of the non- caretaker adult counted against the unit for eligibility and benefit computation? How much of the adult’s income is counted? Under what circumstances are benefits or eligibility affected when sharing living costs? How much are benefits or eligibility reduced when sharing living costs? 4 Alabama None Not counted 5 n.a. No effect n.a. Alaska None Not counted n.a. Unit spends less than 30% of need standard on shelter costs Any unused portion of the 30% is deducted from the Need Standard before benefit calculation Arizona None Not counted n.a. Recipient has no obligation to pay a shelter cost for at least three months Need standard reduced 37% for eligibility and benefit calculations Arkansas Relatives 6 Not counted n.a. No effect n.a. California 7 Registered domestic partners 8 Registered domestic partners Total earned and unearned income less a $90 disregard Adult not included in the unit pays all of shelter costs Need standard reduced by value of shelter, food, and clothing Colorado None Not counted n.a. No effect n.a. Connecticut Relatives Not counted n.a. No effect n.a. Delaware None 9 Not counted n.a. No effect n.a. D.C. Relatives Not counted n.a. No effect n.a. Florida Relatives Not counted n.a. No effect n.a. Georgia None Not counted n.a. No effect n.a. Hawaii All adults 10 Not counted n.a. No effect n.a. Idaho None Not counted n.a. No effect n.a. Illinois Civil union partners Not counted n.a. No effect n.a. Indiana None Not counted n.a. No effect n.a. Iowa None Not counted n.a. No effect n.a. Kansas Relatives and partners 11 Not counted n.a. One or more persons reside in the household and are not in the unit Shelter allowance reduced by 40% 12 Kentucky None Not counted n.a. No effect n.a. Table I.B.8. Treatment of Non-caretaker Adults in Household, July 2017 1 State Which subgroups of non- caretaker adults are potentially eligible to receive assistance as part of the unit? 2 When a non-caretaker adult living in the household is not included in the TANF unit: Treatment of income: Shared living costs: 3 Welfare Rules Databook: State TANF Policies as of July 2017 65 Is the income of the non- caretaker adult counted against the unit for eligibility and benefit computation? How much of the adult’s income is counted? Under what circumstances are benefits or eligibility affected when sharing living costs? How much are benefits or eligibility reduced when sharing living costs? 4 Louisiana None Not counted n.a. No effect n.a. Maine None Not counted n.a. No effect n.a. Maryland None Not counted n.a. No effect n.a. Massachusetts Relatives Not counted n.a. No effect n.a. Michigan Relatives Not counted n.a. No effect n.a. Minnesota None Not counted n.a. No effect n.a. Mississippi None Not counted n.a. No effect n.a. Missouri None Not counted n.a. No effect n.a. Montana None Not counted n.a. No effect n.a. Nebraska None Not counted n.a. If the total amount of the unit’s housing is provided or paid for by an individual outside the unit Amount contributed by the non-unit members, up to $103, is added to the unit’s unearned income for benefit calculation 13 Nevada None Not counted n.a. No effect n.a. New Hampshire None Not counted n.a. No effect n.a. New Jersey None Not counted n.a. No effect n.a. New Mexico Relatives Not counted n.a. Adult residing in the household and not included in the unit pays part or all of shelter costs Amount contributed by non- unit members is counted as unearned income New York All adults 14 Not counted n.a. No effect n.a. North Carolina None Not counted n.a. No effect n.a. North Dakota Relatives Not counted n.a. One or more adults (over age 18) reside in the household and are not included in the unit Unit does not receive $50 increase to payment standard Ohio None Not counted n.a. No effect n.a. Table I.B.8. Treatment of Non-caretaker Adults in Household, July 2017 1 State Which subgroups of non- caretaker adults are potentially eligible to receive assistance as part of the unit? 2 When a non-caretaker adult living in the household is not included in the TANF unit: Treatment of income: Shared living costs: 3 66 Welfare Rules Databook: State TANF Policies as of July 2017 Is the income of the non- caretaker adult counted against the unit for eligibility and benefit computation? How much of the adult’s income is counted? Under what circumstances are benefits or eligibility affected when sharing living costs? How much are benefits or eligibility reduced when sharing living costs? 4 Oklahoma None Partners only 15 Earned and unearned income less $120 the need standard for the number of people outside the unit 16 No effect n.a. Oregon Essential persons 17 Not counted n.a. No effect n.a. Pennsylvania Relatives Not counted n.a. No effect n.a. Rhode Island None Not counted n.a. No effect n.a. South Carolina None Not counted n.a. No effect n.a. South Dakota None Not counted n.a. One or more adults (over age 18) reside in the household and are not included in the unit Payment standard is reduced by $170 12 Tennessee None Not counted n.a. No effect n.a. Texas Relatives Not counted n.a. No effect n.a. Utah None Not counted n.a. No effect n.a. Vermont All adults 18 Not counted n.a. Household includes people who are not in the assistance unit Need standard includes the amount of shelter costs paid by the included members up to $400; Payment standard includes the amount of shelter costs paid by the included members times the ratable reduction 19 Virginia All adults 20 Not counted n.a. No effect n.a. Washington None Not counted n.a. No effect n.a. West Virginia None Not counted n.a. No effect n.a. Table I.B.8. Treatment of Non-caretaker Adults in Household, July 2017 1 State Which subgroups of non- caretaker adults are potentially eligible to receive assistance as part of the unit? 2 When a non-caretaker adult living in the household is not included in the TANF unit: Treatment of income: Shared living costs: 3 Welfare Rules Databook: State TANF Policies as of July 2017 67 Is the income of the non- caretaker adult counted against the unit for eligibility and benefit computation? How much of the adult’s income is counted? Under what circumstances are benefits or eligibility affected when sharing living costs? How much are benefits or eligibility reduced when sharing living costs? 4 Wisconsin None Not counted n.a. No effect n.a. Wyoming None Not counted n.a. If unit is not obligated to pay any portion of the shelter costs, lives in government subsidy housing or contains a minor parent living with adult supervisor Maximum benefit is reduced to $455 12 Table I.B.8. Treatment of Non-caretaker Adults in Household, July 2017 1 State Which subgroups of non- caretaker adults are potentially eligible to receive assistance as part of the unit? 2 When a non-caretaker adult living in the household is not included in the TANF unit: Treatment of income: Shared living costs: 3 5 The income of adult non-unit members living in the household is included only if the income received is formally earmarked for a member of the assistance unit. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 A \”non-caretaker adult\” is an additional adult living in the household with a parent or caretaker of children. The non-caretaker adult is not the primary caretaker of the children, nor a parent of any children in the household. In this table, a non-caretaker adult could be an adult who is related to the parent or children, the unmarried partner of the parent, or a friend of the parent who is not a relative or in a relationship with the parent. A separate set of policies may apply to non-caretaker adults who are renters or boarders sharing a household with the unit. When there is variation, the values in the table represent the amounts for individuals living in the largest county and for a family size of three. 2 This column indicates which subgroups of non-caretaker adults\u2014defined in terms of relationship to the unit members\u2014are potentially eligible to be included in the unit; specific requirements for inclusion may be provided in footnotes. When \”all adults\” appears in this column, it means relatives who are not primary caretakers, partners of the parent or caretaker, and nonrelative non-partners are potentially eligible to receive assistance as part of the unit, subject to other requirements. 3 The policies regarding shared living costs apply to assistance units living in households including other adults. These columns do not capture policies regarding states’ treatment of assistance units in public or subsidized housing. 4 Unless otherwise specified, the reduction applies to both eligibility calculations and benefit computation, when applicable. 6 Only one additional adult may be included in the unit. 7 California has two categories of non-caretaker-adults. The first category includes spouses, registered domestic partners, and aided relative non-caretakers. The policies shown here are for this category of adults. The second category includes unrelated non-partner adults (e.g. boyfriend, girlfriend, etc.). 8 Relatives and registered domestic partners of the primary caretaker may be included at the option of the unit head. 9 To be eligible, the adult must be providing care to the children in the unit. 68 Welfare Rules Databook: State TANF Policies as of July 2017 11 Cohabiting partners are mandatory unit members. 14 To be eligible, the adult must be deemed essential to the well-being of the family applying for or receiving TANF benefits. 17 An essential person is someone not required to be in the unit who provides a service necessary to the health or protection of a unit member with a mental or physical disability, when it is less expensive to include this person in the unit than to purchase the service from another source. 18 Non-caretaker adults are included only if they qualify as a needy essential person, which is defined as someone not required to be in the unit who provides a service necessary to the health or protection of a unit member with a mental or physical disability, when it is less expensive to include this person in the unit than to purchase the service from another source. 20 Additional adults can be included in the unit at the option of the caretaker only if they are needy, not otherwise eligible for TANF, and providing services essential to the well-being of the children\u2014either caring for a disabled family member living in the home or providing child care that allows the caretaker to work or participate in work-related activities on a full-time basis. 15 The income of any non-relative adult of the opposite sex, not receiving TANF, who lives in the home is counted. However, the income of non-relative adults of the opposite sex not receiving TANF may be excluded if the adults have separate living quarters and demonstrate no characteristics of a person acting in the role of spouse. 16 Partners may also subtract the actual amount paid to individuals not living in the household but claimed as dependents, and alimony and child support payments made to individuals outside the household. The remaining income after all disregards are applied is counted in the unit’s unearned income for eligibility and benefit computation purposes. 12 The amount of the reduction varies by family size. 13 The amount added to the unit’s unearned income varies by family size. 19 If the individual lives in Chittenden County, the need standard includes the amount of shelter costs paid by the included members up to $450. 10 The additional adult must provide care that is deemed essential and would need to be provided if the additional adult were not in the household. Welfare Rules Databook: State TANF Policies as of July 2017 69 State If not attending secondary or vocational\/technical school full time If attending secondary or vocational\/technical school full time Are children living with nonrelative caretakers potentially eligible? 2 Alabama 17 18 No Alaska 17 18 No Arizona 17 3 18 Yes Arkansas 17 17 No California 17 18 No Colorado 17 18 Yes Connecticut 17 18 Yes Delaware 17 18 Yes D.C. 15 18 No Florida 17 18 No Georgia 17 18 Yes Hawaii 17 3 18 4 No Idaho 17 18 No Illinois 17 18 No Indiana 17 17 No Iowa 17 18 No Kansas 17 18 Yes 5 Kentucky 17 18 No Louisiana 17 18 No Maine 17 20 No Maryland 17 19 6 No Massachusetts 17 18 7 No Michigan 5 8 18 Yes 9 Minnesota 17 18 Yes Mississippi 17 3 17 3 No Missouri 17 18 Yes 9 Montana 15 18 No Nebraska 17 18 Yes 10 Nevada 17 18 No New Hampshire 17 18 11 No New Jersey 17 18 12 Yes New Mexico 17 18 13 Yes New York 17 18 Yes North Carolina 17 3 18 14 Yes North Dakota 17 3 18 15 No Ohio 17 18 Yes Oklahoma 17 18 No Oregon 17 18 No Pennsylvania 17 18 No Rhode Island 17 18 16 No South Carolina 17 18 No Table I.B.9. Eligibility Requirements for Children, July 2017 1 Maximum age a child can be eligible for TANF 70 Welfare Rules Databook: State TANF Policies as of July 2017 State If not attending secondary or vocational\/technical school full time If attending secondary or vocational\/technical school full time Are children living with nonrelative caretakers potentially eligible? 2 South Dakota 17 17 18 No Tennessee 17 18 18 No Texas 17 18 15 No Utah 17 18 No Vermont 17 17 18 19 Yes Virginia 4 20 18 21 No Washington 17 18 Yes 22 West Virginia 17 18 Yes Wisconsin 17 18 No Wyoming 17 18 No 3 The child is eligible through the month in which he or she turns 18. 4 The child is eligible through the month in which he or she turns 19. 5 A nonrelative caretaker must be a court-appointed guardian, conservator, or legal custodian in order to be potentially eligible for assistance. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This table covers policies for children living with families or caretakers. Policies for children in foster care may differ. 2 This column provides information on the potential eligibility of children who live with non-relative caretakers in regular household settings; it does not address the extent to which pregnant or parenting teens may live with non-relatives in alternative living arrangements. Table I.B.9. Eligibility Requirements for Children, July 2017 1 Maximum age a child can be eligible for TANF 6 The child is eligible through the calendar year in which he or she turns 19. 16 A child is eligible through age 18 if the child is expected to graduate before or in the month of his or her 19th birthday. 9 Unrelated legal guardians receive benefits paid from a state-only funding source. 8 If a child is age 6 through 15 and not attending school full time, the entire family loses TANF eligibility, regardless of whether there are other eligible children present. If the child is age 16 or older and not attending school full time, and the family has other eligible children, only the child not attending school is excluded from the assistance unit. 10 A child must be living with nonrelative caretakers who are either court-appointed guardians or conservators in order to be potentially eligible for assistance. 11 The policy shown in the table reflects eligibility for federal TANF. New Hampshire funds an additional separate state program where students through age 19 are eligible for benefits. 12 Individuals up to age 21 are considered children if they are enrolled in a special education program. 13 A student receiving special education services regulated by the State Board of Education will be considered a dependent child until age 22. 7 A child is eligible, provided the child’s expected graduation date falls before he or she turns 19. 15 Children are eligible through the month in which they turn 19 if they will graduate high school that month. 14 The child is eligible through the month he or she turns 19 if he or she also graduates from high school in the same month. 17 A 16- or 17-year-old not attending school must take part in case management services. Welfare Rules Databook: State TANF Policies as of July 2017 71 22 Only children living with nonrelative caretakers who are court ordered guardians or acting in loco parentis are eligible. Nonrelatives must pass a criminal background check in order to receive a TANF grant on behalf of a child. 18 A child with a disability who will not complete high school or an equivalent vocational or technical training before turning 19 is eligible for benefits through the month of his or her 19th birthday. 19 Children age 18 and without a disability are eligible for benefits if they will graduate before their 19th birthday. A child with a disability who will not complete high school or an equivalent vocational or technical training before turning 19 is eligible for benefits through the month of his or her 19th birthday. 20 A truant child is removed from the grant unless the parent cooperates in developing a plan to return the child to school. 21 An 18-year-old is eligible if enrolled in secondary school or vocational\/technical school and is expected to graduate prior to or in the same month as his or her 19th birthday. 72 Welfare Rules Databook: State TANF Policies as of July 2017 State Is a child who receives SSI included in the TANF unit with his or her parents or siblings? Is an adult who receives SSI included in the TANF unit with his or her children or spouse? Alabama No No n.a. Alaska No 1 No n.a. Arizona No No n.a. Arkansas No No n.a. California No No n.a. Colorado No No n.a. Connecticut No No n.a. Delaware No No n.a. D.C. No No n.a. Florida No No n.a. Georgia No No n.a. Hawaii No No n.a. Idaho Yes Yes Only non-SSI income is counted 2 Illinois No No n.a. Indiana No No n.a. Iowa No No n.a. Kansas No No n.a. Kentucky No No n.a. Louisiana No No n.a. Maine No No n.a. Maryland No No n.a. Massachusetts No No n.a. Michigan No No n.a. Minnesota No No n.a. Mississippi No No n.a. Missouri No No n.a. Montana No No n.a. Nebraska No No n.a. Nevada No No n.a. New Hampshire Yes Yes Adult SSI recipients: Count all income; Dependent child SSI recipients: Exclude SSI benefits 3 New Jersey No No n.a. New Mexico No No n.a. New York No No n.a. North Carolina No No n.a. North Dakota No No n.a. Ohio No No n.a. Table I.B.10. Inclusion of SSI Recipients in the Assistance Unit, July 2017 Treatment of SSI Recipients in Families with Children Inclusion in the Assistance Unit If an SSI recipient is included in the assistance unit, is his or her income counted? Welfare Rules Databook: State TANF Policies as of July 2017 73 State Is a child who receives SSI included in the TANF unit with his or her parents or siblings? Is an adult who receives SSI included in the TANF unit with his or her children or spouse? Oklahoma No No n.a. Oregon No No n.a. Pennsylvania No No n.a. Rhode Island No No n.a. South Carolina No No n.a. South Dakota No No n.a. Tennessee No No n.a. Texas No No n.a. Utah No No n.a. Vermont No No n.a. Virginia No No n.a. Washington No No n.a. West Virginia Yes No Only non-SSI income is counted 4 Wisconsin Yes Yes Adult SSI recipients: Count all income; Child SSI recipients: Count unearned non-SSI income 5 Wyoming No No n.a. 2 The SSI income and other assets are counted if the person receiving SSI is part of a one-parent household, a two-parent household, or a caretaker household with only one child in the unit. In a caretaker household with multiple children, if any child receives SSI, that income is not counted. 3 SSI benefits received by dependent children are not counted. 4 While the SSI recipient’s SSI allocation is not counted, the non-SSI income and assets of the individual are counted. 5 For eligible families who receive cash payments, the payment does not vary by income. Also, recipients of SSI and Social Security Disability payments are not considered W-2 participants. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Children receiving SSI under the age of 18 who are blind or disabled may be included in the unit if the caretaker relative requests it. Table I.B.10. Inclusion of SSI Recipients in the Assistance Unit, July 2017 Treatment of SSI Recipients in Families with Children Inclusion in the Assistance Unit If an SSI recipient is included in the assistance unit, is his or her income counted? 74 Welfare Rules Databook: State TANF Policies as of July 2017 State Inclusion of nonparent caretakers in the assistance unit Caretakers who must be included in the unit (when some but not all must be included) Caretakers who have the option to be included (when some but not all have that option) Caretakers who are prohibited from being included in assistance unit 2 If a caretaker’s spouse is included in the unit when the caretaker is included 3 Alabama 4 Prohibited n.a. n.a. n.a. n.a. Alaska 4 Optional for all n.a. n.a. n.a. Prohibited Arizona Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited Arkansas 4 Optional for all 5 n.a. n.a. n.a. Caretaker has option California 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Caretaker has option Colorado Optional for all n.a. n.a. n.a. Mandatory Connecticut Some optional, others prohibited n.a. Income under a limit Income above a limit Caretaker has option Delaware Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory D.C. 4 Optional for all n.a. n.a. n.a. Prohibited Florida 4 Optional for all n.a. n.a. n.a. Prohibited Georgia Some optional, others prohibited n.a. All relative caretakers All nonrelative caretakers Prohibited Hawaii 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory Idaho 4 Optional for all n.a. n.a. n.a. Mandatory Illinois 4 Optional for all n.a. n.a. n.a. Caretaker has option Indiana 4 Optional for all n.a. n.a. n.a. Prohibited Iowa 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited 6 Kansas Optional for all n.a. n.a. n.a. Mandatory Kentucky 4 Optional for all n.a. n.a. n.a. Mandatory Louisiana 4 Some optional, others prohibited n.a. Relative caretakers without minor children in the home Relative caretakers with minor children in the home Mandatory Maine 4 Optional for all n.a. n.a. n.a. Caretaker has option Table I.B.11. Inclusion of Nonparent Caretakers in the Assistance Unit, July 2017 1 In Nonparent-Caretaker Families Potentially Eligible for TANF, Whether the Caretaker and Her or His Spouse Are Included in the Unit Welfare Rules Databook: State TANF Policies as of July 2017 75 State Inclusion of nonparent caretakers in the assistance unit Caretakers who must be included in the unit (when some but not all must be included) Caretakers who have the option to be included (when some but not all have that option) Caretakers who are prohibited from being included in assistance unit 2 If a caretaker’s spouse is included in the unit when the caretaker is included 3 Maryland 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory Massachusetts 4 Optional for all n.a. n.a. n.a. Prohibited Michigan Optional for all n.a. n.a. n.a. Mandatory Minnesota Optional for all n.a. n.a. n.a. Mandatory Mississippi 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory Missouri Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited 6 Montana 4 Optional for all n.a. n.a. n.a. Prohibited 6 Nebraska Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited Nevada 4 Optional for all 5 n.a. n.a. n.a. Prohibited 7 New Hampshire 4 Optional for all n.a. n.a. n.a. Prohibited New Jersey Some optional, others prohibited n.a. All relative caretakers whose income is under a limit All nonrelative caretakers; All relative caretakers whose income is above a limit Mandatory New Mexico Optional for all n.a. n.a. n.a. Mandatory New York Some optional, others prohibited n.a. Income under a limit Income above a limit Caretaker has option North Carolina Prohibited n.a. n.a. n.a. n.a. North Dakota 4 Some mandatory, some optional, others prohibited Legally responsible caretaker relative Non-legally responsible caretaker relative Non-legally responsible caretaker relative if spouse resides in the household Caretaker has option Ohio Some optional, others prohibited n.a. Relative caretakers who do not have eligible children of their own All nonrelative caretakers; All relative caretakers with minor children in the home Prohibited 6 Table I.B.11. Inclusion of Nonparent Caretakers in the Assistance Unit, July 2017 1 In Nonparent-Caretaker Families Potentially Eligible for TANF, Whether the Caretaker and Her or His Spouse Are Included in the Unit 76 Welfare Rules Databook: State TANF Policies as of July 2017 State Inclusion of nonparent caretakers in the assistance unit Caretakers who must be included in the unit (when some but not all must be included) Caretakers who have the option to be included (when some but not all have that option) Caretakers who are prohibited from being included in assistance unit 2 If a caretaker’s spouse is included in the unit when the caretaker is included 3 Oklahoma 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited Oregon 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory Pennsylvania 4 Optional for all n.a. n.a. n.a. Caretaker has option 8 Rhode Island 4 Optional for all n.a. n.a. n.a. Mandatory 9 South Carolina 4 Optional for all n.a. n.a. n.a. Mandatory South Dakota 4 Prohibited n.a. n.a. n.a. n.a. Tennessee 4 Optional for all n.a. n.a. n.a. Mandatory Texas 4 Optional for all n.a. n.a. n.a. Prohibited Utah 4 Optional for all n.a. n.a. n.a. Mandatory Vermont Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited Virginia 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Prohibited Washington Some optional, others prohibited 5 n.a. Income under a limit Income above a limit Prohibited West Virginia Some optional, others prohibited n.a. All relative caretakers All nonrelative caretakers Mandatory Wisconsin 4 Prohibited n.a. n.a. n.a. n.a. Wyoming 4 Some optional, others prohibited n.a. Income under a limit Income above a limit Mandatory Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 A state will only have \”All nonrelative caretakers\” indicated when the state forbids such caretakers from being included the unit, but still allows the children living with such caretakers to be eligible for benefits. 2 \”Included in the assistance unit\” indicates the person is considered in the family size for purposes of determining the benefit. This table applies only to families with potential eligibility for TANF based on their composition; table I.B.8 indicates if families in which the caretaker is a nonrelative are ever eligible. Table I.B.11. Inclusion of Nonparent Caretakers in the Assistance Unit, July 2017 1 In Nonparent-Caretaker Families Potentially Eligible for TANF, Whether the Caretaker and Her or His Spouse Are Included in the Unit Welfare Rules Databook: State TANF Policies as of July 2017 77 4 Information applies only to families with a relative caretaker. Children in families with nonrelative caretakers can never receive TANF in this state. 3 If states have policies allowing for essential persons , a caretaker’s spouse might qualify under those criteria to be a member of the assistance unit; see the first column of table I.B.8 for more information. 8 If the spouse is not included in the unit, his or her income is deemed to the non-parent caretaker. 9 The spouse is included in the unit unless inclusion causes ineligibility. If the caretaker spouse’s income renders the assistance unit ineligible for cash assistance, then the caretaker has the option to apply for cash assistance for the children in his or her care only. 5 Only one caretaker relative may be included in the unit at a time. 6 Although the spouse is not counted as a member of the assistance unit, some of his or her income may be deemed available to the unit. 7 The caregiver’s spouse or domestic partner’s income is used to determine eligibility for the caregiver and children. 78 Welfare Rules Databook: State TANF Policies as of July 2017 State Asset limit 1 Vehicle exemption 2 Alabama No limit n.a. Alaska $2,000\/$3,000 3 All vehicles owned by household 4 Arizona $2,000 All vehicles owned by household Arkansas $3,000 One vehicle per household 5 California $2,250\/$3,250 6 $9,500\/one vehicle per licensed driver E, 7 Colorado No limit n.a. Connecticut $3,000 $9,500 E, 8 Delaware $10,000 All vehicles owned by household D.C. $2,000\/$3,000 3 All vehicles owned by household Florida $2,000 $8,500 E Georgia $1,000 $4,650 E, 9 Hawaii No limit n.a. Idaho $5,000 One vehicle per adult 10 Illinois No limit n.a. Indiana $1,000 $5,000 of one vehicle per household E Iowa $2,000 11 One vehicle per household 12 Kansas $2,250 One vehicle per adult 13 Kentucky $2,000 14 All vehicles owned by household Louisiana No limit n.a. Maine $2,000 One vehicle per household Maryland No limit n.a. Massachusetts $2,500 $15,000 F Michigan $3,000 All vehicles owned by household Minnesota $10,000 15 One vehicle per household member who is 16 or older F, 16 Mississippi $2,000 17 All vehicles owned by household E, 18 Missouri $1,000 First vehicle 100%\/ Second vehicle $1,500 E, 19 Montana $3,000 One vehicle per household 20 Nebraska $4,000\/$6,000 21 One vehicle per household 22 Nevada $6,000 One vehicle per household 23 New Hampshire $1,000 One vehicle per licensed driver 24 New Jersey $2,000 All vehicles owned by household 25 New Mexico $3,500 26 All vehicles owned by household 27 New York $2,000\/$3,000 28 $11,000 F, 29 North Carolina $3,000 All vehicles owned by household North Dakota $3,000\/$6,000\/$6,000+$25 30 One vehicle per household Ohio No limit n.a. Oklahoma $1,000 $5,000 E Oregon $2,500 31 $10,000 of all vehicles owned by household E Pennsylvania $1,000 One vehicle per household 23 Rhode Island $1,000 One vehicle per adult 32 South Carolina $2,500 One vehicle per licensed driver 33 South Dakota $2,000 One vehicle per household 34 Tennessee $2,000 $4,600 E Texas $1,000 $4,650 of each vehicle owned by household E, 35 Table I.C.1. Asset Limits for Applicants, July 2017 Welfare Rules Databook: State TANF Policies as of July 2017 79 State Asset limit 1 Vehicle exemption 2 Utah $2,000 All vehicles owned by household Vermont $9,000 36 One vehicle per adult Virginia No limit n.a. Washington $1,000 $5,000 E, 37 West Virginia $2,000 One vehicle per adult 38 Wisconsin $2,500 $10,000 E Wyoming $5,000 Two vehicles per household E 13 One licensed vehicle per adult household member is exempt. Additional vehicles may be exempt if they are used by a minor for employment, training, education, or seeking employment, used primarily for producing income, essential to employment, used as the household’s home, necessary to transport a household member with a physical disability, used to carry the primary source of fuel and water for the home, or valued at $1,500 or less. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Additional details about policies for units with elderly or older adults, including the age definitions used by states, can be found in the full database. 2 States may have separate policies for non-standard vehicles, such as income-producing vehicles, recreational vehicles, and vehicles that are used as homes. See the Welfare Rules Database for more information. Policies that distinguish between the equity value and fair-market value of vehicles are marked as follows: (E) equity value of the vehicle; (F) fair-market value of the vehicle. 3 Units including an elderly person may exempt $3,000; all other units exempt $2,000. 9 If the vehicle is used for job search, or to travel to work or education and training, the unit may exclude $4,650 of the value. If the vehicle is not used for these purposes, $1,500 of the equity value may be excluded. If the vehicle is used more than 50 percent of the time to produce income or as a dwelling, it is totally excluded. 10 If the unit owns any other vehicle that is non-exempt, the fair market value of the additional vehicle is applied to the resource limit. 11 If at least one member of the household applying was a program recipient in the month prior to the month of application, then the asset limit is increased to $5,000. 12 Additionally, $5,880 of the equity value of a vehicle is exempt for each adult and working teenager whose resources must be considered in determining eligibility. 4 Vehicles are exempt if used for one of the following: (1) to meet the family’s basic needs, such as getting food and medical care or other essentials; (2) to go to and from work, school, training, or work activity (such as job search or community service); (3) as the family’s house; (4) to produce self-employment income; or (5) to transport a disabled family member, whether or not he or she is a part of the assistance unit. If the vehicle does not meet one of these requirements, the equity value of the vehicle is counted in the determination of resources. 5 If the family has more than one vehicle, then the market value of any additional vehicles will be considered in full. 6 Units including an elderly or disabled person may exempt $3,250; all other units exempt $2,250. 7 Each vehicle must be evaluated for its equity value. Before this calculation, a vehicle is excluded if it: (1) is used primarily for income-producing purposes; (2) is necessary for long-distance travel that is essential for employment; (3) is used as the family’s home; (4) is necessary to transport a physically disabled household member; (5) would be exempt under previously stated exemptions but the vehicle is not in use because of temporary unemployment; (6) is used to carry fuel or water to the home and is the primary method of obtaining fuel or water; and (7) is a gift, donation, or family transfer. For each remaining vehicle, the state excludes one additional vehicle per adult and one additional vehicle per licensed child who uses the vehicle to travel to school, employment, or job search. For each remaining vehicle not completely excluded, the equity value that exceeds $9,500 counts against the family’s asset limit. 8 The unit may exempt up to $9,500 of the vehicle’s equity value, or the entire value of one vehicle used to transport a handicapped person. The motor vehicle exclusion is applied to the registered vehicle with the highest fair market value. Table I.C.1. Asset Limits for Applicants, July 2017 80 Welfare Rules Databook: State TANF Policies as of July 2017 38 A person must be work-eligible to qualify for the vehicle exemption. 28 Units including a person age 60 years or older may exempt $3,000; all other units exempt $2,000. 29 One automobile is exempt, up to $11,000 of the fair market value; local districts may adopt a higher vehicle exemption. 30 The asset limit is based on unit size: one person receives $3,000, two people receive $6,000, and another $25 is allowed for each additional person thereafter. 31 The asset limit for new TANF applicants is $2,500. Once the participant enters the pre-TANF program or becomes a TANF recipient, the asset limit increases to $10,000. 32 Exemptions for adult drivers cannot exceed two vehicles per household. Additionally, the entire value of a vehicle is exempt if it is used primarily to provide transportation for a disabled family member, used primarily to produce income, or used as the family’s home. 36 Other excluded resources include assets accumulated from earnings, interest earned on assets, non-liquid assets purchased with savings from earnings, retirement accounts (such as IRAs, 401(k)s, and other qualified accounts), and child education savings accounts (such as the Vermont Higher Education Investment Plan and other qualified plans). 37 The entire equity value of a vehicle used to transport a disabled household member is also exempt. 22 The entire vehicle is exempt only if used for employment, training, medical transportation, or a home. If a unit has more than one vehicle that meets the exemption criteria, only the vehicle with the greatest equity value will be exempt. 15 Withdrawals from ABLE accounts used to pay for a qualified disability expense are excluded. 33 Vehicles owned by or used to transport disabled individuals or that are essential to self-employment are also exempt. If the unit owns any other vehicle that is non-exempt, the equity value of the additional vehicle is applied to the resource limit. 34 In addition to one primary vehicle, an assistance unit may totally exclude a vehicle used to transport water or fuel to the home when it is not piped in, or to transport a disabled member or SSI recipient in the household. The assistance unit may also exclude $4,650 of the fair-market value of a vehicle used to transport members of the unit for education or employment. 35 All licensed vehicles used for income-producing purposes or for transporting a disabled household member are exempt. 16 Any additional vehicle that is not exempt is counted toward the $10,000 asset limit and is valued at the amount of the vehicle’s trade-in value as listed in the current NADA online car values and car prices guide. 17 If the unit is considered broad-based categorically eligible, it is not subject to asset limits. Households that include a convicted drug felon or a member currently disqualified for an intentional program violation are not considered broad-based categorically eligible. When a TANF recipient marries while receiving assistance, the liquid resources of the new spouse are excluded for six months beginning the month after the date of the marriage. 23 Vehicles other than the household’s primary vehicle are evaluated for equity value. 24 The equity value of all non-junk vehicles is counted in addition to any excluded vehicles. 25 Recreational vehicles are not exempt and are evaluated for fair market value. 26 The total limit is $3,500, but only $1,500 of that amount can be in liquid resources and only $2,000 can be in non-liquid resources. 27 The entire vehicle is exempt only if equipped for those with physical impairments or used for transportation to work, work activities, or daily living requirements. If the vehicle is not used for these purposes, the entire equity value of the vehicle is subject to the asset test. 14 Only liquid resources are considered for eligibility determinations. Liquid resources include cash, checking and savings accounts, CDs, stocks and bonds, and money market accounts. 18 Determination of whether to count a vehicle is made case by case. 19 $1,500 of the equity value of the unit’s second vehicle is exempt. 20 All vehicles whose primary use is to produce income or that are used as a home are also exempt. 21 The asset limit is based on unit size: one person receives $4,000, and two or more people receive $6,000. Welfare Rules Databook: State TANF Policies as of July 2017 81 State Deeming 2 Earned income disregard Other income disregards 3 Alabama Yes 20% 100% of countable net income for the grandparent divided by the number of persons in the household not otherwise receiving assistance plus the grandparent and minor parent 4 Alaska Yes $90 100% of the need standard for the unaided family members Arizona Yes 5 None None Arkansas No n.a. n.a. California Yes $90; $225 and 50% of remainder 6 100% of minimum basic standard of adequate care for the unaided family members Colorado Yes $90 100% of the need standard for the unaided family members Connecticut Yes $90 100% of the federal poverty guideline for the unaided family members Delaware n.a., grandparent always in unit n.a. n.a. D.C. Yes $90 100% of standard of assistance for the unaided family members Florida Yes $90 100% of consolidated need standard for the unaided family members Georgia Yes $90 100% of standard of need for the unaided family members Hawaii Yes 20% 100% of standard of need for the unaided family members Idaho n.a., grandparent always in unit n.a. n.a. Illinois Yes Difference between 50% of the current federal poverty guideline for the applicant’s family size and their TANF payment level 300% of the payment standard for the unaided family members Indiana Yes $90 100% of the need standard for the unaided family members Iowa Yes 20% 100% of the need standard for the unaided family members 7 Kansas n.a., grandparent always in unit n.a. n.a. Kentucky Yes $90 100% of standard of need for the unaided family members Louisiana n.a., grandparent always in unit n.a. n.a. Maine Yes $108, 50% 100% of the gross income test for the unaided family members Maryland n.a., grandparent always in unit n.a. n.a. Massachusetts Yes None 200% of the federal poverty guideline for the unaided family members Table I.D.1. Treatment of Grandparent Income, July 2017 1 82 Welfare Rules Databook: State TANF Policies as of July 2017 State Deeming 2 Earned income disregard Other income disregards 3 Michigan n.a., grandparent always in unit n.a. n.a. Minnesota Yes None 200% of the federal poverty guideline for the unaided family members Mississippi Yes $90 100% of the need and payment standard for the unaided family members Missouri Yes 100% of Federal Poverty Guidelines, $90 8 100% of the need standard for the unaided family members Montana n.a., grandparent always in unit n.a. n.a. Nebraska Yes None 300% of the federal poverty guideline for the unaided family members Nevada Yes Greater of $90 or 20% 100% of the need standard for the unaided family members New Hampshire Yes 20% 100% of standard of need for the unaided family members New Jersey Yes 9 None 10 None 11 New Mexico Yes $125 Prorated portion of the grandparent’s remaining countable income 12 New York Yes $90 100% of the need standard for the unaided family members North Carolina n.a., grandparent always in unit n.a. n.a. North Dakota Yes Greater of $180 and 27% 100% of standard of need for the unaided family members Ohio Yes $90 100% of allocation allowance standard for the unaided family members Oklahoma Yes $240 and 50% 13 100% of the need standard for the unaided family members Oregon Yes $90 100% of the adjusted income standard for the unaided family members Pennsylvania Yes $90 100% of standard of need for the unaided family members Rhode Island Yes $90 100% of the cash assistance monthly standard for the unaided family members South Carolina Yes None 185% of the need standard for the grandparent plus dependents living in the home South Dakota Yes $90 and 20% 100% of the payment standard for the unaided family members Tennessee Yes $250 100% of consolidated need standard for the unaided family members Texas Yes $120 100% of budgetary needs standard for the unaided family members Utah Yes $100 100% of adjusted standard needs budget for the unaided family members Vermont No n.a. n.a. Virginia Yes $90 100% of the standard of assistance for the unaided family members Table I.D.1. Treatment of Grandparent Income, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 83 State Deeming 2 Earned income disregard Other income disregards 3 Washington Yes $90 100% of the need standard for the unaided family members West Virginia n.a., grandparent always in unit 14 n.a. n.a. Wisconsin n.a., grandparent always in unit n.a. n.a. Wyoming Yes $600 15 100% of maximum benefit for the unaided family members 13 This disregard is applicable to those working at least 30 hours per week. If those working are employed less than 30 hours a week, then the disregard is $120 and 50 percent of the remainder. 4 The minor child’s child is not included in the calculation. 7 After disregarding 20 percent of earnings and 100 percent of the need standard for the unaided family members, 58 percent of the remainder is deducted for purposes of benefit computation. 5 As part of the needy family test, the income of the grandparent is counted for eligibility determination but not for benefit computation. 9 Income is deemed to a minor parent unit even if he or she is not living in the home with the grandparent. The rules for deeming are the same. 6 Applicants may disregard $90 for the eligibility test that compares net income to the MBSAC. Applicants and recipients may disregard $225 (minus any portion of the $225 applied to disability income), plus 50 percent of the remainder for the eligibility test that compares net income to the MAP, and for benefit computation. 8 The grandparent may initially disregard earned income up to 100 percent of the federal poverty guideline for the number of dependents in his or her household. He or she may then disregard an additional $90 of earned income. 12 The grandparent’s remaining countable income is divided by the total aided plus unaided family members; the disregard equals that per-capita amount times the number of unaided people. 10 For benefit computation, the parent can disregard 100 percent in the first month of earnings, 75 percent in months two- seven, and 50 percent thereafter. 11 For benefit computation, child support is another income disregard. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 In this table, \”grandparent\” refers to the parent of a minor parent. This table describes whether a portion of the grandparent’s income is deemed available to the minor and her child when the grandparent is not part of the assistance unit but living in the household with the minor. The table describes the disregards that the grandparent and his or her dependents are allowed to claim for their own needs. The remaining income after these disregards are deducted from the grandparent’s income is the amount available, or deemed, to the minor parent and the children. The table captures instances in which the income of the grandparent is deemed for both eligibility determination and benefit computation; if those policies differ, the eligibility policies are reflected in the table, and the benefit computation policies are footnoted. In general, states also deduct child support payments, alimony, and payments made to dependents outside the household from the grandparent’s income before deeming to the unit. Some states may deduct the grandparents’ child care expenses prior to deeming; see the WRD for more information. See table I.E.3 for information on the value of the standards for a family of three. 2 In some states, the grandparent is either always included in the unit, or sometimes included in the unit. In those cases, the grandparent’s income is treated like that of other unit members for eligibility and benefit computation purposes. 3 \”Unaided family members\” represents the grandparent and all dependents outside the assistance unit. Table I.D.1. Treatment of Grandparent Income, July 2017 1 84 Welfare Rules Databook: State TANF Policies as of July 2017 15 Married couples with a child in common may disregard $1,200. 14 An un-emancipated minor parent cannot head his or her own unit, but an emancipated minor parent may. If an emancipated minor parent heads his or her own unit and is living with his or her parent, the income of the minor parent’s parent is not deemed to the minor parent. Welfare Rules Databook: State TANF Policies as of July 2017 85 State Earned income disregard Other income disregards 3 Alabama n.a., stepparent is always in unit n.a. n.a. Alaska Yes $90 100% of need standard for the unaided family members Arizona Yes 4 None None Arkansas n.a., stepparent is always in unit n.a. n.a. California Yes 5 $90; $225 and 50% of remainder 6 None Colorado Yes $90 100% of need standard for the unaided family members Connecticut Yes $165 7 100% of federal poverty guideline for the unaided family members Delaware Yes $90 100% of standard of need for the unaided family members D.C. No n.a. n.a. Florida Yes $90 100% of consolidated need standard for the unaided family members Georgia Yes $90 100% of standard of need for the unaided family members Hawaii Yes 20% 100% of standard of need for the unaided family members Idaho n.a., stepparent is always in unit n.a. n.a. Illinois Yes 8 None (Per-person share of payment standard for the unaided family members) times (the stepparent plus any dependents of either spouse or civil union partner living in the home but not in the unit) Indiana Yes $90 100% of need standard for the unaided family members Iowa Yes 20% 100% of need standard for the unaided family members and 58% of remaining earnings Kansas n.a., stepparent is always in unit n.a. n.a. Kentucky Yes $90 100% of standard of need for the unaided family members Louisiana n.a., stepparent is always in unit n.a. n.a. Maine Yes $108 and 50% 100% of gross income test for the unaided family members Maryland Yes 9 20% 100% of allowable payment for the unaided family members Massachusetts Yes $200 100% of need standard and payment standard for the unaided family members Table I.D.2. Treatment of Stepparent Income, July 2017 1 Deeming 2 Disregards applied prior to deeming 86 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregard Other income disregards 3 Michigan n.a., stepparent is always in unit n.a. n.a. Minnesota n.a., stepparent is always in unit n.a. n.a. Mississippi Yes 10 $90 100% of need standard and payment standard for the unaided family members Missouri Yes $90 100% of need standard for the unaided family members Montana n.a., stepparent is always in unit n.a. n.a. Nebraska n.a., stepparent is always in unit n.a. n.a. Nevada Yes Greater of $90 or 20% 100% of need standard for the unaided family members New Hampshire n.a., stepparent is always in unit n.a. n.a. New Jersey Yes 11 None None New Mexico n.a., stepparent is always in unit n.a. n.a. New York Yes $90 100% of need standard for the unaided family members North Carolina n.a., stepparent is always in unit n.a. n.a. North Dakota n.a., stepparent is always in unit 12 n.a. n.a. Ohio Yes $90 100% of allocation allowance standard for the unaided family members Oklahoma Yes $240 and 50% 13 100% of need standard for the unaided family members Oregon n.a., stepparent is always in unit n.a. n.a. Pennsylvania Yes $90 100% of standard of need for the unaided family members Rhode Island n.a., stepparent is always in unit n.a. n.a. South Carolina n.a., stepparent is always in unit n.a. n.a. South Dakota n.a., stepparent is always in unit 14 n.a. n.a. Tennessee Yes 15 $250 100% of consolidated need standard for the unaided family members Texas Yes 16 $120 100% of budgetary needs standard for the unaided family members Utah n.a., stepparent is always in unit n.a. n.a. Table I.D.2. Treatment of Stepparent Income, July 2017 1 Deeming 2 Disregards applied prior to deeming Welfare Rules Databook: State TANF Policies as of July 2017 87 State Earned income disregard Other income disregards 3 Vermont n.a., stepparent is always in unit n.a. n.a. Virginia Yes $90 100% of standard of assistance for the unaided family members Washington n.a., stepparent is always in unit n.a. n.a. West Virginia n.a., stepparent is always in unit n.a. n.a. Wisconsin n.a., stepparent is always in unit n.a. n.a. Wyoming Yes $600 100% of maximum benefit for the unaided family members 2 In cases where the stepparent is included in the unit, there is no deeming; the stepparent’s income is treated like that of other unit members for eligibility and benefit computation purposes. 4 As part of the needy family test, the income of the stepparent is counted for eligibility determination if his or her spouse is applying for benefits as part of the assistance unit, but the stepparent is not counted as part of the unit for benefit computation. 5 If the stepparent is not included as a member of the assistance unit, his or her countable income is counted for eligibility purposes but his or her needs are not considered for benefit computation. 6 Applicants may disregard $90 for the eligibility test that compares net income to the MBSAC. Applicants and recipients may disregard $225 (minus any portion of the $225 applied to disability income), plus 50 percent of the remainder for the eligibility test that compares net income to the MAP, and for benefit computation. 7 In addition to the standard earned income disregard for unit members, stepparents are also allowed an additional $75 for the gross earnings personal employment expenses disregard. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 These policies apply to units in which the stepparent is not a part of the assistance unit but is living in the household, has no child in common with the spouse (head of unit), and has no dependents of his or her own living in the unit. Unless otherwise noted, the stepparent’s income is deemed to the spouse and the spouse’s dependents. The table captures instances in which the income of the stepparent is deemed for both eligibility determination and benefit computation; instances in which the income of the stepparent is treated differently for eligibility determination and benefit computation are footnoted. In general, states also deduct child support payments, alimony, and payments made to dependents outside the household from the stepparent’s income before deeming to the unit. These policies are not captured in this table. For more information on other disregards, see the full Welfare Rules Database. See table I.E.3 for information on the value of the standards for a family of three. Table I.D.2. Treatment of Stepparent Income, July 2017 1 Deeming 2 Disregards applied prior to deeming 3 \”Unaided family members\” represents the stepparent and all dependents outside the assistance unit. 9 The stepparent’s countable income is tested against 50 percent of the federal poverty guideline for a household size that includes the stepparent, the members of the assistance unit, and any other dependents not in the unit. When the income is below 50 percent of the federal poverty guideline, no income is deemed to the unit. When the income is over 50 percent of the federal poverty guideline, all of the stepparent’s income minus deductions is deemed to the unit. 10 If a recipient marries for the first time, his or her new spouse may receive a one-time, 100 percent disregard for six consecutive months. 11 The stepparent’s income is deemed only to the stepchildren. 8 The stepparent’s income is deemed only to the spouse or civil union partner. 88 Welfare Rules Databook: State TANF Policies as of July 2017 13 This disregard is applicable to those working at least 30 hours per week. If those working are employed less than 30 hours a week, then the disregard is $120 and 50 percent of the remainder. 14 The stepparent must be included in the unit, with the exception of a Native American stepparent who is under exclusive jurisdiction of a tribe for the purposes of determining the domestic relations rights of the family, in which case the stepparent has the option of being included in the assistance unit. 15 When a caretaker marries while receiving assistance, different deeming rules can apply. The caretaker can choose to exclude the new spouse and his or her income and resources for a period of three months, beginning on the first day of the month following the month of the marriage. During this time, eligibility and benefits for the unit are determined as if the spouse were not present in the home. No income is deemed, and the spouse’s needs are not included. This policy applies regardless of the spouse’s income and even if the spouse is the father of one of the assistance group children. After the three month period, the new spouse must be included in the assistance unit and his or her income and resources are fully counted. 16 For the first six months of a new marriage, all stepparent income is disregarded, provided the family’s total gross income is less than 200 percent of the federal poverty guideline. 12 The stepparent must be included in the unit. If a parent marries while receiving TANF and the stepparent is not eligible for TANF, his or her income is disregarded for the first six months. Beginning in month seven, there is a stepparent income disregard of 27 percent or $180, whichever is greater. If the stepparent is eligible for TANF, he or she is included in the assistance unit and his or her income is treated the same as other members of the TANF household. Welfare Rules Databook: State TANF Policies as of July 2017 89 State Treatment of income Treatment of assets Treatment of income Treatment of assets Alabama Not included n.a., no assets test n.a., caretaker not included in unit n.a., caretaker not included in unit Alaska Not included Not included Included Included Arizona Included for eligibility; Excluded for benefits 1 Not included Included Included Arkansas Not included Not included Included Included California Not included 2 Not included Included Included Colorado Not included n.a., no assets test Included n.a., no assets test Connecticut Not included Not included Included Included Delaware Not included Not included Included Included D.C. Not included Not included Included Included Florida Not included Not included Included Included Georgia Not included Not included Included Included Hawaii Not included n.a., no assets test Included n.a., no assets test Idaho Not included Not included Included Included Illinois Not included n.a., no assets test Included n.a., no assets test Indiana Not included Not included Included Included Iowa Not included Not included Included Included Kansas Not included Not included Included Included Kentucky Not included Not included Included Included Louisiana Not included n.a., no assets test Included n.a., no assets test Maine Not included Not included Included Included Maryland Not included n.a., no assets test Included n.a., no assets test Massachusetts Not included Not included Included Included Michigan Not included Not included Included Included Minnesota Not included Not included Included Included Mississippi Not included Not included Included Included Missouri Not included Not included Included Included Montana Not included Not included Included Included Nebraska Not included Not included Included Included Nevada Included 3 Not included Included 3 Included New Hampshire Not included Not included Included Included New Jersey Not included Not included Included Included New Mexico Not included Not included Included Included New York Not included Not included Included Included North Carolina Not included Not included n.a., caretaker not included in unit n.a., caretaker not included in unit North Dakota Not included Not included Included Included Ohio Not included n.a., no assets test Included n.a., no assets test Oklahoma Included Included Included Included Oregon Not included 4 Not included Included Included Pennsylvania Not included Not included Included Included Rhode Island Not included Not included Included Included South Carolina Not included Not included Included Included South Dakota Not included Not included n.a., caretaker not included in unit n.a., caretaker not included in unit Tennessee Not included Not included Included Included Table I.D.3. Treatment of Income and Assets of Nonparent Caretakers, July 2017 Caretakers who are not in the assistance unit: Caretakers who are in the assistance unit: 90 Welfare Rules Databook: State TANF Policies as of July 2017 State Treatment of income Treatment of assets Treatment of income Treatment of assets Texas Included if legally responsible Not included Included Included Utah Not included Not included Included Included Vermont Not included Not included Included Included Virginia Not included n.a., no assets test Included n.a., no assets test Washington Included 5 Not included Included Included West Virginia Not included Not included Included Included Wisconsin Not included Not included n.a., caretaker not included in unit n.a., caretaker not included in unit Wyoming Not included Not included Included Included 2 Income of the nonparent caretaker is included if participating in the KinGap program. 3 If countable income (gross earned and unearned) of all household members exceeds 275 percent of the federal poverty guidelines, the assistance unit is ineligible. If the countable income is less than 275 percent of the federal poverty guidelines, only the child’s income and resources are considered in determining the child’s eligibility and payment. 4 If countable income of the nonrelative caretaker, his or her spouse and children, and the child requesting TANF exceeds 185 percent of the federal poverty guidelines, the assistance unit is ineligible. If the countable income is less than 185 percent of the federal poverty guidelines, only the child’s income and resources are considered in determining the child’s eligibility and payment. 5 In most cases, if the caretaker’s family’s net income (gross income minus the earned income disregards and 50 percent of unearned income), exceeds 300 percent of the federal poverty guidelines, the assistance unit is ineligible; this test applies unless a child was placed in the home by a welfare agency and has an open child welfare case. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 As part of the needy family test, the total family income, including the nonparent caretaker’s income, cannot exceed 130 percent of the federal poverty guidelines. Table I.D.3. Treatment of Income and Assets of Nonparent Caretakers, July 2017 Caretakers who are not in the assistance unit: Caretakers who are in the assistance unit: Welfare Rules Databook: State TANF Policies as of July 2017 91 State Earned income disregard Other income disregards 2 Alabama Yes Child care expenses None Standard Alaska Yes $90 None Standard Arizona Yes None None Standard Arkansas Yes 20% 4 None Standard California Yes $90; $225 and 50% of remainder 5 None Eligibility computed for unit size including unaided family members 6 Colorado Yes $90 7 None Standard Connecticut Yes $90 100% of self employment expenses, personal employment expenses, and child care expenses 8 Standard Delaware Yes Gross income test: None; Net income test: $90 9 Gross income test: None; Net income test: Dependent care expenses 10 Standard D.C. Yes $160 11 None Standard Florida Yes None (treated same as unearned income) Prorated share of parent’s countable income 12 Standard Georgia Yes $90 100% of standard of need for unaided family members Standard Hawaii Yes Gross income test: None; Net income test: 20% 13 Gross income test: None; Net income test: Needs of ineligible family members and adult care expenses 14 Standard Idaho Yes 60% Parents with both earned and unearned income: 100% of unearned income; Parents with only unearned income: None Standard Illinois Yes Difference between 50% of federal poverty guideline and 100% of payment standard None Standard Indiana Yes $90 100% of the need standard for unaided family members Standard Computation Method 3 Table I.D.4. Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status, July 2017 1 Deeming Disregards applied prior to deeming 92 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregard Other income disregards 2 Iowa Yes 20%, plus 58% of remainder after other deductions Gross income test: None; Net income test: Needs of the ineligible parent and ineligible children, and child support payments 15 Standard Kansas Yes None None Standard Kentucky Yes $120 and 33.3% of remainder in first 4 consecutive months of earnings, $120 in months 5-12, and $90 thereafter None Standard Louisiana Yes None None Standard Maine Yes $108 and 50% of the remainder 100% of need standard for unaided family members, child care, and child support payments Standard Maryland Yes 20% 16 Prorated share of parent’s countable income 17 Standard Massachusetts Yes $200 Need standard amount for unaided family members Standard Michigan Yes $200, plus 20% of remainder 18 Child support Standard Minnesota Yes $65, plus 50% of remainder after other deductions Need standard amount for unaided family members, child care expenses, and child support payments Standard Mississippi Yes None None Standard Missouri Yes $90 None Standard Montana Yes Gross income test: None; Net income test: $200 and 25% of remainder 19 Gross income test: None; Net income test: Up to $200 for dependent care 19 Eligibility computed for unit size including unaided family members 6 Nebraska Yes 20% 20 None Standard Nevada Yes None None Standard New Hampshire Yes 20% 100% of standard of need for unaided family members Standard New Jersey Yes None 21 None 22 Standard Table I.D.4. Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status, July 2017 1 Deeming Disregards applied prior to deeming Computation Method 3 Welfare Rules Databook: State TANF Policies as of July 2017 93 State Earned income disregard Other income disregards 2 New Mexico Yes $125 Prorated share of parent’s countable income 23 Standard New York Yes $90 100% of the need standard for unaided family members Standard North Carolina Yes 27.5% None Standard North Dakota Yes Greater of $180 and 27% in all months, plus 50% of remainder in first 6 consecutive months of earnings, 35% of remainder in months 7-9, and 25% of remainder in months 10-13 24 Child and spousal support payments and dependent care expenses Standard Ohio Yes $90 100% of allocation allowance standard for unaided family members; child support Standard Oklahoma Yes $240, plus 50% of remainder 25 100% of the need standard for the unaided family members, plus child care expenses Standard Oregon Yes Gross income test: None; Net income test: 50% 26 Gross income test: None; Net income test: Prorated share of parent’s countable income 27 Gross and net income tests computed for unit size including ineligible members; benefit computed for unit size of eligible members Pennsylvania Yes $90 100% of standard of need for unaided family members Standard Rhode Island Yes $90 100% of the cash assistance monthly standard for unaided family members; child care expenses Standard South Carolina Yes 50% None Standard South Dakota Yes $90 and 20% of remainder Child support payments Standard Tennessee Yes $250 100% of consolidated need standard for unaided family members Standard Table I.D.4. Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status, July 2017 1 Deeming Disregards applied prior to deeming Computation Method 3 94 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregard Other income disregards 2 Texas Yes $120 100% of budgetary needs standard for unaided family members; child support payments Standard Utah Yes Gross income test: None; Net income test for applicants: $100 28 Gross income test: None; Net income test: Dependent care costs and child support payments Standard Vermont 29 Yes $250 and 25% of remainder 100% of need standard for parents and all dependents; alimony and child support payments 30 Standard Virginia Yes $90 100% of the standard of assistance for unaided family members; child support payments Standard Washington Yes 50% Payment standard amount for unaided family members; child support payments, child care expenses 31 Standard West Virginia Yes None 32 None 33 Standard Wisconsin n.a. 34 n.a. n.a. n.a. Wyoming Yes $600 None Standard Deeming Disregards applied prior to deeming Computation Method 3 Table I.D.4. Treatment of Income of Parents Excluded from the Assistance Unit Due to Immigrant Status, July 2017 1 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 These policies apply to units in which a child has a parent who is living in the household but not eligible to be part of the assistance unit due to immigrant status. The deeming policies shown here, regarding whether a portion of the immigrant parent’s income is considered available to the children in the unit, generally apply for both explicit eligibility tests and benefit computation formulas (which may also act as implicit eligibility tests); if those policies differ, the eligibility-test policies are reflected in the table, and the benefit computation policies are footnoted. For more information on other disregards, see the full Welfare Rules Database. See table I.E.3 for information on the value of the standards for a family of three. 3 This column describes how the deemed income (the countable portion of the parent’s income, after deductions) is used in computing the unit’s eligibility or benefits. The standard computation method adds deemed income to the unit’s other income, and then performs the eligibility and benefit computations with the unit size of the eligible members. 2 \”Unaided family members\” represents the parent and all dependents outside the assistance unit. Please see the full Welfare Rules Database for more information on states’ disregards for dependent care expenses. Welfare Rules Databook: State TANF Policies as of July 2017 95 20 For benefit computation, there is a 50 percent earned income disregard. 18 For benefit computation, there is a $200 disregard followed by 50 percent of the remainder. 21 For benefit computation, the parent can disregard 100 percent in first month of earnings, 75 percent in months two-seven, and 50 percent thereafter. 22 For benefit computation, child support is another income disregard. 9 For benefit computation and continuing eligibility, the excluded parent may disregard $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3 percent of remainder in first 4 consecutive months of earnings. 10 An excluded parent may disregard dependent care expenses up to $200 per month for each dependent child under the age of 2 and $175 per month for each dependent child age 2 or older or incapacitated adult for the net income test and benefit computation. 13 For purposes of benefit computation, an excluded parent may disregard 20 percent. 14 The needs of ineligible family members are defined as the standard of assistance for the unit size including both eligible and ineligible members minus the standard of assistance for the unit size with only the eligible members. 7 For benefit computation, there is a 67 percent disregard (the $90 disregard is for initial eligibility determination only). 5 Applicants may disregard $90 for the eligibility test that compares net income to the MBSAC. Applicants and recipients may disregard $225 (minus any portion of the $225 applied to disability income), plus 50 percent of the remainder for the eligibility test that compares net income to the MAP, and for benefit computation. 4 For ongoing eligibility, the parent may also disregard 60 percent of earnings remaining after the 20 percent disregard. 6 For benefit computation, an initial benefit is computed for a unit size including the eligible and ineligible family members; the benefit is capped at the maximum for the eligible family members. 19 The disregards for benefit computation are the same as the disregards for the net income test. 16 The earned income disregard is 50 percent for earnings from self-employment, earnings from room and board, or earnings from rental income. 8 For benefit computation, additional disregards are allowed: the need standard for the parent and his or her dependents outside the assistance unit, and actual alimony and child support payments. 11 For benefit computation, the parent can also disregard 67 percent of remaining earnings. 12 The immigrant parent’s total countable income is divided by the total aided plus unaided family members, which includes the parents plus all dependents in the household; the amount disregarded equals that per-capita amount times the number of unaided family members. 15 These disregards are used for initial and ongoing eligibility. The needs of the ineligible parents and ineligible children are computed as the need standard for a unit including the ineligible family members minus the amount for a unit with only the eligible members. For benefit computation, the needs-based disregards are computed using the payment standard; child support payments may also be disregarded. 17 The immigrant parent’s remaining countable income is divided by the number of people in the assistance unit plus the parent; the amount disregarded equals that per-capita amount (i.e., the parent’s per-capita share). 96 Welfare Rules Databook: State TANF Policies as of July 2017 23 The immigrant parent’s countable income is divided by the total aided plus unaided family members, which includes the parents plus all dependents in the household; the amount deemed to the unit equals that per-capita amount times the number of unaided family members. 34 Families with a parent excluded due to immigrant status are not eligible for TANF or components of TANF. 31 The payment standard amount for the unaided family members equals the payment standard amount for both aided and unaided family members minus the amount for only the aided family members. 32 For benefit computation, the parent can disregard 40 percent of earnings. 33 For benefit computation, the parent can disregard child and adult care expenses and child support income. 30 The need-standard disregard amount equals the basic need standard for a family size including the parents and anyone who can be claimed as a dependent for income tax purposes, plus the actual shelter expense up to the applicable maximum. Parents can also disregard amounts paid to people outside the household who can be claimed as dependents. 24 Each excluded parent has a lifetime limit of one 13-month cycle of the extra disregards, unless the excluded parent is employed for less than six consecutive months, in which case the 13-month cycle starts over upon re-employment. 26 The excluded parent may disregard 50 percent of earnings for the net income test and benefit computation. 27 The excluded parent may disregard the prorated share of his or her countable income for the net income test and benefit computation. The immigrant parent’s remaining countable income is divided by the total aided plus unaided family members, which includes the parents plus all dependents in the household; the amount disregarded equals that per-capita amount times the number of unaided family members. 28 For benefit computation, the excluded parent may disregard $100 and 50 percent of the remainder. If the unit has received benefits in at least one of the previous four months, the excluded parent may disregard $100 and 50 percent of the remainder for the net income test. 29 These policies apply to parents who are excluded from the assistance unit due to the five-year bar for qualified immigrants. Vermont’s policies do not describe how income is treated when non-citizen parents are excluded due to other immigrant statuses. 25 This disregard is applicable to those working at least 30 hours per week. If those working are employed less than 30 hours a week, then the disregard is $120 and 50 percent of the remainder. Welfare Rules Databook: State TANF Policies as of July 2017 97 State Type of test 2 Income must be less than 3 Alabama Net income 100% of Payment Standard Alaska Gross income 185% of Need Standard Net income 100% of Need Standard Arizona Gross income 185% of Need Standard Gross income 100% of the 2017 Federal Poverty Guidelines 4 Net income 100% of Need Standard Arkansas Net income 100% of Income Eligibility Standard California Net income 100% of Minimum Basic Standard of Adequate Care (MBSAC) Net income 100% of Maximum Aid Payment (MAP) Colorado Net income 100% of Need Standard Connecticut Net income 100% of Need Standard Unearned income 100% of Payment Standard Delaware Gross income 185% of Standard of Need Net income 100% of Payment Standard D.C. Net income 100% of Payment Level Florida Gross income 185% of Consolidated Need Standard Net income 100% of Payment Standard Georgia Gross income 185% of Standard of Need Net income 100% of Standard of Need Hawaii Gross income 185% of Standard of Need Net income 100% of Standard of Assistance Idaho No explicit tests n.a. Illinois Net income 100% of Payment Standard Indiana Gross income 185% of Need Standard Net income 90% of Need Standard Iowa Gross income 185% of Need Standard Net income 100% of Need Standard Kansas Net income 100% of Budgetary Standards Kentucky Gross income 185% of Standard of Need Louisiana Net income 100% of Flat Grant Amount Maine Gross income 100% of Gross Income Test Net income 100% of the Second Income Test Maryland Net income 100% of Allowable Payment Massachusetts Net income 100% of Need Standard and Payment Standard Michigan Net income 100% of Payment Standard Minnesota Net income 100% of Family Wage Level Mississippi Gross income 185% of Need Standard and Payment Standard Net income 100% of Need Standard and Payment Standard Missouri Gross income 185% of Need Standard Net income 100% of Need Standard Montana Gross income 100% of the Gross Monthly Income Standard Net income 100% of Benefit Standard Nebraska Net income 100% of Standard of Need Nevada Gross income 130% of the 2017 Federal Poverty Guidelines Net income 100% of Need Standard New Hampshire Net income 100% of Payment Standard New Jersey Gross income 5 150% of Maximum Benefit Payment Schedule New Mexico Gross income 85% of the 2016 Federal Poverty Guidelines New York Gross income 185% of Need Standard Gross earnings 100% of the 2017 Federal Poverty Guidelines Net income 100% of Need Standard Table I.E.1. Income Eligibility Tests for Applicants, July 2017 1 98 Welfare Rules Databook: State TANF Policies as of July 2017 State Type of test 2 Income must be less than 3 North Carolina No explicit tests 6 n.a. North Dakota No explicit tests n.a. Ohio Net income 7 50% of the 2017 Federal Poverty Guidelines Oklahoma Gross income 185% of Need Standard Net income 100% of Need Standard Oregon Gross income 100% of Countable Income Limit Net income 100% of Adjusted Income Standard Pennsylvania Net income 8 100% of Standard of Need Rhode Island No explicit tests n.a. South Carolina Gross income 185% of Need Standard South Dakota No explicit tests n.a. Tennessee Gross income 185% of Consolidated Need Standard Texas Net income 100% of Budgetary Needs Standard Net income 100% of Recognizable Needs Utah Gross income 185% of Adjusted Standard Needs Budget (SNB) Net income 100% of Adjusted Standard Needs Budget (SNB) Vermont No explicit tests n.a. Virginia All, except VIEW Gross income 185% of Standard of Assistance Net income 100% of Standard of Assistance VIEW Gross earnings 100% of the 2016 Federal Poverty Guidelines Unearned income 100% of Standard of Assistance Washington Gross earnings 100% of Maximum Gross Earned Income Limit West Virginia Gross income 100% of Standard of Need Wisconsin Gross income 115% of the 2017 Federal Poverty Guidelines Wyoming No explicit tests n.a. 5 When the total countable income equals or exceeds the applicable benefit level, the assistance unit is no longer eligible for WFNJ\/TANF benefits except for cases with earned income that are subject to six-month reporting requirements. Such cases need not report changes in earned income until such time as the assistance unit’s total income exceeds 130 percent of the Federal Poverty Guidelines. However, if the assistance unit does report a change, the county or municipal agency will act on that change. For households where a non-needy stepparent is married to a natural or adoptive recipient parent, the gross household income may not exceed 150 percent of the Federal Poverty Guidelines. 6 While the state does not impose any income tests for applicants to receive cash assistance, the state does impose a gross income eligibility test at 200 percent of the Federal Poverty Guidelines to receive certain social services. 8 This test (the Earned Income Disregard Eligibility Test ) is not imposed on applicants who have received benefits in one of the last four months. 7 This test applies for families who have not received benefits in the past four months. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 See table II.A.2 for information on benefit computation policies. See table I.E.3 for information on the value of the standards for a family of three. 2 \”No explicit tests\” indicates that either the state imposes no income tests on applicants or the state imposes an income test, but the calculation of the test and disregards allowed for the test are no different from those used to calculate the benefit. Also, in some states, applicants could pass the explicit tests shown, but might not be eligible for a positive benefit because of the way the state computes benefits. 3 In some states, the test is passed if income is less than or equal to the amount shown; in other states, the test is passed only if income is less than the amount shown. 4 This test, the needy family test, includes all family members of the adult caretaker for counting income and family size. When the adult caretaker is a non-parent relative of the dependent child receiving benefits for the child only, the income limit is 130 percent of the Federal Poverty Guidelines. Table I.E.1. Income Eligibility Tests for Applicants, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 99 State Earned income disregard Alabama 20% 2 Alaska $90 3 Arizona $90 and 30% of remainder Arkansas 20% California For the test that uses MBSAC: $90 4 For the test that uses MAP: $225 and 50% of remainder Colorado $90 Connecticut $90 Delaware $90 D.C. $160 per employed unit member Florida $90 5 Georgia $90 Hawaii 20%, $200, and 36% of remainder Idaho No explicit net income test Illinois Difference between 50 percent of the current federal poverty guideline for the applicant’s family size and their TANF payment level Indiana $90 Iowa 20% Kansas $90 Kentucky No explicit net income test Louisiana $120 Maine $108 and 50% of remainder Maryland 20% Massachusetts $200 Michigan $200 and 20% of remainder Minnesota $65 and 50% of remainder Mississippi $90 Missouri $90 Montana $200 and 25% of remainder Nebraska 20% Nevada Greater of $90 or 20% New Hampshire 20% New Jersey No explicit net income test New Mexico No explicit net income test New York $90 3 North Carolina No explicit net income test North Dakota No explicit net income test Ohio No disregards allowed 6 Oklahoma $240 7 Oregon 50% Pennsylvania $90 Rhode Island No explicit net income test South Carolina No explicit net income test South Dakota No explicit net income test Tennessee No explicit net income test Texas For the test that uses Budgetary Needs: $120 For the test that uses Recognizable Needs: $120 and 33% of remainder Table I.E.2. Earned Income Disregards for Initial Income Eligibility Purposes, July 2017 1 100 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregard Utah $100 8 Vermont No explicit net income test Virginia All, except VIEW $155 and 20% of remainder 9 VIEW No explicit net income test 10 Washington No explicit net income test West Virginia No explicit net income test Wisconsin No explicit net income test Wyoming No explicit net income test 10 All applicants must pass the same initial income eligibility tests. VIEW income eligibility tests and earned income disregards apply only to recipients who have met the initial eligibility requirements. 9 The dollar amount of the disregard varies by family size. For one to three unit members, the disregard is $155. For four members, it is $168; for five members, it is $197; and for six or more members, it is $226. 2 The earned income disregard cannot be applied to the earnings of an individual receiving assistance beyond the 60th month under a hardship extension. 3 This state considers units who have received assistance in one of the previous four months as recipients for the purpose of earned income disregards. 4 If a participant applies for TANF benefits within three calendar months of his or her subsidized employment placement ending, he or she will be considered a recipient for purposes of earned income disregards. 5 Applicant units receiving assistance in one of the last four months may disregard $200 and 50 percent of the remainder. 8 Applicants who have received benefits in at least 1 of the previous 4 months may disregard $100 and 50 percent of the remainder. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The table describes the disregards used for initial applicant eligibility purposes. See table IV.A.5 for the disregards used for ongoing, recipient eligibility purposes. Note that several states treat applicants who have recently received benefits as recipients. Only earned income disregards are described in the table. Child care disregards and other special disregards, such as deductions for units subject to a time limit or a family cap, are not included. This table only shows earned income disregards for explicit net income tests. \”No explicit net income test\” indicates that either the state does not impose a net income test at application or the state imposes a net income test, but the calculation of the test and disregards allowed for the test are the same as those used to calculate the benefit. See table II.A.2 for information on benefit computation policies. 6 This state does test net income for initial eligibility but does not allow units to apply the type of earned income disregard discussed in this table. The net income test includes more specific disregards, such as deductions for dependent care. 7 This disregard applies to individuals working full time (defined as 20 hours a week for individuals with a child under age 6 and 30 hours a week for all others). Individuals who are not employed full time may disregard $120. Table I.E.2. Earned Income Disregards for Initial Income Eligibility Purposes, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 101 State State name for standard Amount for family of three 2 Alabama Payment Standard $215 Alaska Need Standard $1,594 Arizona Need Standard $964 2017 Federal Poverty Guidelines $1,702 Arkansas Income Eligibility Standard $223 California 3 Non-exempt Minimum Basic Standard of Adequate Care (MBSAC) $1,342 Maximum Aid Payment (MAP) $714 Exempt Minimum Basic Standard of Adequate Care (MBSAC) $1,342 Maximum Aid Payment (MAP) $799 Colorado 3 Need Standard $421 Connecticut 3 Need Standard $818 Payment Standard $597 2017 Federal Poverty Guidelines $1,702 Delaware Standard of Need $1,260 Payment Standard $338 D.C. Standard of Assistance $712 Payment Level $508 Florida Consolidated Need Standard $1,702 Payment Standard $303 Georgia Standard of Need $424 Hawaii Standard of Need $1,590 Standard of Assistance $763 4 Idaho n.a., no explicit income test n.a. Illinois 3 Payment Standard $432 Indiana Need Standard $320 Iowa Need Standard $849 Kansas 3 Budgetary Standards $429 Kentucky Standard of Need $526 Louisiana Flat Grant Amount $240 Maine Gross Income Test $1,023 Second Income Test $596 Maryland Allowable Payment $648 Massachusetts Exempt Need Standard and Payment Standard $633 2017 Federal Poverty Guidelines $1,702 Non-exempt Need Standard and Payment Standard $618 2017 Federal Poverty Guidelines $1,702 Michigan Payment Standard $492 Minnesota Family Wage Level $1,090 2017 Federal Poverty Guidelines $1,702 Mississippi Need Standard and Payment Standard $368 Missouri Need Standard $846 Montana Benefit Standard $463 Gross Monthly Income Standard $1,092 Nebraska Standard of Need $816 2017 Federal Poverty Guidelines $1,702 Table I.E.3. Standards for Determining Eligibility, July 2017 1 102 Welfare Rules Databook: State TANF Policies as of July 2017 State State name for standard Amount for family of three 2 Nevada Need Standard $1,276 2017 Federal Poverty Guidelines $1,702 New Hampshire Payment Standard $1,021 Standard of Need $4,002 New Jersey Maximum Benefit Payment Schedule $424 New Mexico 2016 Federal Poverty Guidelines $1,680 New York 3 Need Standard $789 2017 Federal Poverty Guidelines $1,702 North Carolina n.a., no explicit income test n.a. North Dakota Standard of Need $486 5 Ohio 2017 Federal Poverty Guidelines $1,702 Allocation Allowance Standard $980 Oklahoma Need Standard $645 Oregon Countable Income Limit $616 Adjusted Income Standard $485 Exit Limit Increase Standard $1,012 Pennsylvania 3 Standard of Need $587 Rhode Island Cash Assistance Monthly Standard $554 South Carolina Need Standard $840 South Dakota Payment Standard $615 Tennessee Consolidated Need Standard $1,066 Texas Budgetary Needs Standard $751 Recognizable Needs $188 Utah Adjusted Standard Needs Budget (SNB) $568 Vermont 3 n.a., no explicit income test n.a. Virginia 3 All, except VIEW Standard of Assistance $419 VIEW Standard of Assistance $419 2016 Federal Poverty Guidelines $1,680 Washington Need Standard $2,106 Maximum Gross Earned Income Limit $1,042 West Virginia Standard of Need $991 Wisconsin 2017 Federal Poverty Guidelines $1,702 Wyoming Maximum Benefit $660 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The values in this table represent all standards used during the eligibility process, including those used for grandparent deeming, stepparent deeming, applicant income eligibility tests, and recipient income eligibility tests. See tables I.D.1, I.D.2, I.E.1, and IV.A.4 for more information on how these standards are used. This table provides information on the standards only; to determine how the standards are applied, see the companion tables listed above. For example, states may use a percentage of the above amounts in an eligibility test (e.g. 185 percent of the Standard of Need). Those calculations are not included above. 2 The amounts in the table are based on the following assumptions about the assistance unit: there is one adult and two children; the children are not subject to a family cap; and the unit has no special needs, pays for shelter, and lives in the most populated area of the state. Table I.E.3. Standards for Determining Eligibility, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 103 4 The Standard of Assistance is $610 for a family of three in the third or subsequent months of receiving benefits. 5 North Dakota adds $50 to the Standard of Need for units with sole responsibility for all housing costs. The additional $50, which North Dakota considers to be a special item of need, is included in the amount shown in this table. 3 Dollar amounts used to calculate benefits vary within the state, either by county or by region of the state. Calculations are based on the dollar amount that applies to the majority of the state. See the Welfare Rules Database for more information. 104 Welfare Rules Databook: State TANF Policies as of July 2017 State Maximum earnings an applicant can receive in a month and still be eligible for assistance Alabama $268 Alaska $1,683 Arizona $585 Arkansas $278 California 2 $1,431 Colorado 2 $511 Connecticut 2 $908 Delaware $428 D.C. $668 Florida $393 Georgia $514 Hawaii 3 $1,740 Idaho $972 Illinois 2 $851 Indiana $378 Iowa $1,061 Kansas 2 $519 Kentucky $908 Louisiana $360 Maine $1,023 Maryland $810 Massachusetts Exempt $833 Non-Exempt $818 Michigan $815 Minnesota $2,243 Mississippi $457 Missouri $557 Montana $817 Nebraska $1,020 Nevada $1,595 New Hampshire $1,276 New Jersey $636 New Mexico $942 New York 2 $879 North Carolina $681 North Dakota $1,331 Ohio $851 Oklahoma $823 Oregon $616 Pennsylvania 2 $677 Rhode Island $1,277 South Carolina $1,554 South Dakota $857 Tennessee $1,315 Texas $401 Utah $668 Table I.E.4. Maximum Income for Initial Eligibility for a Family of Three, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 105 State Maximum earnings an applicant can receive in a month and still be eligible for assistance Vermont 2 $1,103 Virginia 4 $677 Washington $1,040 West Virginia $565 Wisconsin 5 n.a. Wyoming $1,259 Mean 6 $881 Median 6 $828 6 The mean and median calculations only include one value per state (the policy affecting the largest portion of the caseload). 5 Units with earnings at application will not receive a cash benefit, except for units with earnings from unsubsidized employment who work less than 30 hours per week and face limitations to increasing their work hours. These units are eligible for a Community Service Job placement where they may receive a prorated benefit. Units with income less than $1,957 at application who find employment during up-front job search have their income disregarded for purposes of determining eligibility for nonfinancial assistance. 3 This threshold applies to units that have received assistance for no more than two months in a lifetime. For units applying for their third and subsequent months of benefits, the eligibility threshold for a family of three is $1,894. 4 Dollar amounts used for calculations vary within the state, either by county or by region of the state. These calculations are based on the dollar amounts that apply to the majority of the state. See the Welfare Rules Database for more information. All applicants, including those who will subsequently participate in the VIEW program, must pass the same initial income eligibility tests. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The values in this table represent the maximum amount of earnings an applicant can have and still be technically eligible for assistance in each state. Technical eligibility does not mean that the unit will necessarily receive a cash benefit, but it will have passed all the eligibility tests and be technically eligible for some positive benefit. Most states only distribute a cash benefit equaling $10 or more. Initial eligibility is calculated assuming that the unit is employed at application, has only earned income, has no child care expenses, contains one adult and no children subject to a family cap, has no special needs, pays for shelter, and lives in the most populated area of the state. 2 Dollar amounts used for calculations vary within the state, either by county or by region of the state. These calculations are based on the dollar amounts that apply to the majority of the state. See the Welfare Rules Database for more information. Table I.E.4. Maximum Income for Initial Eligibility for a Family of Three, July 2017 1 106 Welfare Rules Databook: State TANF Policies as of July 2017 II. Benefits The tables in this chapter of the Databook describe key aspects of the rules for calculating and distributing the assistance unit’s benefit as of July 2017. The tables include information on how benefits are calculated, the maximum benefits for different types of assistance units, and how benefits are administered. A. If a family passes all eligibility tests, what is received? Rules for calculating benefits apply once the family has passed all eligibility tests, both nonfinancial and financial. State rules for calculating benefits vary, and the calculations across states range in complexity. In the more straightforward calculations, net income is subtracted from a state-determined standard (often called the payment standard), which varies by family size, and the benefit paid is the difference (sometimes referred to as the income deficit). Some states, however, either use more complex calculations or pay a flat grant amount. The following section describes these policies in greater detail. Earned Income Disregards for Benefit Computation (Table II.A.1) When states use net income for benefit computation, they disregard a portion of the assistance unit’s income in calculating the income of the unit. Table II.A.1 describes the earned income disregards allowed when calculating the benefit. If a state pays a flat grant amount (explained further below), then earned income disregards are not relevant to benefit computation and no disregards flat grant amount appears in the table. In some cases, states use different earned income disregards to determine the benefit of a unit in its first month of eligibility versus subsequent months. This information is included in the tables and notes. Policies for 2017 include: \u25aa All 49 states that vary benefits with income use an earned income disregard. \u25aa Of the states that do have earned income disregards for benefit computation, 34 have a disregard that applies in all months, and 14 states have an income disregard that changes over time. In the remaining state (Virginia), the amount of the income disregard varies by unit size. Welfare Rules Databook: State TANF Policies as of July 2017 107 Some states disregard a portion of the child care expenses paid by a family or allow special disregards for units subject to a family cap or time limit. Those disregards are not included in the table, but are captured in the WRD. Related tables: Disregards for benefit computation and income eligibility may differ. For information on the earned income disregards used for an applicant’s income eligibility, see table I.E.2. See table IV.A.5 for the earned income disregards used with income eligibility tests for recipients’ ongoing eligibility. Table L4, in the last section of this book, describes the earned income disregards used for benefit computation for selected years from 1996 through 2017. Benefit Determination Policies (Table II.A.2) Table II.A.2 describes how states compute benefits for units that pass all applicable eligibility tests. In many states, net income is subtracted from a state-determined payment standard, which typically varies by the size of the assistance unit. The benefit paid to the family is then the difference between the net income and state payment standard, sometimes referred to as the income deficit. In other states, a statutory maximum benefit is imposed, generally varying by family size. In these states, the benefit is either the income deficit or the statutory maximum, whichever is less. Still other states multiply the income deficit by a percentage, which is sometimes referred to as the benefit reduction rate. This percentage of the income deficit is the benefit provided to the unit. Some states combine both a statutory maximum and benefit reduction rate into their calculation. Finally, some states provide a fixed (flat grant) amount, regardless of family income. Policies for 2017 include: \u25aa A majority of states (34) compute benefits for all or most of their caseload by subtracting income from a selected dollar amount (a payment standard); the benefit equals the difference (the income deficit). \u25aa Fifteen states pay only a portion of the income deficit, impose a maximum, or use both of those strategies in combination. \u25aa Two states\u2014Arkansas and Wisconsin\u2014determine benefits for eligible families in a way that does not vary with family income. Related tables: For the income standards named in this table, table II.A.3 gives the value of the standard for a three-person family. Table II.A.4 combines information from table II.A.2 with information on benefit standards for various family sizes and presents the benefit paid to an assistance unit with no net income and with two, three, four, five, or six members. Table II.A.1 108 Welfare Rules Databook: State TANF Policies as of July 2017 describes the earned income disregards allowed in calculating the net income used for benefit computation, and tables I.D.1, I.D.2, I.D.4, and IV.A.2 include policies on the treatment of unearned income (amounts deemed from grandparent units, stepparent units, immigrant parents, and treatment of child support income). Table L5, in the last section of this book, provides the maximum benefits paid to a three-person unit for selected years from 1996 through 2017. Standards for Determining Benefits (Table II.A.3) As described earlier, benefit computations involve state-established income amounts that almost always vary by the size of the assistance unit. The WRD includes the benefit standards used for each family size from 1 through 12. Table II.A.3 provides the standards for a three- person assistance unit with one adult and two children. The first two columns of the table describe what we refer to in general terms as the payment standard \u2014the dollar amount from which net income is subtracted, or the flat grant amount in the few states that use that approach. The first column gives the state’s name for this standard, and the second column gives the amount of this standard for a three-person family. In states that impose a statutory maximum benefit, the third and fourth columns of the table provide the state’s name for that standard and the amount of the maximum benefit for a three-person family. Policy highlights from 2017 include: \u25aa Twelve states have a statutory maximum benefit. The amount for a family of three ranges from $170 in Mississippi to $991 in Minnesota. (The amount for Minnesota includes the SNAP allotment; excluding the portion intended for food assistance, the maximum benefit in Minnesota is $532.) In some states, different dollar amounts are used in different regions of the state; in those cases, the table includes the amounts applied to the most populous area of the state with a footnote indicating that the benefits are not constant across the state. In other states, the amounts may be higher for families with certain special needs, such as a pregnancy; the amounts in the table assume no special needs. Also, a few states have different sets of standards for one-parent families, two-parent families, and child-only units (in other words, the payment standard might differ for a single parent with two children compared with a married couple with one child, even though both units have three people); the table shows the values for a one-parent family with two children. Finally, some states prorate the eligibility or benefit standards depending on whether a unit pays for shelter; the amounts in the table assume the unit pays all shelter costs and does not live in public or subsidized housing. Welfare Rules Databook: State TANF Policies as of July 2017 109 Related tables: The standards by themselves are not necessarily comparable across states, since benefit computation procedures differ. To determine how the standards are used in practice, see table II.A.2. Table II.A.4 provides the benefit paid to two- to six-person units with no other income, and table L5 provides the three-person maximum benefits for selected years from 1996 through 2017. Table II.A.5 provides the benefit paid to a unit consisting of a single child, with no adults. Maximum Monthly Benefit for a Family with No Income (Table II.A.4) The maximum benefit calculation combines the information on a state’s benefit computation policies with the dollar amounts used for benefit computation to present the benefit paid to a unit with no income. If a state computes benefits as a payment standard minus net income, then this figure will simply equal the payment standard. In other cases, this figure will equal a statutory maximum benefit (which is less than the payment standard). In still other cases, it will be a percentage of the payment standard. Table II.A.4 provides information on the maximum benefit in each state for family sizes two through six. The calculation assumes the assistance unit includes one parent and the other unit members are children, the unit contains no children subject to a family cap, no assistance unit members have special needs, the unit pays for all shelter costs with no subsidies, and the unit is subject to the benefit standard that applies to the majority of the state’s caseload. Key findings for 2017 include: \u25aa The maximum monthly benefit for a family of three with no income ranges from $170 in Mississippi to $1,021 in New Hampshire. \u25aa Across the states, the average (mean) maximum monthly benefit for a family of three is $454. The median figure is slightly lower, at $432. Data for family sizes larger than six people may be found in the WRD. Related tables: Table L5 provides the benefit paid to a three-person assistance unit with no net income for selected years from 1996 through 2017. Table II.A.5 gives the maximum benefits paid to child-only units with one child. Maximum Monthly Benefit for a Child-Only Unit with One Child, No Income (Table II.A.5) Table II.A.5 provides the maximum monthly TANF benefit that could be paid to a child-only unit consisting of a single child. Information is shown for three different circumstances that may lead to child-only units: when the child lives with a nonparent caretaker (and the caretaker was 110 Welfare Rules Databook: State TANF Policies as of July 2017 never included in the unit), a parent or caretaker who receives SSI, or a parent who is excluded due to immigrant status. (If a state’s TANF program does not provide benefits in one or more of those situations, no value is shown and more information is provided in a footnote.) Policies for 2017 include: \u25aa Among the states whose TANF programs include at least two of these three types of child-only units, three states pay different TANF benefits depending on the reason that the unit includes only children. \u25aa Across the states, the average (mean) child-only benefit is $250 when the child lives with a nonparent caretaker, $237 when the child lives with a parent excluded from the unit due to SSI receipt, and $248 when the child lives with a parent excluded from the unit due to immigrant status. Related tables: For more information on policies leading to a unit being child-only, tables I.B.5, I.B.6, and I.B.7 provide information on parents who are immigrants, table I.B.10 provides information on SSI recipients, and table I.B.11 provides information on nonparent caretakers. Benefit Issuance Policies (Table II.A.6) Table II.A.6 provides the method by which states deliver TANF benefits to families. The four possible methods for distributing benefits are: paper check, electronic benefit transfer (EBT) cards, electronic payment cards (EPC), and electronic funds transfers (EFT). An EBT card is a state-issued debit card on which benefits are deposited by the state, similar to (and sometimes the same as) the cards used by the Supplemental Nutrition Assistance Program (SNAP). An EPC card is similar to an EBT card; however, EPC cards are issued and maintained by a third-party brand, such as Visa or MasterCard, rather than the state. An EFT is an electronic direct deposit into a recipient’s checking account. In addition, some states may offer benefits in the form of direct vendor payments or vouchers. These instances are footnoted. Under the Middle Class Tax Relief and Job Creation Act of 2012, states are directed to prevent the use of EBT and EPC cards in any liquor store; any casino, gambling casino, or gaming establishment; or any retail establishment which provides adult-oriented entertainment in which performers disrobe or perform in an unclothed state for entertainment. 34 The last 34 Public Law 112-96. Middle Class Tax Relief and Job Creation Act of 2012: https:\/\/www.gpo.gov\/fdsys\/pkg\/PLAW- 112publ96\/pdf\/PLAW-112publ96.pdf. Welfare Rules Databook: State TANF Policies as of July 2017 111 https:\/\/www.gpo.gov\/fdsys\/pkg\/PLAW-112publ96\/pdf\/PLAW-112publ96.pdf https:\/\/www.gpo.gov\/fdsys\/pkg\/PLAW-112publ96\/pdf\/PLAW-112publ96.pdf column of table II.A.6 describes the locations where states prohibit the use of EBT or EPC cards, beyond those already prohibited under federal law. Policies for 2017 include: \u25aa Forty states allow electronic benefits transfer (EBT) as a form of benefit issuance. \u25aa Nine states allow electronic payment cards (EPC) as a form of benefit issuance. \u25aa Thirty states allow electronic funds transfer (EFT) as a form of benefit issuance. 112 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregards 1 Alabama 100% in first 12 consecutive months of earnings, 20% thereafter 2 Alaska $150 in all months, plus 33% of remainder in first 12 cumulative months of earnings, 25% of remainder in months 13-24, 20% of remainder in months 25-36, 15% of remainder in months 37- 48, 10% of remainder in months 49-60 Arizona $90 and 30% of remainder in all months Arkansas No disregards – flat grant amount California $225 and 50% of remainder in all months 3 Colorado 67% in all months Connecticut 100% up to federal poverty guideline in all months 4 Delaware $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 5 D.C. $160 and 66.7% of remainder in all months 6 Florida $200 and 50% of remainder in all months Georgia $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings Hawaii 20% and $200 of remainder in all months, plus 55% of remainder in first 24 cumulative months of assistance and 36% of remainder thereafter Idaho 60% in all months Illinois 75% in all months Indiana 75% in all months Iowa 20% and 58% of remainder in all months Kansas $90 and 60% of remainder in all months Kentucky 100% in first 2 months earnings would affect eligibility; $120 and 33.3% of remainder in first 4 consecutive months of earnings, $120 in months 5-12, $90 thereafter 7 Louisiana $120 in all months, plus $900 in any 6 months over a recipient’s lifetime 8 Maine $108 and 50% of remainder in all months Maryland 40% in all months Massachusetts n.a. Exempt $200 and 50% of remainder in all months Non-Exempt $200 and 50% of remainder in all months Michigan $200 and 50% of remainder in all months Minnesota $65 and 50% of remainder in all months Mississippi $90 in all months 9 Missouri 100% in first 6 consecutive months of earnings, 66.7% and $90 of remainder in months 7-18, $90 thereafter 10 Montana $200 and 25% of remainder in all months Nebraska 50% in all months Nevada 100% in first 3 cumulative months of earnings, 85% in months 4-6, 75% in months 7-9, 65% in months 10-12, greater of $90 or 20% thereafter 11 New Hampshire 50% in all months New Jersey 100% in first month of earnings, 75% in months 2-7, 50% thereafter 12 New Mexico $125 and 50% of remainder in all months 13 New York $90 and 51% of remainder in all months North Carolina 27.5% in all months Table II.A.1. Earned Income Disregards for Benefit Computation, July 2017 Welfare Rules Databook: State TANF Policies as of July 2017 113 State Earned income disregards 1 North Dakota Greater of $180 and 27% in all months, plus 50% of remainder in first 6 consecutive months of earnings, 35% of remainder in months 7-9, and 25% of remainder in months 10-13 14 Ohio $250 and 50% of remainder in all months Oklahoma 100% in first 3 consecutive months of earnings, $240 and 50% of remainder thereafter 15 Oregon 50% in all months Pennsylvania 50% in all months Rhode Island $170 and 50% of remainder in all months South Carolina 50% in first 4 months earned income is budgeted, $100 thereafter 16 South Dakota $90 and 20% of remainder in all months Tennessee $250 in all months Texas $120 in all months, plus 90% of remainder (up to $1,400) for 4 out of 12 months 17 Utah $100 and 50% of remainder in all months Vermont $250 and 25% of remainder in all months 18 Virginia Varies by unit size 19 Washington 50% in all months West Virginia 40% in all months Wisconsin No disregards – flat grant amount Wyoming $600 in all months 20 3 If a recipient applies for TANF benefits within three calendar months of his or her subsidized employment placement ending, he or she will be considered for the recipient earned income disregard rather than the applicant $90 income disregard. 6 The unit may disregard $160 per employed member. 5 If benefits or employment end before the fourth consecutive month of earnings, the recipient is eligible to receive the $30 and 33.3 percent disregard for four additional months upon reapplication or re-employment. When a recipient has received the $30 and 33.3 percent disregard for four consecutive months and the $30 disregard for an additional eight months, neither disregard may be applied again until the individual has not received any benefits for 12 months. 7 Recipients are eligible for the one-time, two-month 100 percent disregard if they become newly employed or report increased wages acquired after approval. Recipients are eligible to receive the 33.3 percent disregard during the first four consecutive months of earnings if they have not received benefits for at least 12 consecutive months. 8 The six months in which the extra $900 is disregarded need not be consecutive, but the recipient may use this extra disregard in no more than six months over the course of his or her lifetime. 4 A unit that has not received cash assistance in one of the four prior months will disregard $90 of earned income for purposes of benefit computation. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The table describes the earned income disregards used to compute a recipient’s benefit. If different disregards are used to compute an applicant’s benefit in the first month, they are footnoted. Only earned income disregards are described in the table. Child care disregards and other special disregards–such as deductions for units subject to time limits and family caps, and earned income disregards that apply to new marriages or in cases of deeming–are not included in this table. When no duration is specified for the disregards, they remain for the entire period of benefit receipt. 2 The earned income disregard cannot be applied to the earnings of an individual receiving assistance beyond the 60th month under an extension. The disregard can only be applied to earnings reported within 10 days of receipt. Table II.A.1. Earned Income Disregards for Benefit Computation, July 2017 114 Welfare Rules Databook: State TANF Policies as of July 2017 19 The disregard is calculated by excluding varying earned income amounts based on the unit size, followed by a 20 percent disregard of the remainder regardless of unit size in all months. The dollar amounts excluded are: $155 for one to three unit members, $168 for four unit members, $197 for five unit members, and $226 for six or more unit members. A recipient who is participating in unsubsidized employment is eligible for an enhanced earned income disregard, provided the TANF recipient’s income does not exceed 100 percent of the Federal Poverty Guidelines or 150 percent of the Federal Poverty Guidelines for TANF-UP households. 20 Married couples with a child in common may disregard $1,200. 14 Each recipient has a lifetime limit of one 13-month cycle of the extra disregards, unless the recipient is employed for less than six consecutive months, in which case the 13-month cycle starts over upon re-employment. 15 These disregards apply to individuals working full time, defined as 20 hours a week for recipients caring for a child under age 6 and 30 hours a week for all other recipients. Individuals working less than full time may disregard 100 percent in the first three consecutive months of earnings and $120 and 50 percent of the remainder thereafter. Regardless of the number of hours worked, the 100 percent disregard only applies to recipients who reside in units where all members have a combined monthly income less than or equal to $2,064 and remain eligible for cash assistance after all other disregards are applied to the payment standard. 16 The 50 percent disregard is available only once in a lifetime. 17 Once the recipient has received four months (they need not be consecutive) of the 90 percent disregard, he or she is not eligible to receive the disregard again until the TANF case has been denied and remains denied for one full month, and 12 calendar months have passed since the denial. The 12-month ineligibility period begins with the first full month of denial after the client used the fourth month of the 90 percent disregard. 18 These disregards apply to recipients with income from unsubsidized employment or a combination of subsidized and unsubsidized employment. For recipients with earnings from subsidized employment only, the disregard is $90. 10 These disregards apply to recipients who gained employment while receiving TANF. Recipients who gained employment before receiving TANF may disregard $120 and 33.3 percent of the remainder in the first 4 consecutive months of earnings, $120 in months 5-12, and $90 thereafter. 11 The first 12 months of disregards are available to recipients again if they have been off TANF for at least 12 months. 12 These disregards apply to individuals working 20 or more hours a week. Individuals employed fewer than 20 hours a week may disregard 100 percent in the first month of employment and 50 percent thereafter; however, if an individual’s hours increase to 20 hours during the first six months, he or she may disregard 75 percent for the remainder of the six- month period. The 100 percent disregard is applicable only once every 12 months, even if employment is lost and then regained. 13 Two-parent units may disregard $225 and 50 percent of the remainder in all months. 9 Recipients are eligible for a one-time 100 percent disregard for the first six consecutive months of earnings if they find employment of 35 hours a week within the first 30 days of their initial approval for TANF. If work is not found within 30 days, the recipient is ineligible to ever receive the disregard again. An additional 100 percent disregard is available to units for three months when the unit’s case is subject to closure because of increased earnings and the individual is employed for at least 25 hours a week at the federal minimum wage or higher. The recipient may not have already received the six- month disregard, unless there has been at least a 12-month break in receipt of TANF benefits. The three-month disregard may be received more than once during the 60-month TANF benefit period provided there is a period of at least 12 consecutive months in which a family does not receive TANF benefits before the family reapplies for assistance. Welfare Rules Databook: State TANF Policies as of July 2017 115 State Benefit equals 1 Alabama Payment standard minus net income Alaska Lesser of (58.1% of need standard minus net income) or maximum payment 2 Arizona 80% of (payment benefit minus net income) Arkansas Maximum payment level (flat grant amount) 3 California Maximum aid payment minus net income 4 Colorado Grant standard minus net income Connecticut Payment standard minus net income 5 Delaware Lesser of (50% of (standard of need minus net income)) or payment standard D.C. Payment level minus net income Florida Payment standard minus net income Georgia Lesser of (standard of need minus net income) or family maximum Hawaii Standard of assistance minus net income Idaho Lesser of (work incentive payment minus net earnings) or maximum benefit 6 Illinois Payment standard minus net income Indiana Net income standard minus net income Iowa Payment standard minus net income Kansas Budgetary standard minus net income Kentucky Lesser of (55% of (standard of need minus net income)) or maximum benefit Louisiana Flat grant amount minus net income Maine Lesser of (standard of need minus net income) or maximum benefit Maryland Allowable payment minus net income Massachusetts Need standard and payment standard minus net income Michigan Payment standard minus net income Minnesota Lesser of (family wage level minus net income) or transitional standard 7 Mississippi Lesser of (60% of (need standard and payment standard minus net income)) or maximum benefit Missouri Payment standard minus net income Montana Payment standard minus net income Nebraska (Lesser of (standard of need minus net earnings) or payment standard) minus unearned income Nevada Payment allowance minus net income New Hampshire Payment standard minus net income New Jersey Maximum benefit payment schedule minus net income New Mexico Standard of need minus net income minus budgetary adjustment New York Need standard minus net income North Carolina 50% of (need standard minus net income) North Dakota Standard of need minus net income Ohio Payment standard minus net income Oklahoma Payment standard minus net income Oregon All, except JOBS Plus Payment standard minus net income JOBS Plus Cash value of the unit’s SNAP and TANF benefits minus a measure of net earnings 8 Pennsylvania Family size allowance minus net income Rhode Island Cash assistance monthly standard minus net income South Carolina 33.72% of (need standard minus net income) South Dakota Payment standard minus net income Tennessee Lesser of (consolidated need standard minus net income) or maximum benefit 9 Table II.A.2. Benefit Determination Policies, July 2017 116 Welfare Rules Databook: State TANF Policies as of July 2017 State Benefit equals 1 Texas Maximum grant minus net income Utah Maximum financial assistance payment minus net income Vermont Payment standard minus net income Virginia All, except VIEW Lesser of (standard of assistance minus net income) or maximum benefit VIEW Lesser of (federal poverty guideline minus net income) or (standard of assistance minus gross unearned income) or maximum benefit 10 Washington Lesser of (payment standard minus net income) or maximum benefit 11 West Virginia Payment standard minus net income Wisconsin W-2T Benefit amount (flat grant amount) CSJ Benefit amount (flat grant amount) TEMP No benefit 12 UE No benefit 13 Wyoming Maximum benefit minus net income Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 For information on the benefit standards, see table II.A.3. 2 Two-parent units in which both parents are able to perform gainful activities will have their benefits reduced by 50 percent for July, August, and September. 7 This formula is for units with earned income and no unearned income. The calculation for recipients without earned income is the transitional standard minus net income. The calculation for recipients with earned and unearned income is the following: if the family wage level minus earned income is less than the transitional standard, the benefit equals the family wage level minus total net income (earned and unearned income). If the family wage level minus earned income is greater than the transitional standard, the benefit equals the transitional standard minus unearned income. The MFIP payment standards include the state’s SNAP allotment. MFIP recipients’ cash and SNAP grants are computed with the same calculation. A flat amount (based on family size) for the SNAP allotment is subtracted from the benefit amount, and any remaining amount is provided to the unit in cash. To calculate the TANF grant amount without SNAP, the food portion of the MFIP standard is subtracted from the benefit. 3 The benefit is equal to the maximum payment level for the unit size if the unit’s gross income is less than $446. If the gross income is greater than $446, the benefit will be reduced to 50 percent of the maximum payment level. Arkansas refers to this policy as the gross income trigger. 4 In households with a stepparent not receiving assistance, the unit receives the lesser of (1) maximum aid payment (for family size including the stepparent) minus net income or (2) the maximum aid payment for family size excluding the stepparent. 5 For each capped child, $50 is added to the payment standard. The capped children are not included in the family size used to determine eligibility and benefit amounts. 6 This formula is for units with earned income; for these units, all unearned income is disregarded. For units without earned income, the benefit equals the maximum benefit minus the unearned income. Table II.A.2. Benefit Determination Policies, July 2017 Welfare Rules Databook: State TANF Policies as of July 2017 117 13 Units in the unsubsidized employment component receive wages from an unsubsidized job and are ineligible for a cash benefit; they may still receive support services if they are otherwise eligible. 8 If a unit’s combined JOBS Plus wages are less than the combined value of the unit’s combined determined TANF and SNAP benefits, then the state will provide a wage supplement benefit to make up the difference. The benefit is equal to the maximum of (A-C or B-D), where A equals the full benefit equivalent, the sum of TANF and SNAP benefits, calculated using normal rules. B equals the minimum benefit equivalent, A minus the difference between the income\/payment standard for the unit including the JOBS Plus participant and adjusted income\/payment standard for the unit not including the JOBS Plus participant. C equals the JOBS Plus participant’s wage multiplied by his or her available hours to work (all scheduled hours, regardless of whether the participant worked those hours) minus $90 and the amount of garnishments withheld. Added to the remainder is child support received. D equals the JOBS Plus participant’s wage multiplied by his or her actual worked hours minus $90 and the amount of garnishments withheld. Added to the remainder is child support received. 9 When a caretaker marries while receiving assistance, he or she can choose to exclude the new spouse from the assistance unit for up to three months. If the new spouse is not included in the unit, none of his or her income or resources is counted for eligibility or benefit computation purposes. If the caretaker chooses to include the new spouse in the unit, all of his or her income is counted for eligibility and benefit computation calculations. After three months, the new spouse becomes a mandatory unit member and all of his or her income is considered in determining eligibility and benefit computation. 11 For child-only units with nonparent caretakers, the payment standard is reduced when the net income of the caretaker’s family exceeds 200 percent of the Federal Poverty Guidelines, as follows: the payment standard is 80 percent of the full payment standard if net income is between 201 and 225 percent of poverty; it is 60 percent of the full payment standard if net income is between 226 and 250 percent of poverty; it is 40 percent of the full payment standard if net income is between 251 and 275 percent of poverty; and it is 20 percent of the full payment standard if net income is between 276 and 300 percent of poverty. 10 The benefit for two-parent units equals the lesser of (150 percent of the Federal Poverty Guidelines minus net income), or (standard of assistance minus gross unearned income), or maximum benefit. For all units, the maximum benefit only limits benefits for units with six or more members. 12 TEMP participants receive wages from the TEMP employer; they do not receive cash payments from TANF. The employer can also receive a subsidy that covers all or a portion of costs attributed to the employment of the participant. 118 Welfare Rules Databook: State TANF Policies as of July 2017 State name for standard Amount for family of three State name for standard Amount for family of three Alabama Payment Standard $215 n.a. n.a. Alaska Need Standard $1,594 Maximum Payment $923 Arizona Payment Benefit $347 n.a. n.a. Arkansas Maximum Payment Level $204 n.a. n.a. California Non-exempt 2 Maximum Aid Payment (MAP) $714 n.a. n.a. Exempt 2 Maximum Aid Payment (MAP) $799 n.a. n.a. Colorado 2 Grant Standard $462 n.a. n.a. Connecticut 2 Payment Standard $597 n.a. n.a. Delaware Standard of Need $1,260 Payment Standard $338 D.C. Payment Level $508 n.a. n.a. Florida Payment Standard $303 n.a. n.a. Georgia Standard of Need $424 Family Maximum $280 Hawaii Standard of Assistance $610 3 n.a. n.a. Idaho Work Incentive Payment $389 Maximum Benefit $309 Illinois 2 Payment Standard $432 n.a. n.a. Indiana Net Income Standard $288 n.a. n.a. Iowa Payment Standard $426 n.a. n.a. Kansas 2 Budgetary Standards $429 n.a. n.a. Kentucky Standard of Need $526 Maximum Benefit $262 Louisiana Flat Grant Amount $240 n.a. n.a. Maine Standard of Need $620 Maximum Benefit $485 Maryland Allowable Payment $648 n.a. n.a. Massachusetts Exempt Need Standard and Payment Standard $633 n.a. n.a. Non-Exempt Need Standard and Payment Standard $618 n.a. n.a. Michigan Payment Standard $492 n.a. n.a. Minnesota Transitional Standard 4 $991 ($532) 5 n.a. n.a. Family Wage Level 6 $1,090 Transitional Standard $991 ($532) 5 Mississippi Need Standard and Payment Standard $368 Maximum Benefit $170 Missouri Payment Standard $292 n.a. n.a. Montana Payment Standard $588 n.a. n.a. Nebraska Standard of Need $816 Payment Standard $450 Nevada Payment Allowance $383 n.a. n.a. New Hampshire Payment Standard $1,021 n.a. n.a. New Jersey Maximum Benefit Payment Schedule $424 7 n.a. n.a. New Mexico Standard of Need $447 n.a. n.a. Budgetary Adjustment $38 n.a. n.a. New York 2 Need Standard $789 n.a. n.a. North Carolina Need Standard $544 n.a. n.a. Table II.A.3. Standards for Determining Benefits, July 2017 1 State Payment standard: Statutory maximum benefit: Welfare Rules Databook: State TANF Policies as of July 2017 119 State name for standard Amount for family of three State name for standard Amount for family of three North Dakota Standard of Need $486 8 n.a. n.a. Ohio Payment Standard $474 n.a. n.a. Oklahoma Payment Standard $292 n.a. n.a. Oregon All, except JOBS Plus Payment Standard $506 n.a. n.a. JOBS Plus Payment Standard and SNAP 9 n.a. n.a. n.a. Pennsylvania 2 Family Size Allowance $403 n.a. n.a. Rhode Island Cash Assistance Monthly Standard $554 n.a. n.a. South Carolina Need Standard $840 n.a. n.a. South Dakota Payment Standard $615 n.a. n.a. Tennessee Consolidated Need Standard $1,066 Maximum Benefit $185 10 Texas Maximum Grant $286 n.a. n.a. Utah Maximum Financial Assistance Payment $498 n.a. n.a. Vermont 2 Payment Standard $640 n.a. n.a. Virginia 2 All, except VIEW Standard of Assistance $419 Maximum Benefit $419 11 VIEW Standard of Assistance $419 Maximum Benefit $419 11 2016 Federal Poverty Guideline $1,680 Maximum Benefit $419 11 Washington 12 Payment Standard $521 Maximum Benefit $521 West Virginia Payment Standard $340 n.a. n.a. Wisconsin W-2T Benefit Amount $608 n.a. n.a. CSJ Benefit Amount 653 13 n.a. n.a. TEMP 14 n.a. n.a. n.a. n.a. UE 15 n.a. n.a. n.a. n.a. Wyoming Maximum Benefit $660 n.a. n.a. 1 This table provides information on the standards only. For information on how the standards are used, see table II.A.2. The amounts in the table are based on the following assumptions about the assistance unit: there is one adult and two children; the children are not subject to a family cap; the head of the unit is not pregnant; and the unit has no special needs, pays for shelter, and lives in the most populated area of the state. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table II.A.3. Standards for Determining Benefits, July 2017 1 State Payment standard: Statutory maximum benefit: 2 Dollar amounts used to calculate benefits vary within the state, either by county or by region of the state. Calculations are based on the dollar amount that applies to the majority of the state. See the Welfare Rules Database for more information. 3 This applies to units that have received assistance for at least two months in a lifetime. For units receiving their first and second months of benefits, the standard of assistance for a family of three is $763. 4 This standard applies to recipients without earnings. 120 Welfare Rules Databook: State TANF Policies as of July 2017 8 North Dakota adds $50 to the Standard of Need for units with sole responsibility for all housing costs. The additional $50, which North Dakota considers to be a special item of need, is included in the amount shown in this table. 9 If a unit’s combined JOBS Plus wages are less than the combined value of the unit’s combined determined TANF and SNAP benefits, then the state will provide a wage supplement benefit to make up the difference. The wage supplement benefit is equal to the maximum of (A-C or B-D), where A equals the full benefit equivalent, which is the sum of TANF and SNAP benefits calculated using normal rules. B equals the minimum benefit equivalent, which is the full benefit equivalent (A) minus the difference between adjusted income\/payment standard for the unit including the JOBS Plus participant and adjusted income\/payment standard for the unit not including the JOBS Plus participant. C equals the JOBS Plus participant’s wage multiplied by his or her available hours (all scheduled hours, regardless of whether the participant worked those hours), minus $90, minus child support received, and minus any garnishment withheld. D equals the JOBS Plus participant’s wage times hours actually worked, minus $90, minus child support received, and minus any garnishment withheld. 6 This standard applies to recipients with any earned income. 5 Minnesota’s transitional standard includes the SNAP allotment for each unit size. The SNAP and cash benefit are computed together for welfare recipients. The SNAP allotment is a flat benefit, based on family size, which is subtracted from the benefit amount. Any remaining benefit is given to the unit as cash. The value of the TANF benefit only is in parentheses. 7 An additional $150 is added to the benefit amount for exempt units receiving assistance beyond the 60th month. 14 Recipients in TEMP receive wages from the TEMP employer; they do not receive cash payments from TANF. 15 Recipients participating in unsubsidized employment receive wages and do not receive TANF cash assistance. 13 Community Service Jobs participants can receive a prorated payment if they are working 40 hours a week in a combination of unsubsidized employment, work training, and educational activities. Education may never fulfill more than 10 hours of the requirement. Participants working 20 to 29 hours a week in an unsubsidized job may receive $218, those working 15 to 19 hours receive $327, and individuals working 10 to 14 hours a week receive $435. Individuals who are working fewer than nine hours are eligible for the full payment. Individuals employed full time are not considered to have barriers to work and are therefore ineligible for payments. 10 For units where the caretaker is over age 65, disabled, caring full time for a disabled family member, or excluded from the assistance unit, the maximum benefit for a family of three is $232. 11 The maximum benefit only applies to payments for units with six or more members. 12 The maximum benefit only applies to payments for units with nine or more members. Welfare Rules Databook: State TANF Policies as of July 2017 121 State 2 3 4 5 6 Alabama $190 $215 $245 $275 $305 Alaska $821 $923 $1,025 $1,127 $1,229 Arizona $220 $278 $335 $392 $449 Arkansas $162 $204 $247 $286 $331 California 2 Non-exempt $577 $714 $852 $968 $1,087 Exempt $645 $799 $949 $1,080 $1,214 Colorado 2 $364 $462 $561 $665 $767 Connecticut 2 $487 $597 $701 $803 $908 Delaware $270 $338 $407 $475 $544 D.C. $398 $508 $621 $716 $842 Florida $241 $303 $364 $426 $487 Georgia $235 $280 $330 $378 $410 Hawaii 3 $485 $610 $735 $860 $985 Idaho $309 $309 $309 $309 $309 Illinois 2 $318 $432 $474 $555 $623 Indiana $229 $288 $346 $405 $463 Iowa $361 $426 $495 $548 $610 Kansas 2 $352 $429 $497 $558 $619 Kentucky $225 $262 $325 $361 $398 Louisiana $188 $240 $284 $327 $366 Maine $363 $485 $611 $733 $856 Maryland $513 $648 $776 $900 $989 Massachusetts Exempt $531 $633 $731 $832 $936 Non-exempt $518 $618 $713 $812 $912 Michigan $403 $492 $597 $694 $828 Minnesota $437 $532 $621 $697 $773 Mississippi $146 $170 $194 $218 $242 Missouri $234 $292 $342 $388 $431 Montana $467 $588 $709 $830 $950 Nebraska $378 $450 $522 $594 $666 Nevada $318 $383 $448 $513 $578 New Hampshire $812 $1,021 $1,230 $1,439 $1,648 New Jersey $322 $424 $488 $552 $616 New Mexico $327 $409 $493 $576 $659 New York 2 $574 $789 $951 $1,119 $1,238 North Carolina $236 $272 $297 $324 $349 North Dakota 4 $385 $486 $583 $682 $781 Ohio $387 $474 $584 $684 $761 Oklahoma $225 $292 $361 $422 $483 Oregon $432 $506 $621 $721 $833 Pennsylvania 2 $316 $403 $497 $589 $670 Rhode Island $449 $554 $634 $714 $794 South Carolina $224 $283 $341 $399 $457 South Dakota $550 $615 $680 $744 $809 Tennessee $142 $185 $226 $264 $305 Texas $248 $286 $344 $382 $439 Utah $399 $498 $583 $663 $731 Table II.A.4. Maximum Monthly Benefit for a Family with No Income, July 2017 1 Family Size 122 Welfare Rules Databook: State TANF Policies as of July 2017 State 2 3 4 5 6 Vermont 5 $535 $640 $726 $816 $878 Virginia 2 $347 $419 $486 $578 $614 Washington $420 $521 $613 $706 $802 West Virginia $301 $340 $384 $420 $460 Wisconsin W-2T $608 $608 $608 $608 $608 CSJ $653 $653 $653 $653 $653 TEMP 6 n.a. n.a. n.a. n.a. n.a. UE 7 n.a. n.a. n.a. n.a. n.a. Wyoming $621 $660 $660 $701 $701 Mean 8 $374 $454 $531 $607 $679 Median 8 $361 $432 $497 $589 $659 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Maximum benefits are calculated assuming that the unit contains one adult and no children subject to a family cap, has no special needs, pays for shelter, and lives in the most populated area of the state. 8 In states for which this table shows more than one component, the amounts used to compute the means and medians are the amounts for the first component that is listed, which is the one affecting the largest portion of the caseload. 2 Dollar amount used to calculate benefit varies within the state, either by county or by region of the state. Calculations are based on the dollar amount that applies to the majority of the state. See the Welfare Rules Database for more information. 5 Dollar amount used to calculate benefit varies within the state, either by county or by region of the state. Calculations are based on the dollar amount that applies to the majority of the state. See the Welfare Rules Database for more information. These amounts apply to units paying $400 per month for housing. Benefits are lower if housing expenses are lower. For units with higher expenses, the benefit may be higher by up to $90 times the ratio of the payment standard to need standard. 6 Recipients in TEMP receive wages from the TEMP employer; they do not receive cash payments from TANF. The wage is determined by the employer, but is at least the federal minimum wage; the agency subsidizes a portion of the wages. Most TEMP jobs are 40 hours per week. 7 Recipients participating in unsubsidized employment receive wages and do not receive TANF cash assistance. 4 The amounts shown include an additional $50 payment for units that pay their own shelter costs. 3 The benefits shown here apply to units that have received assistance for three or more months in a lifetime. Table II.A.4. Maximum Monthly Benefit for a Family with No Income, July 2017 1 Family Size Welfare Rules Databook: State TANF Policies as of July 2017 123 State SSI Immigrant status Alabama $165 $165 $165 Alaska $452 $452 $452 Arizona $164 $164 $164 Arkansas $81 $81 $81 California $355 $355 $355 Colorado $128 $128 $128 Connecticut $366 $366 $366 Delaware $201 $201 $201 D.C. $320 $320 $320 Florida $180 $180 $180 Georgia $155 $155 $155 Hawaii $450 $450 $450 Idaho $309 n.a. 2 $309 Illinois $117 $117 $117 Indiana $139 $139 $139 Iowa $183 $183 $183 Kansas $186 $186 $186 Kentucky $186 $186 $186 Louisiana $122 $122 $122 Maine $138 $138 $138 Maryland $293 $293 $293 Massachusetts $428 $428 $428 Michigan $158 $158 $306 Minnesota $250 $250 $250 Mississippi $110 $110 $110 Missouri $136 $136 $136 Montana $347 $347 $347 Nebraska $306 $306 $306 Nevada $417 $253 $253 New Hampshire $603 n.a. 2 $603 New Jersey $162 $162 $162 New Mexico $244 $244 $244 New York $460 $460 $460 North Carolina $181 $181 $181 North Dakota $166 $166 $166 Ohio $283 $283 $283 Oklahoma $104 $104 $104 Oregon $228 $228 $228 Pennsylvania $205 $205 $205 Rhode Island $327 $327 $327 South Carolina $166 $166 $166 South Dakota $379 $278 $278 Tennessee $140 $140 $140 Texas $98 $98 $98 Utah $288 $288 $288 Vermont $434 $434 $434 Table II.A.5. Maximum Monthly TANF Benefit for a Child-Only Unit with One Child, No Income, July 2017 Child lives with a nonparent caretaker 1 Child lives with a parent excluded from the unit due to: 124 Welfare Rules Databook: State TANF Policies as of July 2017 State SSI Immigrant status Virginia $260 $260 $260 Washington $332 3 $332 $332 West Virginia $262 $262 $262 Wisconsin $232 4 n.a. 5 n.a. 6 Wyoming $376 $376 $376 Mean 7 $250 $237 $248 Median 7 $228 $203 $236 7 The calculations only include one value per state (the policy affecting the most populous area). Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This column provides benefit amounts for units with one child and with a nonparent caretaker who has never been included in the unit. The figures shown are for child-only benefits from TANF unless otherwise stated. In some states, nonparent caretakers are eligible for higher benefits under a kinship care program in some cases (e.g., when a child would otherwise be in foster care). 2 Parents receiving SSI are also eligible for TANF benefits. 4 Families with a nonparent caretaker are potentially eligible for a kinship care payment of $232 per month per child. 5 Children whose parents or caretakers are SSI recipients are covered by a component of the TANF program called Caretaker Supplement (CTS). CTS benefits are $250 per child per month for the first child and $150 per child per month for each additional child. (CTS families do not receive any other type of TANF cash payment.) To be eligible, a child’s sole custodial parent must receive SSI or the child must live with both custodial parents and both receive SSI. Children must still meet asset and income requirements. 6 Families with a parent excluded due to immigrant status are not eligible for TANF or components of TANF. 3 For child-only units with nonparent caretakers, the benefit is reduced when the net income of the caretaker’s family exceeds 200 percent of the Federal Poverty Guidelines, as follows: the benefit is 80 percent of the maximum benefit if net income is between 201 and 225 percent of poverty; it is 60 percent of the maximum benefit if net income is between 226 and 250 percent of poverty; it is 40 percent of the maximum benefit if net income is between 251 and 275 percent of poverty; and it is 20 percent of the maximum benefit if net income is between 276 and 300 percent of poverty. Table II.A.5. Maximum Monthly TANF Benefit for a Child-Only Unit with One Child, No Income, July 2017 Child lives with a nonparent caretaker 1 Child lives with a parent excluded from the unit due to: Welfare Rules Databook: State TANF Policies as of July 2017 125 Paper check Electronic Benefit Transfer (EBT) Electronic Payment Card (EPC) Electronic Funds Transfer (EFT) Alabama No Yes No No No additional restrictions Alaska No Yes No Yes Bars Arizona No Yes No No Cannabis shops Arkansas No Yes No No No additional restrictions California 3 Yes Yes No Yes Bars, Tobacco retailers, Firearms retailers, Spas\/Massage parlors, Cruise ships, Bail bond agencies, Psychic readers, Cannabis shops, Establishments outside of the state Colorado 3 Yes 4 Yes No Yes Bars, Firearms retailers, Cannabis shops Connecticut 3 No Yes No Yes n.a. Delaware 5 Yes No No No n.a. D.C. No Yes No No No additional restrictions Florida No Yes No Yes No additional restrictions Georgia No Yes Yes Yes Bars, Tobacco retailers, Firearms retailers, Tattoo\/Piercing parlors, Spas\/Massage parlors, Cruise ships, Bail bond agencies, Psychic readers Hawaii No Yes No Yes No additional restrictions Idaho No Yes No Yes Tobacco retailers, Tattoo\/Piercing parlors, Bail bond agencies, Any establishment where minors under age 18 are not permitted Illinois Yes Yes No Yes No additional restrictions Indiana No Yes No No Bars, Firearms retailers Iowa 6 Yes No Yes Yes No additional restrictions Kansas 6 Yes Yes No No Tobacco retailers, Tattoo\/Piercing parlors, Spas\/Massage parlors, Cruise ships, Bail bond agencies, Psychic readers, Jewelry stores, Nail salons, Lingerie shops, Vapor cigarette stores, Video arcades, Movie theaters, Swimming pools, Theme parks, Any establishments where minors under age 18 are not permitted, Establishments outside of the state Kentucky Yes Yes No Yes No additional restrictions Table II.A.6. Benefit Issuance Policies, July 2017 State Forms of Benefit Issuance 1 Locations where EBT\/EPC\/EFT use is prohibited, in addition to those prohibited by federal law 2 126 Welfare Rules Databook: State TANF Policies as of July 2017 Paper check Electronic Benefit Transfer (EBT) Electronic Payment Card (EPC) Electronic Funds Transfer (EFT) Louisiana No Yes No No Bars, Tobacco retailers, Tattoo\/Piercing parlors, Spas\/Massage parlors, Cruise ships, Bail bond agencies, Jewelry stores, Amusement attractions, Psychic readers Maine 3 Yes Yes No Yes Bars, Tobacco retailers, Firearms retailers, Tattoo\/Piercing parlors, Cruise ships, Lotteries conducted by the State, Vacation or travel services 7 Maryland No Yes No No No additional restrictions Massachusetts Yes Yes No Yes Tobacco retailers, Firearms retailers, Tattoo\/Piercing parlors, Cruise ships, Bail bond agencies, Rent-to-own stores, Cash transmittal agencies to foreign countries 8 Michigan No Yes No No Tobacco retailers, Tattoo\/Piercing parlors, Spas\/Massage parlors, Cruise ships, Bail bond agencies 9 Minnesota Yes Yes No Yes Tobacco retailers, Tattoo\/Piercing parlors Mississippi No No Yes No No additional restrictions Missouri Yes Yes No Yes Tobacco retailers, Tattoo\/Piercing parlors, Any establishment where minors under age 18 are not permitted Montana Yes Yes No Yes No additional restrictions Nebraska No No Yes Yes No additional restrictions Nevada Yes Yes No Yes No additional restrictions New Hampshire No Yes No Yes Tobacco retailers, Tattoo\/Piercing parlors, Locations where alcohol comprises 50% or more of visible inventory, Cannabis shops New Jersey No Yes No No No additional restrictions New Mexico No Yes No No No additional restrictions New York No Yes No No No additional restrictions North Carolina No Yes No Yes No additional restrictions North Dakota No No Yes No No additional restrictions Ohio 6 No No Yes Yes No additional restrictions Oklahoma 3 No No No Yes Tobacco retailers Oregon Yes Yes No Yes Cannabis shops Pennsylvania Yes Yes No No No additional restrictions Table II.A.6. Benefit Issuance Policies, July 2017 State Forms of Benefit Issuance 1 Locations where EBT\/EPC\/EFT use is prohibited, in addition to those prohibited by federal law 2 Welfare Rules Databook: State TANF Policies as of July 2017 127 Paper check Electronic Benefit Transfer (EBT) Electronic Payment Card (EPC) Electronic Funds Transfer (EFT) Rhode Island No Yes No No No additional restrictions South Carolina Yes No Yes Yes No additional restrictions South Dakota Yes No Yes Yes No additional restrictions Tennessee No Yes No No Tobacco retailers 10 Texas 6 No Yes No No Bars, Tobacco retailers, Firearms retailers, Tattoo\/Piercing parlors, Spas\/Massage parlors, Cruise ships, Bail bond agencies, Locations that receive more than 10% of gross revenue from entertainment 11 Utah No Yes No No No additional restrictions Vermont 3 Yes Yes No Yes No additional restrictions Virginia Yes Yes No Yes Tobacco retailers, Tattoo\/Piercing parlors Washington Yes Yes No Yes Bars, Tattoo\/Piercing parlors, Any establishment where minors under age 18 are not permitted West Virginia No Yes No Yes No additional restrictions Wisconsin Yes No Yes Yes No additional restrictions Wyoming Yes No No No n.a. 9 Michigan also prohibits the use of TANF cash assistance to purchase lottery tickets; the assistance unit agrees not to use TANF cash assistance to purchase lottery tickets during the initial contract agreement. 8 If a store sells a majority of prohibited items (even if not a location where EBT use is prohibited), the Department of Temporary Assistance takes steps to block the location. 1 In states that offer more than one benefit delivery method, policies may vary for whether the participant is able to choose the method for delivery or whether it is determined by the state. An EBT card is a state-issued debit card; an EPC card is a debit card issued and maintained by a third-party brand; an EFT is an electronic direct deposit into a recipient’s checking account. 2 Federal law prohibits the use of Electronic Benefit Transfer (EBT) cards and Electronic Payment Cards (EPC) in any liquor store, casino\/gambling establishment, and adult-oriented businesses. This column displays any additional restrictions that the state imposes on locations where EBT\/EPC transactions can be made, including ATMs located in these establishments. 3 This state may also issue benefits as direct payments to vendors. 4 If continued misuse occurs, the cash portion of the recipient’s EBT card is disabled for one month, requiring the county to notify the participant of additional options for receipt of payment (direct deposit or county warrant). 5 Recipient may request voluntary protective payee as a basic delivery method. 6 This state may also issue benefits through a pay warrant or voucher. 7 EBT and EPC use is prohibited at retail establishments where 50 percent or more of gross revenue is derived from the sale of liquor, and for any transportation service that is incurred for an extended period of recreation or any other costs incurred for such purpose. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table II.A.6. Benefit Issuance Policies, July 2017 State Forms of Benefit Issuance 1 Locations where EBT\/EPC\/EFT use is prohibited, in addition to those prohibited by federal law 2 128 Welfare Rules Databook: State TANF Policies as of July 2017 10 ATM use is permitted in tobacco stores. 11 Texas only allows the use of TANF cash assistance to purchase goods and services deemed essential for the welfare of the family, which include: food, clothing, housing, utilities, furniture, transportation, telephone, laundry, medical supplies not paid by Medicaid, and incidentals such as household equipment, supplies, and recreation for children. Any locations not selling those goods and services, while not explicitly prohibited, are implicitly prohibited. Welfare Rules Databook: State TANF Policies as of July 2017 129 III. Requirements The tables in this chapter of the Databook describe requirements that individual members of an assistance unit must meet to become or remain eligible for assistance, as of July 2017. To receive benefits, most states require recipients to negotiate and sign contracts detailing what is required of individuals within the unit. These requirements vary considerably by state but can include conditions for dependent children as well as conditions for the adult head of the household. All states’ TANF programs include work requirements, as well as sanctions if work requirements are not met. A. Once determined eligible, what must a recipient family do to maintain benefits? States place various types of requirements on members of the assistance unit\u2014including not only work requirements but also other types of behavioral requirements. For example, dependent children may be required to maintain a minimum grade point average in school, and adults may be required to keep current with immunizations for their children. Fulfilling behavioral requirements can be a condition of initial and continuing eligibility. Behavioral Requirements and Bonuses (Table III.A.1) Behavioral requirements affect adults and minor parents in many states. Requirements imposed on children may include school, immunization, health screening, and other health requirements. Table III.A.1 captures whether the following requirements and bonuses are imposed for either initial or continuing eligibility: \u25aa School policies may require children to attend school or to achieve at least a minimum grade point average. This Databook addresses only the school requirements imposed on dependent children, not those that may be imposed on minor parents. (Although not included in this report, information about school requirements for minor parents is available in the WRD.) \u25aa States may also offer a school bonus, which provides financial incentives for assistance units whose children meet specific attendance or achievement standards. 130 Welfare Rules Databook: State TANF Policies as of July 2017 \u25aa Immunization policies require parents\/caretakers to have their children immunized. Sometimes, proof of immunization for children is not required if they are enrolled in school because the school systems impose their own immunization requirements. Additionally, the immunization requirement may be waived if the immunization requirement might risk a child’s health or violate a family’s religious beliefs. \u25aa Health screening requirements may include regular checkups for both children and adults, although the requirements usually apply only to children. Other health requirements primarily involve compliance with the rules of the Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) program. Requirements are only included in this table if (1) they are either explicitly mentioned in the state’s TANF manual as a requirement for cash assistance or recipients must sign a contract including one of the requirements to receive benefits and (2) a sanction results from noncompliance. The dollar amounts of bonuses and the dollar amounts of sanctions for not complying with requirements are not included in the table but are available in the WRD. Key policies from 2017 include: \u25aa Thirty-seven states have some sort of school requirements recipients must follow to remain eligible. \u25aa Twenty-five states have immunization requirements for recipients. \u25aa Five states require health screenings for recipients. B. What work activities are required? Under the TANF block grant, the federal government requires states to (1) meet the annual work participation rates determined by the federal government and (2) ensure that every recipient is working (as defined by the state) as soon as the state determines he or she is able or after 24 months of benefit receipt, whichever is earlier.35 States that do not meet the federal 35 The work participation rate is the percentage of the state TANF caseload with a work-eligible individual that must be participating in work activities in order to meet federal requirements. In 2017, federal rules required that among a state’s cases that include a work-eligible individual, 50 percent participate in work activities an average of 30 hours a week (an average of 20 hours per week if a single-parent family with a child under 6); two-parent families (with two work-eligible individuals) were required to participate at a rate of 90 percent for an average of 35 hours a week. For more information on the work participation rate, see the FFY 2014 and 2015 TANF Report to Congress available at https:\/\/www.acf.hhs.gov\/sites\/default\/files\/ofa\/12th_annual_tanf_report_to_congress_final.pdf. Welfare Rules Databook: State TANF Policies as of July 2017 131 https:\/\/www.acf.hhs.gov\/sites\/default\/files\/ofa\/12th_annual_tanf_report_to_congress_final.pdf requirements may be sanctioned financially. Within the context of the federal policies, states determine who is exempt from activities requirements, what activities are possible for non- exempt recipients, and what sanctions are imposed on individuals who do not comply with requirements.36 Work-Related Activity Exemptions for Single-Parent Head of Unit (Table III.B.1) States may, but are not required to, exempt certain individuals or groups from participating in work-related activities.37 Table III.B.1 describes each state’s rules for exempting a single-parent head of an assistance unit from work-related requirements. The table includes exemptions for individuals who are working a specified number of hours in an unsubsidized job, are ill or incapacitated, are caring for an ill or incapacitated person, are elderly, are in a specified month of pregnancy, or are caring for a child under a specified age. Policies for 2017 include: \u25aa Thirty states exempt single-parent unit heads from work requirements if they are ill or incapacitated. \u25aa Nineteen states exempt single-parent unit heads from work requirements if they are 60 years or older, one state (New Jersey) exempts single-parent heads if they are 62 years or older, and six states exempt single-parent heads if they are 65 years or older. \u25aa Eight states exempt single-parent unit heads from work requirements during some portion of a pregnancy. \u25aa Four states (Colorado, Idaho, Montana, and New Mexico) do not allow any of the work- related activity exemptions shown in the table. The exemptions shown in this table are the most common, but this list is not exhaustive. For other exemption criteria, see the WRD. Also, some states will consider some of these criteria as good cause for noncompliance, even if they do not provide an explicit exemption in these cases. 36 The Deficit Reduction Act of 2005, which reauthorized the TANF program, substantially changed federal work- related policies. For more information about the Deficit Reduction Act of 2005, see the Reauthorization of TANF Final Rule, February 5, 2008, https:\/\/www.acf.hhs.gov\/sites\/default\/files\/ofa\/tanf_final_rule.pdf. 37 The denominator for the work participation rate calculation is established at the federal level. It excludes single parents of a child under 12 months old, recipients sanctioned for refusing to meet work requirements under certain situations, and parents needed in the home to care for a family member with a disability. Further, a single parent may only be excluded from the participation rate calculation under these circumstances for a maximum of 12 months over the assistance unit’s lifetime. 132 Welfare Rules Databook: State TANF Policies as of July 2017 https:\/\/www.acf.hhs.gov\/sites\/default\/files\/ofa\/tanf_final_rule.pdf Related tables: See Table L6 for information about the exemptions for a parent caring for a young child for selected years from 1996 through 2017. Work-Related Activity Requirements for Single-Parent Head of Unit (Table III.B.2) Work programs vary widely from state to state based on several factors, including who must work, how much work is required, and what activities are considered work. Table III.B.2 provides a general overview of state activity requirements. The table describes when the recipient must begin participating, allowable activities the recipient could participate in, and how many hours the recipient must participate each week, including what share of those hours can be spent in education and training programs. Not all assistance units have the same work requirements. For simplicity, this table only includes the activities requirements for units headed by a single-parent 20 years old or older with children at least 6 years of age. Work activity requirements for other units may be found in the WRD. Policies for 2017 include: \u25aa Thirty-six states require single-parent unit heads to immediately meet work requirements upon benefit receipt. \u25aa Thirty-eight states require single-parent unit heads to work a minimum of 30 hours per week. This table should be interpreted as providing an overview of states’ work-related activity policies rather than a full picture of those policies. In particular, caseworker manuals (which are the primary source documents for the WRD) do not generally indicate the likelihood that a recipient will be assigned to one activity or another. Thus, two states could have the same potential activities but have very different policies for how often different activities are assigned in practice. Alternatively, one state might include a potential activity not listed in another state’s list but in practice rarely assign anyone to that activity. Despite these limitations, the table provides a starting point for understanding the range of work-related requirements across states. Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit (Table III.B.3) If adults required to participate in activities do not comply with the requirements, the state can sanction the unit. States have discretion in defining what constitutes noncompliance and the consequences for noncompliance. Typically, if a recipient does not participate in his or her assigned activities for the specified number of hours, he or she is not complying and could be Welfare Rules Databook: State TANF Policies as of July 2017 133 sanctioned. A sanction generally results in the removal of the noncompliant individual from the unit for benefit computation, a percentage reduction in the entire unit’s benefit, a full benefit sanction, or complete case closure. A full benefit sanction results in the unit losing its entire benefit for some period, whereas a complete case closure often requires the applicant to reapply after the sanction period. Often states increase the severity of the sanction based on the number of times or the amount of time the individual is noncompliant. Table III.B.3 describes sanction policies for failing to comply with work requirements. The table provides both the initial sanction (for the first instance of noncompliance) and the most severe sanction (after multiple instances of noncompliance). For both the initial and most severe sanctions, the table describes the amount of the reduction in benefits and the duration of the sanction. When the sanction is described as adult portion of the benefit, the state re- computes benefits using an assistance unit size that excludes the noncompliant adult. (If the adult has any income, some or all of it is deemed available to the children to prevent an increase in benefit.) When the sanction is instead described as pro rata portion of the benefit, the state reduces the benefit by one-half in the case of a two-person unit with a noncompliant member, by one-third in the case of a three-person unit with a noncompliant member, and so on. Policy highlights from 2017 include: \u25aa Twelve states reduce the TANF benefit by a fixed percentage for the first case of noncompliance with work requirements. Eight states reduce the TANF benefit by removing the adult portion of the benefit for the first case of noncompliance with work requirements. Washington reduces the TANF benefit by the adult portion or 40 percent, whichever is greater. \u25aa Thirty states close the TANF case for the most severe sanction of noncompliance with work requirements. The WRD includes more details on sanctions, including any sanctions that occur between the initial and most severe sanctions. Related table: See table L7 for information about the most severe sanction for selected years from 1996 through 2017. 134 Welfare Rules Databook: State TANF Policies as of July 2017 Work-Related Activity Requirements for Parents Outside the Unit and Nonparent Caretakers (Table III.B.4) Parents and caretakers who are not included in the assistance unit are generally not required to engage in work-related activities. However, in some cases, adults who are not included in the assistance unit are still subject to work-related activity requirements, with variations in policy across states and by the reason that the adult is not in the unit. Nonparent caretakers who are in the assistance unit are generally required to participate in the same way as parents, but these policies vary across the states. Table III.B.4 shows the work-related activity requirements for parents who are not in the assistance unit due to immigrant status or due to time limits. The table also shows the policies for nonparent caretakers who are not in the assistance unit and for nonparent caretakers who are in the assistance unit. Key policies for 2017 include: \u25aa Thirty-six states do not require parents outside the assistance unit due to immigrant status to participate in work requirements. Participation is required in 12 states and optional in 3 states. \u25aa Among the four states in which a child-only unit may be created due to a family reaching a time limit, two states (Indiana and Oregon) require parents outside the assistance unit due to time limits to participate in work requirements, and one state (Texas) offers parents outside the assistance unit due to time limits the option to participate in work requirements. \u25aa Forty-seven states do not require nonparent caretakers outside the assistance unit to participate in work requirements; their participation is required in one state and optional in two states. \u25aa All of the 47 states that ever include a nonparent caretaker in the assistance unit require those caretakers to participate in work requirements. Welfare Rules Databook: State TANF Policies as of July 2017 135 State School requirements 1 School bonuses 2 Immunization requirements 3 Health screening requirements 4 Alabama No No No No Alaska No No No No Arizona Yes No Yes No Arkansas Yes No Yes 5 No California Yes Yes 6 Yes 5 No Colorado Yes Yes 7 No No Connecticut No No No No Delaware Yes Yes Yes No D.C. Yes No No No Florida Yes No Yes 5 No Georgia Yes No Yes No Hawaii No No No No Idaho Yes No Yes 5 No Illinois Yes No No No Indiana Yes No Yes No Iowa No No No No Kansas Yes No No No Kentucky Yes Yes No No Louisiana Yes No Yes No Maine No No Yes No Maryland Yes No Yes Yes Massachusetts Yes No Yes 8 No Michigan Yes No Yes 9 No Minnesota No No No No Mississippi Yes No Yes 10 No Missouri No No No No Montana No No No 11 No Nebraska Yes No No No Nevada Yes No Yes 5 No New Hampshire Yes No No No New Jersey Yes No Yes No New Mexico Yes No Yes No New York Yes No No No North Carolina Yes No Yes 5 Yes North Dakota Yes Yes No No Ohio No Yes 12 No No Oklahoma Yes Yes Yes 5 No Oregon No No No No Pennsylvania No No No No Rhode Island No No No No South Carolina Yes No Yes 13 No South Dakota Yes No Yes No Tennessee Yes No Yes 5 Yes Table III.A.1. Behavioral Requirements and Bonuses, July 2017 136 Welfare Rules Databook: State TANF Policies as of July 2017 State School requirements 1 School bonuses 2 Immunization requirements 3 Health screening requirements 4 Texas Yes No Yes Yes Utah Yes Yes 14 No No Vermont No Yes 15 No No Virginia Yes No Yes 16 No Washington Yes No No No West Virginia Yes No Yes Yes Wisconsin Yes No No No Wyoming Yes No No No Total states with policy 37 9 25 5 11 Assistance units must cooperate with the third party liability unit and maintain cost effective health insurance as a condition of eligibility. 3 Immunization requirements include information on standard immunizations for children. A requirement is coded \”Yes\” only if the state explicitly mentions it as a requirement for cash assistance or if it is included as a requirement in the recipient’s contract and noncompliance results in a sanction. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 School requirements apply only to requirements for dependent children, not minor parents. A requirement is coded \”Yes\” if the state explicitly mentions it as a requirement for cash assistance or if it is included as a requirement in the recipient’s contract and noncompliance results in a sanction. These policies may require children to attend school or to achieve a minimum grade point average; they may also require parents to be involved in their children’s education in some way. The requirements may apply only to a subset of children; for additional detail, see the Welfare Rules Database. 2 This column captures financial incentives for assistance units whose children meet specific attendance or achievement standards. Unless otherwise noted, school bonuses apply to both dependent children and minor parents. 8 Children are exempt from showing proof of required immunization if they are enrolled in school. 9 The immunization requirement may be waived if the procedures would risk the child’s health or violate the family’s religious beliefs. Additionally, children under 2 months of age may also be exempt. 10 Children are exempt from showing proof of required immunization if they are enrolled in school. School-age children not attending school, being home-schooled, or attending a non-public school must provide proof of current immunizations. 4 Health screening requirements include information on regular checkups for both children and adults, although the requirements usually apply only to children. A requirement is coded \”Yes\” only if the state explicitly mentions it as a requirement for cash assistance or if it is included as a requirement in the recipient’s contract and noncompliance results in a sanction. 5 The immunization requirement may be waived if the procedures would risk the child’s health or violate the family’s religious beliefs. 6 School bonuses apply to pregnant or teen parents under age 19. 7 School bonuses only apply to teen parents aged 16 through 19. These policies refer to Denver County. Table III.A.1. Behavioral Requirements and Bonuses, July 2017 16 The immunization requirement may be waived if the procedures would risk the child’s health or violate the family’s religious beliefs. Additionally, children are exempt from showing proof of required immunization if they are enrolled in school or a licensed day care provider. 15 School bonuses only apply to teen parents aged 16 through 19. School bonuses are allowed at case manager discretion. 12 School bonuses are issued under the Learning, Earning, and Parenting (LEAP) program for teen custodial parents and pregnant teens under age 19 who have not obtained a high school diploma or equivalent. 13 Children are exempt from showing proof of immunization if they are enrolled in school or a licensed day care provider. 14 Minor parents are potentially eligible for a school bonus if they are enrolled in the WIOA Youth program. Welfare Rules Databook: State TANF Policies as of July 2017 137 State Exempt if working in unsubsidized job for X hours per week Exempt if ill or incapacitated Exempt if caring for an ill or incapacitated person Exempt if age X or older (years) Exempt if in month X or later of pregnancy Exempt if caring for a child under age X (months) Alabama No Yes 2 Yes 60 No 3 12 Alaska No Yes 4 Yes 5 No No 12 6 Arizona 40 7 No No No No No Arkansas 8 No Yes Yes 60 7 3 9 California No Yes Yes 60 No 3 24 10 Colorado 11 No No 12 No 12 No No No 13 Connecticut No Yes Yes 60 No 14 12 15 Delaware No Yes 16 Yes 17 No No 12 18 D.C. 30 19 Yes 20 Yes 60 4 12 Florida No No Yes No No 3 21 Georgia No No Yes No No 12 22 Hawaii No No 23 Yes 24 65 No 6 18 Idaho No No No No No No Illinois No Yes Yes 60 No 25 12 26 Indiana No Yes 27 Yes 60 No 3 Iowa No No No No No 3 28 Kansas No No Yes No No 3 Kentucky 30 No 12 Yes 29 60 No 12 18 Louisiana No Yes Yes 60 No No Maine No Yes 30 Yes 31 No No 12 18 Maryland 32 30 33 Yes 34 Yes No No 12 35 Massachusetts Exempt 36 n.a. Yes 37 Yes 37 60 37 5 37 24 37 Non-exempt 30 38 n.a. 39 n.a. 39 n.a. 40 n.a. 41 n.a. 42 Michigan 40 33 Yes 43 Yes 65 No 3 2 44 Minnesota No No 45 No No 46 No 3 12 Mississippi No Yes 47 Yes 60 No 48 12 18 Table III.B.1. Work-Related Activity Exemptions for Single-Parent Head of Unit, July 2017 1 138 Welfare Rules Databook: State TANF Policies as of July 2017 State Exempt if working in unsubsidized job for X hours per week Exempt if ill or incapacitated Exempt if caring for an ill or incapacitated person Exempt if age X or older (years) Exempt if in month X or later of pregnancy Exempt if caring for a child under age X (months) Missouri No Yes Yes 60 No 3 Montana No No 49 No No No No 50 Nebraska Time-limited assistance No n.a. 39 n.a. 39 n.a. 51 n.a. 52 n.a. 53 Non-time-limited assistance 54 n.a. Yes 55 Yes 55 65 55 8 55 3 56 Nevada 30 57 No Yes 60 58 No 59 12 22 New Hampshire NHEP No Yes 60 Yes n.a. 40 No 61 12 62 FAP 54 n.a. Yes 63 n.a. 60 64 n.a. n.a. New Jersey No Yes Yes 62 7 65 3 New Mexico 66 No No No No No No New York No Yes 67 Yes 60 9 3 68 North Carolina No No 69 Yes No No 12 18 North Dakota No No 12 No 12 65 No 70 2 Ohio 30 No Yes 71 No No 12 Oklahoma No Yes Yes No No 4 18 Oregon No No Yes 60 9 6 Pennsylvania No Yes Yes No No 12 18 Rhode Island No Yes 72 Yes No 7 73 12 South Carolina All, except CARES 30 n.a. 74 Yes No No 75 12 76 CARES 54 n.a. Yes 77 n.a. n.a. n.a. n.a. South Dakota No No 78 No 79 No No 3 Tennessee No Yes Yes 65 No 3 12 Texas No Yes 80 Yes 60 81 No 3 12 Utah No No Yes 71 No No No 82 Table III.B.1. Work-Related Activity Exemptions for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 139 State Exempt if working in unsubsidized job for X hours per week Exempt if ill or incapacitated Exempt if caring for an ill or incapacitated person Exempt if age X or older (years) Exempt if in month X or later of pregnancy Exempt if caring for a child under age X (months) Vermont No Yes Yes 60 No 24 83 Virginia All, except VIEW 54 n.a. Yes 84 Yes 85 60 85 n.a. 12 86 VIEW No n.a. 39 n.a. 39 n.a. 39 No 87 n.a. 39 Washington No Yes Yes No 88 No 12 89 West Virginia No Yes Yes No No 3 No 90 Wisconsin No No 12 No 91 No No 2 Wyoming No No No 65 No 3 18 Table III.B.1. Work-Related Activity Exemptions for Single-Parent Head of Unit, July 2017 1 5 If the incapacitated person is an adult, the caretaker is exempt only if he or she is related to the person and providing 24-hour care. 4 While an incapacitated person may be fully or partially exempt from work activities, he or she is still required to develop a Family Self-Sufficiency Plan outlining the self-sufficiency activities in which he or she will participate. Source: The Urban Institute’s Welfare Rules Database, funded by HHS\/ACF and HHS\/ASPE. 1 This table refers to single-parent unit heads over 21 years old. In some cases, recipients meeting certain criteria are placed in alternative components; see appendix 1 for more information on components. 2 An incapacitated person may be fully or partially exempt from work requirements. 3 A pregnant woman may qualify for an exemption if the pregnancy is disabling and prohibits her from participating in work or training programs. 6 The exemption is limited to 12 cumulative months in the recipient’s lifetime. While the caretaker is exempt from work activities requirements, the recipient will still be required to develop a Family Self-Sufficiency Plan outlining the self-sufficiency activities in which he or she will participate. 7 To be exempt, the job must pay at least the minimum wage and be expected to last at least 30 days. 8 Counties are given discretion to grant temporary exempt status when the recipient does not have adequate support services, such as transportation or child care. A review of the exemptions occurs at least every six months. SSI and SSDI recipients and individuals ineligible because of immigration status are exempt. 9 A parent loses this exemption after retaining it for 12 cumulative months. Months in which the parent is exempt because child care is unavailable for a child less than 12 months old also count toward the 12-month lifetime limit. 10 Months spent as a primary care provider for one child, birth to 23 months old, are exempt. For two-parent families, each parent has the option to receive the exemption but only one exemption can be granted at a time. An individual may only be eligible for this exemption one time. An exemption for care of an additional child six months of age or under is also available. 140 Welfare Rules Databook: State TANF Policies as of July 2017 25 Pregnant women are not exempt, but they are considered to have a barrier to full-time employment for the six weeks before the due date and the 12 weeks after birth. The amount of participation required is determined case by case. 26 Recipients may be required to attend classes or other activities. 12 The state does not consider these groups technically exempt, but they may meet the state’s criteria for good cause for noncompliance or deferral. 13 A recipient caring for a child under the age of six who is unable to obtain child care may be exempt from work activities or sanctions. 19 The hours apply to recipients with children age six or older. Recipients with children under six years old are required to work 20 hours in order to be exempt. 14 A pregnant woman may qualify for an exemption if the pregnancy is disabling and prohibits her from participating in work or training programs. She may also be exempt from work requirements for six weeks postpartum. 15 The exemption applies only if the child is not subject to a family cap. 16 Disabled parents and caretakers are referred to the Transitional Work Program (TWP) to determine employability and, if appropriate, develop an employability plan. 17 To qualify for this exemption, the ill or incapacitated individual must be a direct relative, either a child or spouse, and living in the home. 18 The exemption is limited to 12 cumulative months in the recipient’s lifetime. 27 Individuals who are eligible for Medicaid for the disabled or blind and individuals receiving Social Security Disability Insurance (SSDI) or other assistance due to disability are exempt. 11 Counties have the option to vary some activities exemptions. These policies refer to Denver County. 20 Individuals are screened during assessment for physical or mental incapacities that interfere with their ability to participate in countable work activities. After a medical evaluation confirms incapacity, the client is moved from TANF to POWER. POWER requires limited work activities and has no time limits. 21 Recipients may be required to attend classes or other activities. 22 Single custodial parents can have one three-month exemption per child up to a cumulative total of 12 months. 23 Although not exempt, the state recognizes that recipients who are ill or incapacitated may not be able to participate fully. The amount of participation required from each recipient is determined on a case-by-case basis by a medical board. The recipient is also subject to sanctions for noncompliance with required activities. 24 To qualify for this exemption, the ill or incapacitated individual must be a direct relative, such as a child or spouse, and living in the home. 28 Although recipients are not exempt, they may be absent from work without sanction if they have a newborn child. Absence from activities is determined using the standards of the Family and Medical Leave Act of 1993. The maximum time available for one parent is 12 work weeks during any 12-month period. 29 A parent providing constant care for a disabled family member for more than eight consecutive weeks is exempt, provided the disabled person lives in the home and does not attend school or participate in another activity full time. A parent caring for disabled family members for less than eight consecutive weeks has good cause for non-compliance but is not technically exempt. 30 To be exempt, an ill or incapacitated person must receive SSI or the head of household must be caring for a spouse who is receiving SSI. Welfare Rules Databook: State TANF Policies as of July 2017 141 32 Exemptions do not apply to individuals who have received 24 cumulative months of federal cash assistance. The only exemption that may be available after 24 months is to single parents who are caring for a child under age six and who are unable to obtain appropriate child care. 33 To be exempt, the job must pay minimum wage or higher. 34 Exemptions are limited to 12 months unless the individual has applied for SSI and the SSI application is approved, pending, or in appeal. 35 The exemption is limited to 12 cumulative months in the recipient’s lifetime. A recipient caring for a child under the age of six who is unable to obtain child care may be exempt from work activities or sanctions. 40 Recipients age 60 or older are placed in an alternative component. 31 The need for the recipient to care for the disabled family member must be verified at least every six months by an acceptable medical or mental health source. The recipient is not considered to be personally providing care if the individual is a full-time student. 38 This exemption applies to parents whose youngest child is mandatory school age or older. If the youngest child is between two years old and mandatory full-time school age, 20 hours a week are required. Parents with children less than two years old are placed in the exempt component and do not have work requirements. 39 Individuals with this characteristic are placed in an alternative component. 36 Recipients who are in the Exempt component are automatically exempt from activities requirements. 37 Individuals with this characteristic are placed in the exempt component. All individuals in this component are exempt from activities requirements. 41 Women who are pregnant and within 120 days of their expected due date are placed in an alternative component. 42 Individuals caring for a child under two years old are placed in an alternative component. 43 Individuals with a mental or physical illness, limitation, or incapacity that is expected to last more than 90 days and that prevents participation in employment activities are required to undergo a medical review. After the medical review, the individual may be determined disabled and required to apply for SSI or RSDI, work ready with limitations and referred to the work program, or work ready and referred to the work program. 44 Women are exempt from activities requirements for two months after giving birth when the newborn is in the home or for postpartum recovery when the newborn is not in the home. 45 Persons meeting this criterion will not be required to meet full participation requirements if the participant’s condition significantly restricts his or her employment opportunities or ability to maintain suitable employment for at least 20 hours per week. The number of hours and the types of activities required will be determined on a case-by-case basis. 46 While not explicitly exempt, a person meeting this criteria will not be required to meet full participation requirements if the participant’s condition significantly restricts his or her range of employment opportunities or his or her ability to maintain suitable employment for at least 20 hours per week. The number of hours and the types of activities required will be determined on a case-by-case basis. 47 If determined eligible for vocational rehabilitation, ill and incapacitated clients can be assigned to a work program activity. 48 A pregnant woman may be exempt from work requirements for six weeks postpartum. A pregnant woman may qualify for an exemption if the pregnancy is disabling and prohibits her from participating in work or training programs. 142 Welfare Rules Databook: State TANF Policies as of July 2017 54 Recipients in this component are automatically exempt from activities requirements. 55 Individuals with this characteristic are placed in the non-time-limited component. All individuals in this component are exempt from activities requirements. 51 Recipients age 65 and older are placed in an alternative component. 52 Pregnant women will be placed in an alternative component the month before the month of their due date. 53 Recipients caring for children under three months old are placed in an alternative component. 49 A person declared totally incapacitated by a qualified medical professional and who is unable to engage in any participation activities may not be required to participate. 50 Individuals caring for a newborn child may count this activity toward participation requirements for three full months following the child’s birth, up to a total of 12 months in an individual’s lifetime. Individuals can choose not to participate in other work activities during this time. 66 There are no activities exemptions. Participants may request a limited work participation status reducing their required hours to no less than one hour per week. Individuals who have extraordinary circumstances may be granted a complete reduction of required hours. 67 A person may be exempt up to three months if supported by medical documentation. 68 The exemption may last for no more than 12 months in a recipient’s lifetime and it may not last for more than three months for any one child unless the social services official makes a determination to extend the exemption for up to the total 12 months. 56 Recipients caring for a child under 3 months old are exempt and would be non-time-limited for the period of time they qualify for this exemption. This exemption can be extended under special circumstances. 57 Recipients working 30 hours a week or more are exempt only from job training requirements. A single custodial parent with a child under age six must be employed a minimum of 20 hours a week to be exempt from job training requirements. 63 Recipients who are permanently ill or incapacitated are placed in the Family Assistance Program component. All individuals in this component are exempt from activities requirements. 60 Recipients who are temporarily ill or incapacitated are exempt from work requirements for a six-month period with medical verification. Clients may apply for an additional six-month exemption, but will be required to apply for SSI or SSDI. 58 A needy relative caregiver other than a parent is exempt at 60 years of age or older (parents are not exempt). 59 A woman is exempt only when determined unable to work by a physician. The exemption applies only to job training requirements. 61 A pregnant woman with a verified medical condition that prevents participation would follow the same exemption protocol as other clients with a temporary incapacity. 62 The exemption is limited to 12 cumulative months in the recipient’s lifetime. If the recipient has exhausted this 12-month limit or has received 39 or more months of assistance prior to the birth of an additional child, the unit must participate in NHEP when the youngest child turns 12 weeks old. 64 Individuals with this characteristic are placed in the Family Assistance Program component. All individuals in this component are exempt from activities requirements. 65 Prior to the third trimester, recipients may be exempt if a physician certifies that a medical reason exists. Welfare Rules Databook: State TANF Policies as of July 2017 143 86 The exemption is limited to 12 cumulative months in the recipient’s lifetime. The caretaker can be exempt for a maximum of six additional weeks if he or she has another child after the limit expires. Recipients caring for a child subject to a family cap are only exempt while the child is under six weeks old. Individuals with this characteristic are placed in the All, except VIEW component. All individuals in this component are exempt from activities requirements. 83 The exemption is limited to 24 months in a recipient’s lifetime. In addition, recipients may be exempt for 13 weeks following the birth of each additional child. 84 To be fully exempt, a recipient must obtain a note from a doctor or other certified professional indicating that he or she is unable to participate in at least 20 hours of activities a week. If the individual can participate in at least 20 hours of activities a week, he or she must participate in work activities that take into consideration his or her limitations. Individuals with this characteristic are placed in the All, except VIEW component. All individuals in this component are exempt from activities requirements. 85 Individuals with this characteristic are placed in the All, except VIEW component. All individuals in this component are exempt from activities requirements. 82 If parents are unable to find care for a child under age 13, the state may exempt the parents from activity requirements while it provides assistance in finding child care. 69 A healthcare provider may limit the activities and participation hours for a disabled individual to less than 30 per week. 81 Single grandparents who are age 50 or older and caring for a child under age three are exempt. 79 The state does not consider these groups technically exempt, but they may meet the state’s criteria for good cause for noncompliance or deferral if the condition is expected to last at least 30 days and the ill or incapacitated individual is a family member living in the home. 73 An applicant in her third trimester or a recipient in her third trimester who has documentation she cannot work may be exempt. 74 Individuals with incapacities expected to last 90 days or longer are placed in the CARES program. 75 Although technically not an exemption, an individual in the seventh month of pregnancy has legal cause for not meeting participation requirements. 76 A parent personally providing care for his or her child under age one will be expected to participate in the work program but cannot be sanctioned for failure to do so. 70 An individual may be granted good cause from participation in work-related activities due to medical reasons, beginning with the sixth month of pregnancy through the month of birth. Once born, the caretaker is exempt from participation for two months. However, the individual is subject to 12 cumulative months in the recipient’s lifetime. 71 To qualify for this exemption, the ill or incapacitated individual must be a family member living in the home full time and the disability must last a minimum of 30 days. 77 Individuals with this characteristic are placed in the CARES component. All individuals in this component are exempt from activities requirements. 78 The state does not consider these groups technically exempt, but they may meet the state’s criteria for good cause for noncompliance or deferral if the condition is expected to last at least 30 days. 80 To qualify for this exemption, the incapacity must be expected to last a minimum of 180 days. A temporary illness qualifies as good cause for noncompliance. 72 Recipients of SSI, RSDI\/SSDI, or other disability benefits that have the same standards of disability as defined by the Social Security Administration, or those determined likely to be eligible for SSI or SSDI benefits by a DHS approved provider or DHS designated staff, may be exempt. 144 Welfare Rules Databook: State TANF Policies as of July 2017 91 The state does not consider these groups technically exempt; however, they may meet the state’s criteria for good cause for noncompliance. In addition, an individual’s participation requirement may be to care for an ill or incapacitated child, spouse, or co-parent who is living in the home. 87 A recipient in her third trimester of pregnancy may have the initial job search or job readiness assignment waived and be assigned to another activity. 88 Nonparent relative caretakers over the age of 55 are exempt. 89 The exemption is limited to 12 cumulative months in the recipient’s lifetime. Participants may be required to participate in mental health or chemical dependency treatment if it is indicated in their assessment. 90 The state does not consider these groups technically exempt; however, they may meet the state’s criteria for good cause for noncompliance or deferral. This may be taken any time while the child is under 12 months for up to 12 months in the recipient’s lifetime. In addition, all mothers are eligible for a 12-week postpartum exemption good cause period following the birth of any additional child. Welfare Rules Databook: State TANF Policies as of July 2017 145 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Alabama Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, self-employment, child care provision for others, community service 35 4 10 5 Alaska Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, life skills training, community service 30 No limit Arizona Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, work experience programs Case-by-case No limit Arkansas Immediately Basic or remedial education, high school\/GED, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 4 10 California 6 After assessment Basic or remedial education, high school\/GED, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, counseling, community service, substance abuse treatment 30 4 No limit 7 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 146 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Colorado 8 After assessment Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 9 n.a. Connecticut Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, child care provision for others, counseling, community service Case-by-case No limit Delaware All, except TWP 10 Upon application 11 Basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, on-the- job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, child care provision for others, counseling, life skills training, community service, substance abuse treatment, post- secondary education, job development and placement 30 4 10 12 TWP Upon referral by DSS Basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, on-the- job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, child care provision for others, counseling, life skills training, community service, substance abuse treatment, post- secondary education, job development and placement 13 No minimum 14 n.a. 15 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 147 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 D.C. Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, self-employment, child care provision for others, community service 30 4 10 Florida Immediately Basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, on-the- job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others 30 10 Georgia Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 16 10 Hawaii Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, community service, substance abuse treatment 30 4 No limit Idaho Immediately Basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, community service 17 Number of work days in a month multiplied by 6 hours 18 No limit Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 148 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Illinois 19 31 days after application Postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service, substance abuse treatment 30 No limit 20 Indiana Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, counseling, life skills training, community service 30 4 10 21 Iowa Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 22 No limit Kansas Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service 30 23 10 21 Kentucky Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 10 21 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 149 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Louisiana 19 Immediately Postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, community service 30 4 n.a. 24 Maine Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, self-employment, child care provision for others, counseling, life skills training, community service 30 4 10 25 Maryland Upon application Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, community service, substance abuse treatment 30 26 16 27 Massachusetts Exempt 28 n.a. n.a. n.a. n.a. Non-exempt After 2 months of receiving assistance 29 Basic or remedial education, high school\/HiSET, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, child care provision for others, counseling, community service, grandparent providing care for child in home, substance abuse treatment 30 30 No limit 31 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 150 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Michigan 19 Upon application Basic or remedial education, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, community service 30 4 10 Minnesota Immediately Basic or remedial education, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others, counseling, life skills training, community service 130 hours per month No limit Mississippi 19 Within 24 months of receiving assistance Basic or remedial education, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, life skills training, community service 40 No limit Missouri Within 24 months of receiving assistance 32 Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, counseling 30 4 No limit Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 151 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Montana All, except PAS Upon application 33 Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, job search, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, community service 33 34 10 35 PAS Immediately Basic or remedial education, high school\/GED, postsecondary education 12 school credit hours per semester 36 No limit Nebraska Time-limited assistance Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service, substance abuse treatment 30 4 10 21 Non-time-limited assistance Immediately Job skills training, job readiness activities, life skills training 30 n.a. Nevada Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service 30 4 10 21 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 152 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 New Hampshire NHEP Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training 30 37 10 38 FAP 28 n.a. n.a. n.a. n.a. New Jersey Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 39 35 No limit New Mexico NMW Within 3 months of receiving assistance Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, child care provision for others, counseling, life skills training 40 34 41 14 EWP Within 2 months after application English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, community service 20 No limit Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 153 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 New York 19 Upon application 42 English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others, community service 30 43 10 North Carolina Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service, substance abuse treatment 30 4 No limit 44 North Dakota Immediately Basic or remedial education, high school\/GED, postsecondary education, job skills training, job readiness activities, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, child care provision for others, counseling, community service 30 4 No limit Ohio Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 10 Oklahoma Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, community service 30 No limit Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 154 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Oregon All, except JOBS Plus Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training Case-by-case No limit JOBS Plus 45 n.a. Job search, on-the-job training, work supplement\/subsidized job Case-by-case n.a. Pennsylvania Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, community service, substance abuse treatment 30 4 10 46 Rhode Island Upon application Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 4 10 47 South Carolina All, except CARES Immediately Job readiness activities, job search, life skills training 48 30 4 n.a. CARES Immediately Postsecondary education, job readiness activities, on-the-job training, counseling, life skills training, community service 49 Case-by-case No limit Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 155 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 South Dakota 19 Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, community service, substance abuse treatment 30 4 10 Tennessee Upon signing agreement Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service, substance abuse treatment 30 10 21 Texas Upon signing agreement Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, community service 30 4 10 50 Utah Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, life skills training, community service, substance abuse treatment 30 4 10 51 Vermont Immediately Basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, on-the- job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, child care provision for others, life skills training, community service 30 52 10 53 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 156 Welfare Rules Databook: State TANF Policies as of July 2017 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Virginia All, except VIEW 28 n.a. n.a. n.a. n.a. VIEW Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, counseling, community service, substance abuse treatment 35 54 15 Washington Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job development and placement, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment, counseling, life skills training, community service 32 4 No limit West Virginia Immediately Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self- employment, child care provision for others, counseling, life skills training, community service, substance abuse treatment 30 4 10 25 Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 157 State Timing of requirement relative to benefit receipt Allowable activities listed 2 Minimum hour requirement (weekly unless noted) Limit on education hours that count toward work hour requirement 3 Wisconsin W-2T After assessment Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job development and placement, on-the-job training, counseling, life skills training, community service, substance abuse treatment Case-by-case 12 CSJ After assessment Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, job readiness activities, job search, on-the-job training, life skills training, community service Case-by-case 10 TEMP 10 After assessment Basic or remedial education, high school\/GED, English as a second language, postsecondary education, job skills training, on-the-job training, work supplement\/subsidized job 25 55 No limit UE After assessment Unsubsidized employment 56 No minimum 57 n.a. Wyoming Immediately High school\/GED, job skills training, job readiness activities, job search, on-the-job training, unsubsidized employment, work supplement\/subsidized job, work experience programs, self-employment 30 4 10 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 This table covers work-related activity requirements for recipients, while table I.A.2 covers mandatory job search requirements for diversion programs at application. The table contains the activity requirements for single-parent recipients 20 years old or older with children at least 6 years of age, in cases when the parents are not exempt from work-related activity requirements. (See table III.B.1 for work-related activity exemptions.) 2 Possible activities include the following: (a) Job-related activities include job skills training, job readiness activities, and job search; (b) Education and training (E&T) activities include basic or remedial education, high school\/GED, English as a second language, postsecondary education (including vocational training), and on-the-job training; (c) Employment activities include unsubsidized job, work supplement\/subsidized job, work experience program (CWEP and\/or AWEP), self-employment, and community service; (d) Other allowable activities include child care provision for others, counseling, life skills training, and substance abuse treatment. (Some states may accept the TASC in addition to or in place of the GED.) Table III.B.2. Work-Related Activity Requirements for Single-Parent Head of Unit, July 2017 1 158 Welfare Rules Databook: State TANF Policies as of July 2017 4 Recipients with children under 6 years old are only required to work 20 hours. 3 If education is not an approved activity, \”n.a.\” is shown. Policies regarding training activities are not captured here; see the Welfare Rules Database for more information on training policies. 16 Recipients who are able to work 40 hours per week are required to do so. Recipients with children under 6 years old are only required to work 20 hours. 5 In cases where the caseworker determines that educational activities are necessary for a recipient to overcome barriers to employment, the limit on the number of hours that may be spent in education may be waived. 6 The list of potential activities includes all those allowed by the state. Counties choose whether to include all of the potential activities or a subset. All other activities requirements policies are statewide. 7 California allows clients to spend a total of 36 months in an education and training activity with no hourly limit; 24 months while on the Welfare-to-Work 24-Month Time Clock, and an additional 12 months aligned with federal requirements. After 36 months education can only be counted as a non-core activity. 8 Counties have the option to vary their activity requirements. These policies refer to Denver County. 10 This applies to non-exempt recipients who are unemployed. 11 Participation in required activities is required for two weeks prior to receipt of benefits. 13 Recipients in the transitional work program must develop an individualized transitional work plan with their case manager and comply with the activities requirements and deadlines established in the plan. 14 While TWP participants do not have to participate in activities for a specific number of hours per week, they are expected to adhere to their employability plan, which may include a minimum hour requirement. 12 Those who opt into the employment and training program defined by Senate Bill 101-1999 do not have a limit on their education hours as long as they are also participating in work or a work-related activity. 15 TWP participants do not have to participate in educational activities or meet a minimum hour requirement. However, their employability plan may include an activity requirement and a limitation on the number of education hours that count toward the requirement. 9 Recipients with children under 6 years old are only required to work 20 hours. Single parents under age 20 are also only required to work 20 hours. 17 Recipients with children under the age of 12 weeks are only required to participate in life skills training. 18 Single parents who have children older than 12 weeks but younger than 6 months are only required to work 20 hours per month. 19 The state distinguishes between those with and without a high school diploma or GED. The requirements shown here are for TANF recipients who have obtained at least a high school diploma or GED. 20 This applies to post-secondary education only. 21 There is no limit on post-secondary education. Welfare Rules Databook: State TANF Policies as of July 2017 159 22 Participation must be either equivalent to the level of commitment required for full-time employment or deemed significant enough to move the recipient toward full-time employment. Recipients with children under 6 years old are only required to work 20 hours. 23 Single parents with children under age 6 are required to work a minimum of 20 hours per week. 24 Post-secondary education may be included if applicable, but does not count towards the required hours. 25 The number of hours that may be spent in education and training is not capped for parents of children under 6 years old. 26 The state requires recipients to work 40 hours, but recipients caring for a child age 6 or older are not sanctioned if working at least 30 hours, and recipients caring for a child under 6 years old are not sanctioned if working at least 20 hours. 27 Educational activities hours are counted after 24 hours are met with core activities. 29 Non-exempt adults are expected to use this 60-day period for job search prior to the imposition of work program requirements. 30 Recipients with children under 6 years old are only required to work 20 hours. Recipients with children under two years old are placed in the exempt component and do not have work requirements. 31 An education or training activity cannot exceed 24 months. 28 Recipients in this component are not required to participate in work activities. 38 Individuals may count postsecondary education as core activities for 12 months with no limit on the hours per week. After 12 months as a core activity, there is a 10- hour limit. Certain types of basic or remedial education and English as a Second Language (ESL) can count towards the first 20 hours. 32 The requirement is imposed at 24 months or until the state determines the recipient is work ready, whichever is sooner. 33 The unit may request for work-related activity requirements to begin on the first day of the month following the month of application. 34 Recipients with children under 6 years old are only required to work 27 hours. 35 The number of hours that may be spent in education and training is capped at two hours for parents of children under 6 years old. 36 Recipients in this component must be enrolled in at least 12 credit hours per semester and up to a maximum of 30 credit hours per year. 37 A recipient with a child under 6 years old is required to work 20 hours but may be required to work more if he or she is participating in unsubsidized employment, AWEP, or CWEP, does not face substantial barriers, and is meeting participation requirements. 39 Life skills training refers to the TANF Initiative for Parents (TIP), which offers parenting skills assistance to mothers of children under 12 months of age. 40 Education Works program activities are focused on education and training; however, with program approval, participants may also take part in any other activity relevant to their education and pursuant to the New Mexico Works Cash Assistance Program. 41 Recipients with children under 6 years old are only required to work 24 hours. 42 The social services official shall ensure that each parent or caretaker of a dependent child is engaged in work as soon as practicable, but no later than 24 months (whether or not consecutive) from initial receipt of assistance. 43 Recipients can be assigned to work activities for up to 40 hours per week, unless otherwise limited. 160 Welfare Rules Databook: State TANF Policies as of July 2017 44 Postsecondary education only counts toward non-core hours. 45 All recipients in JOBS Plus are working for an employer, receiving actual wages reimbursed by the state. 46 There is no limit on high school or GED. 47 Individuals with reading test scores below third grade level or below sixth grade level, if the individual has very limited or no prior work experience, and individuals with very limited English language skills, may participate in educational activities for 30 hours per week minimum as part of an intensive work readiness program. There is no limit on post-secondary education. 48 Post-secondary education is an allowable activity for those who are not considered job-ready. 56 The allowable activity listed is for those in the CMU placement within the Unsubsidized Employment component. Those in the Case Management Job Ready (CMJ) placement may participate through basic or remedial education, high school\/GED, English as a second language, job skills training, job readiness activities, job search, life skills, while those in the Case Management Follow-up (CMF) may participate through basic or remedial education, high school\/GED, English as a second language, and unsubsidized employment. 57 Those in the CMU and CMF placements within the Unsubsidized Employment component do not have a weekly minimum hour requirement. Those in the CMJ placement have a 30 hour requirement. 49 Recipients experiencing disabilities that prevent full-time participation, but who are able to participate in limited work and training activities, may participate in any cash assistance work program activities for which they qualify even though special accommodations may be needed. The participant’s disability must prevent full participation in these cash assistance work activities for 90 days or longer. 50 Recipients with children under 6 years old must spend all required hours in non-education-related activities. 51 There is no limit on post-secondary education for one year. Recipients with children under 6 years old must spend all required hours in non-education-related activities. 52 Recipients with children under 6 years old are only required to work 20 hours. A participant at least 20 years old who is engaged in at least 25 hours per week of learning activities to obtain a diploma or GED, and who is making satisfactory progress, does not have to engage in other work-related activities for a period of up to six months. This is considered a deferment of work requirements. 55 Custodial parents in TEMP placement have a 25 hour minimum requirement. Noncustodial parents in TEMP are not subject to a minimum requirement. 54 These hours refer to a unit’s collective hour requirement if no one in the unit is employed full time. Recipients employed full time are required to work 30 hours. 53 This does not apply to students who qualify for the education deferment. Welfare Rules Databook: State TANF Policies as of July 2017 161 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Alabama 50% 2 Until compliance or 3 months, whichever comes first 2 Entire benefit 12 months Alaska 40% Until compliance or 4 months Case is closed 3 Must reapply Arizona 25% 1 month Entire benefit Until compliance or 1 month, whichever is longer Arkansas Entire benefit 1 month Case is closed Until in compliance for 2 weeks and must reapply California Adult portion of benefit 4 Until compliance Adult portion of benefit Until compliance Colorado 5 25% 1 month Entire benefit Until compliance or 3 months, whichever is longer Connecticut 25% 3 months Case is closed 3 months and must reapply Delaware All, except TWP Case is closed Until compliance 6 Case is closed Until compliance TWP $50 per month Until compliance Case is closed Until compliance D.C. 20% Until in compliance for 4 weeks Entire benefit Until in compliance for 4 weeks Florida Entire benefit Until compliance or 10 days, whichever is longer Entire benefit 7 Until compliance or 3 months, whichever is longer Georgia 25% 3 months Case is closed 12 months Hawaii Entire benefit Until compliance Entire benefit Until compliance or 3 months, whichever is longer Idaho Entire benefit Until compliance or 1 month, whichever is longer Case is closed Permanent Illinois 50% Until compliance or 3 months, whichever comes first Case is closed Until compliance or 3 months, whichever is longer and must reapply Indiana Case is closed Until compliance or 1 month, whichever is longer Case is closed Permanent Table III.B.3. Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit, July 2017 1 State Initial sanction Most severe sanction 162 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Iowa Entire benefit Until compliance 8 Case is closed Until compliance or 6 months, whichever is longer and must reapply 9 Kansas Entire benefit Until compliance or 3 months, whichever is longer Case is closed 10 years and must reapply Kentucky Pro rata portion of the benefit Until in compliance for 15 days Entire benefit Until compliance Louisiana Case is closed Until compliance or 1 month, whichever is longer Case is closed Until compliance or 3 months, whichever is longer Maine Adult portion of benefit 10 Until compliance or 3 months, whichever comes first Entire benefit Until compliance Maryland Entire benefit Until compliance Entire benefit Until in compliance for 1 month Massachusetts Exempt 11 n.a. n.a. n.a. n.a. Non-exempt 12 None 13 n.a. 13 Entire benefit Until in compliance for 2 weeks Michigan Case is closed 3 months Case is closed Permanent Minnesota 10% Until compliance or 1 month, whichever is longer Case is closed Until compliance or 1 month, whichever is longer Mississippi Entire benefit Until compliance or 2 months, whichever is longer Case is closed Permanent Missouri 50% 10 weeks or until in compliance for 4 consecutive weeks, whichever is shorter 14 Case is closed Until in compliance for 1 week and must reapply Montana All, except PAS Adult portion of benefit 1 month Case is closed 6 months and must reapply PAS Adult portion of benefit 1 month Case is closed 15 6 months and must reapply Nebraska Entire benefit Until compliance or 1 month, whichever is longer Entire benefit Until compliance or 12 months, whichever is longer Table III.B.3. Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit, July 2017 1 State Initial sanction Most severe sanction Welfare Rules Databook: State TANF Policies as of July 2017 163 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Nevada Case is closed Until compliance or 3 months, whichever is longer and must reapply Case is closed Until compliance or 3 months, whichever is longer and must reapply New Hampshire NHEP Adult portion of benefit 16 Until in compliance for 2 weeks or 1 month, whichever is longer Case is closed 17 Until in compliance for 2 weeks FAP 11 n.a. n.a. n.a. n.a. New Jersey Pro rata portion of the benefit 1 month Case is closed 1 month and must reapply New Mexico NMW 25% Until compliance or 1 month, whichever is longer Case is closed 6 months and must reapply EWP None 18 n.a. Case is closed 19 Until compliance New York Pro rata portion of the benefit 20 Until compliance Pro rata portion of the benefit Until compliance or 6 months, whichever is longer 21 North Carolina Case is closed Must reapply Case is closed 3 months and must reapply North Dakota Adult portion of benefit 22 1 month Case is closed 1 month Ohio Entire benefit Until compliance or 1 month, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Oklahoma Entire benefit Until compliance Entire benefit Until compliance Oregon 25% 1 month Case is closed Until compliance or 2 months, whichever is shorter, and must reapply Pennsylvania Adult portion of benefit 1 month and until in compliance for 1 week 23 Entire benefit Permanent Rhode Island Adult portion of benefit 24 3 months or until in compliance for 2 consecutive weeks, whichever is shorter Case is closed 25 Must reapply Table III.B.3. Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit, July 2017 1 State Initial sanction Most severe sanction 164 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) South Carolina All, except CARES Case is closed Until in compliance for 1 month Case is closed Until in compliance for 1 month CARES 11 n.a. n.a. n.a. n.a. South Dakota None 13 n.a. 13 Case is closed Until compliance or 1 month, whichever is longer and must reapply Tennessee Entire benefit 1 month Entire benefit 12 months Texas Entire benefit Until compliance or 1 month, whichever is longer Case is closed Until compliance or 2 months, whichever is longer and must reapply Utah Case is closed 1 month Case is closed 1 month and must reapply 26 Vermont $75 Until in compliance for 2 weeks $150 Until in compliance for 2 weeks Virginia All, except VIEW 11 n.a. n.a. n.a. n.a. VIEW Entire benefit Until compliance or 1 month, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Washington Adult portion of benefit or 40%, whichever is greater Until in compliance for 4 weeks 27 Case is closed Permanent West Virginia Entire benefit 1 month Entire benefit Until compliance or 12 months, whichever is longer Wisconsin W-2T and CSJ $5 multiplied by the hours of nonparticipation Until compliance Case is closed Until compliance TEMP Adult portion of benefit 28 Until compliance 28 Case is closed 29 Permanent 29 UE 11 n.a. n.a. n.a. n.a. Wyoming Entire benefit Until compliance Entire benefit Until compliance Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table III.B.3. Sanction Policies for Noncompliance with Work Requirements for Single-Parent Head of Unit, July 2017 1 State Initial sanction Most severe sanction Welfare Rules Databook: State TANF Policies as of July 2017 165 13 The initial sanction does not reduce benefits. Recipients are given a written warning detailing the consequences of subsequent failures to comply. 11 Recipients in this component are not required to participate in work activities; therefore, they are not subject to sanctions. 3 Case closure follows eight months of non-compliance. 1 \”Adult portion of benefit\” describes the portion of the benefit the sanctioned individual would have received. Because the table only represents sanctions for single- parent units, in all cases the sanctioned individual is an adult. In some cases, recipients in certain component are not required to participate in work activities; therefore, they have no sanctions. See appendix 1 for more information about components. 6 The assistance unit must engage in four consecutive weeks of employment and training activities before full family sanctions are cured. 7 Assistance may still be provided to children under age 16 in the unit; these benefits are issued to a protective payee (after the second and subsequent sanction). 8 A new application for TANF assistance may be required to reinstate eligibility. 9 The sanctioned parent must sign a new family investment agreement and complete 20 hours of eligible education or work activities to become eligible again. 10 Benefits to the sanctioned individual are terminated; however, the sanctioned parent’s income (after disregards listed below) and assets are still included for eligibility and benefit calculation purposes. If the head is sanctioned, the benefit is issued to a protective payee. Disregards include an amount equal to the standard of need for support of non-categorically eligible dependents living in the household with the sanctioned parent, alimony and child support payments to persons outside the household, and payments to dependents of the sanctioned parent who live outside the household. If the unit head is sanctioned, the benefit is issued to a third- party payee. In determining benefit payment, only the income and assets of sanctioned parents are considered. Only the sanctioned stepparent’s income (not assets) is considered. The income and assets of sanctioned individuals who are not parents or stepparents is excluded. 15 The participant loses eligibility for the PAS program and the household loses benefits for up to six months. 16 If the adult is compliant within two weeks, only the adult portion of the benefit is removed (this is referred to as the adjusted payment standard). If the adult is compliant within two to four weeks, the adjusted payment standard is reduced by one-third; if the adult is compliant within five to eight weeks, the adjusted payment standard is reduced by two-thirds. In addition, the case may also be closed if the adult is sanctioned for more than three months in any 12-month period (any portion of a month counts as one month). 17 If a unit accrues three months of sanctions in any 12-month period, the case may be closed. Any portion of a month counts as one full month. 14 The unit is sanctioned for 10 weeks. The sanction ends when the participant completes four consecutive weeks of participation in work activities for an average of 30 hours per week in the 10 week period. 2 This sanction applies to noncompliance that occurs during the first 24 months of assistance. For noncompliance that occurs after the first 24 months, the entire unit is ineligible for benefits for one month. 4 The needs of the sanctioned individual are not included for benefit calculation; however, the individual’s income (after standard disregards) and assets are still included for eligibility and benefit calculation purposes. The individual is sanctioned until compliance. If the head is sanctioned, the benefit is issued to a protective payee. In a two-parent unit, the second parent will also lose his or her benefits unless he or she participates in activities requirements or is exempt from participation. 5 Counties have the option to determine the amount and duration of sanctions. These policies refer to Denver County. 12 An individual who demonstrates good cause will not be sanctioned for noncompliance with work requirements. 166 Welfare Rules Databook: State TANF Policies as of July 2017 24 In a two-person unit, the adult portion is equal to the difference between the benefit a family of three would have received and the benefit the two-person family actually received. For all other family sizes, the adult portion is computed normally, using the difference between the family’s current monthly benefit and the monthly benefit for a family size excluding the sanctioned adult. Benefits are restored on the first of the month following the month in which the unit came into compliance. If no work activity was previously assigned, the sanction ends on the day that the recipient agrees to participate. 18 The individual is placed on probationary status for the following school term to improve his or her grade point average or meet the educational institution’s standards. 19 If the participant is not complying with child support enforcement, school attendance, or reporting requirements in the New Mexico Works Program, the individual’s Education Work Program case is closed and the individual is transitioned back to the New Mexico Works Program. If noncompliance stems from not meeting the educational institution’s standards or having a GPA for the semester below 2.0, the program participant is placed on probation. If standards have not been met or an overall GPA of 2.0 has not been achieved by the end of the probationary period, the department may take action to terminate an individual’s participation in the Education Works Program and transition the individual back to the New Mexico Works Program. 20 The assistance unit’s benefit is reduced pro rata by the sanctioned individual’s share; however, the individual’s income (after standard disregards) and assets are still included for eligibility and benefit calculation purposes. 21 This policy applies to individuals who do not reside in a city with a population of one million or more individuals. For individuals who reside in a city of one million or more, the length of the sanction is until compliance with employment requirements, as assigned by the local district. 22 The needs of the individual are not included for benefit calculation; however, the individual’s income (after standard disregards) and assets are still included for eligibility and benefit calculation purposes. A sanction penalty runs from the effective date of the sanction through the last day of that month. 23 The sanction applies for a minimum of 30 days and until the adult demonstrates and maintains compliance for one week. After 90 days, all cash benefits are closed until compliance is maintained for one week. 25 If a person is penalized and then becomes exempt, the benefits will be restored in the first full month following the month in which the state received documentation of the exemption. 28 Recipients in the Trial Employment Match Program component are not subject to hourly reductions because they are paid wages directly by the employer. The initial sanction for an unplanned and unexcused absence by a recipient is a decrease in wages as determined by their employer. 29 Recipients in the Trial Employment Match Program component are not subject to hourly reductions because they are paid wages directly by the employer. The TEMP employer and participant work together to allow for planned and excused absences. However, unplanned and unexcused absences by the participant will be reflected by a decrease in wages as determined by the employer. If unplanned and unexcused absences continue, the recipient will be ineligible for benefits in the TEMP program for life but may be eligible to receive benefits in another component. 26 The unit must also complete a two-week trial participation period before it is eligible to receive benefits again. 27 The sanction remains in effect until the individual is compliant for four weeks; after four weeks of compliance, benefits are restored to their pre-sanction level. Welfare Rules Databook: State TANF Policies as of July 2017 167 State Parents outside the assistance unit due to immigrant\/citizenship status Parents not counted in the unit due to time limit 2 Nonparent caretakers who are not in the assistance unit 3 Alabama No requirements n.a. No requirements n.a. Alaska Optional n.a. No requirements Required Arizona No requirements n.a. No requirements Required Arkansas No requirements n.a. No requirements Required California No requirements No requirements No requirements Required Colorado No requirements n.a. No requirements Required Connecticut Required n.a. No requirements Required Delaware No requirements n.a. No requirements Required D.C. No requirements n.a. No requirements Required Florida No requirements n.a. No requirements Required Georgia No requirements n.a. Required Required Hawaii Required n.a. No requirements Required Idaho Required n.a. No requirements Required Illinois No requirements n.a. No requirements Required Indiana No requirements Required 5 No requirements Required Iowa Required 6 n.a. No requirements Required Kansas No requirements n.a. No requirements Required Kentucky No requirements n.a. No requirements Required Louisiana No requirements n.a. No requirements Required Maine No requirements n.a. No requirements Required Maryland No requirements n.a. No requirements Required 7 Massachusetts Required n.a. No requirements Required Michigan Optional n.a. No requirements Required Minnesota No requirements n.a. No requirements Required Mississippi No requirements n.a. No requirements Required Missouri No requirements n.a. No requirements Required Montana No requirements n.a. No requirements Required Nebraska No requirements n.a. No requirements Required Nevada No requirements n.a. No requirements Required New Hampshire Required n.a. No requirements Required New Jersey No requirements n.a. No requirements Required New Mexico No requirements n.a. No requirements Required New York Required 8 n.a. Optional Required 9 North Carolina No requirements n.a. No requirements n.a. North Dakota No requirements n.a. No requirements Required Ohio No requirements n.a. No requirements Required Oklahoma No requirements n.a. Optional Required Oregon Required 10 Required No requirements Required Pennsylvania No requirements n.a. No requirements Required Table III.B.4. Work-Related Activity Requirements for Parents Outside the Unit and Nonparent Caretakers, July 2017 Individuals who are not in the assistance unit 1 Nonparent caretakers who are in the assistance unit 4 168 Welfare Rules Databook: State TANF Policies as of July 2017 State Parents outside the assistance unit due to immigrant\/citizenship status Parents not counted in the unit due to time limit 2 Nonparent caretakers who are not in the assistance unit 3 Rhode Island Required n.a. n.a. Required South Carolina No requirements n.a. No requirements Required South Dakota Required n.a. No requirements n.a. Tennessee No requirements n.a. No requirements Required Texas No requirements Optional No requirements Required Utah Required n.a. No requirements Required Vermont No requirements n.a. No requirements Required Virginia Required n.a. No requirements Required Washington No requirements n.a. No requirements Required West Virginia Optional n.a. No requirements Required Wisconsin No requirements n.a. No requirements n.a. Wyoming No requirements n.a. No requirements Required Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 A coding of \”n.a.\” implies that the described case is not applicable in a given state. For example, if a state’s policy is to always include nonparent caretakers in the assistance unit, the corresponding column would be coded \”n.a.\” because it refers to cases where the nonparent caretaker is excluded from the unit, which cannot exist in that state. An entry of optional means that the state’s policies explicitly allow members of a group to volunteer to participate in work activities, although their participation is not required. Table III.B.4. Work-Related Activity Requirements for Parents Outside the Unit and Nonparent Caretakers, July 2017 Individuals who are not in the assistance unit 1 Nonparent caretakers who are in the assistance unit 4 10 Immigrant parents who are ineligible for TANF but are authorized to work in the U.S. are required to participate in work activities. 2 This column is only relevant in those states that, under some circumstances, exclude a parent from an assistance unit after a time limit is reached but continue to pay benefits to the children. 3 This column refers to those non-parent caretakers who are either prohibited from being included due to their status as a non-parent or because their non-parent status gives them an option of choosing to not be a part of the unit. 4 An n.a. in this column means the state never allows non-parent caretakers to be a part of the assistance unit. 5 Parents who are excluded from the unit due to meeting the time limit under the IMPACT program, Indiana’s employment and training program, must continue to cooperate with the work requirements and meet all other eligibility criteria in order for the assistance unit to continue receiving benefits. 7 Nonparent caretakers are only required to participate if they have children of their own in the unit. 8 A nonexempt parent residing in the same household as a child receiving assistance and who is receiving non-federal assistance may be required to participate in work activities up to 40 hours per week, unless otherwise limited. 9 A nonexempt individual receiving assistance may be required to participate in work activities up to 40 hours per week, unless otherwise limited. 6 Nonqualified aliens are not subject to work-related activity requirements. Welfare Rules Databook: State TANF Policies as of July 2017 169 IV. Ongoing Eligibility The tables in this chapter of the Databook describe key aspects of the rules that affect recipients’ ongoing eligibility as of July 2017. After a family applies for assistance and passes all eligibility tests, its members become recipients and a benefit is calculated. However, the recipients still face eligibility requirements that affect their ability to continue receiving benefits. States may impose income and asset tests on recipients, which generally differ from the initial eligibility tests for applicants. Having an additional child may or may not affect eligibility limits and benefits. States also impose time limits, which reduce or eliminate benefits to recipients based on their accumulated total months of benefit receipt. Additionally, states may provide some transitional cash benefit to families who are leaving TANF. The following four sections describe the requirements that affect ongoing eligibility and transitional assistance. A. What eligibility tests must recipient families pass for continuing eligibility? Like applicants, recipients must pass both nonfinancial and financial tests to remain eligible for assistance each month. The nonfinancial rules generally do not vary for applicants and recipients; however, for some rules, such as two-parent eligibility, they may. Unlike nonfinancial rules, the financial rules often differ for applicants and recipients. The following provides more information on two-parent hours tests, treatment of child support income, asset tests, income eligibility tests, and earned income disregards for recipient units, as well as the maximum amount a recipient can earn and remain eligible. Eligibility Rules for Two-Parent, Nondisabled Recipient Units (Table IV.A.1) In addition to the standard eligibility tests that all recipient units must pass, some states impose hours tests on two-parent units. Under an hours test, the unit is not eligible if the principal wage earner is working more than a specified number of hours per month. States may apply this rule when determining the initial or continuing eligibility of two-parent families. For states providing benefits to two-parent families, table IV.A.1 describes the hours test imposed on two- 170 Welfare Rules Databook: State TANF Policies as of July 2017 parent recipients where neither parent is disabled ( unemployed-parent families, in the former AFDC program).38 Policies for 2017 include: \u25aa Forty-five states have no limit on hours worked per month for two-parent, nondisabled recipient units. \u25aa In the three states that do limit the hours worked in a month, the limit is 100 hours in Mississippi and South Dakota, and 130 hours in Maine. Related tables: See table I.B.2 for details on the hours test for applicants and table L2 for information on the rules for two-parent units for selected years from 1996 through 2017. Treatment of Child Support Income for Recipients (Table IV.A.2) TANF recipients are required to assign their child support income to the state. The state then decides what portion, if any, of the child support collected is counted for eligibility determination; what portion, if any, is transferred to the family as unearned income; and how much of the portion transferred to the family is counted as income in determining the benefit.39 Table IV.A.2 describes each state’s treatment of child support income for recipients. The first column of the table displays the amount of collected child support counted for recipients’ eligibility determination (regardless of whether any is transferred to the family). Those states that do not count child support collections for determining recipients’ eligibility typically establish some method to ensure that families with high and continuing child support amounts do not remain on TANF indefinitely. The second column of the table shows what portion of the collected child support is transferred to the family as unearned income, and the third column indicates how much of that transferred amount is disregarded for benefit computation. The traditional $50 pass-through that was allowed under AFDC would be represented in this table with a $50 coded in both the second and third columns; $50 is transferred to the unit as unearned income, and, of that amount, all $50 is disregarded for benefit computation. 38 Louisiana, New Hampshire, and North Dakota no longer provide TANF benefits to two-parent, nondisabled units. Also, in some states, benefits are provided to two-parent units under solely state-funded or separate state programs funded by state monies rather than the TANF grant. The table includes those states as providing benefits to two-parent families regardless of the funding source. 39 States are required to pay a share (equal to the state’s Medicaid match rate) of all child support collected on behalf of TANF recipients to the federal government. States may still provide all child support collected to the recipient; in that case, the state must use other funds to pay the federal share. Welfare Rules Databook: State TANF Policies as of July 2017 171 Key policies in place as of July 2017 include: \u25aa Twenty-seven states consider at least a portion of the child support income collected by the state for purposes of a recipient’s eligibility. \u25aa Twenty-seven states do not transfer any portion of the child support collected to the family. Asset Limits for Recipients and Related Assets Policies (Table IV.A.3) States determine the maximum amount of assets\u2014including vehicles and restricted assets\u2014a family may hold and still remain eligible for benefits. Table IV.A.3 describes each state’s asset tests for recipients. The first column of the table provides the limit on the value of unrestricted assets a family may hold and still be eligible for assistance. Unrestricted assets include the cash value of any asset the state counts toward the limit, regardless of the asset’s purpose. Limits may vary for determining initial eligibility versus continuing eligibility. The second column describes whether some or all of the value of a vehicle or vehicles is excluded in determining the amount of a family’s assets for eligibility purposes. When a portion of the vehicle’s value is exempted, the value may be given in terms of equity or fair-market value. The fair-market value is the amount for which the vehicle could be sold, while the equity value is the fair-market value minus any amount still owed on the vehicle. When a family still owes money on a vehicle, the equity value will be less than the fair-market value, so this distinction is important when comparing vehicle exemption amounts across states. The last three columns describe programs that allow families to save money in a special account, often with no fees, sometimes with their savings matched with funds from the government or other entity (referred to as the match rate in the tables), and with some requirements placed on the uses of the funds. These programs may be available to non-TANF as well as TANF families, but even those not explicitly connected with the TANF program are shown in the table to provide a more complete picture of asset-related policies affecting TANF families. In states that limit the countable assets that families may have and still be eligible for TANF, the funds in an account of this type are not counted against the asset limit. For example, a unit may be allowed to save money toward educational expenses or the purchase of a home without that money counting toward its overall asset limit. Some, but not all, restricted accounts are federally defined individual development accounts (IDAs). In the table, accounts that states specify as IDAs are distinguished from other restricted accounts. 172 Welfare Rules Databook: State TANF Policies as of July 2017 Key policies from 2017 include: \u25aa All but eight states have asset limits for recipients. For the states that do have asset limits for recipients, the limit ranges from $1,000 in Georgia, Oklahoma, Pennsylvania, Rhode Island, and Texas to $10,000 in Delaware, Minnesota, and Oregon. \u25aa Forty-one states offer some type of restricted asset account. Related tables: See tables L8 and L9 for information on asset rules in effect in selected years from 1996 through 2017. See table I.C.1 for the asset tests applied at application. Income Eligibility Tests for Recipients (Table IV.A.4) Table IV.A.4 describes income eligibility tests that states impose to determine whether a recipient (whose income might have increased since initial eligibility) is eligible to continue receiving benefits. The table indicates which state income standard is used for each test. Even if a family passes all eligibility tests, it is possible in some states that the family will not qualify for a positive benefit under the state’s benefit computation formula. In those cases, the family will not receive a benefit. In some cases, states have streamlined their eligibility policies and do not perform any income tests other than the implicit test imposed by benefit computation. In these states, the table indicates no explicit tests. Key policies for 2017 include: \u25aa Twenty-nine states have an explicit net income, gross income, or gross earnings test for recipients. \u25aa Ten states require recipients to pass two or more income eligibility tests. \u25aa Twenty-two states have no explicit income eligibility tests for recipients. Related tables: To determine the value of the particular standard for a family size of three, see table I.E.3. Tables I.D.1, I.D.2, and I.D.4 describe policies concerning the deeming of income from grandparents, stepparents, and immigrant parents, and table IV.A.2 shows the extent to which child support collections are counted in determining gross income for income eligibility tests. Table IV.A.5 describes the earned income disregards used for the net income tests listed in IV.A.4. The tables in sections I.B, I.D, and II.A are also relevant to ongoing eligibility. In most states, recipients are required to pass both nonfinancial and financial tests to continue receiving benefits. Welfare Rules Databook: State TANF Policies as of July 2017 173 Earned Income Disregards for Continuing Income Eligibility Purposes (Table IV.A.5) Table IV.A.5 describes the earned income disregards associated with the net income tests in table IV.A.4, which may differ from the amount of earnings disregarded for purposes of initial eligibility or from the amount of earnings disregarded for benefit computation. Some states consider units who have received assistance in one of the previous four months as recipients for the purpose of earned income disregards, even if they stopped receiving assistance and are reapplying for benefits. Policies for 2017 include: \u25aa Twelve states use earned income disregards for recipient eligibility purposes. \u25aa The remaining states do not use an earned income disregard because they do not have an explicit net income test. Related tables: Table I.E.2 contains the earned income disregards that apply to new TANF applicants for the purpose of determining their initial eligibility, and table II.A.1 gives the earned income disregards for benefit computation. Maximum Income for Ongoing Eligibility for a Family of Three (Table IV.A.6) Table IV.A.6 synthesizes the various financial rules related to ongoing eligibility to provide information on the maximum amount of income a family of three can earn and remain eligible for assistance in various months (2, 7, 13, and 25) of combining work and welfare. This calculation incorporates information on the income eligibility rules for recipients, earned income disregards for ongoing eligibility and benefit computation, benefit computation policies, and the eligibility and payment standards. The calculation determines the maximum amount of earnings a three-person family can have and still be technically eligible for assistance in each state, in each month. Technical eligibility does not mean the unit will necessarily receive a cash benefit\u2014most states only distribute a cash benefit if it is over $10\u2014but the unit will have passed all eligibility tests and be eligible for some positive amount. The calculation assumes the assistance unit includes one parent and two children, has only earned income, has no child care expenses, contains no children subject to a family cap, has no special needs, pays for all shelter costs with no subsidies, and is subject to the benefit standard that applies to the majority of the state’s caseload. Policy highlights for 2017 include: \u25aa The maximum earnings a recipient can have and remain eligible for assistance in month two ranges from $565 in West Virginia to $2,528 in Alaska. Four states have no maximum in the second month. 174 Welfare Rules Databook: State TANF Policies as of July 2017 \u25aa In 14 states, the maximum earnings is lower at the 25-month point (the latest month shown in the table) compared with maximum possible earnings in the 2nd month. Related tables: Table I.E.4 provides information on the amount of earnings an applicant may have and become eligible for assistance. Table L3 provides the maximum income for initial (applicant) eligibility for selected years from 1996 through 2017. B. Are children eligible if born while the family receives benefits? Benefits to recipients who give birth to a child while receiving aid may or may not be affected by the addition of the child to the assistance unit. A type of policy often referred to as a family cap prevents or limits an increase in a family’s benefit when another child is born. In the states with this type of policy, the benefit increase an assistance unit would otherwise receive for adding another member to the unit is limited. Family Cap Policies (Table IV.B.1) Table IV.B.1 describes states’ family cap policies. The table first indicates whether the state imposes a family cap, then provides the number of months following the case opening after which a newborn child is excluded from the assistance unit. The table also describes the impact on the benefit when an additional child is born (whether there is no increase in benefit or some increase smaller than what would occur in the absence of a family cap). In some cases, the amount of cash paid directly to the family does not increase, but the increment that would have been paid in the absence of the policy is instead paid to a third party or provided in the form of a voucher. That information is noted in the table as none (voucher) and is explained further in the footnotes. States with none (disregard) displayed in the table increase the earned income disregards for families that have a capped child; again, more details are provided in the footnotes. The table also indicates how long a cap, once applied, endures. The table indicates always capped if a family is never able to regain benefits for a capped child, even after the case has been closed for a period. Otherwise, the table provides the number of months a family must remain off the rolls for the cap to be removed\u2014that is, for the child to be included in the benefit computation should the family apply for assistance again. Welfare Rules Databook: State TANF Policies as of July 2017 175 Policies for 2017 include: \u25aa Fifteen states have a family cap policy. \u25aa For the states with family cap policies, 12 states do not increase the cash benefit for an additional child born to the unit. Three states do increase the benefit, but at less than the normal increment. \u25aa Ten states will not remove the special treatment of the capped child after the family’s case has been closed for a specified number of months. Of the five states that discontinue special treatment after case closure, a family’s case must have been closed anywhere between 1 month in Tennessee to 20 months in Massachusetts in order for the state to remove the family cap. Related tables: See table L10 for information on states’ family cap policies in selected years from 1996 through 2017. C. How long can a family receive benefits? Since the passage of PRWORA, assistance units that include adults have generally been able to receive no more than 60 months of federally-funded TANF aid. Therefore, most states have limited the number of months an assistance unit that includes adults may receive benefits. (Child-only units are not subject to time limits.) States impose two basic types of limits on recipients: (1) lifetime limits (either the federal 60-month limit or a shorter state-determined limit), which permanently eliminate the entire benefit, or (2) other intermittent state time limits (periodic time limits, benefit waiting periods, or benefit reduction time limits), which interrupt or reduce benefits for a certain period but do not eliminate them entirely. Both types of time limits may terminate benefits to the entire unit or just the adults in the unit. In addition, while some states impose only the 60-month federal lifetime limits or only other state time limits, other states impose a combination of the two types. Not all assistance units are subject to time limits. States may continue to provide federally- funded benefits to up to 20 percent of their caseload (referred to as the hardship exemption ) beyond the federal 60-month time limit.40 Exactly which families are eligible to receive this 40 Note that federal rules refer to this policy as a hardship exemption, but the WRD definition would consider this policy an extension, as it adds additional months of assistance after a family reaches the lifetime limit. 176 Welfare Rules Databook: State TANF Policies as of July 2017 extension of benefits (which adds months of assistance after reaching the federal lifetime limit) varies by state. Families who receive a hardship exemption remain eligible as long as the circumstances that led to their extension continue to exist. In addition, states may use state- only funds to provide various exemptions (which stop the time limit clock from accruing months towards the 60-month lifetime limit) or extensions (which extend assistance beyond 60 months). Time Limit Policies (Table IV.C.1) Under TANF, the federal government imposed a maximum 60-month lifetime limit on receipt of TANF funds by families with an adult. Therefore, a family is generally no longer eligible for federal cash assistance if an adult family member has received federally-funded TANF assistance for 60 months, either consecutively or nonconsecutively.41 Some states have adopted shorter lifetime limits, while others have chosen to fund recipients after the 60 months with state dollars. States may also choose to terminate benefits only for the adults in the unit, in which case all children in the assistance unit remain eligible for benefits after the lifetime limit expires, as a child-only unit. The first four columns of table IV.C.1 describe states’ lifetime limit policies. The first column indicates the total months in which the state allows benefits, and the second, third, and fourth columns identify whose benefits are terminated. Key policies for lifetime time limits in 2017 include: \u25aa Thirty-seven states have a lifetime limit of 60 months. \u25aa In states with time limits, 47 states terminate the benefit for the entire unit once the time limit is reached. Two states (California and Oregon) terminate the benefit for the adult only. Indiana terminates the benefit for the adult only once the benefit reduction time limit is reached and for the entire unit once the lifetime limit is reached. D.C. reduces the entire unit’s benefit amount. States have developed several other time limits that interrupt or reduce benefits. These limits are imposed instead of or in addition to the lifetime limits and include periodic limits and benefit waiting periods. Under a periodic limit, a unit (or the head of the unit) may receive benefits for only a specified number of months in a given period. For example, a state might 41 The TANF regulations indicate that the federal 60-month time limit does not apply to child-only units (units that include no adults). However, a few states count months in which units are child-only because of the ineligibility of their parents based on immigrant status or illegal activity. Welfare Rules Databook: State TANF Policies as of July 2017 177 impose a 12-out-of-24-month periodic limit on the unit, in which the unit is eligible to receive only 12 months of benefits in any 24-month period. Under a benefit waiting period, a unit (or the head of the unit) is ineligible for benefits for a specified number of months after the unit has received benefits for another specified number of months. To use the 12 and 24 example again, a unit may receive 12 months of assistance and is then ineligible for 24 months. This means the unit may receive 12 months of benefits over any period, but after it receives its 12th month of assistance, it will be ineligible for benefits for the next 24 months. Both the periodic limit and the benefit waiting period limit may apply to the entire unit or just the adult head of the unit. The last three columns of table IV.C.1 describe other state time limit policies.42 The first of the last three columns describes the type of other time limit imposed, and the second and third columns identify whose benefits are terminated. Policies for intermittent time limits in 2017 include: \u25aa Ten states have time limit policies other than lifetime limit policies. Of those 10 states, half impose a periodic time limit and the other half impose a benefit waiting period. \u25aa Nine states terminate the benefit for the entire unit once this non-lifetime time limit is reached and one state (Texas) terminates the benefit for the adult only. Related tables: Tables IV.C.2(a) and (b) and IV.C.3(a) and (b) describe time limit exemption and extension policies. Time Limit Exemption and Extension Policies (Tables IV.C.2(a) and (b) and IV.C.3(a) and (b)) Exemption and extension policies are important for understanding time limits in the states. Exemptions and extensions could significantly increase the number of months beyond the state or federal time limit that an assistance unit may receive benefits and, depending on the criteria, could impact a substantial portion of a state’s caseload. As defined for the purposes of the WRD, exemptions are policies that stop a recipient’s time-limit clock before it reaches the 60- month limit, and extensions are policies that prolong a recipient’s eligibility once the unit has reached the 60-month time limit. Tables IV.C.2(a) and (b) and IV.C.3(a) and (b) describe time limit exemption and extension policies, respectively. The exemption and extension policies for both lifetime limits and other limits are displayed in the tables. If the policies vary depending on the type of time limit, the differences in the policies are described in the tables’ footnotes. The funding source for 42 The table includes only those time limits that affect the majority of units. For a description of time limits affecting other groups, see the WRD. 178 Welfare Rules Databook: State TANF Policies as of July 2017 benefits received under an exemption or extension may vary between federal and state funds. Families receiving an exemption from the time limit are assumed to be funded with state-only dollars. Families receiving an extension may be funded with federal dollars if they meet the federal hardship exemption criteria as described above; however, states may also use their own funding for other extensions. In some cases, a state may use its own funds to provide an exemption or extension in a manner not permitted by federal TANF rules. Any policies in the tables that conflict with federal TANF requirements are assumed to use other funding. Similarly, states that provide extensions for all families after reaching the 60-month federal time limit are assumed to be using non-federal funds. Time limit exemption and extension policies for 2017 include: \u25aa Forty-three states provide time limit exemptions in at least some cases. \u25aa Forty-eight states provide time limit extensions in at least some cases. Related tables: Table IV.C.1 describes the time limit policies for each state. D. Can families receive transitional cash assistance? While some families might lose TANF eligibility after reaching a state or federal time limit, other families might become ineligible due to other circumstances, such as increased earnings. Several states elect to provide a transitional cash benefit to these families. Transitional Cash Benefits (Table IV.D.1) Table IV.D.1 describes state policies for providing continued cash benefits to families transitioning off the TANF program, usually due to increased work and earnings. The table captures only those transitional benefits paid as cash. (Some transitional benefits are in the form of increases in supplemental food benefits.) Also, the table only captures benefits provided to families who previously received TANF; it does not capture benefits directed more broadly at working families regardless of prior TANF receipt. The table first describes whether a state provides a transitional cash benefit and the hours of work required for participants to receive it. It also displays the monthly benefit amount and the length of time a family can receive this benefit. Welfare Rules Databook: State TANF Policies as of July 2017 179 Key policies for 2017 include: \u25aa Twenty-two states provide transitional cash benefits with time limits that range from 1 month in South Dakota and Washington to 24 months in Arkansas, New Jersey, and New York. Additional details on these rules and information on other transitional benefits\u2014such as transitional child care benefits\u2014can be found in the WRD. 180 Welfare Rules Databook: State TANF Policies as of July 2017 State Upper limit on monthly work hours 2 Alabama No limit Alaska No limit Arizona No limit Arkansas No limit California No limit Colorado No limit Connecticut No limit Delaware No limit D.C. No limit Florida No limit Georgia No limit Hawaii No limit 3 Idaho No limit Illinois No limit Indiana No limit Iowa No limit Kansas No limit Kentucky No limit Louisiana n.a. 4 Maine 130 Maryland No limit 5 Massachusetts No limit Michigan No limit Minnesota No limit Mississippi 100 Missouri No limit Montana No limit Nebraska No limit Nevada No limit New Hampshire n.a. 4 New Jersey No limit New Mexico No limit New York No limit North Carolina No limit North Dakota n.a. 4 Ohio No limit Oklahoma No limit Oregon No limit Pennsylvania No limit Rhode Island No limit South Carolina No limit South Dakota 100 Tennessee No limit Table IV.A.1. Eligibility Rules for Two-Parent, Nondisabled Recipient Units, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 181 State Upper limit on monthly work hours 2 Texas No limit Utah No limit Vermont No limit Virginia No limit Washington No limit West Virginia No limit Wisconsin No limit Wyoming No limit 5 All two-parent families are funded through a state program with the same eligibility rules as the state’s TANF program; however, no two-parent families are eligible for TANF funding. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 In some states, benefits are provided to two-parent units under a state-funded program instead of through federal TANF. The table describes the treatment of two-parent units regardless of the funding source. 3 Two-parent families not eligible for Federal TANF are funded through a state program with the same eligibility rules as the state’s TANF program. 4 The state does not provide benefits to two-parent, nondisabled units. 2 States with this policy generally allow eligibility for units with two nondisabled parents only if the principal earner in the couple works no more than a certain number of hours per month. However, in most states with this policy, eligibility may still be allowed when hours exceed the maximum, if work hours are usually at or below the maximum. See the full database for details. Table IV.A.1. Eligibility Rules for Two-Parent, Nondisabled Recipient Units, July 2017 1 182 Welfare Rules Databook: State TANF Policies as of July 2017 State Amount transferred 3 Amount of transfer disregarded for benefit computation 4 Alabama n.a., no income eligibility test None n.a. Alaska All but $50 $50 $50 Arizona None None 5 n.a. 5 Arkansas All None n.a. California All $50 $50 Colorado None 6 All All Connecticut All but $50 7 $50 $50 Delaware All but $50 $50 plus child support supplement 8 All D.C. n.a., no income eligibility test 9 $150 $150 Florida All None n.a. Georgia All Amount of unmet need 10 All Hawaii All None n.a. Idaho n.a., no income eligibility test None n.a. Illinois n.a., no income eligibility test $100\/$200 11 $100\/$200 Indiana All None n.a. Iowa None None 12 n.a. Kansas All None n.a. Kentucky All None n.a. Louisiana n.a., no income eligibility test None n.a. Maine All but $50 $50 plus amount of unmet need 13 All Maryland All None n.a. Massachusetts All but $50 14 $50 14 $50 14 Michigan n.a., no income eligibility test None n.a. Minnesota n.a., no income eligibility test All $100\/$200 15 Mississippi All None n.a. Missouri All None n.a. Montana None $100 16 $100 Nebraska n.a., no income eligibility test None n.a. Nevada None None n.a. New Hampshire All None n.a. New Jersey n.a., no income eligibility test $100 $100 New Mexico None $100 $100 New York All but $100\/$200 11 $100\/$200 11 $100\/$200 11 North Carolina All None n.a. North Dakota n.a., no income eligibility test None n.a. Ohio n.a., no income eligibility test None n.a. Oklahoma All None n.a. Oregon All but $50\/$200 11 $50\/$200 11 $50\/$200 11 Pennsylvania All but $100\/$200 11 $100\/$200 11 $100\/$200 11 Table IV.A.2. Treatment of Child Support Income for Recipients, July 2017 1 Amount of child support collection counted for recipients’ eligibility determination 2 Portion of child support collection transferred to the family: Welfare Rules Databook: State TANF Policies as of July 2017 183 State Amount transferred 3 Amount of transfer disregarded for benefit computation 4 Rhode Island n.a., no income eligibility test $50 $50 South Carolina All Amount of unmet need 17 All South Dakota n.a., no income eligibility test None n.a. Tennessee None Amount of unmet need 10 All Texas All but $75 None 18 n.a. Utah All None n.a. Vermont n.a., no income eligibility test All $50 Virginia All but $100 $100 $100 Washington None None n.a. West Virginia All but $100\/$200 11 $100\/$200 11 $100\/$200 11 Wisconsin None 75% of child support collected All Wyoming n.a., no income eligibility test None n.a. 8 In addition to the $50 transfer payment, Delaware provides a supplemental child support payment, which is calculated by subtracting a recipient’s current disposable income from his or her disposable income as it would have been calculated in 1975. 3 When dollar amounts are shown, the amount of the transfer is the smaller of the amount shown or the amount of child support paid on behalf of the family. 4 When dollar amounts are shown, the amount of the disregard is the smaller of the amount shown or the amount of child support paid on behalf of the family. 2 Some states with values displayed in this column do not have income eligibility tests for recipients, according to table IV.A.4. In table IV.A.4, we do not display net income tests if the calculation of the test and the disregards allowed for the test do not differ from those used to calculate the benefit. However, for families with child support income, the net income eligibility test may differ from the benefit computation. For purposes of calculating eligibility when the family receives child support income, the net income test for recipients is equivalent to the benefit calculation in the state (see tables II.A.1, II.A.2, and II.A.3). States that do not count any child support collections for calculating recipients’ eligibility (shown as \”None\” in this column) generally use other methods to ensure that families with high and continuing child support amounts do not remain on the rolls indefinitely. 5 Any child support collected on behalf of a child subject to a family cap is transferred to the family and treated as exempt income. 7 For income eligibility for an extension, all child support income, including the disregard, is counted. 6 If the average monthly child support collection over the prior six months exceeds $500, that average is counted in determining a recipient’s ongoing eligibility. 1 This table describes the treatment of child support collected by the state on behalf of a TANF recipient; it does not cover the treatment of child support received by the family directly from the absent parent. Child support collections may be counted as income for eligibility purposes regardless of whether they are transferred to the family; however, child support retained by the state is never counted for purposes of benefit computation. Although many states have created unique child support policies, some states still provide families with the traditional $50 transfer used under AFDC. The traditional transfer is represented in this table with \”All but $50\” in the first column, and \”$50\” in the second and third columns. This table does not cover the transfer of child support payments in excess of current or total TANF benefits. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table IV.A.2. Treatment of Child Support Income for Recipients, July 2017 1 Amount of child support collection counted for recipients’ eligibility determination 2 Portion of child support collection transferred to the family: 184 Welfare Rules Databook: State TANF Policies as of July 2017 17 The unmet need, also called the gap payment, is calculated as 63.7 percent of the smaller of retained child support for the month or the maximum amount that would not make the family ineligible for TANF if counted as income. The state defines \”retained child support\” as the amount equal to the smaller of the current month’s collection, the basic TANF award for the month, or the current monthly obligation excluding arrears. 18 The state will add to the TANF payment the smaller of the court-ordered payment amount, the amount the Office of the Attorney General received during that month, or $75. This money is considered an addition to the TANF benefit, not a transfer of child support income, and is disregarded for eligibility purposes. 11 The first amount applies to families with one child and the second amount applies to families with two or more children. 14 All child support collected on behalf of a child subject to the family cap is transferred to the family. For children subject to the family cap, the first $90 of unearned income, including child support, is disregarded for eligibility and benefit computation; the rest is counted. 16 The transferred amount is considered to be an addition to the TANF payment. 15 The first amount applies to families with one child and the second amount applies to families with two children. 9 If the amount of child support paid by the noncustodial parent exceeds the monthly benefit by more than $150 for two consecutive months, the TANF case is closed. 10 The amount of child support collected or the amount of unmet need, whichever is smaller, is transferred to the family as unearned income and disregarded for benefit determination. The unmet need, also called the gap payment, is calculated as the consolidated need standard for the unit’s family size minus the maximum benefit for the unit’s family size minus the unit’s net income. For units affected by the family cap, the amount of unmet need is calculated using the standard of need for the family size that includes the capped child, but using the family maximum that excludes the capped child. 12 If child support for a child in the assistance unit is paid directly to a recipient for any reason, $50 is disregarded and the remainder is counted as income. However, child support income that is received for a child who is not included in the assistance unit (for example, a child ineligible due to immigrant status, or a stepparent’s child from a prior relationship when the stepparent is not included in the assistance unit) is not counted for TANF eligibility or benefits. 13 After the initial $50 transfer, the state then transfers child support in the amount of the unmet need, also known as the gap payment, to the family as unearned income and disregards the child support for benefit determination. The unmet need is calculated as the consolidated need standard for the unit’s family size minus the maximum benefit for the unit’s family size minus the unit’s net income. Welfare Rules Databook: State TANF Policies as of July 2017 185 State Asset limit 2 Vehicle exemption 3 Amount 5 Description Matching rate Alabama No limit n.a. $6,000 6 IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business 6 2 to 1 6 Alaska $2,000\/ $3,000 7 All vehicles owned by household 8 n.a. n.a. n.a. Arizona $2,000 All vehicles owned by household $9,000 9 IDA accounts: Postsecondary education or job training, purchase of a first home, capitalization of a small business None Arkansas $3,000 One vehicle per household 10 n.a. n.a. n.a. California $2,250\/ $3,250 11 $9,500\/one vehicle per licensed driver E, 12 No limit IDA accounts: Postsecondary Education or job training, purchase of a first home, a new business, homelessness prevention; Retirement accounts: IRAs, 401(k) plans, 403(b) plans, 457 plans; Education accounts: 529 college savings plans, Education Savings Accounts None Colorado No limit n.a. n.a. n.a. n.a. Connecticut $3,000 $9,500 E, 13 No limit Education accounts: Postsecondary education; Retirement accounts: IRAs, Keogh pension plans, 401(k)s None Delaware $10,000 All vehicles owned by household $5,000 Postsecondary education, purchase of a first home, purchase of a vehicle, capitalization of a small business None D.C. $2,000\/ $3,000 7 All vehicles owned by household $10,000 Opportunity accounts: Postsecondary education or job training, purchase of a first home, home repair or improvement, capitalization of a small business, medical emergencies; Retirement accounts: IRAs, general retirement expenses 2 to 1 Florida $2,000 $8,500 E Varies 14 IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business, assistive technology, transportation 1 to 1 Georgia $1,000 $4,650 E, 15 $5,000 IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business Varies 16 Table IV.A.3. Asset Limits for Recipients and Related Assets Policies, July 2017 1 Restricted asset accounts: 4 186 Welfare Rules Databook: State TANF Policies as of July 2017 State Asset limit 2 Vehicle exemption 3 Amount 5 Description Matching rate Hawaii No limit n.a. No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business None Idaho $5,000 One vehicle per adult 17 n.a. n.a. n.a. Illinois No limit n.a. No limit 18 IDA accounts: Postsecondary education, purchase of a first home, purchase of a vehicle, capitalization of a small business 1 to 1 Indiana $1,500 $5,000 of one vehicle per household E, 19 No limit IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business 3 to 1 20 Iowa $5,000 One vehicle per household 21 All deposits and interest IDA accounts: Postsecondary education or job training, purchase of a home, home repair or improvement, capitalization of a small business, medical emergencies 1 to 1 22 Kansas $2,250 One vehicle per adult 23 No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business None Kentucky $2,000 24 All vehicles owned by household $5,000 IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business Varies 25 Louisiana No limit n.a. No limit IDA accounts: Postsecondary education or training, purchase of a first home, capitalization of a small business, work-related clothing or equipment None Maine $2,000 One vehicle per household $10,000 Family Development Accounts: Postsecondary education or training, purchase of a home, home repair or improvement, vehicle repair, capitalization of a small business 2 to 1 26 Maryland No limit n.a. No limit IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business None Massachusetts $2,500 $15,000 F n.a. n.a. n.a. Michigan $3,000 All vehicles owned by household No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business Varies 27 Minnesota $10,000 28 One vehicle per household member who is 16 or older F, 29 No limit IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business 3 to 1 Table IV.A.3. Asset Limits for Recipients and Related Assets Policies, July 2017 1 Restricted asset accounts: 4 Welfare Rules Databook: State TANF Policies as of July 2017 187 State Asset limit 2 Vehicle exemption 3 Amount 5 Description Matching rate Mississippi $2,000 30 All vehicles owned by household E, 31 n.a. n.a. n.a. Missouri $5,000 First vehicle 100%\/ Second vehicle $1,500 E, 32 No limit IDA accounts: Postsecondary education or training, purchase of a first home, capitalization of a small business None Montana $3,000 One vehicle per household 33 No limit IDA accounts: Purchases may not exceed $5,000. Matched Savings Program and IDA purchases must allow a recipient to meet an educational or employment goal, address a barrier, purchase a first home, or for business capitalization. Funds from one program may not be used to satisfy the matching requirement of another program. Funds may not be used in place of Pell Grants and cannot be rolled into Roth IRAs, 529 plans or to purchase Certificates of Deposit. Funds may not be used for reoccurring basic needs, medical expenses, or extracurricular activities. 3 to 1 Nebraska $4,000\/ $6,000 34 One vehicle per household 35 No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business; Trust funds for children in the unit; Cash value of life insurance policies None Nevada $6,000 One vehicle per household 36 No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business None New Hampshire $2,000 One vehicle per licensed driver 37 $4,500 IDA accounts: Postsecondary education or the purchase of a first home 8 to 1 New Jersey $2,000 All vehicles owned by household 38 No limit IDA accounts: Postsecondary education or training, purchase of a first home, capitalization of a small business 1 to 1 New Mexico $3,500 39 All vehicles owned by household 40 No limit IDA accounts: Postsecondary education, purchase of a first home, home repair, purchase of a vehicle, capitalization of a small business None Table IV.A.3. Asset Limits for Recipients and Related Assets Policies, July 2017 1 Restricted asset accounts: 4 188 Welfare Rules Databook: State TANF Policies as of July 2017 State Asset limit 2 Vehicle exemption 3 Amount 5 Description Matching rate New York $2,000\/$3,000 41 $11,000 F, 42 No limit 43 IDA accounts: Postsecondary education or job training, purchase of a home, capitalization of a small business None North Carolina $3,000 All vehicles owned by household n.a. n.a. n.a. North Dakota $3,000\/$6,000\/ $6,000+$25 44 One vehicle per household $2,000 45 IDA accounts: Postsecondary education, purchase of a first home, startup or expansion of a small business 2 to 1 Ohio No limit n.a. $10,000 IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business Up to 4 to 1 Oklahoma $1,000 $5,000 E $4,000 IDA and SEED accounts: Postsecondary education, purchase of a home, capitalization of a small business 46 None Oregon All, except JOBS Plus $10,000 47 $10,000 of all vehicles owned by household E n.a. n.a. n.a. JOBS Plus $10,000 48 $10,000 of all vehicles owned by household E No limit Education Accounts: Continuing education or training 1 to hour worked 49 Pennsylvania $1,000 One vehicle per household 36 No limit Family Savings accounts: Postsecondary education, purchase of a home, capitalization of a small business, other individually approved plans; Education accounts: Postsecondary education 1 to 1 50 Rhode Island $1,000 One vehicle per adult 51 n.a. n.a. n.a. South Carolina $2,500 One vehicle per licensed driver 52 $10,000 IDA accounts: Postsecondary education or training, purchase of a first home, purchase of a vehicle, capitalization of a small business None South Dakota $2,000 One vehicle per household 53 n.a. n.a. n.a. Tennessee $2,000 $4,600 E $5,000 IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business, transportation; Low Income Entrepreneurial Escrow accounts: profit and interest Up to 9 to 1 54 Table IV.A.3. Asset Limits for Recipients and Related Assets Policies, July 2017 1 Restricted asset accounts: 4 Welfare Rules Databook: State TANF Policies as of July 2017 189 State Asset limit 2 Vehicle exemption 3 Amount 5 Description Matching rate Texas $1,000 $4,650 of each vehicle owned by household E, 55 No limit 56 TANF certified and Assets for Independence Act IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business, up to $11,896 in School-Based Savings Accounts 1 to 1 Utah $2,000 All vehicles owned by household No limit IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business 1 to 1 Vermont $9,000 57 One vehicle per adult No limit IDA accounts: Postsecondary education or job training, purchase of a home, capitalization of a small business, retirement accounts, education savings accounts 2 to 1 Virginia No limit n.a. No limit IDA accounts: Postsecondary education, purchase of a home, capitalization of a small business 2 to 1 Washington $4,000 58 $5,000 E, 59 No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business 2 to 1 60 West Virginia $2,000 One vehicle per adult 61 No limit IDA accounts: Postsecondary education, purchase of a first home, capitalization of a small business; HUD Family Self-Sufficiency Escrow Accounts None Wisconsin $2,500 $10,000 E No limit IDA accounts: Postsecondary education or job training, purchase of a home, capitalization of a small business Varies 62 Wyoming $5,000 Two vehicles per household E n.a. n.a. n.a. 2 ABLE accounts are generally excluded from the asset limit. See the Welfare Rules Database for more information. 3 Policies that distinguish between the equity value and fair-market value of vehicles are marked as follows: (E) equity value of the vehicle; (F) fair-market value of the vehicle. 1 No Limit indicates a state does not place a limit on the amount of assets that can be held by the unit. Additional details about policies for units with elderly or older adults, including the age definitions used by states, can be found in the full database. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table IV.A.3. Asset Limits for Recipients and Related Assets Policies, July 2017 1 Restricted asset accounts: 4 190 Welfare Rules Databook: State TANF Policies as of July 2017 7 Units including an elderly person may exempt $3,000; all other units exempt $2,000. 5 In states with asset maximums, this is the maximum amount in the restricted account that can be disregarded for the assets test. In states without asset maximums, this is the maximum amount that can be held in the restricted account, including both the individual’s contribution and the state’s contribution. Amounts in excess of this amount are countable for the state’s asset test. 4 These columns capture programs that allow families to save money in a special account, often with no fees, sometimes with their savings matched with government funds, and with some requirements placed on the uses of the funds. These programs may be available to non-TANF as well as TANF families, but even those that are not explicitly connected with the TANF program are shown here to provide a more complete picture of asset-related policies affecting TANF families. In states that limit the countable assets that families may have and still be eligible for TANF, the funds in an account of this type are not counted against the asset limit. 6 Alabama has no assets test and therefore no limit on assets; the IDA accounts shown here reflect that the state offers this type of saving method, but it does not affect TANF benefits. 18 Deposits must come from earned income, and all deposits must be matched by state or local government, or through contributions made by a nonprofit entity. All withdrawals from the IDA account must be in the form of vendor payments made on behalf of the client for one or more of the intended purposes of the IDA. 8 Vehicles are exempt if used for one of the following: (1) to meet the family’s basic needs, such as getting food and medical care or other essentials; (2) to go to and from work, school, training, or work activity (such as job search or community service); (3) as the family’s house; (4) to produce self-employment income; or (5) to transport a disabled family member, whether or not he or she is a part of the assistance unit. If the vehicle does not meet one of these requirements, the equity value of the vehicle is counted in the determination of resources. 9 Fifty percent of earned income that is deposited into an IDA is disregarded for eligibility and benefit computation. The monthly value of the disregard cannot exceed $100. 10 If the family has more than one vehicle, then the market value of any additional vehicles will be considered in full. 11 Units including an elderly or disabled person may exempt $3,250; all other units exempt $2,250. 12 Each vehicle must be evaluated for its equity value. Before this calculation, a vehicle is excluded if it: (1) is used primarily for income-producing purposes; (2) is necessary for long-distance travel that is essential for employment; (3) is used as the family’s home; (4) is necessary to transport a physically disabled household member; (5) would be exempt under previously stated exemptions but the vehicle is not in use because of temporary unemployment; (6) is used to carry fuel or water to the home and is the primary method of obtaining fuel or water; and (7) is a gift, donation, or family transfer. For each remaining vehicle, the state excludes one additional vehicle per adult and one additional vehicle per licensed child who uses the vehicle to travel to school, employment, or job search. For each remaining vehicle not completely excluded, the equity value that exceeds $9,500 counts against the family’s asset limit. 13 The unit may exempt up to $9,500 of the vehicle’s equity value, or the entire value of one vehicle used to transport a handicapped person. The motor vehicle exclusion is applied to the registered vehicle with the highest fair market value. 14 The amount depends on the savings goal agreed upon by the participant and the Regional Workforce Board. The Regional Workforce Board has the discretion to set the guidelines for contributions made to IDA accounts, which can vary by region. 15 If the vehicle is used for job search, or to travel to work or education and training, the unit may exclude $4,650 of the value. If the vehicle is not used for these purposes, $1,500 of the equity value may be excluded. If the vehicle is used more than 50 percent of the time to produce income or as a dwelling, it is totally excluded. 16 Funds in an IDA may also be matched on behalf of the individual by a qualified entity, which may be defined as one of the following: a specific not-for-profit organization, or Georgia state or local government acting in cooperation with a not-for-profit organization. 17 If the unit owns any other vehicle that is non-exempt, the fair market value of the additional vehicle is applied to the resource limit. Welfare Rules Databook: State TANF Policies as of July 2017 191 32 $1,500 of the equity value of the unit’s second vehicle is exempt. 33 All vehicles whose primary use is to produce income or that are used as a home are also exempt. 34 The asset limit is based on unit size: one person receives $4,000, and two or more people receive $6,000. 35 The entire vehicle is exempt only if used for employment, training, medical transportation, or a home. If a unit has more than one vehicle that meets the exemption criteria, only the vehicle with the greatest equity value will be exempt. 20 Funds are matched up to the first $400 an individual deposited into the individual’s account during the preceding 12 months for 4 years. If the amount appropriated is insufficient to make the deposits required by this section for accounts that have been established, the authority will proportionately reduce the amounts allocated to and deposited into each account. 21 Additionally, $5,880 of the equity value of a vehicle is exempt for each adult and working teenager whose resources must be considered in determining eligibility. 22 The state matches $0.50 for every dollar of a recipient’s assets; federal funds match another $0.50. 23 One licensed vehicle per adult household member is exempt. Additional vehicles may be exempt if they are used by a minor for employment, training, education, or seeking employment, used primarily for producing income, essential to employment, used as the household’s home, necessary to transport a household member with a physical disability, used to carry the primary source of fuel and water for the home, or valued at $1,500 or less. 25 Matching funds must be provided by the non-profit organizations that establish the IDA agreements; the state does not provide the matching funds. 24 Only liquid resources are considered for eligibility determinations. Liquid resources include cash, checking and savings accounts, CDs, stocks and bonds, and money market accounts. 26 Community agencies will contribute matching funds up to $2,000 a year. 27 For IDAs, family contributions are matched by nonprofit organizations. The match rate is dependent on the agreement with the nonprofit organization. 28 Withdrawals from ABLE accounts used to pay for a qualified disability expense are excluded. 29 Any additional vehicle that is not exempt is counted toward the $10,000 asset limit and is valued at the amount of the vehicle’s trade-in value as listed in the current NADA on-line car values and car prices guide. 31 Determination of whether to count a vehicle is made case by case. 30 If the unit is considered broad-based categorically eligible, it is not subject to asset limits. Households that include a convicted drug felon or a member currently disqualified for an intentional program violation are not considered broad-based categorically eligible. When a TANF recipient marries while receiving assistance, the liquid resources of the new spouse are excluded for six months beginning the month after the date of the marriage. 36 Vehicles other than the household’s primary vehicle are evaluated for equity value. 37 The equity value of all non-junk vehicles is counted in addition to any excluded vehicles. 38 Recreational vehicles are not exempt and are evaluated for fair market value. 39 The total limit is $3,500, but only $1,500 of that amount can be in liquid resources and only $2,000 can be in non-liquid resources. 40 The entire vehicle is exempt only if equipped for those with physical impairments or used for transportation to work, work activities, or daily living requirements. If the vehicle is not used for these purposes, the entire equity value of the vehicle is subject to the asset test. 41 Units including a person age 60 years or older may exempt $3,000; all other units exempt $2,000. 19 The exemption can only be applied to the value of one vehicle. 192 Welfare Rules Databook: State TANF Policies as of July 2017 45 Recipients are allowed to save up to $2,000 in a two-year period in restricted asset accounts. Community action programs administer the program and provide a match rate of 2 to 1. 46 Although the asset limit is $4,000, the unit may only save $2,000 in an IDA and $2,000 in the Savings for Education, Entrepreneurship, and Down payment (SEED) accounts, which are savings accounts for individuals age 13 through 18 and are dedicated for purposes such as postsecondary education or training expenses, purchase of a first home, or capitalization of a small business. 47 The limit is reduced to $2,500 if the recipient does not cooperate with his or her case plan. 48 The limit is reduced to $2,500 if the recipient does not cooperate with his or her case plan. JOBS Plus and JOBS participants must first be deemed eligible under normal rules. 43 In addition to the IDA account, recipients may exempt up to $4,650 for the purchase of a first or replacement vehicle that will be used to seek, obtain, or maintain employment. The funds must be kept in a separate bank account from the IDA savings. Recipients may also exempt up to $2,000 for trust funds for infants. 42 One automobile is exempt, up to $11,000 of the fair market value; local districts may adopt a higher vehicle exemption. 62 The IDA program is matched with program funds from the Assets for Independence Act (AFIA), Office of Refugee Resettlement (ORR), or other TANF funds (TANF\/CR). All match funds and accrued interest are disregarded as countable assets. The match rate is dependent on the agreement with one of the participating agencies. 53 In addition to one primary vehicle, an assistance unit may totally exclude a vehicle used to transport water or fuel to the home when it is not piped in, or to transport a disabled member or SSI recipient in the household. The assistance unit may also exclude $4,650 of the fair-market value of a vehicle used to transport members of the unit for education or employment. 58 Recipients can have $1,000 in any type of assets and an additional $3,000 in a savings account or certificates of deposit. 59 The entire equity value of a vehicle used to transport a disabled household member is also exempt. 60 The state will match up to $2 for every $1 the recipient saves, up to maximum of $4,000 in matching funds. 61 A person must be work-eligible to qualify for the vehicle exemption. 55 All licensed vehicles used for income-producing purposes or for transporting a disabled household member are exempt. 56 Only deposits from earnings or EITCs are disregarded. Any withdrawals from an IDA account made for non-allowable purposes are counted as resources. 57 Other excluded resources include assets accumulated from earnings, interest earned on assets, non-liquid assets purchased with savings from earnings, retirement accounts (such as IRAs, 401(k)s, and other qualified accounts), and child education savings accounts (such as the Vermont Higher Education Investment Plan and other qualified plans). 54 Local banks, churches, or IDA nonprofit sponsors will contribute matching funds from rates of 1 to 1, up to 9 to 1. 49 The participant’s employer contributes one dollar for every hour the participant works. 50 The Pennsylvania Department of Community and Economic Development will contribute matching funds up to $1,000 a year. Non-IDA postsecondary education savings accounts are not subject to a match rate. 51 Exemptions for adult drivers cannot exceed two vehicles per household. Additionally, the entire value of a vehicle is exempt if it is used primarily to provide transportation for a disabled family member, used primarily to produce income, or used as the family’s home. 52 Vehicles owned by or used to transport disabled individuals or that are essential to self-employment are also exempt. If the unit owns any other vehicle that is non- exempt, the equity value of the additional vehicle is applied to the resource limit. 44 The asset limit is based on unit size: one person receives $3,000, two people receive $6,000, and another $25 is allowed for each additional person thereafter. Welfare Rules Databook: State TANF Policies as of July 2017 193 State Type of test Income must be less than 2 Alabama No explicit tests n.a. Alaska Gross income 185% of Need Standard Net income 100% of Need Standard Arizona Gross income 185% of Need Standard Gross income 100% of the 2017 Federal Poverty Guidelines 3 Net income 100% of Need Standard Arkansas Net income 100% of Income Eligibility Standard California Net income 100% of Maximum Aid Payment Colorado Net income 100% of Need Standard Connecticut Gross earnings 100% of 2017 Federal Poverty Guidelines Unearned income 100% of Need Standard and then 100% of the Payment Standard Delaware Gross income 185% of Standard of Need Net income 100% of Standard of Need D.C. No explicit tests n.a. Florida Gross income 185% of Consolidated Need Standard Georgia Gross income 185% of Standard of Need Hawaii Gross income 185% of Standard of Need Net income 100% of Standard of Assistance Idaho No explicit tests n.a. Illinois No explicit tests n.a. Indiana Net income 100% of 2017 Federal Poverty Guidelines Iowa Gross income 185% of Need Standard Kansas No explicit tests n.a. Kentucky 4 Gross income 185% of Standard of Need Louisiana No explicit tests n.a. Maine No explicit tests n.a. Maryland No explicit tests n.a. Massachusetts Net income 100% of Need Standard and Payment Standard Michigan No explicit tests n.a. Minnesota No explicit tests n.a. Mississippi 4 Gross income 185% of Need Standard and Payment Standard Missouri Gross income 185% of Need Standard Montana Gross income 100% of Gross Monthly Income Standard Net income 100% of Benefit Standard Nebraska No explicit tests n.a. Nevada No explicit tests n.a. New Hampshire No explicit tests n.a. New Jersey 5 No explicit tests n.a. New Mexico Gross income 85% of 2016 Federal Poverty Guidelines New York Gross income 185% of Need Standard Gross income 6 100% of 2017 Federal Poverty Guidelines North Carolina No explicit tests n.a. North Dakota No explicit tests n.a. Ohio No explicit tests n.a. Oklahoma Gross income 185% of Need Standard Table IV.A.4. Income Eligibility Tests for Recipients, July 2017 1 194 Welfare Rules Databook: State TANF Policies as of July 2017 State Type of test Income must be less than 2 Oregon All, except JOBS Plus, without earnings Gross income 100% of Countable Income Limit Net income 100% of Adjusted Income Standard All, except JOBS Plus, with earnings Gross income 100% of Exit Limit Increase Standard JOBS Plus Gross income 100% of Food Stamp Countable Income Limit Pennsylvania No explicit tests n.a. Rhode Island No explicit tests n.a. South Carolina Gross income 185% of Need Standard South Dakota No explicit tests n.a. Tennessee Gross income 185% of Consolidated Need Standard Texas Net income 100% of Recognizable Needs Utah Gross income 185% of Adjusted Standard Needs Budget Net income 100% of Adjusted Standard Needs Budget Vermont No explicit tests n.a. Virginia All, except VIEW Gross income 185% of Standard of Assistance VIEW Gross earnings 100% of 2016 Federal Poverty Guidelines Unearned income 7 100% of Standard of Assistance Washington 8 Gross earnings 100% of Maximum Gross Earned Income Limit West Virginia Gross income 100% of Standard of Need Wisconsin Gross income 115% of 2017 Federal Poverty Guidelines Wyoming No explicit tests n.a. 8 Child-only units are eligible at up to 300 percent of the Federal Poverty Guidelines. 3 This test, the needy family test, includes all family members of the adult caretaker for counting income and family size. When the adult caretaker is a non-parent relative of the dependent child receiving benefits for the child only, the income limit is 130 percent of the Federal Poverty Guidelines. 4 The gross income test does not apply to earnings for recipients who are receiving the 100 percent benefit computation disregard. 5 In households where the natural or adoptive parent is married to a non-needy stepparent, the gross household income may not exceed 150 percent of the Federal Poverty Guidelines. 6 This test does not apply to recipients temporarily living in hotels or motels, domestic violence shelters, AIDS housing, congregate care facilities, etc. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 \”No explicit tests\” indicates either that the state imposes no income tests on recipients or that the state imposes an income test but the calculation of the test and disregards allowed for it do not differ from those used to calculate the benefit. See table II.A.2 for information on benefit computation policies. See table I.E.3 for information on eligibility standards. 2 In some states, the test is passed if income is less than or equal to the amount shown; in other states, the test is passed only if income is less than the amount shown. 7 For two-parent units to be eligible, their gross earned income must be below 150 percent of the Federal Poverty Guidelines and their unearned income must be below 100 percent of the standard of assistance. Table IV.A.4. Income Eligibility Tests for Recipients, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 195 State Earned income disregard Alabama No explicit net income test Alaska $150 in all months, plus 33% of remainder in first 12 cumulative months of earnings, 25% of remainder in months 13-24, 20% of remainder in months 25-36, 15% of remainder in months 37-48, 10% of remainder in months 49-60 Arizona $90 and 30% of remainder in all months Arkansas 20% and 60% of remainder in all months California $225 and 50% of remainder in all months Colorado 67% in all months Connecticut No explicit net income test Delaware 2 $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings D.C. No explicit net income test Florida No explicit net income test Georgia No explicit net income test Hawaii 20% and $200 of remainder in all months, plus 55% of remainder in first 24 months of cumulative assistance and 36% thereafter Idaho No explicit net income test Illinois No explicit net income test Indiana $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings Iowa No explicit net income test Kansas No explicit net income test Kentucky No explicit net income test Louisiana No explicit net income test Maine No explicit net income test Maryland No explicit net income test Massachusetts $200 Michigan No explicit net income test Minnesota No explicit net income test Mississippi No explicit net income test Missouri No explicit net income test Montana $200 and 25% of remainder in all months Nebraska No explicit net income test Nevada No explicit net income test New Hampshire No explicit net income test New Jersey No explicit net income test New Mexico No explicit net income test New York No explicit net income test North Carolina No explicit net income test North Dakota No explicit net income test Ohio No explicit net income test Oklahoma No explicit net income test Oregon All, except JOBS Plus No explicit net income test for earners JOBS Plus No explicit net income test Pennsylvania No explicit net income test Rhode Island No explicit net income test Table IV.A.5. Earned Income Disregards for Continuing Income Eligibility Purposes, July 2017 1 196 Welfare Rules Databook: State TANF Policies as of July 2017 State Earned income disregard South Carolina No explicit net income test South Dakota No explicit net income test Tennessee No explicit net income test Texas $120 in all months, plus 90% of remainder (up to $1,400) for 4 out of 12 months Utah $100 and 50% of remainder in all months Vermont No explicit net income test Virginia All, except VIEW No explicit net income test VIEW No explicit net income test Washington No explicit net income test West Virginia No explicit net income test Wisconsin No explicit net income test Wyoming No explicit net income test 2 If benefits or employment end before the fourth consecutive month of earnings, the recipient is eligible to receive the $30 and 33.3 percent disregard for four additional months upon reapplication or re-employment. When a recipient has received the $30 and 33.3 percent disregard for four consecutive months and the $30 disregard for an additional eight months, neither disregard may be applied again until the individual has not received any benefits for 12 months. When monthly wages are $90 or less, and net income equals zero before any part of the $30 and 33.3 percent disregard can be applied, the month does not count toward the four consecutive-month limit for receiving the $30 and 33.3 percent disregard and the recipient is eligible to receive the disregard for four additional months. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The table describes the disregards used for ongoing, recipient eligibility purposes. See table I.E.2 for disregards used for initial, applicant eligibility purposes. \”No explicit net income test\” indicates the state does not impose a net income test for determining ongoing eligibility. Only earned income disregards are described in the table. Child care disregards and other special disregards, such as deductions for units subject to a time limit or a family cap, are not included. Table IV.A.5. Earned Income Disregards for Continuing Income Eligibility Purposes, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 197 2 7 13 25 Alabama No maximum No maximum $268 $268 Alaska $2,528 $2,528 $2,274 $2,141 Arizona $585 $585 $585 $585 Arkansas $696 $696 $696 $696 California 2 Non-exempt $1,652 $1,652 $1,652 $1,652 Exempt $1,822 $1,822 $1,822 $1,822 Colorado 2 $1,275 $1,275 $1,275 $1,275 Connecticut 2 $1,702 $1,702 $1,702 $1,702 Delaware $2,009 $1,379 $1,349 $1,349 D.C. $1,684 $1,684 $1,684 $1,684 Florida $805 $805 $805 $805 Georgia $755 $543 $513 $513 Hawaii $2,369 $1,944 $1,944 $1,012 Idaho $972 $972 $972 $972 Illinois 2 $1,727 $1,727 $1,727 $1,727 Indiana $1,151 $1,151 $1,151 $1,151 Iowa $1,267 $1,267 $1,267 $1,267 Kansas 2 $1,162 $1,162 $1,162 $1,162 Kentucky No maximum $645 $615 $615 Louisiana $1,259 $359 $359 $359 Maine $1,347 $1,347 $1,347 $1,347 Maryland $1,079 $1,079 $1,079 $1,079 Massachusetts Exempt $833 $833 $833 $833 Non-exempt $818 $818 $818 $818 Michigan $1,165 $1,165 $1,165 $1,165 Minnesota 3 $2,243 $2,243 $2,243 $2,243 Mississippi No maximum $457 $457 $457 Missouri $1,145 $1,145 $381 $381 Montana $817 $817 $817 $817 Nebraska $1,631 $1,631 $1,631 $1,631 Nevada No maximum $1,531 $478 $478 New Hampshire $2,040 $2,040 $2,040 $2,040 New Jersey $1,695 $1,695 $847 $847 New Mexico $942 $942 $942 $942 New York 2 $1,459 $1,459 $1,459 $1,459 North Carolina $681 $681 $681 $681 North Dakota $1,331 $1,024 $887 $665 Ohio $1,197 $1,197 $1,197 $1,197 Oklahoma $823 $823 $823 $823 Oregon $1,011 $1,011 $1,011 $1,011 Pennsylvania 2 $805 $805 $805 $805 Rhode Island $1,277 $1,277 $1,277 $1,277 South Carolina $1,554 $939 $939 $939 South Dakota $857 $857 $857 $857 Table IV.A.6. Maximum Income for Ongoing Eligibility for a Family of Three, July 2017 1 State Maximum amount a recipient can earn and still remain eligible for assistance in month: 198 Welfare Rules Databook: State TANF Policies as of July 2017 2 7 13 25 Tennessee $1,315 $1,315 $1,315 $1,315 Texas $1,708 $308 $308 4 $308 4 Utah $1,050 $1,050 $1,050 $1,050 Vermont 2 $1,103 $1,103 $1,103 $1,103 Virginia 2 All, except VIEW $677 $677 $677 $677 VIEW $1,680 $1,680 $1,680 n.a. 5 Washington $1,040 $1,040 $1,040 $1,040 West Virginia $565 $565 $565 $565 Wisconsin n.a. 6 n.a. 6 n.a. 6 n.a. 6 Wyoming $1,259 $1,259 $1,259 $1,259 6 Units with earnings at application will not receive a cash benefit, except for units with earnings from unsubsidized employment who work less than 30 hours per week and face limitations to increasing their work hours. These units are eligible for a Community Service Job placement where they may receive a prorated benefit. Units with income less than $1,957 at application who find employment during up-front job search have their income disregarded for purposes of determining eligibility for nonfinancial assistance. 2 Dollar amount used to calculate benefit varies within the state, either by county or by region of the state. Calculations are based on the dollar amount that applies to the majority of the state. See the Welfare Rules Database for more information. 3 This table captures the maximum earnings a recipient of the state’s TANF assistance program may have. The state’s four- month non-assistance diversion program uses different earned income disregards and benefit computation rules. 4 Based on the assumption made for these calculations, the recipient is not receiving the state’s 90 percent disregard. However, under different assumptions, it is possible that a recipient could receive the 90 percent disregard in the 13th or 25th month of combining work and welfare. 5 VIEW recipients are subject to a 24-month limit on TANF benefits followed by a 24-month period of ineligibility. If a recipient participates in VIEW after his or her period of ineligibility is over, he or she may earn $1,680 and remain eligible. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 The values in this table represent the maximum amount a recipient can earn in various months of combining work and TANF and still be technically eligible\” for assistance in each state. Technical eligibility does not mean that the unit will necessarily receive a cash benefit, but it will have passed all the eligibility tests and is eligible for some positive amount. Most states only distribute a cash benefit equaling $10 or more. Ongoing eligibility is calculated assuming that the unit found new employment while on assistance, has only earned income, has no child care expenses, contains one adult and no children subject to a family cap, has no special needs, pays for shelter, and lives in the most populated area of the state. Table IV.A.6. Maximum Income for Ongoing Eligibility for a Family of Three, July 2017 1 State Maximum amount a recipient can earn and still remain eligible for assistance in month: Welfare Rules Databook: State TANF Policies as of July 2017 199 State Family cap policy 1 Special treatment if child born more than X months after case opening Increase in cash benefit for an additional child (and special provisions) Special treatment discontinued if case closed X months 2 Alabama No n.a. n.a. n.a. Alaska No n.a. n.a. n.a. Arizona Yes 10 3 None (disregard) 4 n.a., always capped 5 Arkansas Yes No 6 None 6 California No n.a. n.a. n.a. Colorado No n.a. n.a. n.a. Connecticut Yes 10 $50 per child n.a., always capped Delaware Yes 7 10 None n.a., always capped D.C. No n.a. n.a. n.a. Florida Yes 10 8 Half of normal increase for adding first child; none for additional children n.a., always capped Georgia Yes 10 An amount less than the maximum benefit calculated excluding the capped children 9 n.a., always capped Hawaii No n.a. n.a. n.a. Idaho No 10 n.a. n.a. n.a. Illinois No n.a. n.a. n.a. Indiana Yes 10 None n.a., always capped Iowa No n.a. n.a. n.a. Kansas No n.a. n.a. n.a. Kentucky No n.a. n.a. n.a. Louisiana No n.a. n.a. n.a. Maine No n.a. n.a. n.a. Maryland No n.a. n.a. n.a. Massachusetts Yes 10 11 None (disregard) 12 20 11 Michigan No n.a. n.a. n.a. Minnesota No n.a. n.a. n.a. Mississippi Yes 10 None n.a., always capped Missouri No n.a. n.a. n.a. Montana No n.a. n.a. n.a. Nebraska No n.a. n.a. n.a. Nevada No n.a. n.a. n.a. New Hampshire No n.a. n.a. n.a. New Jersey Yes 13 10 None 12 14 New Mexico No n.a. n.a. n.a. New York No n.a. n.a. n.a. North Carolina Yes 10 15 None n.a., always capped North Dakota Yes 8 None 12 Ohio No n.a. n.a. n.a. Oklahoma No n.a. n.a. n.a. Oregon No n.a. n.a. n.a. Pennsylvania No n.a. n.a. n.a. Rhode Island No n.a. n.a. n.a. Table IV.B.1. Family Cap Policies, July 2017 200 Welfare Rules Databook: State TANF Policies as of July 2017 State Family cap policy 1 Special treatment if child born more than X months after case opening Increase in cash benefit for an additional child (and special provisions) Special treatment discontinued if case closed X months 2 South Carolina Yes 10 None (voucher) 16 n.a., always capped South Dakota No n.a. n.a. n.a. Tennessee Yes 10 None 1 17 Texas No n.a. n.a. n.a. Utah No n.a. n.a. n.a. Vermont No n.a. n.a. n.a. Virginia Yes 10 None n.a., always capped Washington No n.a. n.a. n.a. West Virginia No n.a. n.a. n.a. Wisconsin No 10 n.a. n.a. n.a. Wyoming No n.a. n.a. n.a. 10 The state provides a flat maximum benefit, regardless of family size. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Some units may be exempt from the family cap policies. See the WRD for more details on exemption policies. 2 This column describes the number of months a unit must remain off assistance to regain eligibility for a previously capped child. Some states permanently exclude capped children, even if the unit cycles on and off assistance, while other states may include previously capped children in benefit and eligibility calculations if the unit has not received assistance for a specified period. 3 The child is generally considered benefit-capped until the month after the child’s 18th birthday. A benefit-capped child may receive cash assistance prior to the child’s 18th birthday if the child becomes a minor parent, is adopted, or lives with a caretaker adult due to a court decision, parental death, or parental abandonment and that adult applies for assistance on the child’s behalf. 4 Units subject to the family cap receive an additional earned income disregard equal to the lost benefit amount. This additional disregard is allowed for each month the member is excluded because of the cap. 5 The child is considered benefit-capped until the month after the child’s 18th birthday. A benefit-capped child may receive cash assistance prior to the child’s 18th birthday if the child becomes a minor parent or is adopted. 6 Any child born to a parent receiving assistance will not be included in the unit. This is applicable to both children conceived prior to a unit’s certification as well as to those children conceived after a unit’s certification. 7 In addition to the family cap policy, any child born after December 31, 1998 to an unmarried minor parent is ineligible for cash assistance, regardless of whether the minor was receiving aid at the time of the birth. If the minor received benefits within 10 months of the birth of the child, the child will always be capped. If the minor did not receive benefits within 10 months of the birth of the child, the child will be eligible for assistance once the minor turns 18. Units in which the child is not permanently capped may receive noncash assistance services in the form of vouchers upon request, but he or she will not be automatically given vouchers each month. Receipt is based on need, and the total monthly value of the vouchers is capped at $69. 8 If the family reapplies for assistance after a break of six or more continuous months, the family cap will apply again to any child born more than 10 months from the date of reapplication, and there will be no increase in the benefit. 9 The additional child increases the standard of need but not the family maximum. If the family has no income, the cash benefit will not increase. However, if the family has income, the benefit may increase, but cannot increase higher than the maximum payment for the family size excluding the capped child. Table IV.B.1. Family Cap Policies, July 2017 Welfare Rules Databook: State TANF Policies as of July 2017 201 14 After case closure, if the recipient is employed for three months and loses the job by no fault of his or her own and then reapplies for assistance, the previously capped child is included in the unit. These units, however, do not receive a new 10- month grace period for any subsequent pregnancies. 15 The family cap does not apply to adoptees or to parents receiving assistance from another state. 16 Benefits are available in the form of vouchers up to the amount of increase in cash benefits the unit would have received for the child. 17 The family cap will continue until the case is closed. If the case is reopened, the cap is discontinued unless the case was closed for noncooperation with child support requirements or noncompliance with the work activity requirement. 11 A child is eligible if the child is born at least 20 months after the date that a grantee’s eligibility for TAFDC has ended; the grantee remained ineligible for at least 12 consecutive months from the closing date; and the grantee received TAFDC for no more than 10 consecutive months immediately preceding the child’s birth. 12 Units subject to the family cap receive an additional earned income disregard equal to the first $90 of income received by or on behalf of a capped child in any month. 13 Units in which at least one adult member of the unit is working (any number of hours) are not subject to the family cap. 202 Welfare Rules Databook: State TANF Policies as of July 2017 State Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Other Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Alabama 60 Yes No n.a. n.a. n.a. n.a. Alaska 60 Yes 3 No n.a. n.a. n.a. n.a. Arizona 12 Yes No n.a. n.a. 4 Yes No Arkansas 24 Yes No n.a. n.a. n.a. n.a. California 48 No Yes n.a. n.a. n.a. n.a. Colorado 60 Yes No n.a. n.a. n.a. n.a. Connecticut 21 5 Yes No n.a. n.a. n.a. n.a. Delaware All, except TWP 36 6 Yes No n.a. n.a. n.a. n.a. TWP n.a., no limit n.a. n.a. n.a. n.a. n.a. n.a. D.C. 60 7 No No Benefit is reduced for entire unit 7 n.a. n.a. n.a. Florida 48 8 Yes No n.a. n.a. n.a. n.a. Georgia 48 Yes No n.a. n.a. n.a. n.a. Hawaii 60 Yes No n.a. n.a. n.a. n.a. Idaho 24 9 Yes No n.a. n.a. n.a. n.a. Illinois 60 Yes 3 No n.a. n.a. n.a. n.a. Indiana Lifetime limit 60 Yes 3 No n.a. n.a. n.a. n.a. Benefit reduction limit 24 10 No Yes n.a. n.a. n.a. n.a. Iowa 60 11 Yes No n.a. n.a. n.a. n.a. Kansas 24 Yes No n.a. n.a. n.a. n.a. Kentucky 60 Yes No n.a. n.a. n.a. n.a. Louisiana 60 Yes No n.a. 24 of 60 months Yes No Maine 60 Yes No n.a. n.a. n.a. n.a. Maryland 60 Yes No n.a. n.a. n.a. n.a. Table IV.C.1. Time Limit Policies, July 2017 Lifetime limit Intermittent time limit Consequences Consequences Welfare Rules Databook: State TANF Policies as of July 2017 203 State Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Other Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Massachusetts Exempt n.a., no limit n.a. n.a. n.a. n.a. n.a. n.a. Non-exempt n.a., no limit n.a. n.a. n.a. 24 of 60 months Yes No Michigan 48 Yes No n.a. n.a. n.a. n.a. Minnesota 60 Yes No n.a. n.a. n.a. n.a. Mississippi 60 Yes No n.a. n.a. n.a. n.a. Missouri 45 Yes No n.a. n.a. n.a. n.a. Montana 60 Yes No n.a. n.a. n.a. n.a. Nebraska Time-limited assistance 60 Yes No n.a. n.a. n.a. n.a. Non-time-limited assistance n.a., no limit n.a. n.a. n.a. n.a. n.a. n.a. Nevada 60 Yes No n.a. 24 months; followed by 12 months of ineligibility 12 Yes No New Hampshire NHEP 60 Yes No n.a. n.a. n.a. n.a. FAP n.a., no limit 13 n.a. n.a. n.a. n.a. n.a. n.a. New Jersey 60 Yes No n.a. n.a. n.a. n.a. New Mexico NMW 60 Yes No n.a. n.a. n.a. n.a. EWP 24 Yes No n.a. n.a. n.a. n.a. New York 60 14 Yes No n.a. n.a. n.a. n.a. North Carolina 60 Yes No n.a. 24 months; followed by 36 months of ineligibility Yes No North Dakota 60 Yes No n.a. n.a. n.a. n.a. Table IV.C.1. Time Limit Policies, July 2017 Lifetime limit Intermittent time limit Consequences Consequences 204 Welfare Rules Databook: State TANF Policies as of July 2017 State Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Other Limit (months) 1 Loss of entire benefit 2 Adult removed from unit Ohio 60 15 Yes No n.a. 36 months; followed by 24 months of ineligibility Yes No Oklahoma 60 Yes No n.a. n.a. n.a. n.a. Oregon 60 No Yes n.a. n.a. n.a. n.a. Pennsylvania 60 Yes No n.a. n.a. n.a. n.a. Rhode Island 48 Yes No n.a. 24 of 60 months Yes No South Carolina All, except CARES 60 Yes No n.a. 24 of 120 months Yes No CARES n.a., no limit n.a. n.a. n.a. n.a. n.a. n.a. South Dakota 60 Yes No n.a. n.a. n.a. n.a. Tennessee 60 16 Yes No n.a. n.a. n.a. n.a. Texas 60 Yes No n.a. 12, 24, or 36 months; followed by 60 months of ineligibility 17 No Yes Utah 36 Yes No n.a. n.a. 18 n.a. n.a. Vermont 60 Yes No n.a. n.a. 19 n.a. n.a. Virginia All, except VIEW 60 Yes No n.a. n.a. n.a. n.a. VIEW 60 Yes No n.a. 24 months; followed by 24 months of ineligibility 20 Yes No Washington 60 Yes No n.a. n.a. n.a. n.a. West Virginia 60 Yes No n.a. n.a. n.a. n.a. Wisconsin 60 Yes No n.a. n.a. n.a. n.a. Wyoming 60 Yes No n.a. n.a. n.a. n.a. Table IV.C.1. Time Limit Policies, July 2017 Lifetime limit Intermittent time limit Consequences Consequences Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Welfare Rules Databook: State TANF Policies as of July 2017 205 10 The income of the ineligible individual is still counted in determining the unit’s benefits; however, the needs of the ineligible individual are not included when determining the unit’s benefits. 1 Families may qualify for exemptions from or extensions to the time limit. See tables IV.C.2(a), IV.C.2(b),IV.C.3(a), and IV.C.3(b) for details about state exemption and extension policies. 2 In certain circumstances, a child may be able to continue receiving benefits after the 60 months. Because the time limit follows the adult, a child may enter a new household and become eligible in a new assistance unit. 3 If the adult who has reached the 60-month lifetime limit is not the parent of any child in the assistance unit, only the adult is ineligible for benefits. Children who do not live with a parent can therefore continue to receive assistance after their caretaker reaches the 60-month limit. 4 Two-parent families, in which neither parent is disabled, are eligible for only six months of assistance in any 12-month period. 5 Recipients may apply for extensions after 21 months of benefits, but they may not receive more than 60 total months of assistance. 6 The 36-month time limit applies to assistance units that applied for benefits on or after January 1, 2000. Units that received benefits before this date are eligible for 48 months of assistance. 7 After 60 months, eligibility and benefits are computed using a Reduced Payment Level, which equals 30 percent of the standard Payment Level for the unit’s size. 9 When there is more than one adult in the family, the adult with the greatest number of months of participation must be used to determine when the family reaches the time limit. 8 An individual may request a hardship exemption to the lifetime time limit at any time before or after the time limit expires. 11 In addition to the 60-month lifetime limit, units must establish a time frame with a specific ending date, during which the recipient expects to become self-sufficient (i.e., when income will be above eligibility limits). 12 After receiving 24 months of cumulative or consecutive assistance, the household is ineligible for TANF cash benefits for 12 consecutive months, unless a qualifying hardship exists. This continues until the household has received 60 months of TANF assistance from Nevada or any other state. 13 Groups eligible for or receiving the Family Assistance Program (FAP) are automatically exempt from the 60-month time limit and must have eligibility continued beyond 60 months for as long as the family continues to meet FAP eligibility criteria. 14 Units in compliance with TANF program rules may continue to receive benefits through a separate state program beyond 60 months. 15 Ohio has a 36-month limit on assistance. However, units are eligible for additional assistance, up to the federal time limit of 60 months, through either a hardship or good cause extension. For good cause, a unit must have been ineligible for 24 months and show good cause for reapplying in order to receive additional assistance. 16 If clients marry with different months of assistance, the number of months counted towards the time limit will be the higher of the two. If a marriage dissolves, the number of countable months of the two-parent unit will be the same if the parents reapply for assistance regardless of months earned prior to the marriage. 206 Welfare Rules Databook: State TANF Policies as of July 2017 17 The 12-month limit applies to nonexempt recipients who (1) did not complete the 11th grade and have 18 months or more of recent work experience or (2) have a high school diploma or GED, a certificate from a postsecondary school, or a certificate or degree from a vocational or technical school and any work experience. The 24- month limit applies to nonexempt recipients who (1) did not complete the 11th grade and have between 6 and 17 months of recent work experience or (2) completed the 11th grade but not the 12th grade or have a GED, and have completed 17 or fewer months of work experience. The 36-month limit applies to nonexempt recipients who have less than six months of recent work experience and did not complete the 11th grade. 18 Families with two parents who are each capable of earning at least $500 per month are eligible for only seven months of assistance in any 13-month period. 19 Recipients will be ineligible for assistance for two months if their grant has been terminated for either noncompliance or not fulfilling the work requirement, without good cause, after the 60th month of assistance. 20 After receiving 24 months of assistance, the unit may receive up to 12 months of transitional benefits. The 24 months of ineligibility begins with the month in which the case was closed or in the month transitional benefits were terminated, whichever is later. Welfare Rules Databook: State TANF Policies as of July 2017 207 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Ill, incapacitated, or has a disability Caring for a person who is ill, incapacitated, or has a disability 2 Alabama No No No No Alaska No No Yes Yes Arizona No No No No Arkansas No Yes Yes Yes California No No Yes 3 Yes Colorado 4 No No No No Connecticut No Yes 5 Yes Yes Delaware No No Yes 6 Yes 7 D.C. No No Yes 8 Yes 9 Florida No No No Yes Georgia No No No No Hawaii No No Yes Yes Idaho No No No No Illinois 30 hrs. 10 No No Yes 11 Indiana No No Yes 12 Yes 12 Iowa No No No No Kansas No No No No Kentucky No No No No Louisiana No No Yes 13 No Maine No No No No Maryland Any earned income No Yes 14 No Massachusetts Exempt 15 n.a. n.a. Yes Yes Non-exempt No No n.a. 16 n.a. 16 Michigan No No Yes 17 Yes 18 Minnesota No No No No Mississippi No No No No Missouri No No No 19 No 19 Table IV.C.2(a). Time Limit Exemption Policies, July 2017 1 Unit exempt for months in which the head was: 208 Welfare Rules Databook: State TANF Policies as of July 2017 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Ill, incapacitated, or has a disability Caring for a person who is ill, incapacitated, or has a disability 2 Montana No No No No Nebraska Time-limited assistance No No n.a. 16 n.a. 16 Non-time-limited assistance 20 n.a. n.a. Yes Yes Nevada No No No No New Hampshire NHEP No No Yes 21 Yes 22 FAP 15 n.a. n.a. Yes Yes New Jersey No No Yes Yes New Mexico No No No No New York 23 No No No No North Carolina No No Yes 24 Yes 25 North Dakota No No Yes 26 Yes Ohio No No No No Oklahoma No No No No Oregon No No 27 Yes Yes Pennsylvania No No No No Rhode Island No No No No South Carolina All, except CARES No No n.a. 16 Yes 28 CARES 15 n.a. n.a. Yes n.a. South Dakota No No No No Tennessee No No No No Texas No No Yes 29 Yes 29 Utah No No No No Vermont No No Yes Yes Table IV.C.2(a). Time Limit Exemption Policies, July 2017 1 Unit exempt for months in which the head was: Welfare Rules Databook: State TANF Policies as of July 2017 209 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Ill, incapacitated, or has a disability Caring for a person who is ill, incapacitated, or has a disability 2 Virginia All, except VIEW 30 n.a. n.a. Yes 31 Yes 32 VIEW No No n.a. 33 n.a. 33 Washington No No No No West Virginia No No No No Wisconsin No No No No Wyoming No No No No 4 While state funds cannot be used to exempt units meeting these criteria, counties have the option to use county funds for exemptions. 5 Certain recipients who have received 20 months of benefits and are determined unemployable (age 40 or older, unemployed, have not completed grade six, and have not been employed over six months in the past five years) may be exempt from the time limit. 6 Disabled parents and caretakers will be referred to the Transitional Work Program for the duration of their disability. 3 Months in which the person has been incapacitated for at least 30 days are exempt. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Exemption policies apply to months in which the state does not count a month of assistance toward the state’s time limit (or \”stops the clock\”). These policies are potential exemptions and may not be granted to all that are eligible. In most states, caseworkers have discretion in applying the exemptions. If a state has multiple time limits (for example, a periodic limit and a lifetime limit) and applies the exemption policies differently to the time limits, the differences are footnoted. Time limits apply only to months when adults receive what is considered TANF assistance, which includes all regular monthly cash aid and some other types of help. Some types of aid considered non-assistance are subsidized jobs programs and child care and transportation help for employed families. Months in which only non-assistance is received are always exempt from the TANF time limits. See section 260.31 of the final TANF rule for more information on assistance and non-assistance. The federal government requires that states disregard months during which an adult lived on a Native American reservation or in an Alaskan Native village with an adult unemployment rate of at least 50 percent. Furthermore, because time-limit calculations apply only to families that include adults (or minor heads of household), time limits do not apply to child-only units or to any month in which an adult received assistance as a dependent child. Many states exempt months in which a unit receives diversion payments. These policies are captured in table I.A.1. For information on whether months of receipt of transitional cash benefits (for families leaving TANF with employment) are counted or exempted, see the full database. This table focuses on the exemption rules in place as of July 2017. Rules may have differed for months of assistance received previously. Past policies are mentioned if they exempted a substantial part of the caseload for certain past time periods under TANF. 2 States are shown as having an exemption if they exempt months in which a parent must care for a child or adult in the household who meets the state’s definition for ill or incapacitated. Table IV.C.2(a). Time Limit Exemption Policies, July 2017 1 Unit exempt for months in which the head was: 210 Welfare Rules Databook: State TANF Policies as of July 2017 15 Recipients in this component are exempt from time limits. The criteria for inclusion in this component may include some of the exemptions listed in this table. For exemptions that are not relevant to the criteria for inclusion in this component, n.a. is listed. 17 The recipient must be incapacitated for more than 90 days. 18 The exemption applies when caring for a child or spouse. 19 To meet this exemption, there must be no other satisfactory alternative plan or care available. 20 Recipients in this component are exempt from time limits. The criteria for inclusion in this component may include some of the exemptions listed in this table. For exemptions that are not relevant to the criteria for inclusion in this component, n.a. is listed. 24 Months in which the person is ill or incapacitated are exempt from the benefit waiting period. 25 Months in which the person is caring for someone who is ill or incapacitated are exempt from the benefit waiting period. 26 People with a disability and receiving SSI are always exempted; people who are incapacitated who do not receive SSI may request an exemption. 16 Individuals with this characteristic are placed in an alternative component that is exempt from time limits. 21 The recipient must apply for disability benefits before a second six-month extension can be approved. Individuals who are unable to work due to physical or mental disability are later placed in the FAP which does not have time limits. 22 After receiving the first six-month extension, the family may be transferred to the Family Assistance Program component and become permanently exempt from time limits and work requirements. 23 This state continues to fund families beyond 60 months of benefit receipt using state funding. However, the state may exempt certain months in calculating the number of federally funded months of assistance. 11 The ill, incapacitated, or disabled person must be a related child under age 18 or a spouse. Months in which the family has a disabled child in the home approved for a waiver under the Home and Community-Based Care Program are also exempt. 13 Months in which the person is ill or incapacitated are exempt from the periodic time limit. 14 Persons who are ill or incapacitated must have a pending SSI application or appeal in process in order to be exempt from the time limit. 12 This exemption applies to the benefit reduction limit. 7 When the unit head has been deemed unemployable because he or she is caring for a disabled family member (only a spouse or child who must be living in the home), he or she is placed in the Children’s Program, which is not time limited. 8 Months in which the person is ill or incapacitated are exempt from the benefit reduction limit. 9 Months in which the person is caring for someone who is ill or incapacitated are exempt from the benefit reduction limit. 10 The head of a one-parent unit must work 30 hours a week, while both parents of a two-parent unit must work a combined total of 35 hours a week to receive the exemption. Welfare Rules Databook: State TANF Policies as of July 2017 211 33 Individuals with this characteristic are placed in an alternative component. 28 Months in which the person is caring for someone who is ill or incapacitated are exempt from the periodic time limit. 29 Months with this characteristic are exempt from work activities. When people are exempt from work activities (and do not volunteer to participate), those months are exempt from the benefit waiting period. 30 Recipients in this component are exempt from the 24-month benefit waiting period but not the 60-month lifetime limit. The criteria for inclusion in this component may include some of the exemptions listed in this table. For exemptions that are not relevant to the criteria for inclusion in this component, n.a. is listed. 31 Units with this characteristic are placed in this component and are therefore exempt from the benefit waiting period. Participants who have a temporary illness, incapacity, or disability are still subject to the lifetime time limit, while SSI recipients are exempt from the lifetime limit. 32 Units with this characteristic are placed in this component and are therefore exempt from the benefit waiting period, but their months still count for the lifetime time limit. 27 For a two-parent family, months of benefits received between October 1, 2007 and June 30, 2009 or between October 1, 2011 and April 30, 2012 are not counted if the reason for deprivation was unemployment or underemployment. 212 Welfare Rules Databook: State TANF Policies as of July 2017 State Caring for a child under age X (months) In month X or later of pregnancy Minor parent Age X or older (years) Victim of domestic violence Other Alabama No No No No No n.a. Alaska No No Yes No Yes n.a. Arizona No No No No No Receiving less than a $100 benefit; Full amount of assistance is reimbursed by child support; Receiving assistance in another state; Receiving benefits in Arizona prior to October 2002 Arkansas 3 2 7 No 60 Yes Not required to participate in work activities; Not receiving support services; Receiving assistance in another state (up to 36 months not counted) California 24 3 No Yes 4 60 Yes Sanctioned for noncompliance; Grant is less than $10; Individual is a caretaker of either a dependent child of the court, a kinship care program child, or a child at risk of placement in foster care Colorado 5 No 6 No No No No n.a. Connecticut 12 7 1 8 Yes 9 60 No n.a. Delaware No No No No No Waiting on SSI\/SSDI application; A non-needy, non- parent caretaker receiving benefits D.C. No No Yes 10 60 10 Yes 10 n.a. Florida No No 11 Yes 11 No No Not job-ready; Receiving less than a $10 benefit; Not receiving support services Georgia No No No No No Has an active case with Child Protective Services that creates a barrier to self-sufficiency Hawaii 6 No No 65 Yes 12 n.a. Idaho No No 11 Yes 11 No Yes Receiving a benefit payment in error; Sanctioned for noncompliance Illinois No No Yes No Yes In a post-secondary education program 13 Indiana 3 No No 60 No n.a. Iowa No No No No No Receiving SSI Table IV.C.2(b). Time Limit Exemption Policies (continued), July 2017 1 Unit exempt for months in which the head was: Welfare Rules Databook: State TANF Policies as of July 2017 213 State Caring for a child under age X (months) In month X or later of pregnancy Minor parent Age X or older (years) Victim of domestic violence Other Kansas No No Yes No No n.a. Kentucky No No Yes 14 No No Receiving retroactive payments Louisiana No 7 15 No No No Benefits were received in another state; the parent has earned income and is eligible to receive the $900 time-limited deduction 16 Maine No No No No No Receiving SSI Maryland No No No No Yes No own-children in the assistance unit Massachusetts Exempt 17 24 18 6 19 Yes 60 n.a. n.a. Non-exempt n.a. 20 n.a. 20 n.a. 20 n.a. 20 Yes 15 Not required to participate in work activities; Sanctioned for noncompliance 21 Michigan No No No 65 Yes n.a. Minnesota No No Yes 22 60 Yes 23 Receiving only the food portion of the grant Mississippi No No No No No n.a. Missouri No No Yes 4 60 No Sanctioned for noncompliance prior to October 1998 Montana No No Yes 4 No No n.a. Nebraska Time-limited assistance n.a. 24 n.a. 20 No 25 n.a. 20 n.a. 20 Sanctioned for noncompliance Non-time-limited assistance 17 3 26 8 27 n.a. 65 Yes n.a. Nevada No No No No No n.a. New Hampshire NHEP No No No n.a. 20 No n.a. FAP 17 n.a. n.a. n.a. 60 n.a. n.a. New Jersey No No Yes 60 Yes Not job-ready; Sanctioned for noncompliance Table IV.C.2(b). Time Limit Exemption Policies (continued), July 2017 1 Unit exempt for months in which the head was: 214 Welfare Rules Databook: State TANF Policies as of July 2017 State Caring for a child under age X (months) In month X or later of pregnancy Minor parent Age X or older (years) Victim of domestic violence Other New Mexico NMW No No No No No Participating in post-secondary education for up to 24 months EWP No No No No No n.a. New York 28 No No No No No Receiving an emergency, non- recurring payment North Carolina 12 29 No Yes No Yes 30 Benefits were received in another state; Participating in drug, alcohol, or mental health treatment; Not receiving support services; Not required to participate in work activities; Sanctioned for noncompliance 31 North Dakota No No No 65 Yes A caretaker subject to Pay after Performance whose needs are not yet included in the grant; Sanctioned for noncompliance; Receiving less than a $10 benefit Ohio No No No No No Receiving assistance in a state with a time-limit waiver; Receiving support services when at least one assistance group member is employed Oklahoma No No No No No n.a. Oregon No No No 32 No Yes In drug, alcohol, or mental health treatment; Not job-ready; In a degree program; Receiving benefits before July 2003; Participating in JOBS Plus, Post- TANF, or State Family Pre-SSI\/SSDI (SFPSS) programs after October 1, 2007; Participating in selected activities between July 2003 and September 2007; Receiving benefits between July 2008 and April 2012; Deprived of needed medical care 33 Table IV.C.2(b). Time Limit Exemption Policies (continued), July 2017 1 Unit exempt for months in which the head was: Welfare Rules Databook: State TANF Policies as of July 2017 215 State Caring for a child under age X (months) In month X or later of pregnancy Minor parent Age X or older (years) Victim of domestic violence Other Pennsylvania No No No No Yes Receiving assistance in another state prior to March 1997; Sanctioned for noncompliance; No own-children in the assistance unit Rhode Island No No Yes No Yes n.a. South Carolina All, except CARES No No Yes 15 No Yes 15 Benefits were received in another state; Not receiving support services; An adult family member is providing a home for and caring for a child whom the state has determined to be abandoned and for whom the alternative placement is foster care; Benefit is less than $10 34 CARES 17 n.a. n.a. n.a. n.a. n.a. n.a. South Dakota No No No No No n.a. Tennessee No No No No No n.a. Texas 12 35 No No 60 35 No Sanctioned for noncompliance, Unemployed due to high local unemployment 36 Utah No No No No No Receiving SSI; Receiving Transitional Cash Assistance payments after April 1, 2007 Vermont 24 37 No Yes 60 Yes Not required to participate in work activities Virginia All, except VIEW 38 12 39 n.a. Yes 39 60 39 n.a. Receiving SSI; Sanctioned for noncompliance VIEW n.a. 40 No n.a. 40 n.a. 40 Yes Not receiving support services 41 Washington No No Yes No No n.a. West Virginia No No No No No n.a. Wisconsin 2 No No No No n.a. Wyoming No No Yes 4 No No n.a. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table IV.C.2(b). Time Limit Exemption Policies (continued), July 2017 1 Unit exempt for months in which the head was: 216 Welfare Rules Databook: State TANF Policies as of July 2017 13 To be exempt, the caretaker relative must attend the postsecondary education program full time and retain a cumulative GPA of at least 2.5. The exemption only applies to one-parent units. 14 A minor parent who lives in an adult-supervised setting and is not considered a head of household may be exempt. 4 Minor parents are exempt in months in which they are participating in designated activity requirements, such as high school, GED, or a state learning program. 5 While state funds cannot be used to exempt units meeting these criteria, counties have the option to use county funds for exemptions. 2 A parent is exempt if caring for a child under three months of age. If no child care is available, a parent is exempt if caring for a child under 12 months of age. 11 A minor is exempt from the time limit if he or she has a child or if she is pregnant. 12 To be exempt, the individual must be unemployed, employed less than 20 hours a week, or attend school for no more than six credit hours per week, have had a relationship to the perpetrator of the violence, and have taken action as a result of the domestic violence (such as getting a court order protecting the individual from the perpetrator or living in a domestic violence shelter within the past 12 months). 6 While the state does not allow for an explicit exemption for caring for a child under a specific age, if there is inadequate access to child care an exemption may be granted so the parent may stay home to care for the child. 7 The exemption does not apply to children subject to a family cap. 8 A woman who is pregnant may be granted an exemption if a physician certifies the woman’s inability to work. A woman in postpartum is granted an exemption until the end of the month that includes the sixth week after the pregnancy has ended. 9 Minor parents may be exempt from time limits when exempt from the requirements of living with an adult. 10 This exemption applies to the benefit reduction limit. 1 Exemption policies apply to months in which the state does not count a month of assistance toward the state’s time limit (or \”stops the clock\”). These policies are potential exemptions and may not be granted to all that are eligible. In most states, caseworkers have discretion in applying the exemptions. If a state has multiple time limits (for example, a periodic limit and a lifetime limit) and applies the exemption policies differently to the time limits, the differences are footnoted. Time limits apply only to months when adults receive what is considered TANF assistance, which includes all regular monthly cash aid and some other types of help. Some types of aid considered non-assistance are subsidized jobs programs and child care and transportation help for employed families. Months in which only non-assistance is received are always exempt from the TANF time limits. See section 260.31 of the final TANF rule for more information on assistance and non-assistance. The federal government requires that states disregard months during which an adult lived on a Native American reservation or in an Alaskan Native village with an adult unemployment rate of at least 50 percent. Furthermore, because time-limit calculations apply only to families that include adults (or minor heads of household), time limits do not apply to child-only units or to any month in which an adult received assistance as a dependent child. Many states exempt months in which a unit receives diversion payments. These policies are captured in table I.A.1. For information on whether months of receipt of transitional cash benefits (for families leaving TANF with employment) are counted or exempted, see the full database. This table focuses on the exemption rules in place as of July 2017. Rules may have differed for months of assistance received previously. Past policies are mentioned if they exempted a substantial part of the caseload for certain past time periods under TANF. 3 Months spent as primary care provider for one child, birth to 23 months old, are exempt. The exemption does not apply to pregnant and parenting teens under age 20 who do not have a high school diploma or equivalent. For two-parent families, each parent has the option to receive the exemption, but only one exemption can be granted at a time. An individual may only be eligible for this exemption one time. Welfare Rules Databook: State TANF Policies as of July 2017 217 33 A state-wide exemption was applied due to economic hardship for all participants between July 1, 2008 and April 30, 2012. Additionally participants were exempt for months they were not required to participate in work activities between July 2003 and September 2003. 30 This exemption applies to the benefit waiting period. 31 The assistance unit may receive an exemption for the benefit waiting period, but not the lifetime limit, for months in which the unit meets the following circumstances: benefits were received in another state; participating in drug, alcohol, or mental health treatment; not receiving support services; or not required to participate in work activities. 24 Individuals caring for a child under 12 weeks of age are placed in an alternative component that is exempt from time limits. 25 A minor parent who meets the definition of a dependent child is exempt. 26 The unit is placed in this component if caring for a child under 12 weeks of age. 27 Pregnant women are placed in this component beginning the month before the month of their due date. 28 This state continues to fund families beyond 60 months of benefit receipt using state funding. However, the state may exempt certain months in calculating the number of federally funded months of assistance. 29 Single parents caring for a child under 12 months old are exempt from the benefit waiting period time limit. 32 If the minor parent is not the head of the assistance unit, the months do not count. 23 To be exempt, the family must be complying with a safety plan. 15 This exemption applies to the periodic time limit. 16 The assistance unit may receive an exemption to the periodic limit, but not the lifetime limit, for months in which the unit receives benefits in another state or the parent has earned income and is eligible to receive the $900 time-limited deduction. 20 Individuals with this characteristic are placed in an alternative component that is exempt from time limits. 21 The assistance unit may receive an exemption to the periodic limit, but not the lifetime limit, for months in which either a sanction results in the ineligibility of the entire unit or the unit head does not have to participate in work activities. 17 Recipients in this component are exempt from time limits. The criteria for inclusion in this component may include some of the exemptions listed in this table. For exemptions that are not relevant to the criteria for inclusion in this component, n.a. is listed. 18 The unit is placed in this component if (1) the recipient is caring for a child under age 2 who is in the unit or would be in the unit except that the child receives SSI, foster care maintenance payments, or adoption assistance, or (2) the recipient is caring for a child under 3 months old who is not included in the unit. 19 Units where the head is pregnant and the child is expected to be born within 120 days are placed in this component. 22 To be exempt, minor parents must be living in a supervised setting and complying with a social service plan or, if they are 18 or 19 years old, they must be complying with education requirements. 218 Welfare Rules Databook: State TANF Policies as of July 2017 40 Individuals with this characteristic are placed in an alternative component. 41 Individuals not receiving support services may be exempt from the benefit waiting period time limit but not the lifetime limit. 35 Months with this characteristic are exempt from work activities. When people are exempt from work activities (and do not volunteer to participate), those months are exempt from the benefit waiting period. 36 Individuals who are unemployed because of high local unemployment may be exempt as long as they contact an average of 40 employers a month. This exemption applies only to the benefit waiting period time limit. 37 The first 12 months of a possible 24-month young-child time limit exemption do not count towards the state time limit. The child may be any age under 24 months. 38 Recipients in this component are exempt from the 24-month benefit waiting period but not the 60-month lifetime limit. The criteria for inclusion in this component may include some of the exemptions listed in this table. For exemptions that are not relevant to the criteria for inclusion in this component, n.a. is listed. 39 Units with this characteristic are placed in this component and are therefore exempt from the benefit waiting period, but their months still count for the lifetime time limit. 34 The assistance unit may receive an exemption for the periodic limit, but not the lifetime limit, for months in which the unit meets the following circumstances: benefits were received in another state; not receiving support services; an adult family member is providing a home for and caring for a child whom the state has determined to be abandoned and for whom the alternative placement is foster care; or the benefit is less than $10. Welfare Rules Databook: State TANF Policies as of July 2017 219 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Unemployed due to high local unemployment Ill, incapacitated, or has a disability 2 Caring for a person who is ill, incapacitated, or has a disability 3 Alabama No Yes 4 Yes 5 Yes Yes Alaska No No No Yes Yes Arizona No No No Yes Yes 6 Arkansas No Yes No Yes Yes California No No 7 No Yes Yes Colorado 8 No Yes No Yes Yes Connecticut 9 No Yes No No No Delaware 10 No No Yes 11 n.a. 12 n.a. 13 D.C. No No No Yes 14 Yes 14 Florida No Yes Yes Yes No Georgia No No No Yes Yes Hawaii No No No No No Idaho No No No Yes Yes Illinois No No No Yes Yes 15 Indiana 1 month for every 6 worked 16 Yes 14 No Yes 14 No Iowa No No No Yes Yes Kansas No No No Yes Yes Kentucky No Yes Yes Yes Yes Louisiana No Yes Yes Yes Yes Maine 35 hrs. No No Yes Yes Maryland No Yes No No No Massachusetts Exempt 17 n.a. n.a. n.a. n.a. n.a. Non-Exempt Case-by-case 18 Yes 18 Yes 18 n.a. 19 n.a. 19 Michigan No No No No No Minnesota 30 hrs. 20 No No Yes Yes Mississippi No Yes Yes Yes Yes Table IV.C.3(a). Time Limit Extension Policies, July 2017 1 Assistance extended to unit for months in which the head is: 220 Welfare Rules Databook: State TANF Policies as of July 2017 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Unemployed due to high local unemployment Ill, incapacitated, or has a disability 2 Caring for a person who is ill, incapacitated, or has a disability 3 Missouri No No No No No Montana No No No Yes Yes Nebraska Time-limited assistance No No No n.a. 19 n.a. 19 Non-time-limited assistance 17 n.a. n.a. n.a. n.a. n.a. Nevada No No No Yes Yes New Hampshire NHEP 30 hrs. 21 Yes 22 Yes 23 Yes 24 Yes 24 FAP 17 n.a. n.a. n.a. n.a. n.a. New Jersey 40 hrs. Yes No Yes No New Mexico NMW No No No Yes Yes EWP No No No No No New York 25 No No No Yes Yes North Carolina No Yes 26 Yes Yes Yes North Dakota No No No No No Ohio No No No No No Oklahoma 30 hrs. No No Yes Yes Oregon No No No Yes Yes Pennsylvania 30 hrs. 27 Yes 28 No Yes Yes Rhode Island No No Yes Yes Yes South Carolina All, except CARES 30 hrs. Yes 18 No n.a. 19 No CARES 17 n.a. n.a. n.a. n.a. n.a. South Dakota No No No Yes Yes Tennessee No No No Yes Yes Table IV.C.3(a). Time Limit Extension Policies, July 2017 1 Assistance extended to unit for months in which the head is: Welfare Rules Databook: State TANF Policies as of July 2017 221 State Working (min. weekly hrs.) or had earned income (min. dollars) Cooperating but unable to find employment Unemployed due to high local unemployment Ill, incapacitated, or has a disability 2 Caring for a person who is ill, incapacitated, or has a disability 3 Texas 29 Earnings up to $168 per month Yes 30 Yes Yes Yes Utah 31 20 hrs. 32 Yes No Yes Yes Vermont 33 Case-by-case Yes No Yes Yes Virginia All, except VIEW 34 n.a. n.a. n.a. Yes Yes VIEW No No Yes 35 n.a. 36 n.a. 36 Washington 32 hrs. 37 No No Yes Yes West Virginia 31 No No No Yes Yes Wisconsin No No Yes Yes Yes Wyoming No No No Yes Yes Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Extension policies apply to months in which the state provides additional benefits to families after they have reached their time limit. These policies are potential extensions and may not be granted to all that are eligible. In most states, caseworkers have discretion in applying the extensions. If a state has multiple time limits (for example, a periodic limit and a lifetime limit) and applies the extension policies differently to the time limits, the differences are footnoted. The federal government requires that states disregard months during which an adult lived on a Native American reservation or in an Alaskan Native village with an adult unemployment rate of at least 50 percent. Furthermore, because time limit calculations apply only to families that include adults (or minor heads of household), time limits do not apply to child-only units or to any month in which an adult received assistance as a dependent child. 2 See the Welfare Rules Database for more information on how states define illness, incapacity, and disability. Table IV.C.3(a). Time Limit Extension Policies, July 2017 1 Assistance extended to unit for months in which the head is: 3 States are shown as having an exemption if they exempt months in which a parent must care for a child or adult in the household who meets the state’s definition for ill or incapacitated. See the Welfare Rules Database for more information on how states define illness, incapacity, and disability. 4 To receive an extension, the individual must cooperate with Child Support and comply with JOBS in each month past the 60th month. Failure to meet these criteria results in permanent loss of program eligibility regardless of family circumstances and recovery of all benefits received past month 60. 5 The extension applies to those who live in SNAP ABAWD waiver counties, are compliant with JOBS, are not currently employed, and have not been disqualified due to noncompliance. 222 Welfare Rules Databook: State TANF Policies as of July 2017 13 Parents caring for a disabled child or spouse who is living in the same home are placed in the Children’s Program, which is not time-limited. 6 This extension is limited to single-parent units where the caretaker provides care for a disabled child, parent, spouse, or domestic partner. The unit must receive respite care for less than 20 hours a week and the disabled person may not attend school or vocational rehabilitation more than 20 hours a week. 7 An extension may be granted if the participant is considered likely to obtain employment within six months. 8 These policies are for Denver County. 9 Recipients may only receive two extensions unless they meet specific criteria. If recipients are sanctioned during the extension period, they are ineligible to receive benefits again. Units may receive only 60 total months of benefits, including extensions. 10 Extensions will not be granted if the caretaker adult received and rejected offers of employment, quit a job without good cause, was fired for cause, or did not comply with the contract. Units that reapply after their time limit may receive assistance if circumstances exist for an extension to be granted. 11 An extension may be available for caretakers who put forward their best effort but could not find a job due to a lack of suitable employment in the local economy; the maximum extension is 12 cumulative months. 12 These parents may be placed in the Children’s Program or the Transitional Work Program, which are not time-limited. 15 The ill, incapacitated, or disabled person must be a related child under age 18 or a spouse. Months in which the family has a disabled child in the home approved for a waiver under the Home and Community-Based Care Program are also exempt. 16 An individual may earn one month for every six months he or she works in an unsubsidized job. This extension applies to the benefit reduction limit. 20 The 30 hours a week applies to one-parent families. Two-parent families must participate in activities for 55 hours a week. For one-parent families, 25 of the 30 hours must be in employment; for two-parent families, 45 of the 55 hours must be in employment. Participants must be in compliance in the 60th month as well as for 10 of the last 12 months preceding the 61st month to be eligible for the extension. 14 This extension applies to the benefit reduction limit. 17 Recipients in this component are exempt from time limits. The requirements for inclusion in this component may include some of the criteria listed in this table. 18 This extension applies to the periodic time limit. 19 Individuals with this characteristic are placed in the alternative component, which is exempt from time limits. 21 The extension is available only to assistance groups whose cases were closed because of time limits and who are reapplying for assistance. 22 This extension cannot be used for cases that are reapplying for an extension after the case has been closed. 23 Extensions may be granted to: (1) everyone if New Hampshire Employment Security has determined that the state is eligible for the federal\/state cooperative extended benefit program, or if the state has an unemployment rate above 7 percent; (2) to families living in areas designated by the US Department of Labor as surplus areas. 24 Recipients who are unable to work are moved into the alternative component, which is exempt from time limits. Recipients with a temporary incapacity remain in the time-limited component but may receive an extension. 25 New York continues to provide noncash assistance to all units that have reached the 60-month federal time limit. Welfare Rules Databook: State TANF Policies as of July 2017 223 26 Individuals who are substantially complying with their mutual responsibility agreement and are unable to obtain or maintain employment that provides a basic subsistence (defined as less than the state’s maximum Work First payment minus 27.5 percent from each worker’s income) may receive an extension up to a maximum of six months from the benefit waiting period. 37 Households must participate full time (32 to 40 hours a week) in work-related activities, which may include a combination of working, job search, or preparing for work, in order to continue receiving assistance. 29 To qualify for any extension, a caretaker must have fewer than 12 months of activities or child support sanctions since November 1, 1996. 30 To be eligible for an extension, the recipient must have been unable to obtain sufficient employment during the last 12 consecutive months before the end of the 60- month limit and may not have had more than one sanction since November 1, 1996. The inability to obtain sufficient employment cannot be the result of voluntarily quitting a job. This applies to the lifetime limit but not the benefit waiting period. 33 All participating adults must be either deferred from work requirements or engaged in countable work activities equal to the work hour requirement in order for the unit to receive benefits past 60 months. 27 Two-parent families must work 55 hours a week to receive this extension. An individual may also receive this extension if he or she is working 20 hours a week and participating in approved work or training activities for at least 10 hours a week. 28 To receive this extension, an individual must have completed the eight-week job search and, in the first 12 months of assistance, begun an approved employment and training program for 30 hours a week or a full-time postsecondary educational activity. 31 For two-parent households, both parents must be eligible to receive an extension for the unit to qualify for continued financial assistance. If either parent does not qualify for an extension, the household is not eligible for continued financial assistance. 32 An extension is granted if the following two conditions are met: (1) during the previous two months, the parent was employed for no less than 20 hours a week, (2) the parent is expected to be employed for no less than 20 hours a week in the month for which financial assistance is being authorized. 34 Recipients in this component are exempt from the 24-month benefit waiting period but not the 60-month lifetime limit. The requirements for inclusion in this component may include some of the criteria listed in this table. 35 If local unemployment is greater than 10 percent for the six months prior to the client’s request for hardship exception, an extension may be granted. This extension applies to the benefit waiting period. 36 Individuals with this characteristic are placed in the alternative component. 224 Welfare Rules Databook: State TANF Policies as of July 2017 State Caring for a child under age X (months) In month X or later of pregnancy Age X or older (years) Victim of domestic violence Other Alabama No No 60 Yes In drug, alcohol, or mental health treatment; Unemployed due to significant personal barrier Alaska No No No Yes Suffering from a hardship Arizona No No 60 2 Yes Not receiving support services; Suffering from a hardship Arkansas 3 3 7 60 Yes Not required to participate in work activities; In an education or training program within 6 months of ending; Not receiving support services; Likely to neglect his or her children as a result of loss of benefit California No No 60 Yes Sanctioned for noncompliance; Full amount of cash assistance is reimbursed by child support; Unable to maintain employment or participate in activity requirements; A caretaker of either a dependent child of the court, a kinship care program child, or a child at risk of placement in foster care; Excluded from the AU for reasons other than exceeding the time limit Colorado 4 No No No Yes Suffering from a hardship; Not receiving support services; Suffering from family instability; Has a member of the assistance unit involved in the judicial system Connecticut 5 No No No Yes n.a. Delaware 6 No No No No Not receiving support services D.C. No No 60 7 Yes 7 In drug, alcohol, or mental health treatment; Not required to participate in work activities 7 Florida No No No Yes Not job-ready; Not receiving support services; Waiting on SSI\/SSDI application; Likely to require foster care or emergency shelter for children if benefits are ended Georgia No No No Yes Has an active case with Child Protective Services that creates a barrier to self-sufficiency Hawaii No No No No n.a. Table IV.C.3(b). Time Limit Extension Policies (continued), July 2017 1 Assistance extended to unit for months in which the head is: Welfare Rules Databook: State TANF Policies as of July 2017 225 State Caring for a child under age X (months) In month X or later of pregnancy Age X or older (years) Victim of domestic violence Other Idaho No No No No n.a. Illinois No No No Yes In drug, alcohol, or mental health treatment; In services that prevent full-time work; In an approved education or training program within 6 months of completion Indiana No No No Yes 8 Not receiving support services 8 Iowa No No No Yes In drug, alcohol, or mental health treatment; Not job-ready; Not receiving support services Kansas No No No Yes In family services with an open social service plan which prevents full-time employment Kentucky No No No Yes In a unit in which a member lost his or her job within 30 days of reaching the 60-month time limit; A non-parent relative caretaker and is likely to place the child in foster care if benefits are terminated Louisiana No No No Yes In drug, alcohol, or mental health treatment; Not job-ready; Loses job as a result of factors not related to job performance; Experiencing a temporary family crisis; Not receiving support services Maine No 7 No Yes In an approved education or vocational program 9 Maryland No No No No Suffering from a hardship; Not receiving support services Massachusetts Exempt 10 n.a. n.a. n.a. n.a. n.a. Non-Exempt n.a. 11 n.a. 11 n.a. 12 No Not receiving support services; In an approved education or training program 13 Michigan No No No No n.a. Minnesota No No No Yes 14 Assessed by a vocational specialist to be unemployable; mental illness or developmental disability that severely limits employability; An IQ below 80 or a learning disability that severely limits employability Mississippi No No 60 15 No Not receiving support services Table IV.C.3(b). Time Limit Extension Policies (continued), July 2017 1 Assistance extended to unit for months in which the head is: 226 Welfare Rules Databook: State TANF Policies as of July 2017 State Caring for a child under age X (months) In month X or later of pregnancy Age X or older (years) Victim of domestic violence Other Missouri No No No Yes In drug, alcohol, or mental health treatment; Experiencing a family crisis; Participating in children’s services with an open case Montana No No No Yes Has other special circumstances as determined by the caseworker Nebraska Time-limited assistance n.a. 11 n.a. 11 n.a. 16 n.a. 11 n.a. Non-time-limited assistance 10 n.a. n.a. n.a. n.a. n.a. Nevada 12 17 No 60 Yes In drug, alcohol, or mental health treatment; Suffering from a hardship; A minor parent; Participating in a program likely to lead to self-sufficiency New Hampshire NHEP No No n.a. 12 Yes In drug, alcohol, or mental health treatment; Lives in a household with an adult who has a learning disability; Loses employment and is actively seeking re-employment and unemployment compensation; Suffering from a hardship; Unable to find adequate child care FAP 10 n.a. n.a. n.a. n.a. n.a. New Jersey 3 7 No Yes Terminated from full-time, unsubsidized employment through no fault of his or her own; Suffering from a hardship or likely to undergo hardship if benefits are terminated; Employed full time New Mexico NMW No No 60 Yes 18 Waiting on SSI\/SSDI application EWP No No No No n.a. New York 19 No No No Yes In drug, alcohol, or mental health treatment; Not job-ready Table IV.C.3(b). Time Limit Extension Policies (continued), July 2017 1 Assistance extended to unit for months in which the head is: Welfare Rules Databook: State TANF Policies as of July 2017 227 State Caring for a child under age X (months) In month X or later of pregnancy Age X or older (years) Victim of domestic violence Other North Carolina No No No Yes In drug, alcohol, or mental health treatment; Not job-ready; Suffering from a hardship; Not receiving support services; Participating in post-secondary education with a 2.5 minimum grade point average 20 North Dakota No No No No n.a. Ohio No No No Yes Likely to undergo hardship if benefits are terminated Oklahoma No No No No In drug, alcohol, or mental health treatment; Underemployed for an extended period because of documented barriers; In a training or education program during the 60th month that could be completed within 12 months; Waiting on SSI\/SSDI application Oregon No No No Yes Is a minor parent; In drug, alcohol, or mental health treatment; Not job-ready; Has a mental health condition or learning disability; Enrolled in a degree program; Participating in JOBS Plus, Pre-TANF, Post-TANF, or State Family Pre-SSI\/SSDI (SFPSS) programs after October 1, 2007; Deprived of needed medical care Pennsylvania 12 21 No No Yes n.a. Rhode Island No No No Yes Homeless; Unable to work due to a critical circumstance South Carolina All, except CARES 12 22 7 23 No Yes In drug, alcohol, or mental health treatment; Has an open case with Child Protective Services; Participating in a county approved training program that will not be completed by the 24th month 24 CARES 10 n.a. n.a. n.a. n.a. n.a. South Dakota No No No Yes Not job-ready; Unable to work because of low intellectual function; Unable to work because of a family safety issue such as homelessness or family violence Table IV.C.3(b). Time Limit Extension Policies (continued), July 2017 1 Assistance extended to unit for months in which the head is: 228 Welfare Rules Databook: State TANF Policies as of July 2017 State Caring for a child under age X (months) In month X or later of pregnancy Age X or older (years) Victim of domestic violence Other Tennessee No No 65 Yes In drug, alcohol, or mental health treatment; Experiencing a significant life crisis 25 Texas 26 No No No Yes Not receiving support services Utah 27 No No No Yes Suffering from a hardship; Not receiving support services; Completed education or training in the 36th month and needs additional time to obtain employment; A minor parent; Participating in Next Generation Kids pilot program Vermont 28 24 29 No 30 60 Yes Not required to participate in work activities Virginia All, except VIEW 31 12 32 n.a. 60 32 n.a. n.a. VIEW n.a. 33 No n.a. 34 No Experiencing a hardship; Enrolled in post-secondary education; Lost a job or cannot find a job; Participating in training or education at the end of the 24-month benefit period when training or education is expected to be completed within the next 12 months 35 Washington No No 55 36 Yes 14 Has an open child welfare case; Exempt from work requirements 37 West Virginia 27 6 7 38 No Yes In a training or education program in the 55th month and making satisfactory progress toward graduation Wisconsin 2 No No Yes Has significant barriers to employment 39 Wyoming No No No Yes In a post-secondary degree program and within one year of completion; Claiming abandonment Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. Table IV.C.3(b). Time Limit Extension Policies (continued), July 2017 1 Assistance extended to unit for months in which the head is: Welfare Rules Databook: State TANF Policies as of July 2017 229 15 Units with an elderly caretaker may have their benefits extended beyond 60 months by converting the case to child-only. 10 Recipients in this component are exempt from time limits. The requirements for inclusion in this component may include some of the criteria listed in this table. 11 Individuals with this characteristic are placed in the alternative component, which is exempt from time limits. 17 Months in which the parent was exempt from activities requirements because he or she was caring for a young child are deducted from the 12-month extension period. For example, if the unit head was previously exempted from activities requirements for 3 months and then reaches the 60-month time limit, he or she may only receive an additional 9-month extension, provided one of his or her children is under 12 months old. 16 Individuals over the age of 65 are placed in the alternative component, which is exempt from time limits. 18 In addition to victims of domestic violence, individuals considered battered or subjected to extreme cruelty receive an extension. Battery and extreme cruelty occur when an individual has been physically attacked, sexually abused, raped, threatened with physical or sexual abuse, exposed to mental abuse, or deprived of medical care. 12 Individuals 60 years of age or older are placed in the alternative component, which is exempt from time limits. 13 These extensions apply to the periodic limit. 3 The extension applies to parents who either have child care or do not have child care and have children less than 12 months old. 2 This extension is limited to cases in which the unit head is a nonparent-specified relative and is included in the unit. 5 Recipients may only receive two extensions unless they meet specific criteria. If recipients are sanctioned during the extension period, they are ineligible to receive benefits again. Units may receive only 60 total months of benefits, including extensions. 4 These policies are for Denver County. 1 Extension policies apply to months in which the state provides additional benefits to families after they have reached their time limit. These policies are potential extensions and may not be granted to all that are eligible. In most states, caseworkers have discretion in applying the extensions. If a state has multiple time limits (for example, a periodic limit and a lifetime limit) and applies the extension policies differently to the time limits, the differences are footnoted. The federal government requires that states disregard months during which an adult lived on a Native American reservation or in an Alaskan Native village with an adult unemployment rate of at least 50 percent. Furthermore, because time limit calculations apply only to families that include adults (or minor heads of household), time limits do not apply to child-only units or to any month in which an adult received assistance as a dependent child. 9 An individual who is participating in good standing in an approved education program such as vocational education training may be eligible for an extension of up to six months. Three subsequent incremental extensions of up to six months are available. 14 To receive the extension, the family must be complying with activities in an approved plan. 8 This extension applies to the benefit reduction limit. 7 These extensions apply to the benefit reduction limit. 6 Extensions will not be granted if the caretaker adult received and rejected offers of employment, quit a job without good cause, was fired for cause, or did not comply with the contract. Units that reapply after their time limit may receive assistance if circumstances exist for an extension to be granted. 230 Welfare Rules Databook: State TANF Policies as of July 2017 26 To qualify for any extension, a caretaker must have fewer than 12 months of activities or child support sanctions since November 1, 1996. 27 For two-parent households, both parents must be eligible to receive an extension for the unit to qualify for continued financial assistance. If either parent does not qualify for an extension, the household is not eligible for continued financial assistance. 31 Recipients in this component are exempt from the 24-month benefit waiting period but not the 60-month lifetime limit. The requirements for inclusion in this component may include some of the criteria listed in this table. 33 Individuals with this characteristic are placed in an alternative component. 34 Individuals 60 years of age or older are placed in an alternative component. 35 These extensions apply to the benefit waiting period. 28 All participating adults must be either deferred from work requirements or engaged in countable work activities equal to the work hour requirement in order for the unit to receive benefits past 60 months. 29 The extension is limited to 24 months in a recipient’s lifetime. In addition, an extension may be allowed for 13 weeks following the birth of each additional child. 30 A participant may request a modification or deferment of the work requirement on the basis of an unpaid leave of absence from employment (to which the participant is entitled under Vermont’s Parental and Family Leave statute) and must provide verification that his or her employer has approved this leave of absence. 36 This extension applies only to nonparent relative caretakers. 37 Only a family’s first child welfare case potentially qualifies the family for a time limit extension. 32 Units with this characteristic are placed in this component and are therefore exempt from the benefit waiting period, but they are not eligible to receive an extension to the lifetime limit. 21 Recipients caring for children under six years old may also receive an extension if an alternative child care arrangement is unavailable. 22 This extension applies to the periodic time limit. 23 A pregnant woman, who has not been participating in the work program because she is in the seventh month of her pregnancy, may receive an extension to the periodic limit but not the lifetime limit. The woman must begin participating in the work program to receive the extension. 24 The assistance unit may receive an extension to the periodic time limit, but not the lifetime limit, for months the unit head is participating in a county approved training program that will not be completed by the 24th month. 25 Examples of a significant life crisis include eviction from the home, natural disaster, family crisis, or complications from pregnancy or birth. 20 When a family reaches the end of their 60-month limit, they can request a hearing to qualify for a hardship extension based on 1) an inhibiting criminal record; 2) homelessness or sub-standard housing; 3) one or more children receiving child welfare services in the home; 4) lack of transportation; or 5) any other situation which makes employment unattainable. The assistance unit may receive an extension to the benefit waiting period, but not the lifetime limit, for months in which a recipient participates in post-secondary education and maintains a 2.5 minimum grade point average. 19 New York continues to provide noncash assistance to all units that have reached the 60-month federal time limit. These extensions apply to the 60-month limit for receiving regular cash assistance. Welfare Rules Databook: State TANF Policies as of July 2017 231 39 Significant barriers include, but are not limited to, low achievement ability, learning disability, severe emotional problems, or family problems, which include legal problems, family crises, homelessness, domestic abuse, or children’s school or medical activities that affect one of the members of the assistance unit. 38 Single, pregnant women (including emancipated minor parents under 18 years old) who are in their third trimester may receive an extension until their child is six months old. If the pregnancy does not end in a live birth, the extension continues for two months following the end of the pregnancy. 232 Welfare Rules Databook: State TANF Policies as of July 2017 State Does the state provide transitional cash benefits? Average work hour requirement for transitional benefits Monthly benefit amount for transitional benefits Time limit on transitional benefits Alabama No n.a. n.a. n.a. Alaska No n.a. n.a. n.a. Arizona No n.a. n.a. n.a. Arkansas Yes 24 hours per week $204 24 months California No n.a. n.a. n.a. Colorado 2 No 3 n.a. n.a. n.a. Connecticut No n.a. n.a. n.a. Delaware No n.a. n.a. n.a. D.C. No n.a. n.a. n.a. Florida No n.a. n.a. n.a. Georgia Yes Varies 4 $200 12 months 5 Hawaii No n.a. n.a. n.a. Idaho No n.a. n.a. n.a. Illinois No n.a. n.a. n.a. Indiana No n.a. n.a. n.a. Iowa No n.a. n.a. n.a. Kansas Yes None $50 5 months Kentucky Yes None 6 $130 9 months Louisiana No n.a. n.a. n.a. Maine No n.a. n.a. n.a. Maryland No n.a. n.a. n.a. Massachusetts Yes None Varies 7 4 months Michigan No n.a. n.a. n.a. Minnesota No n.a. n.a. n.a. Mississippi No n.a. n.a. n.a. Missouri Yes 30 hours per week 8 $50 8 6 months Montana Yes 30 hours per week Varies 9 12 months Nebraska Yes None Varies 10 5 months Nevada Yes None 11 $50 6 months New Hampshire No n.a. n.a. n.a. New Jersey Yes 20 hours per week $200 24 months New Mexico No n.a. n.a. n.a. New York Yes 30 hours per week Varies 12 24 months 13 North Carolina Yes None $100 3 months North Dakota Yes 30 hours per week 14 Varies 15 6 months Ohio No n.a. n.a. n.a. Oklahoma Yes None Varies 16 3 months Oregon Yes None Varies 17 3 months Pennsylvania Yes Varies 18 $100 3 months Rhode Island 19 No n.a. n.a. n.a. South Carolina No n.a. n.a. n.a. South Dakota Yes 20 hours per week Varies 16 1 month Table IV.D.1. Transitional Cash Benefits, July 2017 1 Welfare Rules Databook: State TANF Policies as of July 2017 233 State Does the state provide transitional cash benefits? Average work hour requirement for transitional benefits Monthly benefit amount for transitional benefits Time limit on transitional benefits Tennessee No n.a. n.a. n.a. Texas No n.a. n.a. n.a. Utah Yes 30 hours per week Varies 20 3 months Vermont No n.a. n.a. n.a. Virginia All, except VIEW No n.a. n.a. n.a. VIEW Yes 30 hours per week $50 12 months Washington Yes None Varies 21 1 month West Virginia Yes Varies 22 Varies 16 6 months Wisconsin No n.a. n.a. n.a. Wyoming Yes 30 hours per week Varies 23 6 months Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 2 These policies are for Denver County. 1 This table captures cash benefits that are time-limited in some way, and that are restricted to some or all families who previously received TANF but who are no longer receiving TANF, for example, due to ineligibility from increased earnings. This table does not cover cases where states transition TANF participants into a solely state-funded program with no change in benefit levels. States may also provide other non-cash benefits to families transitioning off of TANF, such as child care assistance and Medicaid. See the WRD for more information. Table IV.D.1. Transitional Cash Benefits, July 2017 1 3 Denver’s policies include a description of employment-related incentives that are paid to individuals who are employed 1 month after first getting an unsubsidized job ($200 payment), 6 months after first employment ($300), and 12 months after first employment ($500). This program is not currently being operated. 4 Employment must be full time, stable, and permanent. Participants must maintain employment at the same number of hours that caused the TANF case closure. 5 Recipients are eligible for Work Support Payment (WSP) twice in their lifetime. 6 There is no minimum hour requirement, but recipients of transitional benefits must maintain employment. 8 Single parents or two-parent households in which one parent is disabled, with children age six or older, must work 30 hours per week, or 20 hours if they have children under age six. Two-parent, nondisabled households must work 55 hours per week. 13 For families no longer eligible for TANF due to time limits, they may be eligible for state and locally-funded safety net assistance cash benefits for up to 24 months. After 24 months, payments are restricted to vendors. There is no time limit on payments restricted to vendors. 7 Transitional benefits are equal to $280 in the first month, $210 in the second month, $140 in the third month, and $70 in the fourth month. 9 Transitional benefits are equal to $100 in the first 6 months, $50 in the last 6 months, and an additional Work Pays incentive of $300 in each of the 1st, 7th, and 12th month. 10 The transitional benefit is equal to one-fifth of the previous month’s benefit. 11 If employment terminates or income decreases to a dollar amount that is below the TANF payment income limit, the recipient is no longer eligible. 12 The supplement must equal the monthly net loss of cash income that would occur if the supplement were not paid to the household. 234 Welfare Rules Databook: State TANF Policies as of July 2017 22 Participants must maintain the employment level to remain eligible for transitional cash assistance. 23 The transitional benefit is equal to half of the previous month’s benefit. 15 The monthly benefit amount consists of special allowances for child care, job retention, health insurance reimbursement, health tracks reimbursement, and a high school diploma or GED bonus. 16 Transitional benefits are equal to the monthly benefit the unit received. 17 Transitional benefits are equal to $100 in the first month, $75 in the second month, and $50 in the third month. 18 A recipient must meet the work participation rate requirement, which is based on his or her circumstances. 19 Rhode Island’s policies include a description of a Post-Closure Employment Incentive Bonus to be paid for up to 12 months, for individuals who stop receiving regular cash aid while employed, and who remain employed. However, the program has not been implemented. 20 Transitional benefits are equal to the unit’s full benefit for the first two months and one half the benefit for the third month. 21 Transitional benefits for the Consolidated Emergency Assistance Program work as an income deduction. The following expenses are deducted when determining the amount of transitional benefits: a $90 work expense, payments made by a member with earned income for care of a member child up to specified maximums, and expenses for members during the current month that include medical bills, emergency child care, dental care, employment expenses, and the disaster cash assistance program. 14 If there is a child under age six in the household, the average work requirement is 20 hours a week. Welfare Rules Databook: State TANF Policies as of July 2017 235 V. Policies across Time, 1996 2017 This chapter of the Databook includes longitudinal tables for selected areas of policy from 1996, 2003, 2010, and 2017 (as of July of each year). (For years not shown in these tables, and for prior-year data for policies not covered in this section, see the full online WRD data.) To help users more easily identify changes in policies across time, the changes from one year to the next have been bolded in all the longitudinal tables. Because the tables do not represent every year, the changes may have occurred in a year before the bolded year. Information on when specific changes occurred is available in the WRD. The following discussion provides more information on the policies included in this section and the specific policies discussed in the tables. Formal diversion: Table L1 indicates which states have a formal diversion program that diverts eligible applicants or recipients from ongoing TANF receipt by providing a one-time cash payment directly to the family or to a vendor for expenses incurred by the family. Other strategies that states may use to divert applicants from ongoing receipt of cash benefits (such as requiring an applicant to participate in job search or resource and referral services) are not identified as diversion programs in the table. States did not have the option to divert units under AFDC. However, a few states experimented with diversion through waivers. Generally, diversion programs began as pilot projects in a few counties and, after TANF, were expanded statewide.43 Two-parent eligibility: Table L2 describes states’ deviation from the prior federal AFDC rules for two-parent, nondisabled units over time. The key AFDC policies were the 100-hour rule for applicants and recipients, a 6-out-of-13-quarter work history test, and a 30-day waiting period. Standard AFDC describes the states that impose the AFDC rules. Modified describes the states that no longer impose all the former AFDC requirements on units but still impose some additional requirements. The specific combination of modified rules is footnoted. States that no longer impose any special requirements on two-parent units are denoted by none. 43 Years in which the state implemented a diversion program as a pilot project in only a few counties are footnoted. 236 Welfare Rules Databook: State TANF Policies as of July 2017 Many states began modifying or removing special requirements for two-parent units under waivers. This process continued under TANF, which does not require states to impose any special requirements on two-parent units. Initial eligibility at application: Table L3 calculates the amount of earned income a three- person unit can receive and still be technically eligible for assistance. Technically eligible means the unit is eligible for assistance but may not actually receive a cash benefit. Most states will not pay out a benefit for less than a specified amount (usually $10), but as long as the unit’s potential benefit is positive, the unit is technically eligible. The calculations in this table are based on the states’ income eligibility tests, earned income disregards, benefit computation, and eligibility and payment standards. Earned income disregards for benefit computation: Table L4 describes the earned income disregards allowed in determining net income used for benefit computation. The disregards in this table apply to recipients.44 Earned income disregards for benefit computation under AFDC were a standard $120 and 33.3 percent for the first four months, $120 for the next eight months, and $90 thereafter. Through waivers, many states began changing their disregard policies, which often allowed units to keep more of their income and remain eligible for aid. This broadening of disregards continued under TANF, which allows states to determine their own disregard policies. Maximum monthly benefit for a family of three with no income: Table L5 indicates the benefit that a family of three will receive if it has no income. The benefits are calculated assuming the assistance unit includes one parent and two children, contains no children subject to a family cap, has no special needs, pays for all shelter costs with no subsidies, and is subject to the benefit standard that applies to the majority of the state’s caseload. Maximum benefits have always varied across states. Benefit computation formulas and payment standards were two policies that states were able to determine under AFDC. The wide variation in states’ benefits still exists under TANF. In many states, benefits have changed relatively infrequently across time. Work-related exemption when caring for a child under X months: Table L6 indicates what age a child must be under for the unit head to be exempt from work-related requirements. The unit head is assumed to be a single parent age 20 or older with a high school diploma or GED. 44 If units in the first month of receipt (applicants) receive different disregards, they are footnoted. This table does not include disregards related to child care or any other special disregards for units affected by family caps or time limits. Welfare Rules Databook: State TANF Policies as of July 2017 237 Under AFDC, parents were exempt from the Job Opportunities and Basic Skills Training (JOBS) program if they had children younger than 36 months old.45 Under waivers, many states began reducing the age of the child exemption. Then, with the passage of TANF, the federal government reduced the maximum age for the exemption to 12 months for the states’ participation rate calculations. States can exempt units with children younger or older than 12 months, but units with children over 12 months old will be included in their work participation rate denominator. States with waivers were allowed to continue their previous exemption policy under TANF until the waivers expired. Most severe sanction policy for noncompliance with work requirements for single-parent adults: Table L7 describes the most severe sanction policy for noncompliance with work requirements. Under AFDC, the worst-case sanction for not complying with work requirements was the removal of the adult for benefit computation purposes. The unit was sanctioned for six months or until compliance. By 1996, a few states had begun to impose more severe sanctions on noncompliant units. These policies continued and expanded under TANF. The federal government requires that all states sanction individuals for not complying with work requirements, but states are allowed to determine the severity of the sanction. Asset tests: Tables L8 and L9 describe the asset limits and vehicle exemptions for recipients, respectively. If the tests differ for applicants, they are footnoted. States have liberalized asset tests over the past several years, and, since the beginning of TANF, states’ asset limits (and the decision whether to impose limits) have generally trended toward fewer restrictions or higher asset thresholds. Under AFDC rules, the federal government set the maximum amount of assets a unit could retain and still remain eligible at $1,000 of countable assets, with an exclusion of $1,500 of the equity value of a vehicle. During the early 1990s, states began experimenting with higher asset limits and vehicle exemptions through waivers. Under TANF, states determine the maximum allowable level of assets. Family caps: Table L10 indicates which states have implemented family cap policies. States did not have the option to cap additional children under AFDC. However, a few states experimented with family caps through waivers.46 TANF neither requires nor prohibits family cap policies. 45 States had the option to require JOBS participation of parents with children as young as 12 months old. 46 Years in which the state imposed a family cap as a pilot project in only a few counties are footnoted. 238 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama No No No No Alaska No Yes Yes No 2 Arizona No Yes Yes 3 Yes 4 Arkansas No Yes Yes Yes California 5 No Yes Yes Yes Colorado 6 No Yes Yes 7 Yes Connecticut No Yes Yes Yes Delaware No Yes 8 Yes 8 Yes 8 D.C. No Yes Yes Yes Florida No Yes 9 Yes 9 Yes 10 Georgia No No Yes 11 No Hawaii No Yes 12 No No Idaho No Yes Yes Yes Illinois No Yes 13 Yes 14 Yes 14 Indiana No No No No Iowa No Yes 15 No No Kansas No No No Yes Kentucky No Yes Yes Yes Louisiana No Yes No No Maine No Yes 16 Yes Yes Maryland No Yes Yes Yes Massachusetts No No No No Michigan No No Yes No Minnesota No No Yes 17 Yes 17 Mississippi No No No No Missouri No No No Yes Montana Yes 18 No No No Nebraska No No No No Nevada No No No Yes New Hampshire No No No No New Jersey No Yes 19 Yes 19 Yes 19 New Mexico No Yes 20 Yes 21 Yes 21 New York No Yes 22 Yes 22 Yes 22 North Carolina Yes Yes Yes Yes North Dakota No No Yes Yes Ohio No No No No Oklahoma No Yes 20 Yes 20 No Oregon No No No No Pennsylvania No No Yes Yes Rhode Island No No No No South Carolina No No No No South Dakota No Yes Yes Yes Tennessee No No Yes 23 Yes 24 Table L1. Formal Diversion Payments, 1996 2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 239 State 1996 2003 2010 2017 Texas No Yes 25 Yes 25 Yes 25 Utah Yes 26 Yes Yes Yes Vermont No No Yes 27 Yes 27 Virginia Yes Yes Yes Yes Washington No Yes Yes Yes West Virginia No Yes Yes Yes Wisconsin No Yes 28 Yes 28 Yes 28 Wyoming No No No No Total States with Any Diversion 4 29 33 32 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 2 Alaska’s TANF program is not currently implementing the diversion payment option due to systematic and program integrity reasons. Alaska may re-implement the payment option when its new eligibility software is fully launched and state statutes\/regulations have been updated to better define diversion-eligible households. According to the legislation authorizing the program, a recipient can receive a cash payment worth up to three months of TANF benefits. If a family applies for assistance during the three-month ineligibility period, the entire amount of the diversion payment is treated as unearned income to the family. The diversion payment is prorated equally over the three months, and the prorated amount is counted as monthly income. An individual can receive diversion payments up to four times in a lifetime but no more than once every 12 months. 3 To be eligible, applicants must be employed full time, have an offer of full-time employment, or be likely to gain full-time employment based on education, skills, and work history. Applicants must also have a short-term verified financial need that is a barrier to achieving self-sufficiency, such as needing car repairs, child care, work clothes, overdue housing expenses, or transportation assistance. Table L1. Formal Diversion Payments, 1996 2017 (July) 1 4 To be eligible, applicants must have employment or self-employment history in the application month or within the 12 months prior to the application month, have successfully completed an educational, vocational, or job training program in the application month or within the six months prior to the application month, or have a job offer for full-time employment that will begin within three calendar months of the grant diversion period. 5 Counties have the option to vary their diversion programs. These policies refer to Los Angeles County. 6 Counties have the option to vary their diversion programs. These policies refer to Denver County. 7 The individual must demonstrate a need for a specific item or type of assistance, such as cash, supportive services, housing, or transportation. 8 The state’s diversion program is related to retaining or obtaining employment and is only for parents living with natural or adopted children. 240 Welfare Rules Databook: State TANF Policies as of July 2017 18 Montana conducted a pilot project in eight counties that provided diversion assistance to its clients. 19 New Jersey’s diversion program, the Early Employment Initiative (EEI), is mandatory for applicants who have a work history that equals or exceeds four months of full-time employment in the past 12 months, appear to meet TANF eligibility requirements, are not in immediate need, and do not meet criteria for a deferral from work requirements. Participants receive a one-time, lump-sum payment and are required to pursue an intensive job search for 15 to 30 days while their application is processed. If participants obtain employment and withdraw their application, they are eligible to receive a second lump-sum payment to assist in the transition to employment. If no employment is secured, the applicant is referred back to the Work First New Jersey (WFNJ)\/TANF agency for cash assistance. 20 The diversion payment is only available to assist applicants in keeping a job or accepting a bona fide offer of employment. 22 New York has three types of diversion payments: diversion payments (for crisis needs such as moving expenses, storage fees, or household structural or equipment repairs), diversion transportation payments (for employment-related transportation expenses), and diversion rental payments (for rental housing). 21 The diversion payment is intended to assist the benefit group with accepting or retaining employment, remedying an emergency situation, or alleviating an unexpected short-term need. 13 An applicant who has found a job that will make him or her ineligible for cash assistance or who wants to accept the job and withdraw his or her application for assistance is eligible for a one-time payment to begin or maintain employment. 14 Illinois operates its diversion program through local community partners. 16 The caretaker relative or parent must be employed or looking for work. 17 Minnesota’s four-month Diversionary Work Program (DWP) is mandatory for all TANF applicants, unless exempt. Recipients receive financial assistance and must participate in four months of intensive employment services focused on helping the participant obtain an unsubsidized job before entering regular TANF. Failure to comply with the employment services, which may include a structured job search, results in ineligibility for both DWP and TANF until compliance. After completing the four-month program, participants who still require assistance may apply for TANF as applicants. 9 Florida has three separate diversion programs. Up-front diversion is for individuals in need of assistance because of unexpected circumstances or emergency situations. Relocation assistance is available for individuals who reside in an area with limited employment opportunities and experience one of the following: geographic isolation, formidable transportation barriers, isolation from extended family, or domestic violence that threatens the ability of a parent to maintain self- sufficiency. Early exit diversion is available to TANF recipients if they meet the following criteria: they are employed and receiving earnings, they are able to verify their earnings, they will remain employed for at least six months, they have received cash assistance for at least six consecutive months since October 1996, and they are eligible for at least one more month of TANF. 10 Florida has three separate diversion programs. Up-front diversion is for individuals in need of assistance because of unexpected circumstances or emergency situations. Relocation assistance is available for individuals who reside in an area with limited employment opportunities and experience one of the following: geographic isolation, formidable transportation barriers, isolation from extended family, or domestic violence that threatens the ability of a parent to maintain self- sufficiency. Cash severance is available to TANF recipients if they meet the following criteria: they are employed and receiving earnings, they are able to verify their earnings, they will remain employed for at least six months, they have received cash assistance for at least six consecutive months since October 1996, and they are eligible for at least one more month of TANF. 11 The applicant is eligible for diversion assistance if she or he: (1) has a full-time job, but is on unpaid leave due to her or his temporary illness or the illness of a family member (under four months) and meets the gross income test, or (2) is employed and eligible for less than the maximum amount of cash assistance and declines it. 12 To be eligible for diversion assistance, a household must include at least one work-eligible individual as defined by the state, include one adult who has a work history of at least six months in the 36 months before the month of request for diversion assistance, and be eligible for cash assistance in the month the diversion assistance was issued. 15 Diversion was offered through a limited pilot program. Welfare Rules Databook: State TANF Policies as of July 2017 241 28 The diversion payment is considered a loan to assist with expenses related to obtaining or maintaining employment, and it must be repaid. Repayments are expected within 12 months but may be extended to 24 months. The loan may be paid back in cash or through a combination of cash and volunteer community service (valued at the higher of the state or federal minimum wage). 23 To be eligible, the applicant must have an identifiable one-time financial need, have been a resident of Tennessee for six months, have not received cash assistance in any state in the past two years, have never received a diversion payment in any state, have no identifiable barriers to employment, have earned a high school diploma or GED, and either be currently employed or have been steadily employed in six of the last 12 months, with at least three being consecutive. In two-parent units, both parents must meet the eligibility criteria to qualify for a diversion payment. 24 To be eligible, the applicant must have an identifiable one-time financial need, have been a resident of Tennessee for six months, have no identifiable barriers to employment, have earned a high school diploma or GED, and either be currently employed or have been steadily employed in six of the last 12 months, with at least three being consecutive. In two-parent units, both parents must meet the eligibility criteria to qualify for a diversion payment. 25 To qualify for the state’s diversion program, the assistance unit must meet one of the crisis criteria, including (1) the caretaker or second parent lost employment in the process month, application month, or two months before application; (2) a dependent child experienced a loss of financial support from the legal parent or stepparent within the past 12 months as a result of death, divorce, separation, abandonment, or termination of child support and the caretaker was employed within 12 months of the application or process month; (3) the caretaker or second parent graduated from a university, college, junior college, or technical training school within 12 months of the application or process month and was underemployed or unemployed; or (4) the caretaker or second parent is currently employed but still meets TANF requirements and is facing the loss or potential loss of transportation or shelter or has a medical emergency temporarily preventing him or her from continuing to work. If the unit has an open TANF activity requirement sanction and fails to demonstrate cooperation within the allowed time or is not eligible for a TANF grant of at least $10, the unit is ineligible for diversion assistance. 26 Utah phased 50 percent of the caseload into the diversion program in 1996, and then the remainder in 1997. 27 To be eligible for diversion assistance, an applicant family must meet cash assistance financial eligibility and diversion eligibility criteria and, if it has no members who are mandatory applicants, must choose to participate in the diversion program. Families who meet the following criteria are mandatory applicants: (1) at least one member of the family is work eligible, (2) work-eligible individuals in the family are neither disregarded from nor meeting their cash assistance work requirement, (3) none of the work-eligible individuals have received a diversion assistance payment in the 12 months before the application month, and (4) at least one work-eligible adult is part of a two-parent family, has recent and stable employment with earnings of at least 150 percent of the federal poverty guidelines, or has a marketable college degree or vocational education certificate. 242 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama Standard AFDC None None None Alaska Standard AFDC None None None Arizona Modified 2 Modified 2 None None Arkansas Standard AFDC None None None California Modified 3 Modified 4 Modified 5 Modified 5 Colorado Standard AFDC None None None Connecticut None None None None Delaware None None None None D.C. Standard AFDC Standard AFDC None None Florida Standard AFDC None None None Georgia Standard AFDC Modified 6 Modified 6 Modified 6 Hawaii Standard AFDC None None None Idaho Standard AFDC None None None Illinois None None None None Indiana Modified 3 Modified 3 None None Iowa Modified 7 None None None Kansas Standard AFDC None None None Kentucky Standard AFDC Modified 8 Modified 8 Modified 8 Louisiana Standard AFDC None None Not eligible 9 Maine Standard AFDC Modified 10 Modified 10 Modified 10 Maryland Standard AFDC None None None Massachusetts Modified 11 None None None Michigan None None None 12 None 12 Minnesota Standard AFDC None None None Mississippi Standard AFDC Standard AFDC Standard AFDC Standard AFDC Missouri Standard AFDC None None None Montana Standard AFDC None None None Nebraska Standard AFDC None None None Nevada Standard AFDC None None None New Hampshire Standard AFDC Standard AFDC Standard AFDC Not eligible 9 New Jersey Standard AFDC None None None New Mexico Standard AFDC None None None New York Standard AFDC None None None North Carolina None None None None North Dakota Standard AFDC Not eligible 9 Not eligible 9 Not eligible 9 Ohio None None None None Oklahoma Standard AFDC Modified 11 Modified 11 Modified 11 Oregon None None None None Pennsylvania Standard AFDC Modified 2 None None Rhode Island Standard AFDC None None None South Carolina Standard AFDC None None None South Dakota Standard AFDC Modified 13 Modified 13 Modified 13 Tennessee Standard AFDC Standard AFDC Standard AFDC None Texas Standard AFDC None None None Table L2. Types of Special Restrictions on Two-Parent, Nondisabled Units’ Eligibility, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 243 State 1996 2003 2010 2017 Utah Modified 11 None None None Vermont None None None None Virginia Standard AFDC None None None Washington Modified 14 None None None West Virginia Standard AFDC None None None Wisconsin Modified 14 None None None Wyoming Standard AFDC None None None Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. Standard AFDC rules for two-parent units include the following: (1) a 100-hour limit on work for both applicants and recipients, (2) applicants must have worked in at least six of the last 13 calendar quarters before application, and (3) applicants must have been unemployed for a minimum of 30 days before application. States with this policy generally allow eligibility for units with two nondisabled parents only if the principal earner in the couple works no more than a certain number of hours per month. However, in most states with this policy, eligibility may still be allowed when hours exceed the maximum, if work hours are usually at or below the maximum. )See the full database for details.) The special restrictions considered in this table include limits on work hours for applicants and recipients, work history requirements, and waiting period restrictions. The combination of restrictions does not, however, include any variation in state programs from special time limits that apply only to two-parent units. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 2 Modified rules for two-parent units: no work limit for applicants or recipients, six of the last 13 quarters work history, and no waiting period. 3 Modified rules for two-parent units: 100-hour work limit for applicants only, six of the last 13 quarters work history, and 30-day waiting period. 4 Modified rules for two-parent units: applicants must have been employed less than 100 hours during the four weeks before the date of application, 100 hour work limit for recipients, six of the last 13 quarters work history, and no waiting period. 5 Modified rules for two-parent units: applicants must have been employed less than 100 hours during the four weeks before the date of application, no work limit for recipients, no work history test, and no benefit waiting period. 6 Modified rules for two-parent units: must be connected to the workforce, which includes one of the following: (1) currently working at least 20 hours a week; (2) receiving unemployment compensation; (3) unemployed or working less than 20 hours a week and have earned at least $500 within the six months before application; (4) receiving retirement benefits; or (5) received disability benefits based on 100 percent disability in any of the last six months. 7 Modified rules for two-parent units: 30-day waiting period. The determination of primary earner was also eliminated, meaning although there is no limit to the number of hours either parent can work, they are still subject to unemployment classifications depending upon the number of hours they work. If one parent is working more than 100 hours then the family may not receive assistance for 30 days. If both parents are working less than 100 hours then the assistance begins 30 days from the date either one of the parents worked more than 100 hours. This applies to both applicants and recipients. Table L2. Types of Special Restrictions on Two-Parent, Nondisabled Units’ Eligibility, 1996-2017 (July) 1 244 Welfare Rules Databook: State TANF Policies as of July 2017 9 The state does not provide benefits to two-parent, nondisabled units. 8 Modified rules for two-parent units: 100-hour work limit for applicants only, applicant must have earned at least $1,000 during the 24-month period before the month of application, and 30-day waiting period. Two semesters of full-time attendance in a postsecondary institution may be substituted for $500 of the $1,000. 10 Modified rules for two-parent units: 100-hour work limit for applicants, 130-hour work limit for recipients, six of the last 13 quarters work history, and 30-day waiting period. 11 Modified rules for two-parent units: no work limit for applicants or recipients, six of the last 13 quarters work history, and 30-day waiting period. 13 Modified rules for two-parent units: 100-hour work limit for applicants and recipients, and applicants must have a combined (both parents) gross income over the past six months equal to at least $1,500. Parents must not have terminated employment, reduced hours worked, or refused a job offer within the previous six months (without good cause). 14 Modified rules for two-parent units: 100-hour work limit for applicants, no work limit for recipients, six of the last 13 quarters work history, and 30-day waiting period. 12 Applicants who refuse suitable employment without good cause while their application is pending, or up to 30 days before their application date, are not eligible for benefits until the 30th day after the refusal of employment. Welfare Rules Databook: State TANF Policies as of July 2017 245 State 1996 2003 2010 2017 Alabama $366 $268 $268 $268 Alaska $1,118 $1,291 $1,553 $1,683 Arizona $639 $585 $585 $585 Arkansas $426 $278 $278 $278 California $823 $980 2 $1,203 2 $1,431 2 Colorado $511 $511 2 $511 2 $511 2 Connecticut 2 $835 $835 $790 $908 Delaware $428 $428 $428 $428 D.C. $742 $539 $588 $668 Florida $574 $393 $393 $393 Georgia $514 $514 $514 $514 Hawaii $1,187 $1,640 3 $1,740 4 $1,740 5 Idaho $1,081 $972 $972 $972 Illinois $467 $486 2 $763 2 $851 2 Indiana $378 $378 $378 $378 Iowa $1,061 $1,061 $1,061 $1,061 Kansas $519 $519 2 $519 2 $519 2 Kentucky $616 $908 $908 $908 Louisiana $405 2 $360 $360 $360 Maine $643 $1,023 $1,023 $1,023 Maryland $607 $591 $717 $810 Massachusetts n.a. n.a. n.a. n.a. Exempt $655 $1,069 $1,069 $833 Non-exempt $669 $1,143 $1,143 $818 Michigan $774 2 $773 2 $814 $815 Minnesota $621 2 $1,029 $1,225 $2,243 Mississippi $457 $457 $457 $457 Missouri $557 $557 $557 $557 Montana $631 $875 $810 $817 Nebraska $454 $732 $886 $1,020 Nevada $642 $1,132 $1,430 $1,595 New Hampshire $943 $781 $843 $1,276 New Jersey $783 $636 $636 $636 New Mexico $479 $1,060 6 $1,017 $942 New York 2 $667 $667 $843 $879 North Carolina $936 $681 $681 $681 North Dakota $521 $1,306 $1,306 $1,331 Ohio $631 $980 $762 $851 Oklahoma $580 $703 $823 $823 Oregon $550 $616 $616 $616 Pennsylvania 2 $677 $677 $677 $677 Rhode Island $644 $1,277 $1,277 $1,277 South Carolina $614 $1,156 $1,411 $1,554 South Dakota $597 $705 $782 $857 Tennessee $767 $1,029 $1,315 $1,315 Texas $400 $401 $401 $401 Utah $525 $668 $668 $668 Table L3. Maximum Income for Initial Eligibility for a Family of Three, 1996-2017 (July) 1 246 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Vermont 2 $945 $1,001 $1,053 $1,103 Virginia 7 $291 $479 $626 $677 Washington $937 $1,090 $1,122 $1,040 West Virginia $498 $753 $565 $565 Wisconsin $895 2 n.a. 8 n.a. 9 n.a. 10 Wyoming $680 $539 $760 $1,259 Mean 11 $653 $768 $820 $881 Median 11 $621 $704 $773 $828 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. The values in this table represent the maximum amount of earnings an applicant can have and still be technically eligible for assistance in each state. Technical eligibility does not mean that the unit will necessarily receive a cash benefit, but it will have passed all the eligibility tests and be eligible for some positive amount. Most states only distribute a cash benefit equaling $10 or more. Initial eligibility is calculated assuming that the unit is employed at application, has only earned income, has no child care expenses, contains one adult and no children subject to a family cap, has no special needs, and pays for shelter. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 9 Units with earnings at application will not receive a cash benefit, except for units with earnings from unsubsidized employment who work less than 30 hours per week and face limitations to increasing their work hours. These units are eligible for a Community Service Job placement where they may receive a prorated benefit. Applicants earning $1,755 or less may be eligible for nonfinancial assistance. 7 Dollar amounts used for calculations vary within the state, either by county or by region of the state. This table shows the figures for the area of the state that is currently the most populous. See the Welfare Rules Database for more information. All applicants, including those who will subsequently participate in the VIEW program, must pass the same initial income eligibility tests. 8 Units with earnings at application will not receive a cash benefit, except for units with earnings from unsubsidized employment who work less than 30 hours per week and face limitations to increasing their work hours. These units are eligible for a Community Service Job placement where they may receive a prorated benefit. Applicants earning $1,462 or less may be eligible for nonfinancial assistance. 6 For purposes of the state’s earned income disregard (allowing earnings from all hours past 34 per week to be disregarded), the adult head is assumed to be working 40 hours per week. 2 Dollar amounts used for calculations vary within the state, either by county or by region of the state. This table shows the figures for the area of the state that is currently the most populous. See the Welfare Rules Database for more information. 3 This threshold applies to units that have received assistance for no more than two months in a lifetime. For units applying for their third and subsequent months of benefits, the eligibility threshold for a family of three is $1,363. 4 This threshold applies to units that have received assistance for no more than two months in a lifetime. For units applying for their third and subsequent months of benefits, the eligibility threshold for a family of three is $1,441. 5 This threshold applies to units that have received assistance for no more than two months in a lifetime. For units applying for their third and subsequent months of benefits, the eligibility threshold for a family of three is $1,894. Table L3. Maximum Income for Initial Eligibility for a Family of Three, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 247 11 In states for which this table shows more than one component, the amounts used to compute the means and medians are the amounts for the first component that is listed, which is the one affecting the largest portion of the caseload. Calculations for 2003, 2010, and 2017 do not include Wisconsin. 10 Units with earnings at application will not receive a cash benefit, except for units with earnings from unsubsidized employment who work less than 30 hours per week and face limitations to increasing their work hours. These units are eligible for a Community Service Job placement where they may receive a prorated benefit. Units with income less than $1,957 at application who find employment during up-front job search have their income disregarded for purposes of determining eligibility for nonfinancial assistance. 248 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 100% in first 3 consecutive months of earnings, 20% thereafter 2 100% in first 12 consecutive months of earnings, 20% thereafter 2 100% in first 12 consecutive months of earnings, 20% thereafter 2 Alaska $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $150 in all months, plus 33% of remainder in first 12 cumulative months of earnings, 25% of remainder in months 13-24, 20% of remainder in months 25-36, 15% of remainder in months 37- 48, 10% of remainder in months 49-60 $150 in all months, plus 33% of remainder in first 12 cumulative months of earnings, 25% of remainder in months 13-24, 20% of remainder in months 25-36, 15% of remainder in months 37- 48, 10% of remainder in months 49-60 $150 in all months, plus 33% of remainder in first 12 cumulative months of earnings, 25% of remainder in months 13-24, 20% of remainder in months 25-36, 15% of remainder in months 37- 48, 10% of remainder in months 49-60 Arizona $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 and 30% of remainder in all months $90 and 30% of remainder in all months $90 and 30% of remainder in all months Arkansas $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings No disregards – flat grant amount No disregards – flat grant amount No disregards – flat grant amount California $120 and 33.3% of remainder in all months $225 and 50% of remainder in all months $225 and 50% of remainder in all months $225 and 50% of remainder in all months 3 Colorado $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 66.6% in first 12 cumulative months of earnings, $120 and 33.3% of remainder in months 13- 16, $120 in months 17-24, $90 thereafter 4 66.6% in first 12 cumulative months of earnings, $120 and 33.3% of remainder in months 13- 16, $120 in months 17-24, $90 thereafter 4 67% in all months Connecticut 100% up to federal poverty guideline in all months 5 100% up to federal poverty guideline in all months 5 100% up to federal poverty guideline in all months 5 100% up to federal poverty guideline in all months 5 Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 249 State 1996 2003 2010 2017 Delaware $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 6 $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 6 $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 6 D.C. $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $160 and 66.7% of remainder in all months 7 $160 and 66.7% of remainder in all months 7 $160 and 66.7% of remainder in all months 7 Florida $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $200 and 50% of remainder in all months $200 and 50% of remainder in all months $200 and 50% of remainder in all months Georgia $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings Hawaii $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 20%, $200, and 36% of remainder in all months 20% and $200 of remainder in all months, plus 55% of remainder in first 24 cumulative months of assistance and 36% of remainder thereafter 20% and $200 of remainder in all months, plus 55% of remainder in first 24 cumulative months of assistance and 36% of remainder thereafter Idaho $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 60% in all months 60% in all months 60% in all months Illinois 67% in all months 66.7% in all months 75% in all months 75% in all months Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 250 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Indiana $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 75% in all months 75% in all months 75% in all months Iowa 20% and 50% of remainder in all months 8 20% and 50% of remainder in all months 20% and 58% of remainder in all months 20% and 58% of remainder in all months Kansas $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 and 40% of remainder in all months $90 and 60% of remainder in all months $90 and 60% of remainder in all months Kentucky $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 100% in first 2 months earnings would affect eligibility; $120 and 33.3% of remainder in first 4 consecutive months of earnings, $120 in months 5-12, $90 thereafter 9 100% in first 2 months earnings would affect eligibility; $120 and 33.3% of remainder in first 4 consecutive months of earnings, $120 in months 5-12, $90 thereafter 9 100% in first 2 months earnings would affect eligibility; $120 and 33.3% of remainder in first 4 consecutive months of earnings, $120 in months 5-12, $90 thereafter 9 Louisiana $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $120 in all months, plus $900 in any 6 months over a recipient’s lifetime 10 $120 in all months, plus $900 in any 6 months over a recipient’s lifetime 10 $120 in all months, plus $900 in any 6 months over a recipient’s lifetime 10 Maine $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $108 and 50% of remainder in all months $108 and 50% of remainder in all months $108 and 50% of remainder in all months Maryland $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 40% in all months 40% in all months 40% in all months Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 251 State 1996 2003 2010 2017 Massachusetts n.a. n.a. n.a. n.a. Exempt $120 and 33.3% of remainder in all months $120 and 33.3% of remainder in all months $120 and 33.3% of remainder in all months $200 and 50% of remainder in all months Non-Exempt $120 and 50% of remainder in all months $120 and 50% of remainder in all months $120 and 50% of remainder in all months $200 and 50% of remainder in all months Michigan $200 and 20% of remainder in all months $200 and 20% of remainder in all months $200 and 20% of remainder in all months $200 and 50% of remainder in all months Minnesota $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 38% in all months 37% in all months $65 and 50% of remainder in all months Mississippi $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months 11 $90 in all months 12 $90 in all months 12 Missouri $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 66.7% and $90 of remainder in first 12 consecutive months of earnings, $90 thereafter 13 66.7% and $90 of remainder in first 12 consecutive months of earnings, $90 thereafter 13 100% in first 6 consecutive months of earnings, 66.7% and $90 of remainder in months 7-18, $90 thereafter 13 Montana $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $200 and 25% of remainder in all months $200 and 25% of remainder in all months $200 and 25% of remainder in all months Nebraska $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 20% in all months 20% in all months 50% in all months Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 252 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Nevada $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 100% in first 3 cumulative months of earnings, 50% in months 4-12, $90 or 20% whichever is greater thereafter 100% in first 3 cumulative months of earnings, 85% in months 4-6, 75% in months 7-9, 65% in months 10-12, greater of $90 or 20% thereafter 14 100% in first 3 cumulative months of earnings, 85% in months 4-6, 75% in months 7-9, 65% in months 10-12, greater of $90 or 20% thereafter 14 New Hampshire $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 50% in all months 50% in all months 50% in all months New Jersey $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 100% in first month of earnings, 50% thereafter 100% in first month of earnings, 75% in months 2-7, 50% thereafter 15 100% in first month of earnings, 75% in months 2-7, 50% thereafter 15 New Mexico $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $125 and 50% of remainder in all months, plus 100% of earnings in excess of 34 hours a week in first 24 months of receiving benefits 16 $125 and 50% of remainder in all months 17 $125 and 50% of remainder in all months 17 New York $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 and 51% of remainder in all months $90 and 52% of remainder in all months $90 and 51% of remainder in all months North Carolina $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 100% in first 3 consecutive months of earnings, 27.5% thereafter 18 100% in first 3 consecutive months of earnings, 27.5% thereafter 18 27.5% in all months Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 253 State 1996 2003 2010 2017 North Dakota $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings Greater of $180 and 27% in all months, plus 50% of remainder in first 6 consecutive months of earnings, 35% of remainder in months 7-9, and 25% of remainder in months 10-13 19 Greater of $180 and 27% in all months, plus 50% of remainder in first 6 consecutive months of earnings, 35% of remainder in months 7-9, and 25% of remainder in months 10-13 20 Greater of $180 and 27% in all months, plus 50% of remainder in first 6 consecutive months of earnings, 35% of remainder in months 7-9, and 25% of remainder in months 10-13 20 Ohio $250 and 50% of remainder in first 18 consecutive months of earnings, no disregards thereafter 21 $250 and 50% of remainder in all months $250 and 50% of remainder in all months $250 and 50% of remainder in all months Oklahoma $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $120 and 50% of remainder in all months $240 and 50% of remainder in all months 22 100% in first 3 consecutive months of earnings, $240 and 50% of remainder thereafter 23 Oregon $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 50% in all months 50% in all months 50% in all months Pennsylvania $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 50% in all months 50% in all months 50% in all months Rhode Island $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $170 and 50% of remainder in all months $170 and 50% of remainder in all months $170 and 50% of remainder in all months South Carolina $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 50% in first 4 months earned income is budgeted, $100 thereafter 24 50% in first 4 months earned income is budgeted, $100 thereafter 24 50% in first 4 months earned income is budgeted, $100 thereafter 24 Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 254 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 South Dakota $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 and 20% of remainder in all months $90 and 20% of remainder in all months $90 and 20% of remainder in all months Tennessee $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $150 in all months $250 in all months $250 in all months Texas $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $120 in all months, plus 90% of remainder (up to $1,400) for 4 out of 12 months 25 $120 in all months, plus 90% of remainder (up to $1,400) for 4 out of 12 months 25 $120 in all months, plus 90% of remainder (up to $1,400) for 4 out of 12 months 25 Utah $100 and 50% of remainder in all months $100 and 50% of remainder in all months $100 and 50% of remainder in all months $100 and 50% of remainder in all months Vermont $150 and 25% of remainder in all months $150 and 25% of remainder in all months $200 and 25% of remainder in all months 26 $250 and 25% of remainder in all months 26 Virginia $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings Varies by unit size 27 Varies by unit size 28 Washington $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 50% in all months 50% in all months 50% in all months West Virginia $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings 40% in all months 40% in all months 40% in all months Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 255 State 1996 2003 2010 2017 Wisconsin $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings No disregards – flat grant amount No disregards – flat grant amount No disregards – flat grant amount Wyoming $90 in all months, plus $30 in first 12 consecutive months of earnings, plus 33.3% of remainder in first 4 consecutive months of earnings $200 in all months 29 $200 in all months 29 $600 in all months 30 8 One hundred percent of income is exempt for the first four consecutive months of earnings under the following conditions: (1) the new job must start after the date of household application, (2) earnings must be timely reported, and (3) the person with the new job must have earned less than $1,200 in the 12 calendar months before the month that the new job begins. 3 If a recipient applies for TANF benefits within three calendar months of his or her subsidized employment placement ending, he or she will be considered for the recipient earned income disregard rather than the applicant $90 income disregard. 4 Individuals who have received the $120 disregard and the 33.3 percent disregard for the maximum numbers of months cannot qualify to receive those disregards again until they have not received basic cash assistance for 12 consecutive months. 7 The unit may disregard $160 per employed member. 6 If benefits or employment end before the fourth consecutive month of earnings, the recipient is eligible to receive the $30 and 33.3 percent disregard for four additional months upon reapplication or re-employment. When a recipient has received the $30 and 33.3 percent disregard for four consecutive months and the $30 disregard for an additional eight months, neither disregard may be applied again until the individual has not received any benefits for 12 months. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. Only earned income disregards are described in the table. Child care disregards and other special disregards–such as deductions for units subject to time limits and family caps, and earned income disregards that apply to new marriages or in cases of deeming–are not included in this table. The table describes benefit computation disregards for recipients. If the disregards differ for applicants, it is footnoted. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually- exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 2 The earned income disregard cannot be applied to the earnings of an individual receiving assistance beyond the 60th month under an extension. The disregard can only be applied to earnings reported within 10 days of receipt. 5 A unit that has not received cash assistance in one of the four prior months will disregard $90 of earned income for purposes of benefit computation. Table L4. Earned Income Disregards for Benefit Computation, 1996-2017 (July) 1 256 Welfare Rules Databook: State TANF Policies as of July 2017 18 The 100 percent disregard is available only once in a lifetime and may be received only if the recipient is newly employed at a job that is expected to be permanent for more than 20 hours a week. 19 Each recipient has a lifetime limit of one 13-month cycle of the extra disregards, unless the recipient is employed for less than four consecutive months, in which case the 13-month cycle starts over upon re-employment. 17 Two-parent units may disregard $225 and 50 percent of the remainder in all months. 9 Recipients are eligible for the one-time, two-month 100 percent disregard if they become newly employed or report increased wages acquired after approval. Recipients are eligible to receive the 33.3 percent disregard during the first four consecutive months of earnings if they have not received benefits for at least 12 consecutive months. 10 The six months in which the extra $900 is disregarded need not be consecutive, but the recipient may use this extra disregard in no more than six months over the course of his or her lifetime. 13 These disregards apply to recipients who gained employment while receiving TANF. Recipients who gained employment before receiving TANF may disregard $120 and 33.3 percent of the remainder in the first 4 consecutive months of earnings, $120 in months 5-12, and $90 thereafter. 11 Recipients are eligible for a one-time 100 percent disregard for the first six consecutive months of earnings if they find employment of 35 hours a week within the first 30 days of their initial approval for TANF. If work is not found within 30 days, the recipient is ineligible to ever receive the disregard again. An additional 100 percent disregard is available to units for three months when the unit’s case is subject to closure because of increased earnings and the individual is employed for at least 25 hours a week at the federal minimum wage or higher. The recipient may not have already received the six-month disregard, unless there has been at least a 12- month break in receipt of TANF benefits. The three-month disregard may be received more than once during the 60-month TANF benefit period provided there is a period of at least 12 consecutive months in which a family does not receive TANF benefits before the family reapplies for assistance. Two-parent units are also eligible to receive the six-month and three-month disregards. Once a two-parent unit is ineligible for the six-month disregard, they may disregard $120 and 33.3 percent of the remainder for 12 consecutive months and $90 thereafter. 12 Recipients are eligible for a one-time 100 percent disregard for the first six consecutive months of earnings if they find employment of 35 hours a week within the first 30 days of their initial approval for TANF. If work is not found within 30 days, the recipient is ineligible to ever receive the disregard again. An additional 100 percent disregard is available to units for three months when the unit’s case is subject to closure because of increased earnings and the individual is employed for at least 25 hours a week at the federal minimum wage or higher. The recipient may not have already received the six-month disregard, unless there has been at least a 12- month break in receipt of TANF benefits. The three-month disregard may be received more than once during the 60-month TANF benefit period provided there is a period of at least 12 consecutive months in which a family does not receive TANF benefits before the family reapplies for assistance. 14 The first 12 months of disregards are available to recipients again if they have been off TANF for at least 12 months. 15 These disregards apply to individuals working 20 or more hours a week. Individuals employed fewer than 20 hours a week may disregard 100 percent in the first month of employment and 50 percent thereafter; however, if an individual’s hours increase to 20 hours during the first six months, he or she may disregard 75 percent for the remainder of the six-month period. The 100 percent disregard is applicable only once every 12 months, even if employment is lost and then regained. 16 Two-parent units may disregard all earnings in excess of 35 hours a week for one parent and 24 hours a week for the other parent, $225, and 50 percent of the remainder in the first 24 consecutive months of benefit receipt. Thereafter, they may disregard $225 and 50 percent of the remainder. Welfare Rules Databook: State TANF Policies as of July 2017 257 30 Married couples with a child in common may disregard $1,200. 22 These disregards apply to individuals working full time, defined as 20 hours a week for recipients caring for a child under age 6 and 30 hours a week for all other recipients. Individuals working less than full time may disregard $120 and 50 percent of the remainder. 23 These disregards apply to individuals working full time, defined as 20 hours a week for recipients caring for a child under age 6 and 30 hours a week for all other recipients. Individuals working less than full time may disregard 100 percent in the first three consecutive months of earnings and $120 and 50 percent of the remainder thereafter. Regardless of the number of hours worked, the 100 percent disregard only applies to recipients who reside in units where all members have a combined monthly income less than or equal to $2,064 and remain eligible for cash assistance after all other disregards are applied to the payment standard. 24 The 50 percent disregard is available only once in a lifetime. 25 Once the recipient has received four months (they need not be consecutive) of the 90 percent disregard, he or she is not eligible to receive the disregard again until the TANF case has been denied and remains denied for one full month, and 12 calendar months have passed since the denial. The 12-month ineligibility period begins with the first full month of denial after the client used the fourth month of the 90 percent disregard. 27 The disregard is calculated by excluding varying earned income amounts based on the unit size, followed by a 20 percent disregard of the remainder regardless of unit size in all months. The dollar amounts excluded are: $141 for one to three unit members, $153 for four unit members, $179 for five unit members, and $205 for six or more unit members. A recipient who is participating in unsubsidized employment is eligible for an enhanced earned income disregard, provided the TANF recipient’s income does not exceed 100 percent of the Federal Poverty Guidelines or 150 percent of the Federal Poverty Guidelines for TANF-UP households. 21 The unit is not eligible to receive the disregard again until the unit has been off of AFDC for at least 12 consecutive months. 28 The disregard is calculated by excluding varying earned income amounts based on the unit size, followed by a 20 percent disregard of the remainder regardless of unit size in all months. The dollar amounts excluded are: $155 for one to three unit members, $168 for four unit members, $197 for five unit members, and $226 for six or more unit members. A recipient who is participating in unsubsidized employment is eligible for an enhanced earned income disregard, provided the TANF recipient’s income does not exceed 100 percent of the Federal Poverty Guidelines or 150 percent of the Federal Poverty Guidelines for TANF-UP households. 26 These disregards apply to recipients with income from unsubsidized employment or a combination of subsidized and unsubsidized employment. For recipients with earnings from subsidized employment only, the disregard is $90. 29 Married couples with a child in common may disregard $400. 20 Each recipient has a lifetime limit of one 13-month cycle of the extra disregards, unless the recipient is employed for less than six consecutive months, in which case the 13-month cycle starts over upon re-employment. 258 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama $164 $215 $215 $215 Alaska $923 $923 $923 $923 Arizona $347 $347 $278 $278 Arkansas $204 $204 $204 $204 California n.a. n.a. n.a. n.a. Non-exempt $594 $704 2 $694 2 $714 2 Exempt $663 $786 2 $776 2 $799 2 Colorado $356 $356 2 $462 2 $462 2 Connecticut 2 $543 $543 $576 $597 Delaware $338 $338 $416 $338 D.C. $415 $379 $428 $508 Florida $303 $303 $303 $303 Georgia $280 $280 $280 $280 Hawaii $570 3 $570 3 $610 4 $610 4 Idaho $317 $309 $309 $309 Illinois $377 $396 2 $432 2 $432 2 Indiana $288 $288 $288 $288 Iowa $426 $426 $426 $426 Kansas $429 $429 2 $429 2 $429 2 Kentucky $262 $262 $262 $262 Louisiana $190 2 $240 $240 $240 Maine $418 $485 $485 $485 Maryland $373 $473 $574 $648 Massachusetts n.a. n.a. n.a. n.a. Exempt $565 $633 $633 $633 Non-exempt $579 $618 $618 $618 Michigan $459 2 $459 2 $492 $492 Minnesota $532 2 $532 $532 $532 Mississippi $120 $170 $170 $170 Missouri $292 $292 $292 $292 Montana $425 $507 $504 $588 Nebraska $364 $364 $364 $450 Nevada $348 $348 $383 $383 New Hampshire $550 $625 $675 $1,021 New Jersey $424 $424 $424 $424 New Mexico $389 $389 $447 $409 New York 2 $577 $577 $753 $789 North Carolina $272 $272 $272 $272 North Dakota $431 $477 5 $477 5 $486 5 Ohio $341 $373 $434 $474 Oklahoma $307 $292 $292 $292 Oregon $460 $497 $528 $506 Pennsylvania 2 $403 $403 $403 $403 Rhode Island $554 $554 $554 $554 South Carolina $200 $205 $270 $283 South Dakota $430 $493 $555 $615 Tennessee $185 $185 $185 $185 Table L5. Maximum Monthly Benefit for a Family of Three with No Income, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 259 State 1996 2003 2010 2017 Texas $188 $213 $260 $286 Utah $426 $474 $498 $498 Vermont 2 $597 6 $639 7 $640 7 $640 7 Virginia 2 $354 $389 $389 $419 Washington $546 $546 $562 $521 West Virginia $253 $453 $340 $340 Wisconsin $518 2 n.a. n.a. n.a. W-2T n.a. $628 $628 $608 CSJ n.a. $673 $673 $653 TEMP n.a. 8 n.a. 8 n.a. 8 n.a. 9 UE n.a. n.a. 10 n.a. 10 n.a. 10 Wyoming $360 $340 $561 $660 Mean 11 $392 $416 $438 $454 Median 11 $377 $396 $429 $432 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. Maximum benefits are calculated assuming that the unit contains one adult and two children who are not subject to a family cap, has no special needs, pays for shelter, and lives in the most populated area of the state. Only earned income disregards are described in the table. Child care disregards and other special disregards, such as deductions for units subject to a time limit or a family cap, are not included. The figures include the impact of earned income disregards for recipients. If the disregards differ for applicants, it is footnoted. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 11 In states for which this table shows more than one component, the amounts used to compute the means and medians are the amounts for the first component that is listed, which is the one affecting the largest portion of the caseload. 2 Dollar amounts used for calculations vary within the state, either by county or by region of the state. This table shows the figures for the area of the state that is currently the most populous. See the Welfare Rules Database for more information. 5 The amount shown includes an additional $50 payment for units that pay their own shelter costs. 3 The benefit amount applies to units who have already received assistance for at least two months in their lifetime. For units applying for their first or second months of benefits, the maximum monthly benefit for a family of three is $712. 4 The benefit amount applies to units who have already received assistance for at least two months in their lifetime. For units applying for their first or second months of benefits, the maximum monthly benefit for a family of three is $763. 10 Recipients participating in unsubsidized employment receive wages and do not receive TANF cash assistance. 6 This amount applies to units paying at least $371 for housing. Benefits are lower if housing expenses are lower. 7 This amount applies to units paying $400 per month for housing. Benefits are lower if housing expenses are lower. For units with higher expenses, the benefit may be higher by up to $90 times the ratio of the payment standard to need standard. 8 The TEMP component was not in place in this year. 9 Recipients in TEMP receive wages from the TEMP employer; they do not receive cash payments from TANF. The wage is determined by the employer, but is at least the federal minimum wage; the agency subsidizes a portion of the wages. Most TEMP jobs are 40 hours per week. Table L5. Maximum Monthly Benefit for a Family of Three with No Income, 1996-2017 (July) 1 260 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama 24 3 3 12 Alaska 36 12 2 12 2 12 2 Arizona 24 No exemption No exemption No exemption Arkansas No exemption 3 3 3 3 3 3 California 36 4 12 5 24 6 24 7 Colorado 8 12 No exemption 9 No exemption 9 No exemption 9 Connecticut 10 12 12 12 12 Delaware 36 3 12 12 11 D.C. 36 12 12 12 Florida 36 3 12 3 12 3 12 Georgia 36 12 13 12 14 12 14 Hawaii 36 6 6 11 6 11 Idaho 36 No exemption No exemption No exemption Illinois 36 15 12 12 12 12 12 Indiana 36 10 3 3 3 Iowa 3 3 16 3 17 3 17 Kansas 36 12 6 18 3 Kentucky 36 12 11 12 11 12 11 Louisiana 12 12 11 No exemption No exemption Maine 36 12 11 12 11 12 11 Maryland 36 12 19 12 19 12 20 Massachusetts n.a. n.a. n.a. n.a. Exempt 21 24 24 24 24 Non-exempt 22 n.a. n.a. n.a. n.a. Michigan No exemption 3 3 23 2 24 Minnesota 36 12 12 12 Mississippi 36 12 11 12 11 12 11 Missouri 36 12 12 3 Montana 12 No exemption No exemption 25 No exemption 26 Nebraska 12 n.a. n.a. n.a. Time-limited assistance n.a. n.a. 27 n.a. 27 n.a. 27 Non-time-limited assistance 28 n.a. 3 29 3 29 3 30 Nevada 36 12 12 14 12 14 New Hampshire 36 n.a. n.a. n.a. NHEP n.a. 24 31 12 32 12 32 FAP 28 n.a. n.a. n.a. n.a. New Jersey 24 12 3 3 3 New Mexico 36 12 11 12 11 No exemption New York 36 3 33 3 33 3 33 North Carolina 60 34 12 11 12 11 12 11 Table L6. Work-Related Exemption When Caring for a Child under X Months, 1996 2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 261 State 1996 2003 2010 2017 North Dakota 24 4 4 2 Ohio 12 12 12 12 Oklahoma 12 3 11 4 11 4 11 Oregon 3 3 6 6 Pennsylvania 36 12 11 12 11 12 11 Rhode Island 36 12 12 12 South Carolina 36 12 n.a. n.a. All, except CARES n.a. n.a. 35 12 36 12 36 CARES 28 n.a. n.a. n.a. n.a. South Dakota 12 3 3 3 Tennessee 12 4 4 12 Texas 36 12 12 12 Utah No exemption No exemption No exemption No exemption 37 Vermont 18 38 24 39 24 39 24 39 Virginia 36 n.a. n.a. n.a. All, except VIEW 28 n.a. 18 40 12 40 12 40 VIEW n.a. n.a. 41 n.a. 41 n.a. 41 Washington 36 4 42 12 42 12 42 West Virginia 36 12 43 No exemption 44 No exemption 44 Wisconsin 12 3 3 2 Wyoming 12 3 11 3 11 3 11 4 This exemption is limited to one child during a period of continuous TANF eligibility, where continuous is defined as receiving welfare without a break of at least six consecutive months. 5 This exemption may be granted only one time and as a limited exemption for a second or subsequent child under 6 months old. 3 A parent loses this exemption after retaining it for 12 cumulative months. Months in which the parent is exempt because child care is unavailable for a child less than 12 months old also count toward the 12-month lifetime limit. 6 Persons caring for one child 12 to 23 months old or two or more children under six years old are exempt from work requirements. An individual may only be eligible for this exemption one time. An exemption for care of an additional child six months of age or under is also available. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. This table refers to single-parent unit heads over 21 years old. In some cases, recipients meeting certain criteria are placed in alternative components; see appendix 1 for more information on components. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 2 The exemption is limited to 12 cumulative months in the recipient’s lifetime. While the caretaker is exempt from work activities requirements, the recipient will still be required to develop a Family Self-Sufficiency Plan outlining the self- sufficiency activities in which he or she will participate. Table L6. Work-Related Exemption When Caring for a Child under X Months, 1996 2017 (July) 1 262 Welfare Rules Databook: State TANF Policies as of July 2017 22 Individuals caring for a child under two years old are placed in an alternative component. 27 Recipients caring for children under three months old are placed in an alternative component. 29 Although recipients caring for children between three and six months old are in the non-time-limited assistance component, they are expected to participate in limited work activities. Recipients caring for a child under three months old are exempt. 28 Recipients in this component are automatically exempt from activities requirements. 23 Women are exempt from activities requirements for three months after giving birth when the newborn is in the home or for postpartum recovery when the newborn is not in the home. 24 Women are exempt from activities requirements for two months after giving birth when the newborn is in the home or for postpartum recovery when the newborn is not in the home. 25 Although it is technically not an exemption, individuals caring for a newborn child may count this activity toward participation requirements for two full months following the child’s birth. The lifetime limit for this activity is 12 months. 26 Individuals caring for a newborn child may count this activity toward participation requirements for three full months following the child’s birth, up to a total of 12 months in an individual’s lifetime. Individuals can choose not to participate in other work activities during this time. 16 Although recipients are not exempt, they may be absent from work without sanction if they have a newborn child. Absence from activities is determined using the standards of the Family and Medical Leave Act of 1993. The maximum time available for one parent is 12 work weeks during any 12-month period, and for two parents, the maximum is the aggregate of 12 work weeks of leave for both parents. 17 Although recipients are not exempt, they may be absent from work without sanction if they have a newborn child. Absence from activities is determined using the standards of the Family and Medical Leave Act of 1993. The maximum time available for one parent is 12 work weeks during any 12-month period. 18 The exemption cannot be claimed by any adult in the unit when at least one adult has reached the 48th month of cash assistance. 21 Recipients who are in the Exempt component are automatically exempt from activities requirements. 19 This is a one-time exemption for the first child only. A single parent caring for a child under the age of six who is unable to obtain child care may be exempt. 20 The exemption is limited to 12 cumulative months in the recipient’s lifetime. A recipient caring for a child under the age of six who is unable to obtain child care may be exempt from work activities or sanctions. 15 This exemption does not apply to units in which the youngest related child is age 13 or older. 7 Months spent as a primary care provider for one child, birth to 23 months old, are exempt. For two-parent families, each parent has the option to receive the exemption but only one exemption can be granted at a time. An individual may only be eligible for this exemption one time. An exemption for care of an additional child six months of age or under is also available. 8 Counties have the option to vary some activities exemptions. These policies refer to Denver County. 9 A recipient caring for a child under the age of six who is unable to obtain child care may be exempt from work activities or sanctions. 10 The exemption applies only if the child is not subject to a family cap. 11 The exemption is limited to 12 cumulative months in the recipient’s lifetime. 12 Recipients may be required to attend classes or other activities. 13 The exemption is limited to once in the recipient’s lifetime. 14 Single custodial parents can have one three-month exemption per child up to a cumulative total of 12 months. Welfare Rules Databook: State TANF Policies as of July 2017 263 36 A parent personally providing care for his or her child under age one will be expected to participate in the work program but cannot be sanctioned for failure to do so. 41 Individuals with this characteristic are placed in an alternative component. 42 The exemption is limited to 12 cumulative months in the recipient’s lifetime. Participants may be required to participate in mental health or chemical dependency treatment if it is indicated in their assessment. 44 The state does not consider these groups technically exempt; however, they may meet the state’s criteria for good cause for noncompliance or deferral. This may be taken any time while the child is under 12 months for up to 12 months in the recipient’s lifetime. In addition, all mothers are eligible for a 12-week postpartum exemption good cause period following the birth of any additional child. 43 The exemption applies only to the birth of a first child. The recipient is exempt for only six months after the birth of any additional child (the six months include any time the recipient chooses to be exempt during pregnancy). 37 If parents are unable to find care for a child under age 13, the state may exempt the parents from activity requirements while it provides assistance in finding child care. 38 The parent is exempt from working but must participate in the Reach Up program. 39 The exemption is limited to 24 months in a recipient’s lifetime. In addition, recipients may be exempt for 13 weeks following the birth of each additional child. 40 The exemption is limited to 12 cumulative months in the recipient’s lifetime. The caretaker can be exempt for a maximum of six additional weeks if he or she has another child after the limit expires. Recipients caring for a child subject to a family cap are only exempt while the child is under six weeks old. Individuals with this characteristic are placed in the All, except VIEW component. All individuals in this component are exempt from activities requirements. 34 The exemption does not apply to parents who are working more than 30 hours a week. These parents are automatically enrolled into the Work First component and are subject to activities requirements. 32 The exemption is limited to 12 cumulative months in the recipient’s lifetime. If the recipient has exhausted this 12 month limit or has received 39 or more months of assistance prior to the birth of an additional child, the unit must participate in NHEP when the youngest child turns 12 weeks old. 33 The exemption may last for no more than 12 months in a recipient’s lifetime and it may not last for more than three months for any one child unless the social services official makes a determination to extend the exemption for up to the total 12 months. 35 The exemption does not apply to individuals under the age of 25 without high school diplomas or GEDs. 31 Recipients who have received 39 or more months of assistance cannot receive this exemption, unless the youngest child in the assistance group is under 12 weeks of age. 30 Recipients caring for a child under 3 months old are exempt and would be non-time-limited for the period of time they qualify for this exemption. This exemption can be extended under special circumstances. 264 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Alabama Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit 6 months Entire benefit 12 months Entire benefit 12 months Alaska Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed 2 Must reapply Case is closed 2 Must reapply Case is closed 2 Must reapply Arizona n.a. n.a. Entire benefit Until compliance or 1 month, whichever is longer Entire benefit Until compliance or 1 month, whichever is longer Entire benefit Until compliance or 1 month, whichever is longer All, except JOBSTART Adult portion of benefit Until compliance or 6 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. JOBSTART 50% 3 Until compliance or 1 month, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. Arkansas Adult portion of benefit Until compliance or 6 months, whichever is longer 50% or case is closed 4 Until in compliance for 2 weeks and must reapply Case is closed Until in compliance for 2 weeks and must reapply Case is closed Until in compliance for 2 weeks and must reapply California Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance Adult portion of benefit Until compliance Colorado 5 Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Connecticut Case is closed 3 months and must reapply Case is closed 6 3 months and must reapply Case is closed 3 months and must reapply Case is closed 3 months and must reapply Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 Welfare Rules Databook: State TANF Policies as of July 2017 265 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Delaware Case is closed Permanent Case is closed Permanent n.a. n.a. n.a. n.a. All, except TWP n.a. n.a. n.a. n.a. Case is closed One month plus 4 consecutive weeks of participation Case is closed Until compliance TWP n.a. n.a. n.a. n.a. Case is closed Until compliance Case is closed Until compliance D.C. Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until in compliance for 4 weeks Florida Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit 7 Until compliance or 3 months, whichever is longer Entire benefit 7 Until compliance or 3 months, whichever is longer Entire benefit 7 Until compliance or 3 months, whichever is longer Georgia Adult portion of benefit Until compliance, until granted an exemption, or 6 months, whichever is longer Case is closed 12 months Case is closed 12 months Case is closed 12 months Hawaii Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Idaho Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Permanent Case is closed Permanent Case is closed Permanent Illinois Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Until compliance or 3 months, whichever is longer and must reapply Case is closed Until compliance or 3 months, whichever is longer and must reapply Case is closed Until compliance or 3 months, whichever is longer and must reapply Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 266 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Indiana n.a. n.a. Case is closed Until compliance Case is closed Until compliance Case is closed Permanent Non-placement track Adult portion of benefit Until compliance or 6 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. Placement Track Adult portion of benefit Until compliance or 36 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. Iowa Case is closed Until compliance or 6 months, whichever is longer and must reapply Case is closed Until compliance or 6 months, whichever is longer and must reapply 8 Case is closed Until compliance or 6 months, whichever is longer and must reapply 8 Case is closed Until compliance or 6 months, whichever is longer and must reapply 8 Kansas Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 2 months, whichever is longer Entire benefit Until compliance Case is closed 10 years and must reapply Kentucky Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance Entire benefit Until compliance Entire benefit Until compliance Louisiana Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Until compliance or becomes exempt Case is closed Until compliance or 3 months, whichever is longer Case is closed Until compliance or 3 months, whichever is longer Maine Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance Maryland Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until in compliance for 1 month Entire benefit Until in compliance for 1 month Entire benefit Until in compliance for 1 month Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 Welfare Rules Databook: State TANF Policies as of July 2017 267 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Massachusetts n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. Exempt 9 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. Non-exempt 10 Entire benefit Until in compliance for 2 weeks Entire benefit Until in compliance for 2 weeks Entire benefit Until in compliance for 2 weeks Entire benefit Until in compliance for 2 weeks Michigan Entire benefit Until compliance Case is closed 1 month Case is closed 12 months Case is closed Permanent Minnesota Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Until compliance or 1 month, whichever is longer Case is closed Until compliance or 1 month, whichever is longer Case is closed Until compliance or 1 month, whichever is longer Mississippi Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Permanent Case is closed Permanent Case is closed Permanent Missouri Adult portion of benefit Until compliance or 6 months, whichever is longer 25% Until compliance or 3 months, whichever is longer 25% Until compliance or 3 months, whichever is longer Case is closed Until in compliance for 1 week and must reapply Montana Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit 11 Until compliance or 1 month, whichever is longer n.a. n.a. n.a. n.a. All, except PAS n.a. n.a. n.a. n.a. Case is closed 6 months and must reapply Case is closed 6 months and must reapply PAS n.a. n.a. n.a. n.a. Case is closed 12 6 months and must reapply Case is closed 13 6 months and must reapply Nebraska Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit 12 months or remainder of 48- month potential benefit period, whichever is shorter Entire benefit Until compliance or 12 months, whichever is longer Entire benefit Until compliance or 12 months, whichever is longer Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 268 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Nevada Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Permanent Case is closed Until compliance or 3 months, whichever is longer and must reapply Case is closed Until compliance or 3 months, whichever is longer and must reapply New Hampshire Adult portion of benefit Until compliance or 6 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. NHEP n.a. n.a. 67% of Adjusted Payment Standard 14 Until compliance or 1 month, whichever is longer Case is closed 15 Until in compliance for 2 weeks Case is closed 16 Until in compliance for 2 weeks FAP 9 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. New Jersey 20%; Adult portion of benefit Until compliance or 3 months, whichever is longer Case is closed 17 Must reapply Case is closed 1 month and must reapply Case is closed 1 month and must reapply New Mexico Adult portion of benefit Until compliance or 6 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. NMW n.a. n.a. Case is closed 6 months and must reapply Case is closed 6 months and must reapply Case is closed 6 months and must reapply EWP n.a. n.a. Case is closed 18 Until compliance Case is closed 19 Until compliance Case is closed 19 Until compliance New York Adult portion of benefit Until compliance or 6 months, whichever is longer Pro rata portion of the benefit Until compliance or 6 months, whichever is longer Pro rata portion of the benefit Until compliance or 6 months, whichever is longer Pro rata portion of the benefit Until compliance or 6 months, whichever is longer 20 Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 Welfare Rules Databook: State TANF Policies as of July 2017 269 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) North Carolina n.a. n.a. Case is closed 21 Must reapply Case is closed 21 Must reapply Case is closed 3 months and must reapply Work First Active $75 12 months n.a. n.a. n.a. n.a. n.a. n.a. Pre-Work First and Work First Preparatory n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. North Dakota Adult portion of benefit Until compliance or 3 months, whichever is longer Case is closed Until compliance or 12 months, whichever comes first Case is closed 22 1 month Case is closed 22 1 month Ohio Entire benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Oklahoma Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance Entire benefit Until compliance Entire benefit Until compliance Oregon Case is closed Until compliance and must reapply Case is closed Until compliance and must reapply Case is closed Until compliance and must reapply Case is closed Until compliance or 2 months, whichever is shorter, and must reapply Pennsylvania Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed 23 Permanent Case is closed 23 Permanent Entire benefit Permanent Rhode Island Adult portion of benefit Until compliance or 6 months, whichever is longer Pro rata portion of the benefit 24 Until in compliance for 2 weeks Case is closed 25 Must reapply Case is closed 25 Must reapply Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 270 Welfare Rules Databook: State TANF Policies as of July 2017 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) South Carolina Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Until in compliance for 1 month and must reapply n.a. n.a. n.a. n.a. All, except CARES n.a. n.a. n.a. n.a. Case is closed Until in compliance for 1 month Case is closed Until in compliance for 1 month CARES 9 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. South Dakota Adult portion of benefit Until compliance or 6 months, whichever is longer Case is closed Until compliance or 1 month, whichever is longer and must reapply Case is closed Until compliance or 1 month, whichever is longer and must reapply Case is closed Until compliance or 1 month, whichever is longer and must reapply Tennessee Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until in compliance for 5 days Entire benefit 12 months Texas Adult portion of benefit Until compliance or 6 months, whichever is longer $78 26 Until compliance or 6 months, whichever is longer Case is closed Until compliance or 2 months, whichever is longer and must reapply Case is closed Until compliance or 2 months, whichever is longer and must reapply Utah Entire benefit 27 Until compliance Entire benefit 27 Until compliance Case is closed 2 months and must reapply Case is closed 1 month and must reapply 28 Vermont Adult portion of benefit Until compliance or 6 months, whichever is longer $225 Until in compliance for 2 weeks $225 Until in compliance for 2 weeks $150 Until in compliance for 2 weeks Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 Welfare Rules Databook: State TANF Policies as of July 2017 271 Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Reduction in benefit Length of sanction (months) Virginia Adult portion of benefit Until compliance or 6 months, whichever is longer n.a. n.a. n.a. n.a. n.a. n.a. All, except VIEW 9 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. VIEW n.a. n.a. Entire benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 6 months, whichever is longer Washington Adult portion of benefit Until compliance or 6 months, whichever is longer Adult portion of benefit or 40%, whichever is greater Until in compliance for 4 weeks 29 Adult portion of benefit or 40%, whichever is greater Until in compliance for 4 weeks Case is closed Permanent West Virginia Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 3 months, whichever is longer Entire benefit Until compliance or 12 months, whichever is longer Wisconsin Entire benefit Until compliance n.a. n.a. n.a. n.a. n.a. n.a. W-2T and CSJ n.a. n.a. Case is closed Permanent 30 Case is closed Permanent 30 Case is closed Until compliance Trial Jobs n.a. n.a. Case is closed Permanent 30 Case is closed Permanent 30 n.a. n.a. TEMP n.a. n.a. n.a. n.a. n.a. n.a. Case is closed 31 Permanent 31 UE 9 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. Wyoming Adult portion of benefit Until compliance or 6 months, whichever is longer Entire benefit Until compliance Entire benefit Until compliance Entire benefit Until compliance Table L7. Most Severe Sanction Policy for Noncompliance with Work Requirements for Single-Parent Adults, 1996-2017 (July) 1 State 1996 2003 2010 2017 Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 272 Welfare Rules Databook: State TANF Policies as of July 2017 4 For the seventh and subsequent months of noncompliance, the caseworker has discretion to either reduce the unit’s benefits by 50 percent or close the case. If the case is closed, the unit may reapply for its full benefits, but the application will be pending until the unit complies with requirements for two weeks. 3 The participant will be removed from the JOBSTART program but will be eligible to participate in the non-JOBSTART component. 2 Case closure follows eight months of non-compliance. 1 Bolded text indicates a change from the previous year shown. \”Adult portion of benefit\” describes the portion of the benefit the sanctioned individual would have received. Because the table only represents sanctions for single-parent adults, in all cases the sanctioned individual is an adult. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 6 For recipients who have not reached the time limit, the entire assistance unit loses benefit eligibility for three months and must reapply for assistance after the sanction period. For recipients who have had their time limit extended, the entire assistance unit loses benefit eligibility for the remainder of the extension and does not qualify for additional extensions. 5 Counties have the option to determine the amount and duration of sanctions. These policies refer to Denver County. 10 An individual who demonstrates good cause will not be sanctioned for noncompliance with work requirements. 9 Recipients in this component are not required to participate in work activities; therefore, they are not subject to sanctions. 13 The participant loses eligibility for the PAS program and the household loses benefits for up to six months. 7 Assistance may still be provided to children under age 16 in the unit; these benefits are issued to a protective payee (after the second and subsequent sanction). 11 When a recipient fails to comply for the fourth or subsequent time, the needs of the individual are removed and the benefit is paid to a protective payee. The individual is sanctioned for 12 months. If a new contract has not been negotiated by one month after the end of the sanction period, the case is closed for noncompliance. The unit may reapply for benefits after a one-month period of ineligibility. 8 The sanctioned parent must sign a new Family Investment Agreement and complete 20 hours of eligible education or work activities to become eligible again. 17 This sanction applies to noncompliance that continues for three or more months. If the adult is noncompliant for less than three months, the pro rata share is removed, but the case remains open. 18 The benefit group will transition back into the NMW program and appropriate sanctions and benefit reductions will be applied. 12 The participant loses eligibility for the PAS program and the household loses benefits for one month. 15 After eight weeks of continuous noncompliance, or three non-consecutive months of noncompliance within a 12-month period, the case is closed. To have the case reopened, the sanctioned individual must fully participate in activities requirements for at least two consecutive weeks before eligibility can be redetermined. 16 If a unit accrues three months of sanctions in any 12-month period, the case may be closed. Any portion of a month counts as one full month. 14 The adjusted payment standard refers to the new benefit amount once the adult portion is removed. Welfare Rules Databook: State TANF Policies as of July 2017 273 21 This sanction applies to noncompliance that continues for three or more months. If the adult is noncompliant for less than three months, the entire benefit is removed, but the case remains open. 23 This sanction applies to noncompliance that occurs after the first 24 months of assistance. For instances of noncompliance occurring within the first 24 months of assistance, the needs of the sanctioned individual are permanently excluded for benefit calculation purposes. 24 If the individual is noncompliant for one to six months, 110 percent of the parent’s benefits is reduced from the unit’s benefit. For 7 to 12 months of noncompliance, 120 percent of the parent’s benefits is reduced from the unit’s benefit. For months 13 18, there is a 130 percent reduction. For months 19 24, there is a 140 percent reduction. Following 24 months of noncompliance, the reduction is decreased to 100 percent of the parent’s benefit, but the entire remaining benefit must be made to a protective payee. The individual is sanctioned until he or she is in compliance for two weeks. 19 The program participant is placed on probation if he or she has not met program requirements. At the end of the probationary period, if standards have not been met or an overall GPA of 2.5 has not been achieved, the department may take action to terminate an individual’s participation in the Education Works program, and the individual is transitioned back to the New Mexico Works Program. 22 If the adult is noncompliant for one month or less, only the adult portion of the benefit is removed. If noncompliance continues after one month of reduced benefits, the case is closed. 26 A financial penalty is imposed on the household benefits for six months or until the unit complies with requirements and signs form 2580, whichever is later, up to the financial penalty cap limit. The monthly penalty amount for noncompliance is $78 when only one parent fails to comply and $125 when both parents fails to comply with JOBS requirements. 20 This policy applies to individuals who do not reside in a city with a population of one million or more individuals. For individuals in a city with a population of one million or more individuals, the length of the sanction is until compliance with employment requirements, as assigned by the local district. 25 If a person is penalized and then becomes exempt, the benefits will be restored in the first full month following the month in which the state received documentation of the exemption. 28 The unit must also complete a two-week trial participation period before it is eligible to receive benefits again. 27 The entire unit is ineligible if the adult is in noncompliance for two or more months. If the adult is noncompliant for less than two months, only $100 of the benefit is removed. 30 Wisconsin has multiple components. If a recipient refuses to participate in an activity, he or she is permanently ineligible for benefits in that component. The unit may receive benefits again if it becomes eligible for one of the other components. There is no permanent sanction for individuals in unsubsidized employment. 31 Recipients in the Trial Employment Match Program component are not subject to hourly reductions because they are paid wages directly by the employer. The TEMP employer and participant work together to allow for planned and excused absences. However, unplanned and unexcused absences by the participant will be reflected by a decrease in wages as determined by the employer. If unplanned and unexcused absences continue, the recipient will be ineligible for benefits in the TEMP program for life but may be eligible to receive benefits in another component. 29 The sanction remains in effect until the individual is compliant for four weeks; after four weeks of compliance, benefits are restored to their pre-sanction level and the individual is paid retroactively for the four weeks of compliance. 274 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Alabama $1,000 $2,000\/$3,000 2 No limit No limit Alaska $1,000 $2,000\/$3,000 2 $2,000\/$3,000 2 $2,000\/$3,000 2 Arizona $1,000 $2,000 $2,000 $2,000 Arkansas $1,000 $3,000 $3,000 $3,000 California $2,000 3 $2,000\/$3,000 2 $2,000\/$3,000 2 $2,250\/$3,250 4 Colorado $1,000 $2,000 $15,000 No limit Connecticut $3,000 $3,000 $3,000 $3,000 Delaware $1,000 $1,000 $10,000 $10,000 D.C. $1,000 $2,000\/$3,000 2 $2,000\/$3,000 2 $2,000\/$3,000 2 Florida $1,000 $2,000 $2,000 $2,000 Georgia $1,000 $1,000 $1,000 $1,000 Hawaii $1,000 $5,000 $5,000 No limit Idaho $1,000 $2,000 $2,000 $5,000 Illinois $1,000 $2,000\/$3,000\/$3,000 +$50 5 $2,000\/$3,000\/$3,000 +$50 5 No limit Indiana $1,000 $1,500 3 $1,500 3 $1,500 3 Iowa $5,000 6 $5,000 7 $5,000 7 $5,000 7 Kansas $1,000 $2,000 $2,000 $2,250 Kentucky $1,000 $2,000 8 $2,000 8 $2,000 8 Louisiana $1,000 $2,000 No limit No limit Maine $1,000 $2,000 $2,000 $2,000 Maryland $1,000 $2,000 No limit No limit Massachusetts $2,500 $2,500 $2,500 $2,500 Michigan $1,000 $3,000 $3,000 $3,000 Minnesota $1,000 $5,000 6 $5,000 6 $10,000 9 Mississippi $1,000 $2,000 10 $2,000 11 $2,000 11 Missouri $5,000 3 $5,000 3 $5,000 3 $5,000 3 Montana $1,000 3,000 $3,000 $3,000 Nebraska $1,000 $4,000\/$6,000 12 $4,000\/$6,000 12 $4,000\/$6,000 12 Nevada $1,000 $2,000 $2,000 $6,000 New Hampshire $1,000 $2,000 3 $2,000 3 $2,000 3 New Jersey $1,000 $2,000 $2,000 $2,000 New Mexico $1,000 $3,500 13 $3,500 13 $3,500 13 New York $1,000 $2,000\/$3,000 14 $2,000\/$3,000 14 $2,000\/$3,000 14 North Carolina $3,000 $3,000 $3,000 $3,000 North Dakota $1,000 $3,000\/$6,000\/$6,000 +$25 15 $3,000\/$6,000\/$6,000 +$25 15 $3,000\/$6,000\/$6,000 +$25 15 Ohio $1,000 No limit No limit No limit Oklahoma $1,000 $1,000 $1,000 $1,000 Oregon $10,000 16 $10,000 16 $10,000 16 $10,000 16 Pennsylvania $1,000 $1,000 $1,000 $1,000 Rhode Island $1,000 $1,000 $1,000 $1,000 South Carolina $1,000 $2,500 $2,500 $2,500 South Dakota $1,000 $2,000 $2,000 $2,000 Table L8. Asset Limits for Recipients, 1996 2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 275 State 1996 2003 2010 2017 Tennessee $1,000 $2,000 $2,000 $2,000 Texas $1,000 $2,000\/$3,000 2 $1,000 17 $1,000 Utah $2,000 $2,000 $2,000 $2,000 Vermont $1,000 18 $1,000 18 $2,000 19 $9,000 20 Virginia n.a. n.a. No limit No limit All, except VIEW $1,000 $1,000 n.a. n.a. VIEW $1,000 $1,000 n.a. n.a. Washington $1,000 $1,000 $1,000 21 $4,000 22 West Virginia $1,000 $2,000 $2,000 $2,000 Wisconsin $1,000 $2,500 $2,500 $2,500 Wyoming $1,000 $2,500 $2,500 $5,000 4 Units including an elderly or disabled person may exempt $3,250; all other units exempt $2,250. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. This table describes the asset limits for recipients. If the exemptions differ for applicants, it is footnoted. No Limit indicates a state does not place a limit on the amount of assets that can be held by the unit. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. ABLE accounts are generally excluded from the asset limit. See the Welfare Rules Database for more information. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 2 Units including an elderly person may exempt $3,000; all other units exempt $2,000. 3 The asset limit for applicants is $1,000. Table L8. Asset Limits for Recipients, 1996 2017 (July) 1 13 The total limit is $3,500, but only $1,500 of that amount can be in liquid resources and only $2,000 can be in non- liquid resources. 14 Units including a person age 60 years or older may exempt $3,000; all other units exempt $2,000. 5 The asset limit is based on unit size; the limit is $2,000 for one person, $3,000 for two people, and $3,000 for three or more people plus $50 for each additional person. 6 The asset limit for applicants is $2,000. 7 The asset limit is $5,000 for households that have at least one member who was a program recipient in the month before the month of application. The asset limit for applicants is $2,000. 12 The asset limit is based on unit size: one person receives $4,000, and two or more people receive $6,000. 9 Withdrawals from ABLE accounts used to pay for a qualified disability expense are excluded. 10 When a TANF recipient marries for the first time while receiving assistance, the resources of the new spouse are disregarded for six consecutive months. This is a one-time, lifetime disregard. 11 If the unit is considered broad-based categorically eligible, it is not subject to asset limits. Households that include a convicted drug felon or a member currently disqualified for an intentional program violation are not considered broad- based categorically eligible. When a TANF recipient marries while receiving assistance, the liquid resources of the new spouse are excluded for six months beginning the month after the date of the marriage. 8 Only liquid resources are considered for eligibility determinations. Liquid resources include cash, checking and savings accounts, CDs, stocks and bonds, and money market accounts. 276 Welfare Rules Databook: State TANF Policies as of July 2017 15 The asset limit is based on unit size: one person receives $3,000, two people receive $6,000, and another $25 is allowed for each additional person thereafter. 16 The limit is reduced to $2,500 if the recipient does not cooperate with his or her case plan. JOBS Plus and JOBS participants must first be deemed eligible under normal rules. The asset limit for applicants is $2,500. 17 When a TANF recipient marries while receiving assistance, the liquid resources of the new spouse are excluded for six months beginning the month after the date of the marriage. To receive the disregard, the resources must result from the new spouse’s earnings and total gross income must not exceed 200 percent of the Federal Poverty Guidelines. 18 In addition to the $1,000 asset limit, assets accumulated from earnings, interest earned on those assets, and non- liquid assets purchased with savings from earnings and other excluded income or resources are excluded as a resource. 19 In addition to the $2,000 asset limit, assets accumulated from earnings, interest earned on those assets, and non- liquid assets purchased with savings from earnings and other excluded income or resources are excluded as a resource. 20 Other excluded resources include assets accumulated from earnings, interest earned on assets, non-liquid assets purchased with savings from earnings, retirement accounts (such as IRAs, 401(k)s, and other qualified accounts), and child education savings accounts (such as the Vermont Higher Education Investment Plan and other qualified plans). 21 $3,000 in a savings accounts or certificates of deposit may also be excluded. 22 Recipients can have $1,000 in any type of assets and an additional $3,000 in a savings account or certificates of deposit. Welfare Rules Databook: State TANF Policies as of July 2017 277 State 1996 2003 2010 2017 Alabama $1,500 E All vehicles owned by household n.a., no assets test n.a., no assets test Alaska $1,500 E All vehicles owned by household 2 All vehicles owned by household 2 All vehicles owned by household 2 Arizona One vehicle per household 3 All vehicles owned by household All vehicles owned by household All vehicles owned by household Arkansas $1,500 E One vehicle per household One vehicle per household One vehicle per household 4 California $4,500 E, 3 $4,650 E $4,650\/one vehicle per licensed driver F, 5 $9,500\/one vehicle per licensed driver E, 6 Colorado $1,500 E $4,500 F, 7 One vehicle per employed adult n.a., no assets test Connecticut $9,500 E $9,500 E, 8 $9,500 E, 8 $9,500 E, 8 Delaware $4,650 E $4,650 E All vehicles owned by household All vehicles owned by household D.C. $1,500 E All vehicles owned by household All vehicles owned by household All vehicles owned by household Florida $1,500 E $8,500 E $8,500 E $8,500 E Georgia $1,500 E $4,650 E, 9 $4,650 E, 9 $4,650 E, 9 Hawaii $1,500 E All vehicles owned by household All vehicles owned by household n.a., no assets test Idaho $1,500 E $4,650 F, 10 One vehicle per adult One vehicle per adult 11 Illinois $1,500 E One vehicle per household 12 One vehicle per household 12 n.a., no assets test Indiana $1,000 E, 13 $5,000 of one vehicle per household E, 13 $5,000 of one vehicle per household E, 13 $5,000 of one vehicle per household E, 13 Iowa $3,889 E $4,115 per vehicle for each adult and working teenager E One vehicle per household 14 One vehicle per household 15 Kansas $1,500 E All vehicles owned by household 16 All vehicles owned by household 16 One vehicle per adult 17 Kentucky $1,500 E All vehicles owned by household All vehicles owned by household All vehicles owned by household Louisiana $1,500 E All vehicles owned by household n.a., no assets test n.a., no assets test Maine One vehicle per household One vehicle per household One vehicle per household One vehicle per household Maryland $1,500 E All vehicles owned by household n.a., no assets test n.a., no assets test Massachusetts $5,000 F $5,000\/$10,000 E\/F, 18 $5,000\/$10,000 E\/F, 18 $15,000 F Michigan One vehicle per household 19 All vehicles owned by household All vehicles owned by household All vehicles owned by household Minnesota $1,500 E $7,500 F, 20 $15,000 F, 20 One vehicle per household member who is 16 or older F, 21 Table L9. Asset Limit Vehicle Exemptions for Recipients, 1996 2017 (July) 1 278 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 Mississippi $1,500 E All vehicles owned by household All vehicles owned by household 22 All vehicles owned by household E, 23 Missouri First vehicle 100%\/ Second vehicle $1,500 E, 24 First vehicle 100%\/ Second vehicle $1,500 E, 24 First vehicle 100%\/ Second vehicle $1,500 E, 24 First vehicle 100%\/ Second vehicle $1,500 E, 24 Montana $1,500 E One vehicle per household 25 One vehicle per household 25 One vehicle per household 25 Nebraska $1,500 E One vehicle per household 26 One vehicle per household 26 One vehicle per household 26 Nevada $1,500 E One vehicle per household One vehicle per household One vehicle per household 27 New Hampshire $1,500 E One vehicle per licensed driver One vehicle per licensed driver One vehicle per licensed driver 28 New Jersey $1,500 E $9,500 F, 29 All vehicles owned by household All vehicles owned by household 30 New Mexico $1,500 E All vehicles owned by household 31 All vehicles owned by household 32 All vehicles owned by household 32 New York $1,500 E $4,650 F, 33 $4,650 F, 33 $11,000 F, 34 North Carolina $5,000 F One vehicle per adult All vehicles owned by household 35 All vehicles owned by household North Dakota $1,500 E One vehicle per household One vehicle per household One vehicle per household Ohio $4,600 F n.a., no assets test n.a., no assets test n.a., no assets test Oklahoma $1,500 E $5,000 E $5,000 E $5,000 E Oregon $10,000 of one vehicle E $10,000 of one vehicle E $10,000 of all vehicles owned by household E $10,000 of all vehicles owned by household E Pennsylvania $1,500 E One vehicle per household One vehicle per household One vehicle per household 27 Rhode Island $1,500 E $1,500\/$4,650 E\/F, 36 One vehicle per adult 37 One vehicle per adult 37 South Carolina $1,500 E One vehicle per licensed driver 38 One vehicle per licensed driver 38 One vehicle per licensed driver 39 South Dakota $1,500 E, 40 One vehicle per household 41 One vehicle per household 41 One vehicle per household 42 Tennessee $1,500 E $4,600 E $4,600 E $4,600 E Texas $1,500 E $4,650 of each vehicle owned by household F, 43 $4,650 of each vehicle owned by household F, 44 $4,650 of each vehicle owned by household E, 44 Utah $8,000 E, 10 $8,000 E, 10 All vehicles owned by household All vehicles owned by household Vermont One vehicle per household E One vehicle per adult One vehicle per adult One vehicle per adult Table L9. Asset Limit Vehicle Exemptions for Recipients, 1996 2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 279 State 1996 2003 2010 2017 Virginia n.a. n.a. n.a., no assets test n.a., no assets test All, except VIEW $1,500 E One vehicle per household E, 45 n.a. n.a. VIEW One vehicle per household F\/E, 46 One vehicle per household E\/F, 46 n.a. n.a. Washington $1,500 E $5,000 E, 10 $5,000 E, 10 $5,000 E, 47 West Virginia $1,500 E One vehicle per household One vehicle per household One vehicle per adult 48 Wisconsin $2,500 E $10,000 E $10,000 E $10,000 E Wyoming $1,500 E $12,000 F, 49 One vehicle per household E, 49 Two vehicles per household E Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. This table describes the vehicle exemptions for recipients. If the exemptions differ for applicants, it is footnoted. Policies that distinguish between the equity value and fair-market value of vehicles are marked as follows: (E) equity value of the vehicle; (F) fair-market value of the vehicle. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. If a state’s program includes mutually-exclusive components in some years but not others, then in the years without components, the state’s information is shown on the statewide row and the component rows show n.a. , and in the years with components, the state’s information is shown on the component rows and the statewide row shows n.a. 3 Applicants may only exempt $1,500 of the equity value of a vehicle. 4 If the family has more than one vehicle, then the market value of any additional vehicles will be considered in full. Table L9. Asset Limit Vehicle Exemptions for Recipients, 1996 2017 (July) 1 2 Vehicles are exempt if used for one of the following: (1) to meet the family’s basic needs, such as getting food and medical care or other essentials; (2) to go to and from work, school, training, or work activity (such as job search or community service); (3) as the family’s house; (4) to produce self-employment income; or (5) to transport a disabled family member, whether or not he or she is a part of the assistance unit. If the vehicle does not meet one of these requirements, the equity value of the vehicle is counted in the determination of resources. 5 Each vehicle must be evaluated for both its equity and fair-market values; the higher of the two values counts against the family’s asset limit. Before this calculation, all the following vehicles are completely excluded: (1) vehicles used primarily for income-producing purposes, (2) vehicles that produce annual income consistent with their fair-market value, (3) vehicles necessary for long-distance travel that is essential for employment, (4) vehicles used as the family’s residence, (5) vehicles necessary to transport a physically disabled household member, (6) vehicles that would be exempt under previously stated exemptions but are not in use because of temporary unemployment, (7) vehicles used to carry fuel or water to the home and are the primary method of obtaining fuel or water, and (8) vehicles of which the equity value is $1,501 or less. To determine the countable fair-market value of each remaining vehicle, $4,650 is excluded from the vehicle’s fair-market value. To determine the countable equity value of each remaining vehicle, one additional vehicle per adult and one additional vehicle per licensed child who uses the vehicle to travel to school, employment, or job search are excluded. The full equity value of each remaining vehicle is counted. For each vehicle not completely excluded, the higher of the fair- market value or the equity value counts against the family’s asset limit. 280 Welfare Rules Databook: State TANF Policies as of July 2017 14 Additionally, $4,658 of the equity value of an additional vehicle is exempt for each adult and working teenager whose resources must be considered in determining eligibility. 10 The value of one specially equipped vehicle used to transport a disabled family member is also exempt. 22 Recreational vehicles are not exempt. Additionally, industrial vehicles\u2014heavy haulers, pulpwood trucks, etc.\u2014are exempt as long as they are used for income- producing purposes over 50 percent of the time, or as long as they annually produce income consistent with their fair-market value. Determination of whether to count a vehicle is made case by case. 23 Determination of whether to count a vehicle is made case by case. 19 The value of any additional vehicle necessary for employment is also exempt. 20 For the fair market value, Minnesota uses the loan value of the vehicle as listed in the current NADA Used Car Guide, Midwest edition. 21 Any additional vehicle that is not exempt is counted toward the $10,000 asset limit and is valued at the amount of the vehicle’s trade-in value as listed in the current NADA online car values and car prices guide. 15 Additionally, $5,880 of the equity value of a vehicle is exempt for each adult and working teenager whose resources must be considered in determining eligibility. 16 Campers and trailers are also considered excludable vehicles. 17 One licensed vehicle per adult household member is exempt. Additional vehicles may be exempt if they are used by a minor for employment, training, education, or seeking employment, used primarily for producing income, essential to employment, used as the household’s home, necessary to transport a household member with a physical disability, used to carry the primary source of fuel and water for the home, or valued at $1,500 or less. 18 The state compares the value of the vehicle to two standards: $10,000 of the fair-market value and $5,000 of the equity value. If the value of the vehicle exceeds either limit, the excess counts toward the asset limit; if the value of the vehicle exceeds both limits, only the excess of the greater amount counts toward the asset limit. 11 If the unit owns any other vehicle that is non-exempt, the fair market value of the additional vehicle is applied to the resource limit. 12 When there is more than one vehicle, the equity value of the vehicle of greater value is exempt. If a vehicle has special equipment for the disabled, the added value of the special equipment is exempt and does not increase the vehicle’s value. 13 The exemption can only be applied to the value of one vehicle. 9 If the vehicle is used for job search, or to travel to work or education and training, the unit may exclude $4,650 of the value. If the vehicle is not used for these purposes, $1,500 of the equity value may be excluded. If the vehicle is used more than 50 percent of the time to produce income or as a dwelling, it is totally excluded. 6 Each vehicle must be evaluated for its equity value. Before this calculation, a vehicle is excluded if it: (1) is used primarily for income-producing purposes; (2) is necessary for long-distance travel that is essential for employment; (3) is used as the family’s home; (4) is necessary to transport a physically disabled household member; (5) would be exempt under previously stated exemptions but the vehicle is not in use because of temporary unemployment; (6) is used to carry fuel or water to the home and is the primary method of obtaining fuel or water; and (7) is a gift, donation, or family transfer. For each remaining vehicle, the state excludes one additional vehicle per adult and one additional vehicle per licensed child who uses the vehicle to travel to school, employment, or job search. For each remaining vehicle not completely excluded, the equity value that exceeds $9,500 counts against the family’s asset limit. 7 One vehicle per household may be exempt if used to transport a person with a disability, used to obtain medical treatment, or used for employment. 8 The unit may exempt up to $9,500 of the vehicle’s equity value, or the entire value of one vehicle used to transport a handicapped person. The motor vehicle exclusion is applied to the registered vehicle with the highest fair market value. Welfare Rules Databook: State TANF Policies as of July 2017 281 42 In addition to one primary vehicle, an assistance unit may totally exclude a vehicle used to transport water or fuel to the home when it is not piped in, or to transport a disabled member or SSI recipient in the household. The assistance unit may also exclude $4,650 of the fair-market value of a vehicle used to transport members of the unit for education or employment. 40 A vehicle owned by a child at least 14 years old is exempt if the child is at least a part-time student and a part-time worker, a portion of the payment for the car comes from the child’s income, and the car’s trade-in value does not exceed $2,500. 41 In addition to one primary vehicle, an assistance unit may totally exclude a vehicle used to transport water or fuel to the home when it is not piped in, a vehicle used to transport a disabled member or SSI recipient in the household, or a vehicle used in producing income or as a home. An assistance unit may also exclude $4,650 of the fair-market value of a vehicle used to transport members of the unit for education or employment. 43 All licensed vehicles used for income-producing purposes are exempt. 37 Exemptions for adult drivers cannot exceed two vehicles per household. Additionally, the entire value of a vehicle is exempt if it is used primarily to provide transportation for a disabled family member, used primarily to produce income, or used as the family’s home. 38 Vehicles owned by or used to transport disabled individuals, vehicles essential to self-employment, income-producing vehicles, and vehicles used as a home are also exempt. 39 Vehicles owned by or used to transport disabled individuals or that are essential to self-employment are also exempt. If the unit owns any other vehicle that is non- exempt, the equity value of the additional vehicle is applied to the resource limit. 25 All vehicles whose primary use is to produce income or that are used as a home are also exempt. 26 The entire vehicle is exempt only if used for employment, training, medical transportation, or a home. If a unit has more than one vehicle that meets the exemption criteria, only the vehicle with the greatest equity value will be exempt. 36 A unit may choose to exempt $4,650 of the fair-market value of each vehicle or $1,500 of the equity value of each vehicle. In addition, the value of vehicles used primarily for income-producing purposes or to transport a person with a disability is excluded. 30 Recreational vehicles are not exempt and are evaluated for fair market value. 31 Vehicles used for transportation to work, work activities, or daily living requirements are not considered in eligibility determination. All vehicles that are equipped for the handicapped are also exempt. 32 The entire vehicle is exempt only if equipped for those with physical impairments or used for transportation to work, work activities, or daily living requirements. If the vehicle is not used for these purposes, the entire equity value of the vehicle is subject to the asset test. 33 If the vehicle is needed to seek or retain employment, $9,300 of the vehicle’s fair-market value is exempt. Otherwise, up to $4,650 may be exempt. 34 One automobile is exempt, up to $11,000 of the fair market value; local districts may adopt a higher vehicle exemption. 35 Boats are included in the definition of motor vehicles. Exclusion does not apply to mobile homes other than the primary physical residence. 27 Vehicles other than the household’s primary vehicle are evaluated for equity value. 28 The equity value of all non-junk vehicles is counted in addition to any excluded vehicles. 29 Units with two adults or one adult and a minor child at least 17 years old may exempt up to $4,650 of the fair-market value of a second vehicle if it is essential for work, training, or transporting a handicapped individual. 24 $1,500 of the equity value of the unit’s second vehicle is exempt. 282 Welfare Rules Databook: State TANF Policies as of July 2017 44 All licensed vehicles used for income-producing purposes or for transporting a disabled household member are exempt. 46 If the fair-market value of the vehicle is greater than $7,500, any equity value greater than $1,500 is counted in the resource limit. 48 A person must be work-eligible to qualify for the vehicle exemption. 49 This exemption applies to a single-parent unit. Two vehicles are exempt for a married couple. 45 Any additional vehicles owned by the assistance unit with an equity value of $1,500 or less are excluded. 47 The entire equity value of a vehicle used to transport a disabled household member is also exempt. Welfare Rules Databook: State TANF Policies as of July 2017 283 State 1996 2003 2010 2017 Alabama No No No No Alaska No No No No Arizona Yes Yes Yes Yes Arkansas Yes Yes Yes Yes California No Yes Yes No Colorado No No No No Connecticut Yes Yes Yes Yes Delaware Yes Yes 2 Yes 2 Yes 3 D.C. No No No No Florida No Yes Yes Yes Georgia Yes Yes Yes Yes Hawaii No No No No Idaho No No 4 No 4 No 4 Illinois Yes Yes No 5 No Indiana Yes Yes Yes Yes Iowa No No No No Kansas No No No No Kentucky No No No No Louisiana No No No No Maine No No No No Maryland Yes Yes No No Massachusetts Yes Yes Yes Yes Michigan No No No No Minnesota No Yes Yes No Mississippi Yes Yes Yes Yes Missouri No No No No Montana No No No No Nebraska No 6 Yes No No Nevada No No No No New Hampshire No No No No New Jersey Yes Yes Yes Yes 7 New Mexico No No No No New York No No No No North Carolina Yes Yes Yes Yes North Dakota No Yes Yes Yes Ohio No No No No Oklahoma No Yes No No Oregon No No No No Pennsylvania No No No No Rhode Island No No No No South Carolina No Yes Yes Yes South Dakota No No No No Tennessee No Yes Yes Yes Texas No No No No Utah No No No No Vermont No No No No Virginia Yes Yes Yes Yes Washington No No No No Table L10. Family Cap Policies, 1996-2017 (July) 1 284 Welfare Rules Databook: State TANF Policies as of July 2017 State 1996 2003 2010 2017 West Virginia No No No No Wisconsin Yes No 4 No 4 No 4 Wyoming No Yes No No Total States with Any Cap 14 22 17 15 4 The state provides a flat maximum benefit, regardless of family size. 5 Illinois no longer has a family cap; however, the state applied a cap to children born more than 10 months after case opening between January 1, 1996, and January 1, 2004. Children who were capped during this period continue to be capped. The cap may be removed for these children if the unit does not receive benefits for a minimum of nine months and has not previously experienced an increase in the payment standard as the result of a birth while receiving TANF. 6 Nebraska conducted a demonstration project in five counties in 1996 that subjected units to a family cap. 7 Units in which at least one adult member of the unit is working (any number of hours) are not subject to the family cap. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Bolded text indicates a change from the previous year shown. Data shown in the table for the year 1996 reflect states’ AFDC policies; data shown in the table for all subsequent years reflect states’ TANF policies. 2 In addition to the family cap policy, any child born after December 31, 1998, to an unmarried minor parent is ineligible for cash assistance, regardless of whether the minor was receiving aid at the time of the birth. 3 In addition to the family cap policy, any child born after December 31, 1998 to an unmarried minor parent is ineligible for cash assistance, regardless of whether the minor was receiving aid at the time of the birth. If the minor received benefits within 10 months of the birth of the child, the child will always be capped. If the minor did not receive benefits within 10 months of the birth of the child, the child will be eligible for assistance once the minor turns 18. Units in which the child is not permanently capped may receive noncash assistance services in the form of vouchers upon request, but he or she will not be automatically given vouchers each month. Receipt is based on need, and the total monthly value of the vouchers is capped at $69. Table L10. Family Cap Policies, 1996-2017 (July) 1 Welfare Rules Databook: State TANF Policies as of July 2017 285 Appendix 1: Component Descriptions The WRD and this book define a state’s TANF program as having a component when the state divides its entire caseload into mutually exclusive groups that are treated differently across more than one policy area. These groups are usually defined by more than one characteristic. Not every state uses components. For those that do, appendix table 1 describes how recipients are divided among the components, how long recipients can remain in the various components, and any interaction between the components in the state. 286 Welfare Rules Databook: State TANF Policies as of July 2017 State Name Duration Description Maximum time in component 3 Interaction California Non-exempt 07\/97 – Present Recipients who do not meet any of the exemption requirements described under the Exempt Description of Component. Indefinite, unless recipient becomes exempt Exempt 07\/97 – Present Recipients who meet one of the following are considered exempt for purposes of MAP amounts (payment standard): is a parent or relative, an aided parent of an unaided child, a pregnant woman, or an adult in a Refugee Cash Assistance Unit and receives SSI, In-Home Support Services, State Disability Insurance, or Temporary Worker’s Compensation. Unaided non-parent caretakers are also exempt. Until recipient no longer meets exemption characteristics Delaware All, except TWP 09\/09 – Present Those who are not disabled and therefore do not qualify for the Transitional Work Program. Indefinite, unless recipient becomes disabled Transitional Work Program (TWP) 09\/09 – Present The Transitional Work Program serves disabled caretakers and parents in the TANF program who are unable to participate fully in required work activities. Through TWP, each client develops an individualized plan that suits his or her needs and capabilities. Through the plan, clients can work to gain employment, enter training, or be accepted to a program better suited to meet their long term needs, such as SSI. Until recipient is no longer disabled; Inclusion of persons with temporary disability can last up to six months without medical documentation. Appendix 1: Component Description 2 Recipients change components only when something happens to change their exemption status. Disabled participants in the non-time- limited TANF program are assessed for participation in the Transitional Work Program. Those who can work with accommodation or have temporary disabilities are placed into TWP. When a temporarily disabled TWP participant is determined to be rehabilitated, the participant will be referred to the time- limited Employment and Training program (All, except TWP component). Welfare Rules Databook: State TANF Policies as of July 2017 287 State Name Duration Description Maximum time in component 3 Interaction Massachusetts Exempt 4 11\/95 – Present Recipient must meet one of the following exemptions: child only unit; receiving SSI; disabled; caring for a disabled child, spouse, child’s other parent, recipient’s parents, or grandparent; pregnant women whose child is expected to be born within 120 days; child under the age of 2 who is either in the assistance unit or would be in the assistance unit except that the child receives SSI, state or federal foster care maintenance payments, or state or federal adoption assistance; a child under 3 months old living in the home and not included in the assistance unit; teen parent under age 20 meeting living arrangement requirements and attending school; or recipient age 60 or older. This component is exempt from the reduced Need and Payment Standards, time limits, and work requirements. Until recipient no longer meets exemption characteristics Non-exempt 11\/95 – Present Recipients who do not meet any of the exemption requirements described under the Exempt Description of Component. Indefinite, unless recipient becomes exempt Montana All, except PAS 08\/11 – Present Recipients participating in all other allowable activities not included under the PAS program. No limit Parents as Scholars (PAS) 08\/11 – Present Full-time students enrolled in an approved educational program leading toward a high school diploma, GED, associate’s degree or baccalaureate degree who have exhausted the 12 month limit on vocational education. A limited number of PAS slots are available and are awarded through a lottery. PAS participants face different activities requirements and sanctions. Until graduation or until the 60 month lifetime limit is reached Recipients who have exhausted the 12- month limit on vocational education may apply for a slot in the Parents as Scholars component. PAS participants are selected by lottery. Participants selected for PAS will be moved back into the regular work program upon graduation or upon receiving their second activities sanction. Recipients change components only when something happens to change their exemption status. Appendix 1: Component Description 2 288 Welfare Rules Databook: State TANF Policies as of July 2017 State Name Duration Description Maximum time in component 3 Interaction Nebraska Time-limited assistance 11\/95 – Present Intended for families where the adult family member is able to work. 60 months Non-time- limited assistance 11\/95 – Present Units where the adult member(s) are mentally, emotionally, or physically unable to work. Includes recipients who are one of the following: (1) ill or incapacitated, (2) caring for an ill or incapacitated household member, (3) over 65, (4) pregnant women beginning the month before the month of her due date, (5) caring for a child under 12 weeks old, (6) a single custodial parent who is unable to find child care for a child under the age of 5, (7) victims of domestic violence. An individual can become non-time- limited for up to six months; exemption must be reassessed at least every six months or sooner depending on the service plan, and may be extended beyond six months, if necessary. As part of the reevaluation of the Self- Sufficiency Contract, a family in the non- time-limited program may be reassigned to time-limited assistance if the adult family member becomes able to work. Likewise, a family in the time-limited program may be reassigned to the non- time-limited program if the adult family member becomes disabled or otherwise unable to work. Appendix 1: Component Description 2 Welfare Rules Databook: State TANF Policies as of July 2017 289 State Name Duration Description Maximum time in component 3 Interaction New Hampshire New Hampshire Employment Program (NHEP) 03\/97 – Present The NHEP Program provides financial assistance for families with dependent children who receive assistance and who are cared for by a parent or relative who is able bodied for employment; includes a work program and work sanctions. 60 months, may request 6 month extension of eligibility based on hardship, there is no limit on the number of extensions for which a NHEP group may qualify Family Assistance Program (FAP) 03\/97 – Present The FAP Program provides financial assistance for families with dependent children who receive assistance and who are cared for by a parent or relative who is unable to work due to a physical or mental disability, or are cared for by a relative other than a parent who is not receiving assistance. The program also includes individuals age 60 and older. Families who have reached their sixty-month time limit and have received at least one six-month extension for caring for a disabled relative, assistance unit member, or spouse may be permanently transferred to the Family Assistance Program. FAP does not include a work program and, therefore, does not include work sanctions. Unlimited, as long as FAP eligibility requirements are met —1 Appendix 1: Component Description 2 290 Welfare Rules Databook: State TANF Policies as of July 2017 State Name Duration Description Maximum time in component 3 Interaction New Mexico New Mexico Works Program (NMW) 10\/00 – Present The NMW Program provides financial assistance for families with dependent children who receive assistance and who are cared for by a parent or relative who is able bodied for employment; includes a work program and work sanctions. 60 months Education Works Program (EWP) 10\/00 – Present EWP is a state-funded post-secondary educational program offered as an alternative to the New Mexico Works program. The eligibility criteria for the Educational Works and the New Mexico Works Programs are the same except for the following: applicants for EWP must be in good standing with the NMW Program (this means the applicant can have no activities, child support or reporting sanctions), the applicant must provide proof of enrollment in a two or four year post-secondary education, graduate or post-graduate program, and the applicant must apply for all financial aid available. Participation in the Education Works Program is limited to twenty-four months, whether or not consecutive; Months of participation in the EWP cannot be applied towards the 60 month lifetime limit. Oregon All, except JOBS Plus 01\/96 – Present Recipients participating in all other allowable activities not included under the JOBS Plus program. Until case closure JOBS Plus 01\/96 – Present Recipients volunteer for the JOBS Plus program (under the Oregon Option waiver) that provides recipients with on- the-job training, while paying their benefits as wages from a work-site assignment. Until case closure During the initial application or recertification process, the Family Assistance analyst will screen an applicant for eligibility for the EWP. Recipients who are actively participating in NMW and who meet the requirements for EWP, shall be given first opportunity to switch programs. Benefit groups may not participate in both NMW and EWP simultaneously. Participants who leave EWP for a good cause may resume participation when the individual is able and ready to return to the EWP. An individual who leaves the EWP without establishing good cause, is not eligible to resume participation in the EWP. Appendix 1: Component Description 2 A person in JOBS Plus may participate up to 6 months, but participation in JOBS Plus can be extended by 30 days if the participant meets the exception process. Welfare Rules Databook: State TANF Policies as of July 2017 291 State Name Duration Description Maximum time in component 3 Interaction South Carolina All, except CARES-eligible participants 02\/08 – Present Recipients who do not meet any of the eligibility criteria of the CARES component. Indefinite, unless recipient becomes exempt Challenging Adults Through Rehabilitation, Education, and Services (CARES) 02\/08 – Present CARES is a state funded program that serves TANF-eligible individuals who face a health-related problem expected to last 90 days or more that prevents their participation in TANF work activities. The incapacity may be physical or mental, and must be verified by a physician or other health professional. Individuals accepted for treatment by Vocational Rehabilitation, DDSN, or Mental Health are eligible for cares as long as their treatment was not due to a criminal record or drug addiction. The following characteristics identify those participants placed in Track 1 case management activities: a) participants experience a disability severe enough to prevent full-time participation in the cash assistance Work Program, but not to the extent that all work and training activities are prevented; b) participants may show an indication of a learning disability, diagnosed as Learning Disabled (LD) by a licensed psychologist, and the learning disability prevents full-time cash assistance work participation for a period of 90 days or more; c) recipients may participate in any cash assistance Work Program activities for which they qualify even though special accommodations may be needed. The following characteristics identify those participants placed in Track 2 case management activities: recipients experience a permanent and total disability severe enough to prevent full- or part-time employment or participation in training activities and is expected to last more than 90 days. Until recipient is no longer incapacitated for a period of 90 days or longer Appendix 1: Component Description 2 Adult recipients are screened as part of the family evaluation and assigned to CARES when they meet the program requirements. No restrictions are placed on the number of times a client can move between the CARES program and other activities. 292 Welfare Rules Databook: State TANF Policies as of July 2017 State Name Duration Description Maximum time in component 3 Interaction Virginia All, except VIEW 07\/95 – Present Recipients who are exempt from VIEW; they do not have activities requirements. Component is funded by the state. No limit Virginia Initiative for Employment not Welfare Program (VIEW) 07\/95 – Present Employment activities (unsubsidized, subsidized, community service) are required for all non-exempt recipients. 24 months Wisconsin W-2 Transition (W-2T) 03\/97 – Present Individuals who have been determined not ready for unsubsidized employment and unable to participate in other employment positions for reasons such as an individual’s incapacitation or the need to remain in the home to care for another family member who is incapacitated or disabled. 24 months 5 Community Service Jobs (CSJ) 03\/97 – Present Individuals who are not ready for immediate regular employment, particularly where attempts to place a participant in an unsubsidized job or Trial Job have failed. 24 months 5 Trial Employment Match Program (TEMP) 03\/16 – Present TEMP is available in Dane, Kenosha, Milwaukee, and Racine counties, and in the city of Beloit. TEMP is for W-2 applicants or recipients who are not yet ready for unsubsidized employment. Participants are placed in subsidized jobs, usually 40 hours per week, paying at least the minimum wage. A job can last up to six months with a possible three-month extension; total participation in TEMP is limited to 24 months. In Dane, Marathon, and Milwaukee counties, non-custodial parents who qualify for W-2 case management may qualify for one TEMP job. 24 months Appendix 1: Component Description 2 Units are assigned to VIEW after initial eligibility determination. If a recipient meets the VIEW exemption criteria, they are placed in the All Except for VIEW component. Recipients should always be placed at the highest level of employment participation possible. Therefore, recipients move between components as appropriate. Welfare Rules Databook: State TANF Policies as of July 2017 293 State Name Duration Description Maximum time in component 3 Interaction Wisconsin Unsubsidized Employment (UE) 01\/98 – Present Individuals who are employed at the time of application or who have a strong employment history and skills. Includes individuals who are determined to be capable of obtaining employment, are currently in an unsubsidized job, or were previously assigned to a subsidized employment position. These recipients are not subject to either federal or W-2 time limits. Individuals in this component do not receive cash benefits but some case management services are available. Participation in the Case Management Underemployed (CMU) and Case Management Job Ready (CMJ) placements is not limited, but recipients may only receive services in the Case Management Follow- up (CMF) placement for 12 months (unless they are placed in CMF again, in which case the 12 months starts over). 5 From March 1997 until October 2009, participants were limited to 24 months in a component. Wisconsin discontinued the time limit from November 2009 through December 2011, and reinstated the time limit in January 2012. Source: Urban Institute’s Welfare Rules Database, funded by HHS\/ACF. 1 Information not found in state’s manual. 2 Only those states that have clearly delineated components are included in this table. Historical details about components no longer in use can be found in the Welfare Rules Database. 3 Where \”no limit\” is listed for \”maximum time in component,\” it is assumed that units in this component are bound by state time limits. See table IV.C.1 for information on the maximum amount of time recipients are allowed to receive assistance in the state. For more information on work exemptions and time limit exemptions, see tables III.B.1, IV.C.2(a) and (b), and IV.C.3(a) and (b). Or for more detail, see the WRD. 4 In Massachusetts, the exempt component makes up the majority of the caseload. Appendix 1: Component Description 2 294 Welfare Rules Databook: State TANF Policies as of July 2017 About the Authors Christine Heffernan is a research analyst in the Income and Benefits Policy Center at the Urban Institute. She is a key staff member on the Welfare Rules Database project with prior experience working directly with TANF clients. Benjamin Goehring is a research assistant in the Income and Benefits Policy Center at the Urban Institute. His work focuses on the US social safety net through the Welfare Rules Database and TRIM3 Transfer Income Model microsimulation analyses. Ian Hecker is a research assistant in the Income and Benefits Policy Center at the Urban Institute. He studies workforce development issues and welfare policy. Linda Giannarelli is a senior fellow in the Income and Benefits Policy Center at the Urban Institute. She serves as the project director for the Welfare Rules Database. She also directs the work that produces annual estimates of how many families are eligible for TANF benefits, a process that uses the policy data collected by the WRD. Sarah Minton is a senior research associate in the Income and Benefits Policy Center at the Urban Institute. She serves as co-project director for the Welfare Rules Database. Her work focuses on policies and programs affecting low-income families, with a particular focus on anti-poverty strategies. Welfare Rules Databook: State TANF Policies as of July 2017 295 2 1 0 0 M Street, N .W . W ash in gto n , D .C . 2 0 0 3 7 P h o n e: 2 0 2 .8 3 3 .7 2 0 0 F ax: 2 0 2 .4 6 7 .5 7 7 5 E -M ail: m ed ia@ u rb an .o rg h ttp :\/\/w w w .u rb an .o rg W elfare R ules D atabook Welfare Rules Databook: State TANF Policies as of July 2017 Table of Contents Table of Tables Introduction and Background The Welfare Rules Database The Databook I. Initial Eligibility A. Does the state try to divert some families from becoming recipients? B. How does family composition or individual status affect eligibility? C. What level of assets can a family have and still be eligible? D. How is income counted in determining eligibility? E. How much income can a family have and still be eligible? II. Benefits A. If a family passes all eligibility tests, what is received? III. Requirements A. Once determined eligible, what must a recipient family do to maintain benefits? B. What work activities are required? IV. Ongoing Eligibility A. What eligibility tests must recipient families pass for continuing eligibility? B. Are children eligible if born while the family receives benefits? C. How long can a family receive benefits? D. Can families receive transitional cash assistance? V. Policies across Time, 1996 2017 Appendix 1: Component Descriptions About the Authors ”

” C C W R O P O LI C Y B R IE FI N G – 20 17 – 0 1 Page 1 of 2 The Brown Administration has launched a 1.6 million dollar pilot program, not approved by the Legislature, to test Pondera Solutions replacement to the current Statewide Finger- imaging System (SFIS) for CalWORKs and General Assistance\/General Relief, Los Ange- les, Napa, Placer, Riverside and Stanislaus during 2017. Pondera Solutions was founded in 2011 and in it’s own words. isn’t law en- forcement, per se. The company offers fraud detection software to its clients with the aim of weeding out people that might be gaming pub- lic housing, unemployment, food stamps, and Medicaid systems. For the past five (5) years, MEDS has been doing the same thing for Cal- Fresh (Food Stamps), at no additional cost. The history of statewide finger imaging sys- tem (SFIS) – The SFIS system was enacted in 1996 added by a 1996 trailer budget bill (Stats. 1996, Ch. 206, Sec. 1.5.) to allegedly iden- tify and prevent duplicate participation in the CalWORKs and Food Stamp program (now CalFresh). SFIS is wasteful: In 2003, the Bureau of State Auditor General released a report about SFIS which concluded most of the matches that SFIS identified have turned out to be admin- istrative errors made by county staff, and the level of detected duplicate-aid fraud has been small. After this revelation of waste, Califor- nia’s welfare system still continues to spend taxpayer money to demonstrate that California is concerned about program integrity. To date, California may have spent about $200 million on this failed system. SFIS eliminated for Calfresh: On October 6, 2011, Governor Jerry Brown signed AB 6, Chapter 501, Statutes of 2011, which elimi- nated the Statewide Finger-Imaging System (SFIS). Effective January 1, 2012 California stopped using SFIS to identify duplicate par- ticipation in the CalFresh program and started to use the Medical Eligibility Data System (MEDS) to make sure that an applicant for CalFresh was not receiving CalFresh in another county. Kevin Aslanian, Executive Director [email protected] mobile (916)712-0071 Grace Galligher, Directing Attorney Kishweer Vikaas-Barraca, Staff Attorney 1111 Howe Ave, St. 150 Sacramento, CA 95825 Tel. (916)736-0616 Fax (916)736-2645 www.ccwro.org Pondera’s award- winning software is supported by our Spe- cial Investigations Unit (SIU). The SIU employs certified fraud examin- ers, data mining experts, statisticians, and former government program integrity managers and law enforcement agents. Together, they design, deliver, and support our software which is literal- ly built by investigators, for investigators . In the past five years MEDS addressed CalFresh duplicate participation. State Auditor General’s of- fice reports or any oth- er entity have found widespread duplicated participation in Cal- Fresh. MEDS has been very effective in combating duplicate participation. In 2016-2017, the California Legislature appropriated $13.2 million and the Gover- nor’s budget proposes to use another $13.2 million during 2017- 2018 – most likely for a new system utilizing a form of Knowledge- Coalition of California Welfare Rights Organizations, Inc. RECIPIENT & TAXPAYER IMPACT STATEMENT $13.2 million Pondera Solutions Demonstration Project replaces CalWorks fingerprinting while Medical Eligibility Data System (MEDS) does the same thing at no cost RECOMMENDATION FOR BUDGET LEGISLATIVE ACTION We urge the Legislature to delete any funding for SFIS or a similar system and enact budget control language that none of the funds appropri- ated by this budget can be used for SFIS or any other similar system. March 30, 2017 Based Authentication Pondera or Pondera- like system for CalWORKs and General Assistance. What is our concern with Pondera? This project was initiated in 2016. The Trump administration has launched a major assault against our Hispanic brothers and sisters and their families. Trump’s executive orders implementing his war on immi- grants makes individuals and families vulnerable to deportation with the implementation of the ill- conceived knowledge-based Pondera system. Given the demographics of our caseload, we be- lieve that this would have a horrific impact on our child-only cases which are 29% of the CalWORKs caseload. One could imagine the questions (on column 2) being asked of the ineligible relative caretaker of the child-only caseload. CONCLUSION What Pondera Solutions-like system will do, MEDS has been doing for the past five years with- out spending $13.2 million a year- identify dupli- cate participation in CalFresh and Medi-Cal. We suggest that in the absence of any major duplicate participation in the CalFresh program after 5 years of no fingerprinting, it is time to treat CalWORKs families just like we treat CalFresh and Medi-Cal families in California. There is no evidence of a slew of duplicate CalFresh and Medi-Cal participation. Moreover, it is our view that MEDS is more than capable of identifying du- plicate participation as it is an instrument to verify identity of non-citizens for Medi-Cal. We would urge the DEFUNDING of the multimillion dollar Pondera Solutions, or any other similar system and use MEDS effective 8\/17 when the SFIS contract ends. Why spend $13.2 million for this unneces- sary system when MEDS will do the same for no additional cost? The $13.2 million that is planned to be wasted for SFIS or a similar system in the Governor’s 2017- 2018 proposed budget can better be used to help CalWORKs homeless families by upgrading the Homeless Assistance Program. Recommendation for Legislative Action – We urge the Legislature to require using MEDS for CalWORKs program integrity and delete any funding for SFIS or a simi- lar system and enact budget control lan- guage that none of the funds appropriated by this budget can be used for SFIS or any other similar system. Page 2 of 2 Examples of questions Pondera would ask to determine identity of CalWORKs & CalFresh applicants and recipients. ( These questions assume alternative facts ) Current industry standard is to present 4 questions, 3 of the 4 questions answered correctly will pass the authenti- cation. If not, then the person would be suspected of welfare fraud and could be subject to investigation, a search of their house by the welfare fraud investigators and more. Our benefi- ciary concerns are shown below: 1. What month were you born? 2. How long have you lived at your current residence? BEN- EFICIARY CONCERN: Many are homeless and do not have a residence. 3. Which of the following people have you known? BENEFI- CIARY CONCERN: This sounds like McCarthyism for our Hispanic brothers and sisters. 4. Which of the following vehicles have you recently owned\/ leased? BENEFICIARY CONCERN: Less than 25% of CalWORKs families own a car. This question is demeaning in that it as- sumes the respondent has a car like the person drafting the questions does. 5. Which of the following streets have you ever lived or used as your address? BENEFICIARY CONCERN: Some people are homeless and do not have a residence. 6. What is the color of your current vehicle? BENEFICIARY CONCERN: Less than 25% of CalWORKs families own a car. This question is demeaning in that it assumes the respondent has a car like the person drafting the questions does. 7. Which of the following email addresses have you ever been associated with? BENEFICIARY CONCERN: Many CalWORKs parents, especially those from the 29% child-only cases have no email address. It is also an insulting question and the respondent would feel demeaned for not having an email address. 8. According to your driver’s license, approximately how tall are you? BENEFICIARY CONCERN: Less than 25% of CalWORKs families own a car. This is a demeaning question in that it as- sumes that the respondent has a car like the person drafting these questions does. Moreover, many parents do not even have a driver’s license. 9. Which of the following phone numbers have you ever been associated with? BENEFICIARY CONCERN: This question implies that folks have the same phone numbers for years and can identify the number. In reality, many CalWORKs beneficia- ries are having their telephone services constantly disconnected then getting different numbers. ”

” SPRING 2018-19 April 2019 PRACTICUM RESEARCH TEAM: Nick DeFiesta (JD ’19) Shelby Hart-Armstrong (JD ’19) Liz Lagerfeld (JD ’20) Elizabeth Reetz (JD ’20) Eric Rodriguez (JD ’20) Rachel Waterman (JD ’20) Kelsey Woodford (JD ’19) INSTRUCTORS: Lisa Douglass, Lecturer and Clinical Supervising Attorney, Stanford Community Law Clinic Diane T. Chin, Associate Dean for Public Service and Public Interest Law and Lecturer STANFORD TABLE OF CONTENTS EXECUTIVE SUMMARY 1 I.I. COMPLAINT PROCESS STEPS 8 II. PARALLEL PROCESS (REASONABLE ACCOMMODATION\/AUXILIARY AID GRIEVANCE) 39 III. DATA TRACKING 41 IV. CHILD PROTECTIVE SERVICES 45 V. ALTERNATIVE DISPUTE RESOLUTION 49 VI. PROMISING PRACTICES FROM OTHER STATES’ CIVIL RIGHTS COMPLAINT PROCESSES 52 VII. UPDATE OF DIVISION 21 REGULATIONS 63 APPENDIX 1-273 1 EXECUTIVE SUMMARY Scope of Policy Practicum In 2017, staff from the California Department of Social Services (CDSS) Civil Rights Unit (CRU) and faculty associated with Stanford Law School’s Policy Lab identified CDSS’s discrimination complaint and compliance monitoring processes for county social services agencies as an area with process challenges that would be ripe for student research. Under California and federal law, CDSS is required to provide a process through which complaints about discrimination in the provision of social services by county or state agencies can be investigated and resolved. As a recipient of funds through the U.S. Department of Agriculture, there are also requirements to engage in civil rights compliance monitoring of county agencies that distribute those funds through local programs. This includes reviewing civil rights compliance plans submitted by county agencies and engaging in audits of those agencies. CDSS identified a need for information regarding best practices for complaint and compliance monitoring processes that apply to agencies administering public benefits and social services programs (e.g., food assistance, cash aid, childcare subsidies). This policy practicum was undertaken with the understanding that Californians who need state and federal support should not face discriminatory barriers to be provided life-sustaining and critical assistance. Many users of these programs already face dire circumstances that have led them to seek help to gain subsistence support that meets their basic needs for food, housing, medical care, or child care. It is imperative that unnecessary obstacles from discrimination or failure to provide a reasonable accommodation, as required by state and federal laws, be identified and removed to their obtaining these important forms of aid. The students enrolled in this policy practicum engaged in the following: (1) Research that led to recommendations about best practices to improve the complaint processes for users of government social services to resolve complaints of discrimination. Research included analysis of other state and federal models, including interviews with key stakeholders in those models (government employees, advocates for consumers, etc.), and literature reviews and analysis. A sub-part of this topic was the potential role of alternative dispute resolution (ADR) models in the complaint process. Students conducted research into the viability of incorporating ADR into the complaint processes through interviews and other research. 2 (2) Research on the evolving landscape of civil rights regulation at the state and federal levels and a proposal for modifications to the current CDSS civil rights regulations, contained in CDSS Manual of Policies and Procedures, Division 21. Key Policy and Fiscal Issues The research documented below and accompanying recommendations should be read and understood within certain policy and fiscal constraints. The work of the Unit exists within a complex set of legal, regulatory, social, and policy challenges. Jurisdiction and Resource Allocation Overarching all of our recommendations is the need for the State of California to make decisions about allocation of resources and how to prioritize effective investigation of discrimination complaints by indigent Californians who must use public benefits and other social services in order to meet their basic human needs. Technically, several state and federal agencies have overlapping jurisdiction to investigate and attempt to resolve complaints of discrimination by users of public benefits and social services programs that receive state and federal funds and are administered by CDSS. These include the California Department of Fair Employment and Housing (DFEH), as well as U.S. Departments of Agriculture and Social Services. Through its budgeting and policy purview, California determines how it will allocate resources to address discrimination concerns. Specifically, the state’s DFEH currently receives a very limited number of discrimination complaints in the administration of public benefits and social services programs. However, should this become a more robustly utilized process, the nature of the work of DFEH, which also has jurisdiction to receive complaints by individuals who allege they have experienced civil rights violations in the areas of housing or employment by private as well as public parties, would be significantly changed and challenged. CDSS’s CRU staff are comprised of five (5) analysts, a policy specialist, and a director who are experienced in the areas of administration of public benefits and civil rights laws. For discrimination complaints filed in all of California’s fifty-eight (58) county welfare departments ( CWDs ), the CRU staff is currently responsible for: review of all complaints and investigations; approval of resolutions, dismissals, and case closures; policy development and analysis; training of staff at CWDs; monitoring and auditing of CWDs’ compliance with disability and civil rights laws, investigation for appeals, monitoring and compliance review of the discrimination complaints that are filed throughout the state. Through the counties, the CRU currently reviews and assists with investigations in approximately 400-700 complaints per year. A bulk of these 3 complaints are received from Los Angeles County with the remaining complaints made up largely of complaints form San Diego County and the three Bay Area counties. The limited budget allocation to CDSS’s CRU means that there are only so many staff who can carry out its mission to facilitate compliance with all state and federal civil rights mandates governing equal and effective access to benefits and services. [It is] dedicated to providing [its] constituents with education, services, and proactive leadership necessary to ensure that all programs administered or supervised by the California Department of Social Services are done so equitably and effectively. These limitations require the Unit to make difficult, specific choices about how to meet the needs of the users of government programs in incredibly diverse settings, geographically, by population, as well as across specific constituent needs by language, physical or mental ability, and housing insecurity. All of these decisions also must be made within the context of federal requirements for compliance review, which is a time consuming and complicated process. Based upon our research, it is quite clear that, to fulfill its mission in any meaningful way, the budget of CDSS for staffing of the CRU should be increased. Simultaneously, counties must determine how to allocate their limited resources to staff the intake and investigation of civil rights complaints. While each CWD is required to designate a staff person for this process, those who are designated Civil Rights Coordinators (CRCs) frequently must take on these job duties on top of their existing responsibilities. There is also an inter-relationship between county benefits workers and county-designated employees who specialize in reasonable accommodations for persons with disabilities. In smaller counties, this can present particular challenges. Especially where the best resolution of a complaint about discrimination might be the assignment of a new Eligibility Worker or where a full work up regarding the need for reasonable accommodations or auxiliary aids is needed, there are very limited options for assigning more or new or different work to key employees. Data Tracking and Management Related to resource allocation is the issue of data tracking. There is not a uniform system across all of the counties in California to maintain information required by both state and federal law. The Unit is in the process of shifting to a SalesForce platform that should allow it to better monitor information that is received but has not been provided the financial resources that would allow it to make this platform available to all fifty-eight (58) counties across the state. This raises concerns about the uniformity of types of information that will be kept and maintained as well as limiting the usefulness of the data for purposes of analysis and compliance monitoring. 4 Recommendations and Next Steps Recognizing the policy and fiscal constraints that may impede implementation of the recommendations that we have found would address the civil rights concerns of users of government-funded public benefits and social services programs, we have identified both relatively easier and harder next steps for the State and Unit to undertake. Improving the Discrimination Complaint Process There are several steps with which a user of government-funded public benefits and social services programs must engage in order to successfully file a discrimination complaint and obtain a meaningful resolution. The steps that we considered and address range from the decision to make a civil rights complaint through the decision to appeal a negative finding from an original complaint. Decision to Make a Complaint To start, users must understand the purpose, benefits, and availability of a civil rights complaints process. Based upon our research, it is clear that users lack access to information about all of these realms. Information about this process currently is provided either in CWD offices, with varying degrees of success, or through advocates who represents users. In order to improve user awareness and knowledge of the civil rights complaints process, we recommend that the CDSS Civil Rights Unit: 1. Distribute information about the civil rights complaint process in as many places and through as many methods as possible 2. Modify the complaint system information provided to users in public documents to improve clarity and consistency 3. Require caseworkers to provide accommodations when communicating complaint system information to users 4. Maintain and publicize a clear non-retaliation policy 5. Consider the prospect of an anonymous option for complaints 6. Conduct greater outreach to potential clients by partnering with advocates and non- legal community organizations Complaint Intake Once a user has decided to make a civil rights complaint, there are several critical aspects to the intake process: methods of access; accessibility and accommodations of a disability or language needs; as well as obtaining and tracking necessary information to move forward and to inform broader policy and compliance needs. Based upon our research, we found that the effectiveness of the intake process is heavily reliant upon individual counties’ developed policies, cultures, or norms, both in terms of the information that is obtained and whether or how 5 accommodations are provided during this step of the process. An overarching recommendation for all aspects of intake is to create more consistency and uniformity across counties of the information recorded and the processes for information gathering. In addition, because many of the users of the programs within CDSS’s purview are seeking benefits due to some form of disability, we were particularly attuned to the fact that in addition to accommodations being provided to access benefits, those same users may likely require accommodations to utilize the civil rights complaint process. Therefore, we recommend that CDSS: 1. Improve the Intake Process a. Make complaint forms clear, simple, and widely available in all client-facing county offices b. Provide training to and require county employees to affirmatively offer and give assistance to users making civil rights complaints c. Develop alternative intake methods in addition to use of written complaint forms d. Require county civil rights coordinators to review complaint form information with the user-complainant e. Develop and require consistent tracking of information for all counties and CDSS 2. Complaint Form Content a. Complaint forms should request a narrative description of the discrimination alleged. b. Complaint forms should provide checkboxes for protected classes and request a narrative detail of how problem treatment was discriminatory c. Complaint forms should include checkboxes of potential remedies as well as an other option d. Complaint forms should request a separate contact person and additional contact methods to reach complainants e. Complaint forms should inform complainants of the non-retaliation policy and include instructions for reporting retaliation f. Complaint forms should ask complainants if they need accommodations for intake g. County and state data tracking systems should track intake method h. Complaint forms should ask if alleged conduct is ongoing Initial Review and Application of the Pleading Standard Following intake, a decision must be made about whether there is sufficient evidence to proceed with a civil rights investigation. In this phase, we found that there is a clear lack of guidance about how to evaluate an intake to determine if there are sufficient grounds to designate the complaint as one involving a potential civil rights violation as opposed to one involving a decision to deny benefits or a simple customer service issue. Because of this lack of clarity, this review process is subject to varying practices across counties that leads to judgement calls about how to sort a complaint into the appropriate process. 6 We heard from various stakeholders that there is an overall concern that there is under- reporting of civil rights complaints, so improving this stage of the process is particularly important to address this concern. There are initial decisions that CDSS must make about what will trigger further review for potential civil rights violations. To improve this part of the process, we recommend: 1. CDSS decide upon and make clear to counties the pleading standard and review process, including whether a complainant’s reported allegation is sufficient or whether there needs to be a plausible nexus documented between a protected class and the incident described 2. Once CDSS makes this decision, it also should provide training and clear guidelines Investigation In this stage, there is also a lack of uniformity and clarity across counties about how to conduct investigations of alleged civil rights violations. While every county does engage in some investigative steps once a complaint has been designated a civil rights complaint, limited resources and a lack of uniform training lead to inconsistent tactics. Additionally, because CDSS’s CRU is required to sign off on all case closures, this step is frequently reopened when the Unit asks a CRC to gather additional information, creating frustration and a duplication of efforts, such as needing to interview a party or witness a second or third time. Another problem that was identified within this stage is the potential loss of contact with the original complainant. When the investigation process is lengthy, complainants with housing insecurity or other challenges, can be difficult to reach or locate. Existing and limiting policies about when a complainant can or should be contacted exacerbates this problem To improve the investigation of alleged civil rights complaints, we recommend: 1. Investigations should always include interviewing the complainant and reviewing her\/his entire county record 2. CDSS should develop training and clear guidelines for CRCs and investigators 3. County workers should be required to provide regular updates to complainants 4. CDSS should evaluate whether it can establish its own standing to pursue a complaint when a complainant has become unavailable 5. CDSS should require county workers to record the dates and actions of each investigative step 6. CDSS should evaluate whether to assume more control over all investigations or reduce its review role to increase its availability for training and technical assistance 7 Resolution In the resolution phase, there is an interesting and problematic structural issue created by the current regulations. CDSS’s CRU must perform a detailed review and sign-off on all case closures. As described above, this is a time-consuming process that occupies a lot of the time of already limited staff resources. Again, this drawn out and lengthy process also risks losing contact with the complainant. The regulations also prescribe that CDSS’s CRU be the recipient of any appeal by a complainant dissatisfied by a determination regarding her\/his civil rights complaint. Oddly, CDSS thus functions as the appellate review body over decisions it has previously reached. In addition, for county offices that are particularly leanly staffed, if the best resolution of a complaint would be assignment to a new county worker, there can be very limited options and concerns on the part of the complainant about potential retaliation, in a process that is supposed to assist their ability to access life sustaining benefits and programs. There are also tensions between the needs of a complainant for information about the result of her\/his complaint and the potential privacy requirements regarding disciplinary actions taken with an employee. Due to these important and complicated issues, it is in this aspect of the complaint process that we make our most significant recommendations. The first of these recommendations would require changes in law. 1. The policy requiring CDSS’s CRU to review and approve every civil rights complaint resolution should be eliminated or severely limited 2. Counties should be required to contact complainants a minimum number of times, using various contact methods 3. CDSS should provide model examples of determination letters to county workers 4. CRCs should contact complainants regarding resolutions in ways additional to the written resolution letter and should be available for a phone call to explain the findings 5. Consistent types of data about resolutions of complaints should be recorded 6. CDSS should develop model communications for counties to use that acknowledge a complainants’ experience without conceding liability or breaking privacy rules Appealing an Initial Determination There appears to be a very limited understanding of the process to appeal a determination with which the complainant disagrees as well as narrow use. Similar to the process to file a complaint, available information is limited both in terms of distribution as well as understanding of any benefits an appeal might produce. Therefore, we would reiterate many of the recommendations regarding those made regarding the Decision to Make a Complaint step of the process. In addition, we recommend: 1. The appeal process be reframed as a request for reconsideration 2. Counties should publicize opportunities for reconsideration requests at the outset of the complaint process, including on posters and the complaint form 8 3. Counties should provide a reconsideration request form with determination letters and provide accessible instructions and guidance for filing a request 4. Counties should develop alternative methods for notifying complainants about determinations 5. CDSS should assign reconsideration requests to an analyst uninvolved in the original investigation and complaint review 6. CDSS should document and track reconsideration data to gauge patters and common areas for improvement in investigations Additional Recommendations In addition to these specific steps to improve the civil rights complaint process, we also make recommendations regarding ensuring the availability of reasonable accommodations and auxiliary aids by screening every complainant for a potential disability and seeking to provide those accommodations at the outset. In addition, we recommend adopting parallel procedures for addressing grievances regarding reasonable accommodations through an expedited process. We also make recommendations regarding data tracking that include potential methods for standardization and integration. As noted above, data collection and analysis are critical next steps for CDSS’s CRU to be able to fulfill its compliance review and policy development functions. The CDSS civil rights complaint process also covers the child welfare system. This creates specific challenges due to the urgency of issues related to child dependency and potentially custody as well as some overlapping jurisdiction with the Office of the Foster Care Ombudsman. These challenges make the CDSS process appear to have limited value. There are areas for further research and improved information sharing should CDSS want to increase its engagement with these processes. There are some models for alternative resolution of complaints that are also worthy of further evaluation by CDSS, which we describe below. A tension with either a formal or informal mediation model would be to ensure that either any process include protections so that a user- complainant not feel coerced into a resolution. Updating Division 21 to Ensure Compliance with State and Federal Laws Within the memorandum and Appendix G, we provide updated regulatory language that addresses the need to comply with current state and federal civil rights laws as well as recommendations that particularly address issues related to language and clarity of the regulations, mechanics of the complaint process should others of our recommendations be adopted, as well as specific concerns related to serving users who are limited English proficient or who have disabilities that require accommodations and auxiliary aids. 9 Potentially Promising Practices from Other States Based upon our research of the systems and models used by several other states, we also include a section of this memorandum about promising practices and an Appendix containing model documents from other states. Some of these practices we have identified and recommended for adoption within the sections of our memorandum addressing the varying steps of the complaints process. Conclusion We have been gratified to work on this important project and impressed by the seriousness with which CDSS’s CRU takes its responsibilities. While we have certainly identified numerous areas for improvement, we applaud the work that the Unit has recently undertaken to better engage the user community and to address the shortcomings it already has acknowledged. We also are pleased by the passion and commitment we have witnessed among the CRU staff, county workers, and others with whom we have engaged to ensuring that indigent Californians can gain access to the necessary programs and benefits that provide them with at least a minimum of subsistence to remain in a state facing increasing and complicated economic divides and gaps in opportunity. Disclaimer The information, research, analysis, opinions, and recommendations set forth in this document are the sole opinions and representations of the Stanford Law School Policy Practicum research team. This report is not intended to be legal advice to nor policy directives for the California Department of Social Services. The content is provided for general, informational purposes only. 10 I. COMPLAINT PROCESS STEPS Step Zero: User Decides to Make a Complaint This initial step consists of the elements and factors that impact a user before she makes a complaint: the information users have about the complaint process, their rights, and the decision to file a complaint. Goals and Challenges There are several broad goals for this step. First, and fundamentally, users must become aware that the complaint process exists and how it can be accessed. Without user knowledge about the system or their ability to use it, the civil rights complaint process is completely ineffective. There are multiple challenges to achieving this goal. Advocates have told us repeatedly that it is difficult for unrepresented clients to learn about the existence of the process. This is, in part, because county offices are chock full of all kinds of information and notices directed at relatively unsophisticated users who are often focused primarily on receiving their benefits. When our team visited the Santa Clara County offices, we observed this firsthand: dozens of flyers and posters littered the walls of the CDSS offices, often only in English, and some flyers were presented in such a way to misleadingly suggest the office condoned discriminatory treatment. (County Know Your Rights Pamphlet, Appendix at 2.) The staff greeter at the front of the office was not familiar with the civil rights complaint form, and had none at the front desk to offer us. Moreover, because the written materials about the complaint process are complicated and unclear, they are particularly inaccessible to users with physical and mental disabilities, given what we have heard from many advocates. Second, users must understand when the civil rights complaint process applies to them, \u2014 that is, they must know when they have experienced a civil rights violation. The challenges on this second goal largely mirror the challenges of the first: unsophisticated users, some of whom have physical or mental disabilities, do not receive sufficient information to understand when their rights are violated. Third, and relatedly, another goal for this step is to ensure complaints that are not related to civil rights are filtered out of the process, to avoid inundating CDSS systems with unrelated issues. As a part of this goal, complaints regarding other issues \u2014 such as programmatic complaints or customer service complaints \u2014 should be routed to the proper channel. The challenges of this goal, much like the last two, also relate to imperfect information: as county civil rights coordinators (CRCs) have explained, users often do not understand what constitutes a civil rights complaint or the purpose of the CDSS system, so they use the civil rights complaint system 11 to register programmatic and human resources complaints, which should be addressed through other avenues. Finally, users must feel empowered to use the civil rights complaint system. This encompasses both fostering in users a sense that the complaint system will result in meaningful change as well as addressing fear of retaliation. Many advocates spoke directly to both of these issues, explaining that they often do not direct clients to the civil rights complaint process due to skepticism that the system will benefit the client. They also explained that many users are resistant to using the complaint system in the first place, because they fear retaliation from the case worker who is the subject of the complaint \u2014 a fear that is more pronounced and relevant in smaller counties with fewer staff. Potential Solutions 1. Distribute Information About the Civil Rights Complaint Process in as Many Places and Through as Many Methods as Possible. First, caseworkers should orally inform users about the complaint system when receiving and processing applications for benefit programs. Other government workers who interact with benefits users should also notify users of the complaint process. County staff should also inform users about the process \u2014 and provide a physical copy of the complaint form \u2014 when any user suggests they experienced behavior from which the worker could infer a civil rights violation. Second, complaint process information should be provided to users both within packets of information given to users throughout the benefits application or appeal processes, as well as on the back of every benefits application, a promising practice currently used in Ohio. (Ohio Complaint Notice, Appendix at 136.) Third, CDSS should create a more effective poster and provide counties guidance about effective placement. Posters should convey clear, consistent information about the existence of the complaint system, its benefits, and how users can access it, in multiple languages.1 Including this requirement in regulations, as advocates suggested, would ensure consistency across counties. We also recommend emphasizing this requirement in an All County Letter (ACL). Finally, complaint forms should be available in multiple languages in the lobbies of county offices, with greeters knowledgeable about the forms. 1 For an example of a clear, visible poster about a county’s civil rights policy, see Washington State’s Nondiscrimination Notice, Appendix at 57. This is an example of a multi-lingual notice that could be expanded to further explain how to file a complaint. 12 2. Modify the Complaint System Information Provided to Users in Public Documents. First, the language used should be as simple as possible. Materials should be revised to avoid overly legalistic terminology and to present information in a way that is accessible for unsophisticated users. One tool of improving accessibility could be providing a frequently asked questions (FAQ) pamphlet or online site about the complaint process that answers questions such as the processes available to file a complaint and potential resolutions. (For a sample FAQ that is accessible and informative, see New York City Assistance for the Complainant, Appendix at 110- 111.) Second, to illustrate the types of incidents that could provide the basis for a complaint, public documents should include examples of discrimination focused both on access to benefits, as well as non-programmatic rudeness from county staff. Third, the language used, particularly around disability, should be as broad and inclusive as possible. One advocate explained that her clients often self-describe as having a learning disability instead of an intellectual disability, and emphasized that this language would resonate more with users. For examples of language that addresses the previous three solutions, see sample language for discrimination examples below. Fourth, information should include and clarify the existence of alternative civil rights complaint options, such as the USDA or HHS complaint systems, and ensure users understand when, how, and why they should access those alternative systems. Fifth, and related, the information provided should include avenues that users can follow when seeking to make programmatic or customer service complaints, both to ensure that users know how to access those systems, if applicable, and to filter out non-civil rights complaints. On these final two solutions, a flowchart helping users understand which complaint system(s) they can access and when would assist with these solutions. (For an example of a complaint process flowchart, see Ohio Flowchart, Appendix at 138.) Sample Language for Discrimination Examples (loosely adapted from the Santa Clara County Commonplace Handbook: Section 36, Civil Rights) (Santa Clara County Commonplace Handbook, Appendix at 6-18; 30-34): \u25cf You have trouble filling out forms because you have a learning disability. You told a county worker that you needed help, but she told you to fill it out yourself. \u25cf You don’t understand English well. You think a county worker was telling you something important about your benefits, but you could not understand. You tried to talk to the county worker, but she could not understand you. The county worker did not get an interpreter or ask for other help. \u25cf You have trouble seeing, and you read Braille. You asked for notices in Braille, but the county sent you an important notice printed visually, without Braille. The county ended your benefits because you did not follow the directions in the notice. \u25cf A county worker made a sexual comment to you. \u25cf A county worker treated you very rudely but was polite to people of another race. 13 3. Require Caseworkers to Provide Accommodations When Communicating Complaint System Information to Users. These accommodations should be identical to those provided elsewhere including: large print, interpreters and document translations, accommodations screenings, and so forth. Additionally, given very high call drop rates, advocates have suggested allowing for an accessible call-in process, which could include hiring more hotline staffers and establishing a callback option for users to leave their phone number and have someone return their call within a designated time frame. 4. Maintain and Publicize a Clear Non-Retaliation Policy. Any non-retaliation policy should define retaliation and give examples of prohibited retaliatory acts. The policy should clearly state that it is against the law for county workers to retaliate because a user complained about their behavior, and encourage users to file a complaint, potentially in a different location, if they do not trust the county workers in the office at issue, if they believe they have been retaliated against. This information, or an abridged version, should be included on all materials regarding the complaint process listed above. To the extent they currently do not, county workers should also receive training on non-retaliation. Minnesota’s Department of Human Services notifies users of its non-retaliation policy (and how to report retaliation) in its instructions for filing a civil rights complaints. (Minnesota’s Civil Rights in Human Services Website, Appendix at 146-148.) 5. Consider the Prospect of an Anonymous Option for Complaints. A process to receive anonymous complaints would be of limited utility for individual redress. However, it would serve to track potential user needs and problem offices, issues, or case workers. But both CDSS and advocates have stated their belief that the current civil rights complaint process dramatically undercounts actual violations, a claim backed up by the number of complaints that are filed but do not reach a resolution for one reason or another, and experts suggest an anonymous complaint system would encourage more users to file complaints, particularly given retaliation concerns.2 Tools such as TalkToSpot.com, which allows for follow-up with anonymous discrimination complaints, would also be useful in the process.3 6. Conduct Greater Outreach to Potential Clients by Partnering with Advocates and Non-legal Community Organizations to Inform Users About the Complaint System. 2 See, e.g., Julia Shaw, TED talk on discrimination and harassment complaints (2018), https:\/\/www.ted.com\/talks\/julia_shaw_a_memory_scientist_s_advice_on_reporting_harassment_and_discrimination ?language=en]. 3 HR Reporting Tool for Harassment and Discrimination, SPOT, https:\/\/talktospot.com\/ (last visited Apr. 8, 2019). https:\/\/www.ted.com\/talks\/julia_shaw_a_memory_scientist_s_advice_on_reporting_harassment_and_discrimination?language=en https:\/\/www.ted.com\/talks\/julia_shaw_a_memory_scientist_s_advice_on_reporting_harassment_and_discrimination?language=en 14 In New York City, the Human Rights Commission (HRC) works with legal aid organizations and community groups to ensure that people are aware of the existence of the complaint process.4 Acknowledging that CDSS undertakes some of this activity already, we recommend that it continue and bolster these connections. Many of the changes in this document that should produce more support from advocates, many of whom are skeptical of the benefits of the process. Step One: Complaint Intake Goals and Challenges In this step, the county or CDSS receives the user’s complaint and enters it into the tracking system. This step includes suggestions on the intake process and designing a complaint form. One of the most important goals for this step is to make the process accessible, easy, and transparent for the user. Based on our conversations with advocates, complaint intake accessibility should take into account varying types of complaints, remedies sought, languages spoken, technological literacy and access levels, written literacy levels, abilities, and access to stable housing, among other factors. Advocates also emphasized that transparency throughout the complaint process would improve the experience for users and increase their willingness to follow through. In that light, the intake step should provide clear information to the user about the steps and requirements of the process. Another goal of intake is to collect the information required to determine whether to investigate (Step Two) and begin evaluating the claim. Follow-up on closed complaints with missing information is consuming a lot of CDSS’s time when reviewing county complaints. Although we recommend some changes to the review process that should alleviate that problem, collecting comprehensive intake information will avoid wasted time on duplicative work. There are at least two serious obstacles to obtaining full information. First, users may not understand the information they need to provide or may be unable to provide the information in the format requested. Second, CRCs may not be soliciting enough information during phone intakes. As we explain in more detail in Step Two on the pleading standard, the CRCs we interviewed typically redirect many calls to personnel or programmatic avenues without obtaining very much information about the caller and\/or her complaint. Even a fully informed user with no serious accessibility issues might never have a chance to communicate key information under this limited intake approach. The revised complaint process should therefore prioritize accessibility, clarity, and a consistent CRC interview approach. 4 New York advocate. 15 Finally, the intake process should ensure that every complaint is recorded in a format that CDSS can access and analyze. Given the barriers for users to learn about the complaint process and to decide to complain, an actual complaint is precious information. Our interviews indicate that CRCs typically do not track complaints that are redirected to other avenues, so training is also important for achieving tracking goals. It is also worth noting that the interface between county tracking methods (such as Excel) and CDSS’s SalesForce also present potential challenges for comprehensive tracking generally, including at intake. However, our main analysis of those issues appears in Section III, Data Tracking. Potential Solutions Our recommendations for the intake step fall into two categories: (1) recommendations for the intake process, including logistics, and (2) the content of the intake form. 1. Intake Process a. Complaint Forms Should Be Clear, Simple, and Widely Available in All Client-Facing County Offices. Unless a complainant calls a CRC directly, her first interface with the complaint system will be a form and\/or an employee in a local county office. At this stage, it is crucial that the forms be clear, simple, and widely available, and that county employees be trained to help users complete them. Paper complaint forms should be prominently displayed in all client-facing county offices, near the posters that describe discrimination and the right to complain. Wherever the forms are available (in person or online), the information and examples on discrimination described in Step Zero should be included in flyers to help clients fill out the form effectively. Likewise, simple information on what to expect from the complaint process should be available with the form. For example, a complainant might want to know who receives her complaint, who investigates the claim, when she will hear from the CRC, who can answer questions, and which remedies are available. To improve accessibility, we also recommend that the forms be provided to the counties in several commonly-spoken languages and in large print versions. b. County Employees Should Be Required to Affirmatively Offer and Give Assistance to All Users Who Ask To Make a Civil Rights Complaint and Should Be Trained to Give Such Assistance. Advocates also recommended that county employees be required to affirmatively offer and provide help to all users who ask to make a complaint. Based on our experience in Santa Clara County benefits offices, some county employees do not know the complaint form or process exists. Training on the complaint process, particularly on how to fill out the form, is important for all user-facing county employees. The training should make clear that county employees are required to provide the same accommodations to users in the complaint process as in the administration of 16 benefits. Employees should also explain the complaint process and submission instructions to the client orally (in the language of the user). Disability advocates emphasized that the requirement to offer help should include safeguards to ensure that the user retains control over content. They suggested that an employee who fills out a form for a user be required to read the full content back to the user for approval. Alternatively or in addition, they suggested that the user could take the form home to check its accuracy and then submit it herself. That option gives the user the most control, but, if followed, the employee should make and retain a copy of the complaint, marking in the administrative use section that it is a draft. We recommend that the process require the employee to present the user with both options. The employee could tell the user: I can submit this for you now, or, if you prefer, you can take it home to review. If the user opts to take the complaint home, the employee should provide an addressed and stamped envelope for mailing the complaint, as well as written instructions for submission. If the complaint is filed, a copy should be made and provided to the complainant. c. In Light of Barriers to Users Submitting Paper Complaints, CDSS Should Develop Additional Intake Methods for Complaints such as an Online Portal. Training county employees to effectively help users complete paper complaints will require additional time and resources. However, this step is crucial to ensure that users’ complaints actually reach CRCs with complete information. Without assistance from county employees, paper complaint forms may not be an effective substitute for calling a CRC directly. In fact, our interviews with CRCs indicated that almost all their complaints came in by phone. Although this pattern could indicate a user preference for phone intake, it may also reflect barriers to the submission of paper complaints. Several advocates told us that having multiple, effective intake methods is useful for accessibility purposes, so it is important that filing a written complaint form be easy and accessible. In addition to the paper form, one advocate recommended that CDSS include an option for online submission of the complaint form on its website. For example, the U.S. Department of Health and Human Services’ Office of Civil Rights has a centralized online portal that walks users through submitting a civil rights complaint.5 Allowing users to submit complaints instantaneously would remove logistical barriers for users with computer access. As an interim measure, CDSS’s website could explicitly include an email submission option for complaints. Currently, the complaint form submission page includes the form in several languages and directs the user to print and mail it. Because some users likely lack access to a printer, allowing users to submit the completed form electronically would overcome this barrier. It bears emphasis, however, that CDSS should always maintain its paper form and call-in options to ensure that users without computer access or who have literacy limitations can effectively use the process. 5 See Complaint Portal Assistant, U.S. Department of Health and Human Services, https:\/\/ocrportal.hhs.gov\/ocr\/smartscreen\/main.jsf. https:\/\/ocrportal.hhs.gov\/ocr\/smartscreen\/main.jsf 17 d. During Intake Calls with Complainants, CRCs Should be Required to Review the Questions on the Complaint Form with the User. Once the complaint reaches a CRC, either as a complaint form or a call, it is important that the CRC obtain and track a consistent set of information. One way to ensure that CRCs collect full information from the user during a phone call is to require them to go through the questions on the paper form with the user. However, that approach could risk making the conversation mechanical and stilted, undermining the human, problem-solving approach that some CRCs are already taking to users’ complaints. The remedies-first policy that we introduce in Part 2 of this section and elaborate in Section IV.A is one way to temper that effect by emphasizing problem-solving. In addition, directions to CRCs should encourage them to ask about the complaint generally before going through the form questions. e. The Complaint Form, County Tracking Systems, and the Salesforce Interface for Counties Should All Require the Same Information Be Collected. To ensure consistency in tracking, the complaint form, the various county tracking systems, and the SalesForce interface for counties should all require collection of the same information. As we describe in our data tracking section, CDSS may want to create an Excel template for county logs to streamline interfacing with SalesForce. To build data for compliance reviews and ensure that no complaint is lost, CRCs should be required to enter paper forms immediately into their county tracking system (such as Excel) upon receipt. Ideally, all the information in the paper complaint should be copied into the tracking system so that it is easily accessible for CDSS review. In other words, the paper version should be used only as a point of access for users and should become duplicative after intake. Because the CRCs we interviewed said that most complaints are initiated by phone, this requirement should not be an overwhelming burden, if their experience is typical of most offices. 2. Form Content Although a comprehensive design for CDSS’s new complaint form is outside the scope of this project, we offer some concrete recommendations for the form as a whole and suggestions for fields to include. In general, the form should use checkboxes wherever possible to facilitate tracking. The current CDSS complaint form, as well as most of the other states’ complaint forms, use checkboxes to designate the protected class that forms the basis of discrimination. Using checkboxes and uniform word choices for other fields, such as those relating to the complainant’s demographic characteristics, would facilitate better data analysis for CDSS’s broad compliance efforts. Ohio’s complaint form uses checkboxes for multiple categories (including race, ethnicity, sex, and program area) for ease of filing and recording complaints. (See Ohio Discrimination 18 Complaint, Appendix at 137.) As appropriate, checkbox sections should read check all that apply and include an other checkbox to avoid confining the user to only the options provided. Disability advocates also suggested that the complaint form use simple language and avoid legal jargon to help users understand what information is needed. We have provided some suggestions of simple language for some items in the form throughout. a. Complaint Forms Should Request a Narrative Description of the Discrimination. The form should include a question asking for a narrative description of the discrimination. One potential simple language option for this question is What went wrong during your experience? The form should request the date, time, and location of the problematic experience. Advocates indicated that the form should obtain the names of the worker(s) involved in the complaint, to help CDSS identify trends and target compliance efforts. The form should also request information on whom to interview to facilitate investigation. One simple language option is to ask Who else saw this happen? For both the worker and the witness prompts, the form should clarify that the user can describe the person physically if they do not know their name. b. Complaint Forms Should Provide Checkboxes for Protected Classes and a Narrative Box Requesting Details of How the Treatment was Discriminatory. The form should also ask for the protected class that is the basis of the discrimination and prompt the user to explain why she thinks this was the reason they were treated differently. The form should include checkboxes for protected classes, with a simple language prompt. (See id.) Many agencies use the phrase treated differently because of my ____ to describe discrimination (Appendix at 120-121, 146-47). The checkbox section could read, I believe I was treated differently because of my ____ with all the protected classes listed below. There should also be a reminder to complainants to check all bases of discrimination that apply. For example, North Dakota’s complaint intake form instructs complainants to check all [the bases of the discrimination] that apply. (See Appendix at 126.) This reminder will prevent complainants from having to choose just one basis of discrimination when the discrimination at issue had multiple bases. The form could then include a narrative box asking something like Please explain why you believe the treatment or incident you experienced was because of your actual or perceived race, color, ethnic group identification, sex, religion, national origin, gender, gender identity, gender expression, sexual orientation, age, ancestry, mental disability, physical disability, political affiliation or belief, marital status, and\/or citizenship\/participant status, medical condition, genetic information, and\/or military and veteran status. (Please attached additional sheet(s) of paper, if necessary to fully state your complaint.) This section would help elicit information that supports the user’s claim. However, CRCs should be instructed that a blank in this section does not 19 necessarily indicate the user does not have a valid claim. Even with simple language, the user might not understand the question or know how to answer it, even if their claim has merit. c. Complaint Forms Should Include Checkboxes of Potential Remedies, as well as an Other Option with Space for a Complainant to Request an Unlisted Remedy. The form should also include a requested remedy. Simple language options include What can we do to make this right? or How can we fix this? Those framings are commonly used in the customer service context, where companies are focused on customer satisfaction. Using them in this context would help make the user central to the process. CDSS could consider including checkboxes to help users understand the available options, as well as an other option with space for narration. If CDSS develops the no-fault apology option described in Step Four, it could include an apology as a remedy option. d. Complaint Forms Should Request a Separate Contact Person and Additional Contact Methods for Reaching the Complainants Such as Email or Text. To make sure that the CRC does not lose contact with the complainant, the form should request multiple contact options, including a separate contact person. Based on our team’s experience working in the benefits space, the best way to reach people without stable living situations is often a relative or friend with a stable address. Some clients prefer email or text, so those contact methods should also be collected. e. Complaint Forms Should Inform Complainants of the Non-Retaliation Policy and Include Instructions for Reporting Retaliation. Minnesota’s Department of Human Services notifies users of its non-retaliation policy (and how to report retaliation) in its instructions for filing a civil rights complaints. (Id. at 146.) CDSS should expand this practice and notify complainants of its non-retaliation policy (and how to report retaliation) on the complaint form. f. Complaint Forms Should Ask Complainants if They Need Accommodations Filling Out the Form. The form should also include options to receive help to complete the complaint. One possibility is to provide a CDSS number, with a message like Do you need help filling out this form? Call . . . The form should also prompt the user to indicate any accommodations they might need in going through the complaint process. In its complaint form, North Carolina asks complainants if they will need accommodations in the complaint process and lists examples of 20 accommodations such as sign-language interpreters, large-print materials, and a language interpreter. (Id. at 122.) Also, Minnesota notifies users of the reasonable accommodation process for complaints in its instruction guide for civil rights complaints. (Id. at 145-46.) CDSS’s recent work on improving disability screening in the counties will be helpful in designing that prompt. In addition, a Santa Clara County disability screening document, developed with input from advocates, provides some promising language to use (See Appendix at 51-52.) The Santa Clara screening begins with the phrase Need extra help? (Id.) The CDSS complaint form could indicate that the CRC may need to talk to the complainant and send her written information about the complaint. It could then prompt the user, Do you think you will need extra help with those things? The form could include checkboxes with an other option. The Santa Clara County screening includes the following: \u25cf Do you have difficulty reading? Hearing? Speaking? \u25cf Do you need information in Braille? \u25cf Do you need a sign language interpreter? \u25cf Do you need help arranging appointments to fit your needs or friendly reminders of deadlines or due dates? \u25cf Do you need help filling out or understanding forms or complicated instructions? \u25cf Do you have difficulty walking, sitting, or standing for a long time? \u25cf Do you need any other extra help due to a disability? (Id.) Large print notices should be included as an accommodation option. The form should also prompt the user to indicate whether they need to communicate in a language other than English by asking that question in multiple languages. g. County Data Tracking Systems and Salesforce Should Track the Intake Entry Point (Phone, In Person, Mail). In addition to the information in the client-facing form, the Excel and SalesForce systems should include some additional administrative information. One suggestion is a field with checkboxes for the intake entry point (e.g., phone, in person, etc.). This will allow CDSS to analyze whether some intake methods result in better information collected or different outcomes. Tracking the particular county office involved would also be important information to gather. h. Complaint Forms Should Ask If the Discriminatory Conduct is Ongoing. The New York state discrimination complaint form asks users if the circumstances of [their] complaint is continuing. (Appendix at 100.) This question captures users who may struggle 21 pinpointing one date for the conduct at issue because the conduct is ongoing. Moreover, this inquiry better frames the investigation if the conduct is a pattern of repeated civil rights violations, rather than one discrete event. Step Two: Initial Review and Application of the Pleading Standard Goals and Challenges Application of a pleading standard that allows a complaint to move forward is one of the most important and overlooked steps in the process. CDSS needs to implement a uniform pleading standard across counties to ensure fairness for complainants. The pleading standard should be chosen with an eye towards balancing resource constraints at the county and state levels with the need to address all reported civil rights violations. Currently, there are several challenges to implementing a uniform pleading standard. Counties lack clear guidance about the pleading standard. Thus, the standard that is applied varies among counties. Counties develop their own norms based almost entirely on the judgement of the individual CRC. CRCs we spoke with used a variety of strategies at the initial review stage to decide whether they would investigate a complaint as a civil rights complaint. Some CRCs will probe during an intake interview to identify whether discrimination was involved by asking the complainant whether they are a member of a protected class. Other CRCs will only flag a complaint as a civil rights complaint if the complainant affirmatively mentions being a member of a protected class. Still other CRCs will encourage civil rights complainants to use other complaint processes because the civil rights investigation process is long and unlikely to give them the resolution they are seeking. For example, if a complainant believes their benefits were cut off for a discriminatory reason, the CRC will direct the complainant to the programmatic complaint process because the civil rights process cannot reinstate their benefits. The existence of other complaint processes creates a significant amount of confusion about the civil rights pleading standard. Counties often have several complaint systems\u2014 customer service, programmatic, etc. Because these other avenues exist, CRCs tend not to think of pleading as a distinct step in the civil rights complaint process at all. Instead, they think of intake as a sorting process. They listen to the complainants’ issues and then sort the complaint into the appropriate pile. If they determine the complaint involves discrimination, that will trigger a civil rights investigation (i.e., it meets the pleading standard). If it gets sorted into a different pile, it is no longer considered a civil rights complaint at all. In this sorting process, the CRCs are implicitly applying some form of pleading standard, but it is based on their own beliefs about the system and about complaint needs rather than on clear guidance from the state. This sorting process is indicative of another tension present at the pleading stage: the perceived tradeoff between resolving a complainant’s issue quickly and ensuring that actionable 22 discrimination is recorded and investigated. CRCs tend to see initial review as requiring a choice between these two options. Finally, CDSS is overwhelmed by the number of complaints they are currently reviewing, which raises the question of whether too many complaints are passing the pleading stage. However, it is unclear to us if this problem is largely caused by the number of complaints coming from Los Angeles County. During CRC interviews, it was reported that the annual complaint load from most counties is fairly low, between two and twenty per year. Potential Solutions The first step necessary to getting complaints over the initial hurdle is to make it clear to counties that pleading analysis is a distinct step of the process and to explicitly lay out the pleading standard. Because pleading is not a widely accessible term, this step could be described as deciding whether a complaint will be investigated, referred, or dismissed. CDSS should consider implementing one of these two pleading standards: 1. A Pleading Standard Based Only on Complainant’s Reported Belief that Discrimination Occurred. In this case, staff doing intake for any type of complaint, programmatic, customer service, or otherwise, would be required to ask the complainant if they are a member of a protected class and if they believe the incident described is related to their protected class. If the complainant believes there is a connection, the complaint would advance and require investigation. The primary advantage of this pleading standard is that it would be very simple to apply. Any intake staff could ask these questions and record the answers, even without civil rights training. This standard is also likely to ferret out unreported or underreported civil rights violations because it would capture complaints that are currently being sorted into other complaint processes. This approach would likely increase the number of civil rights complaints significantly. The increased burden would fall on the counties rather than the state if the state substantially reduces its review of county complaints, as discussed below. 2. A Pleading Standard that Requires a Plausible Nexus between the Protected Class and the Incident Described. In this case, staff doing intake for any type of complaint would still be required to ask complainants whether they are a member of a protected classes and whether they believe the incident is related to the protected class, as above. If they respond affirmatively, their complaint would be passed along to the CRC, who would determine whether a plausible nexus exists between the incident and the complainant’s protected class. This process is still likely to ferret out more 23 reported discrimination than the current process by asking all types of complainants about protected class membership. Those complaints with a reported belief that discrimination occurred based upon membership in a protected class would still be recorded as civil rights complaints, but they would no longer automatically require investigation. This process would reduce the burden on CRCs by limiting the number of investigations. Even though full investigations would not be required, CRCs would still have to review all complaints for plausibility. However, CRC discretion could prove a challenge. CRCs would have an incentive not to find a plausible nexus in order to reduce their own investigation workload. Further, CRC training and competency appears uneven across counties. With varied training and ability, giving CRCs more discretion at the pleading stage will likely result in inconsistent outcomes statewide. Either of these standards should be made available to CRCs and other complaint intake staff in a simple flowchart form. A basic example of what a flowchart version of Option 2 might look like can be found in the Appendix at page 54. Giving a flowchart to all staff doing any form of complaint intake will aid in capturing civil rights complaints across the board and will make the process more consistent across counties. Whether or not CDSS chooses to implement one of the above pleading standards, CDSS should at minimum clarify to all counties that discriminatory intent is not required to pass the pleading stage. In order to better understand the civil rights complaint universe, CDSS should require counties to track complaints that do not make it past the pleading stage and describe the reason. The information tracked will depend on what uniform pleading standard is instituted. For example, if the pleading standard requires a plausible nexus between protected class and an alleged incident, CRCs would record that the complaint did not meet the standard because there was: (i) no plausible nexus, (ii) no identified protected class, or (iii) no incident. The CRC would then give a brief accompanying explanation. In general, this data can help CDSS evaluate the effectiveness of its chosen pleading standard. If a noticeably small or large percentage of complaints are being denied at the pleading stage, CDSS can review the reasons for denial and consider adjusting the pleading standard accordingly or providing more guidance. Finally, we propose two processes to resolve the tension between resolving complainants’ immediate needs quickly and thoroughly investigating and resolving civil rights complaints. Both processes are discussed in greater detail below. First, complaints about reasonable accommodations and auxiliary aids should be assigned to a separate, parallel process. (See Section II, Parallel Process.) This process would allow complainants to quickly be provided necessary accommodations. Second, CDSS should implement a general remedy-first policy in which CRCs must attempt to meet the complainant’s immediate need, independent of and in addition to the formal civil rights complaint process.6 For example, if a complainant requests reassignment to 6 This remedy-first track would be simultaneous to the formal complaint process. That way, CDSS will not lose the value of the formal complaint for data tracking purposes, procedural justice for the complainant, and when 24 a different staff member, automatic translation of documents going forward, or restoration of benefits, CRCs should first attempt to solve that problem by directing the complainant through the proper channels. Advocates indicated that these types of informal resolutions are helpful and efficient, but that only some counties were amenable to them. Codifying a remedies-first approach would result in faster resolutions of problems that can delay access to critically needed benefits. As the complainant receives their desired remedy, the civil rights complaint would remain open. CRCs would be required to inform users that they can still proceed with the formal civil rights complaint process after the remedy-first triage. (For further detail, see Section V, Alternative Dispute Resolution.) Step Three: Investigation Goals and Challenges Every county performs some form of investigation when it receives a civil rights complaint. Our goals for this step were to ensure that enough information is collected to create a full understanding of the incident, encourage uniform investigative procedures and standards to ensure fairness for complainants statewide, while keeping complainants engaged and informed throughout the process. Challenges at this step mirror those seen in other steps: intercounty variation and limited resources. Specifically, the scope and content of investigations as well as the resources available to conduct thorough investigations varies among counties. The time investment for CRCs for every investigation is significant. One CRC estimates that completing an interview with just a single employee takes 2 hours and one with a non-employee takes 3 to 4 hours. Writing up the post- investigation report for CDSS is typically a full day’s work. Further, training of CRCs on civil rights investigations is varied and irregular, and some CRCs have never received formal training on investigation techniques. CRCs lack clear guidance on what exactly they should be looking for during an investigation. Because investigations can be lengthy, contact with complainants can be lost during the process. When this occurs, it becomes unclear if and how the investigation should proceed. Potential Solutions 1. For Complaint Investigations, Review the County’s Record for Evidence and Develop Training Guidelines for CRCs and Investigators. To ensure consistency, CDSS should require specific steps be taken during each civil rights complaint investigation. At a minimum, county workers should be required to interview the resolutions involve training for the county worker\/office. The remedy-first track being simultaneous to the formal complaint will also help avoid complications related to tolling statutory deadlines. 25 complainant, the worker involved, and any witnesses identified by the complainant during intake who can be reasonably located. In addition, any investigation should include a review of the complainant’s entire county record to look for any information that points to different treatment or that can explain the treatment forming the basis of the complaint. CDSS should also develop training guidelines for core competencies (e.g., understanding what constitutes nexus, interviewing skills, how to solicit confirmatory evidence from witnesses) expected from any staff member conducting civil rights investigations. Allowing other staff beyond just the CRC to conduct interviews as part of civil rights investigations would relieve the burden on CRCs and allow investigations to move faster, but training of staff is essential to ensure consistency and quality. Requiring a review of the entire county record and developing training guidelines for core competencies are not currently included in the proposed regulations but should be added to the regulations if these practices are adopted. CDSS should also consider incorporating these recommendations into an ACL. 2. Require County Workers Provide Regular Updates to the Complainant in Her Preferred Form of Communication. To prevent loss of communication with a complainant during investigation, CDSS should require that county workers provide updates to a complainant in the preferred form identified by the complainant at specified intervals throughout the investigation process. This requirement would keep complainants engaged, reassure them that action is ongoing, and reduce the number of complainants who fall out of touch during the process. We recommend that a county worker check in with the complainant every two to three weeks, let the complainant know the investigation is ongoing, and give an estimated time for completion of the investigation. Requiring county workers to contact complainants a minimum number of times at various intervals is not currently in the proposed regulations. We recommend adding this requirement to the Regulations Section .224 and explaining this new requirement in an ACL. 3. Consider Allowing Counties to Initiate or Continue a Complaint in Their Own Capacity. If contact with a complainant is lost, CDSS should establish the standing of counties to bring the complaint in their own capacity. In New York City, the human rights division can bring civil rights complaints against an organization if they see a pattern of complaints but no complainants want to pursue a complaint. Similarly, counties could advance civil rights complaints when a complainant falls out of touch, assuming enough information about the incident has already been gathered to move forward. Such a system would need to be codified in the regulations, so that counties are aware of this option. This would ensure that civil rights violations with internal resolutions (resolutions such as re-trainings or reprimands that do not require the complainant) are still completed. 26 4. Require County Workers to Record When Each Step of Investigation is Conducted. To create greater accountability in counties, CDSS should require county workers to record the date and time at which each step of the investigation process is completed. For example, attempts to contact witnesses as well as witness interviews should be documented. Advocates emphasized that this information is key during compliance reviews. Recording this information in real time would allow CDSS to review open investigations mid-process. If CDSS adopts this recommendation, we advise that this recording requirement be added to the regulations. 5. Consider Either Assuming More Control Over Investigations or Reducing Current Review of Investigations to Reallocate Time and Resources on Training. CDSS should choose between assuming more control over the investigation process itself or reducing its review of county investigations to focus on training. In Ohio, all civil rights investigations are managed at the state level. (Interview with Ohio CRC; see also Appendix at 138.) The state decides the investigation’s scope and controls its progress and then outsources specific parts of the investigation that require local expertise to county CRCs. (Interview with Ohio CRC.) The CRCs receive specific questions and tasks from the state and are required to respond with the requested information quickly, typically within 14 days. (Id.) The CRCs generally do not conduct any interviews. (Id.) They primarily review internal data such as case notes and application documents and transmit that information to the state. (Id.) Though CDSS likely does not currently have the capacity to run this type of system, the standing practice of reviewing every county investigation is problematically time-consuming. We understand that there are serious concerns about the quality of investigations conducted at the county level due to insufficient training and resource constraints. To address these concerns in a more efficient way we suggest: (a) assuming more control over conducting investigations at the outset or (b) reducing review and aggressively training investigators statewide to ensure investigative quality at the outset. Options for reducing review will be further discussed in the next step. Step Four: Resolution Goals and Challenges The resolution process presents an opportunity to ensure justice for complainants and improve counties’ effective delivery of services by fostering solutions that capture critical parts of the investigation while offering peace to all parties involved. In considering this final segment of the initial complaint process, we focused on the following goals: (1) increasing complainant 27 satisfaction with the outcome of her complaint, (2) improving county mechanisms for complaint resolution, (3) streamlining and more narrowly focusing CDSS’s involvement with the resolution process, and (4) facilitating future assessment and improvement of the process through comprehensive tracking of data. Complainants, counties, and CDSS face several challenges in executing civil rights complaint resolutions. These challenges fall into three categories: structural, logistical, and legal\/interpersonal. 1. Structural Throughout our assessment of the civil rights complaint process, we observed the largest structural problem to be the mandatory CDSS Civil Rights Unit (CRU) review of all complaint resolutions before closure. We heard from advocates, county workers, and state workers that this process creates frustration and clogs the system. Because the closure of a civil rights complaint is contingent on CRU approval of the counties’ investigation and findings, complaints cannot reach resolution until CRU makes a determination. While the CRU investigators promote justice by methodically assessing every complaint investigation and resolution, this current process complicates and delays remedies for complainants while forestalling CRU from directing its resources and expertise toward larger policy objectives. Complainants and the advocates who support them consistently volunteered to us that they experience the complaint resolution process as taking too long. From their perspective, they launch a complaint into an opaque system, receive no communication as to the progress in their case, and grow frustrated waiting for some resolution or acknowledgement from the state or county. They perceive this delay to mean the state and county are not working on their complaints and are simply letting them drag on. County and state workers’ experiences show a dramatic disconnect from what the complainants and advocates see as apathy: county workers are not allowed to contact complainants until they receive approval of their investigations and findings from CRU. In addition, county workers complain that they receive little to no feedback from the state as to why their investigations were approved or denied.7 They say they are uncertain what CDSS wants from them in the investigations, sometimes resulting in an investigation that does not meet standards that to them are not clearly articulated. Meanwhile, a small number of state workers are tasked with assessing a flood of complaints from all fifty-eight counties across the state of California. The limited number of employees at the state level paired with the high number of complaints that require their attention generate a backlog at the state level that precludes CRU from focusing on more 7 Our team interviewed only a small sample of county workers from across the state, but their feedback in this regard was fairly consistent. 28 substantive training and policy objectives, disrupts counties’ efficiency in resolving civil rights issues, and delays justice for already suffering complainants. Finally, beyond the burdens it places on all stakeholders, the current system creates a problematic structural tension: CDSS reviews all complaints before they are resolved with the county, but the Department is also the authority that reviews appeals of those same complaints if the complainant is unsatisfied with the result. Through this structure, CDSS is oddly functioning as the appellate authority over its own decisions. 2. Logistical County workers often lose communication with complainants due in part to vague CDSS policies about permissible contacts and, in part, to problematic methods of communication. For example, while the current regulations do direct workers to contact complainants within 20 days for complaints under investigation and within 40 days for complaints that will not be investigated, the guidance does not instruct county workers on what methods and how many times they should try to contact a complainant before closing a case for loss of communication. The guidance is insufficient. County workers’ uncertainty is sometimes compounded by inadequate forms of communication and failure to assess the most effective contact methods for complainants. The small workforce of some county offices also creates barriers to an optimal resolution process: fewer staff members mean county offices face heightened challenges in replacing or reassigning case workers (a commonly requested resolution outcome) due to a complaint. Complainants or would-be complainants also fear retaliation for filing complaints against one worker when that worker’s removal may mean a close colleague takes over the complainant’s benefits assessment. Counties lack clarity on both how they should track and how they should respond to complaints that bridge two separate offices. One CRC noted that she often receives complaints that are more personnel complaints than civil rights complaints. She tracks them on intake as civil rights complaints, but she then refers them to the county personnel office. Based on our conversations with other county CRCs, we believe at least some other counties simply perform the referral or reject the complaint if it is a mixed issue without ever tracking it in their civil rights complaint data. 3. Legal\/Interpersonal Advocates say that their clients often express frustration that they were never informed about the resolution of a complaint about a specific county worker. Legally, the state and county cannot divulge worker discipline or termination because such a disclosure would violate the worker’s privacy rights and likely run afoul of union contracts. However, complainants want some 29 acknowledgment that CDSS is taking their complaint and their suffering seriously and addressing it in some way. Potential Solutions 1. CDSS Should Limit the Practice of Requiring CRU Approval of Every Civil Rights Complaint Resolution. Based on our conversations with advocates as well as county and state workers, we recommend CDSS eliminate its current process of requiring CRU approval of every county civil rights complaint resolution. We acknowledge following this recommendation would constitute a major change to the CRU workflow, but we have identified this as the best option to remedy many of the issues we discovered throughout our research. A common refrain among advocates and county workers alike is that County Welfare Department workers need more robust and frequent training in order to better prevent discrimination, provide appropriate disability accommodations and equal access to services, and to receive, process, and resolve complaints. Advocates further recommend more careful and targeted audits of county offices to substantively change how the counties respond to civil rights complaints. Under the current regime, complaint review monopolizes the majority of CRU’s limited staff resources, preventing the Unit from conducting desperately needed training and compliance monitoring. We therefore propose the following methods of limiting CRU review of all county civil rights complaints, in order of our preference: a. Check a random sample of decisions from across the state before the resolutions are submitted to the complainant. We recommend a sample size of 10% of all complaints.8 In practice, this procedure would allow review at the complaint level. We recommend that CDSS incorporate a mechanism for generating this random sample into its data tracking system. Doing so would enable CDSS to generate a sample from its database of all complaints from all counties. This method stems the flow of work through CRU and frees up resources for more substantive interventions while preserving some oversight over county investigations. Multiple advocates recommended unannounced audits of county offices. This method would maintain the spirit of the unannounced audit. This 8 Each complaint should have some indicator of its county of origin, but the CDSS investigator should be blind to that indicator until she has performed her review. Once the review is complete, CDSS may evaluate whether any patterns emerge of certain problematic counties or workers. The process for generating the sample should be shared to the extent possible with the county offices. Approved data tracking of complaints at the county level would allow for targeted sampling and create a larger body of information to fill gaps in this limited review. (See Section III, Data Tracking.) 30 option would still allow CDSS review at the appellate stage and would require a robust and easily accessed appeal process. This practice would be combined with more training and oversight into the investigation process and with close analysis of the data being collected under the new data collection and tracking procedures. (See Section III, Data Tracking.) b. Eliminate CDSS review of county complaint investigations entirely and refocus resources on intense training in identified areas. This method allows CDSS to redirect focus from reviewing resolutions to identifying patterns of problematic behavior around certain offices or employees and then pursue joint training and discipline directives. We believe based on our conversations with CDSS workers and state advocates that complainants would be best served if CRU investigators were free to use their civil rights expertise on substantive changes rather than on individualized complaint review. This option would still allow CDSS review at the appellate stage and would require a robust and easily accessed appeal process, which is discussed in more detail in Step Five. c. Limit CDSS review to problem counties. This method would require CRU to create a probationary designation and determine how counties enter into that designation. The probationary designation could be based on CDSS’s own experience\/knowledge, what percentage of a county’s determinations are getting appealed, and\/or advocates’ assessments. This option could be problematic for several reasons, including the political difficulties of designating probationary status to particular counties. Also, because of the differential sizes of California counties, the gap between this method and unlimited review could be small. For example, if Los Angeles county receives the probationary designation, CRU will face the same backlog problems they have now, and even the non-probationary counties will suffer. 2. Counties Should Be Required to Contact Complainants a Minimum Number of Times and Should Use Complainants’ Preferred Contact Method to Reach Them. Counties should be required to change their contact practices to include more varied forms and methods of communication in order to ensure complainants are not dismissed from the complaint process due to a fixable failure to communicate. CDSS should require, within well- communicated regulations, that county workers perform the following steps and record attempts and outcomes in SalesForce: a. The county worker must attempt to contact the complainant a minimum number of times. 31 b. These efforts should occur at different times of the day and week to account for work, childcare, and other complicated schedules. c. Communication should be attempted through different methods, beginning with the method the complainant notes as preferable and followed by other methods, such as: text, email, phone call, written mail, contact with next of kin or other designated alternative. Further research is required to assess how these resolution communications could function through text messaging as well as whether there are privacy issues to contacting an alternative contact. The proposed requirements listed above are not included in our proposed regulation edits, but should be added to either the regulations themselves or in an ACL. 3. To Improve Consistency in Quality of Determination Letters and Facilitate Provision of Sufficient Information Upon Which to File Appeals, CDSS Should Provide Model and Inadequate Examples of Determination Letters to Counties. Determination letters are the main source of information from which complainants can learn about the investigation of their complaints and file appeals.9 But the guidelines for drafting these letters are limited. Once a county worker resolves a complaint, CDSS policy should require the CRCs to send a written letter to the complainant explaining the decision and including summaries of investigation findings to the extent they are permitted under worker privacy protections. The current requirements for the CRC resolution letter lack sufficient detail; multiple CRCs mentioned calling CDSS with questions about these letters. Also, CDSS analysts answered that common questions they get involve requests for guidance on writing findings letters. In addition to conducting intakes, CRU is spending a lot of time reviewing and re-writing letters. Advocates suggest complainants would benefit from increased transparency into the rigor of the investigation process. To improve consistency and quality of these findings letters and free up CDSS’ time that is spent re-writing these letters, CDSS should provide counties with examples of both excellent and subpar determination letters. First, CDSS should provide counties with model determination letters that reflect a high-quality investigation and sufficiently communicate to complainants the findings, why their complaints were denied, and their appeal rights. Second, CDSS should provide counties with examples of determination letters that fail to provide sufficient information to complainants. Along with providing these what not-to-do letters, CDSS should explain and provide training to counties about how these letters fall short and ways to remedy these gaps. Providing both model and subpar examples will: (i) give clarity to counties on drafting letters, (ii) signal to counties what constitutes a high-quality investigation, and (iii) hopefully decrease calls 9 The two findings letters we reviewed lack any language on the appeals process. We recommend requiring that findings letter include a notification of appeals rights, simple instructions for filing an appeal, and an enclosed appeals form. For a deeper discussion of this recommends, please refer to Step Five. 32 to analysts requesting guidance on drafting letters, enabling analysts to focus on other tasks. With respect to appeals, providing examples may lead to better determination letters that give complainants notice of their appeal rights and provide enough information so they can determine whether to file an appeal. Additionally, we suggest that CRU create templates of findings letters with detailed guidance for CRCs. Eligibility denials are written using electronic templates that have options and guidances for each portion of the letter. We recommend CDSS develop similar templates for findings letters that will help counties write higher-quality findings letters and ensure complainants have sufficient information about the findings. 4. CRCs Should Be Required to Use the Complainant’s Preferred Contact Method to Explain the Resolution of the Complaint and Should Allow Complainants to Opt Into a Resolution Call During Which a CDSS Contact Could Explain the Findings. The CRC should additionally use the complainant’s preferred contact method, if it is not a letter, to explain the resolution of the complaint. Alternatively, CDSS policy could allow complainants to opt into a resolution call in addition to the mandatory letter. This would allow more dynamic communication with the complainant and provide the complainant with an opportunity to ask questions and receive personalized attention. The resolution call would involve an explanation of the findings, the grounds for the findings, notification of the complainants’ appeals rights, and instructions for filing an appeal. For complaints resolved unfavorably to the complainant, this resolution call should be conducted by an appeals worker, as is done for eligibility denials. This recommendation of a call with an appeals worker should be implemented as an initial step, to be revisited if it creates too much of a time commitment for the assigned appeals contact at CRU. 5. County Workers Should Be Required to Record Data Related to Resolutions of Complaints. To ensure justice for the complainant, we would advise that county workers be required to record in both the county logs and on Salesforce the following: \u25cf What kind of complaint was filed (e.g. language access, disability, etc.)? What were the demographic characteristics of the complainant? \u25cf What did the complainant hope for in filing their complaint? A new caseworker? An apology or explanation? A continuation of their benefits? \u25cf Did the complainant receive a remedy? What remedy did they receive? Was it what they requested? Why or why not? \u25cf If not, did the complainant receive a satisfactory explanation of why they did not receive their desired remedy? 33 Also, CDSS should perform assessments of data related to resolutions of complaints to ascertain if certain counties are disproportionately denying complaints and identify gaps in resolutions (i.e., if certain types of complaints are getting denied more than others). 6. Counties Should Affirmatively Acknowledge Complainants’ Experience and Thank Complainants for Filing Their Complaints in the Resolution Letter. Although counties are likely barred from disclosing employee discipline, training, or termination in response to a complaint, we recommend that CDSS train counties to respond to complainants’ frustration by acknowledging their struggles and expressing gratitude for their complaint. Advocates asserted that their clients would benefit greatly from some recognition by the state or county that they had a problematic experience and that what happened to them may have been inappropriate. We therefore suggest CDSS work with advocates to develop a response that acknowledges complainants without conceding liability or breaking privacy rules. The response, which would be incorporated into the resolution letters to complainants, might involve the following plain language: Dear (formal name), We write to thank you for telling us about your dissatisfaction with your experience with (nature of situation). We have worked within our offices to investigate and address your concerns, and we are sorry that you had a negative experience with our office. By submitting your complaint, you allowed us the opportunity to make our county and our state better for you and for others. We remain grateful to you for that opportunity. Sincerely, (county name) Civil Rights Coordinator. Step Five: Appealing an Initial Determination [ Request for Reconsideration ] The right to appeal is critical to ensuring procedural justice and accuracy in the complaint process. Appeals not only allow complainants an additional opportunity for their complaints to be reviewed and resolved but also can be important for identifying and correcting errors in initial determinations from wrong facts to deficient investigations. Despite the importance of appeals rights, however, the appeals process is one of the more under-publicized, under-utilized parts of the complaint process. In our interviews, advocates and the CRCs did not have much, if any, exposure to the appeals process. Overall, the appeals process seems to be considered entirely separate from rather than a fundamental part of the complaint process. To address this issue\u2014 along with others in the appeal process\u2014we have outlined specific goals, challenges, and potential solutions for your consideration. Goals 34 Given the lack of awareness of the appeal process and the low number of appeals CDSS receives, one goal is to ensure that users know about the appeal process, including how and when to file appeals. Another important goal is to make the appeal process more accessible to complainants. A long-term goal could be analyzing appeals data to gauge patterns by counties and common areas of weakness in the complaint process. CDSS could then leverage this data to improve trainings, county reviews, and the complaint process overall. Challenges On the complainant-side, challenges are: (i) lack of awareness of the right to appeal; (ii) lack of trust in the appeal process; and (iii) inaccessibility of the appeal process. A baseline challenge is complainants’ lack of awareness that the option to appeal exists and\/or how to file appeals. Another challenge is complainants’ lack of trust in the appeal process. Complainants may be wary of filing appeals after the denial of their complaint, especially if receiving the initial denial was already a long process. Lastly, complainants lack resources to navigate appeals, a problem that is exacerbated by the opaqueness of the appeal process. There is little to no guidance for complainants on the appeal process on everything from what evidence to offer to which bases would support filing an appeal. For CDSS and the counties, the primary challenges are resource limitations and the structure of the process. CDSS and counties face resource limitations, particularly in regards to staffing, to undertake appellate review. This is exacerbated by duplicative components of the process, including that CDSS both signs off on local determinations and is designated to receive any appeals. CDSS also faces challenges getting counties to comply with reversals of initial determinations in a timely manner, if at all. Multiple advocates have stressed the lack of practicable enforcement mechanisms to ensure county compliance with initial determinations. Given the already weak enforcement mechanisms for county compliance with initial findings, it is likely to be even more challenging to get counties to comply with reversals on appeal. Potential Solutions Our recommendations for achieving the goals described above extend from the initiation of the complaint process to the determination of appeals. As such, many of these recommendations must operate in tandem with solutions described in Steps Zero through Four, e.g., publicizing the appeals process in posters describing the overall complaint process at county offices and improving consistency of determination letters. 1. Consider Re-framing Appeals as Requests For Reconsideration. 35 To encourage more complainants to appeal initial determinations, CDSS should consider re-framing appeals as requests for reconsideration. North Carolina’s DHHS grievance procedure uses reconsideration request rather than appeals. (Appendix at 116-117; see also SSA procedure which includes a request for reconsideration stage.) This language is less intimidating to complainants who may be discouraged by the thought of navigating a formal appeal process. If this change in terminology is adopted, CDSS should update the regulations to reflect this change. Moreover, determination letters should include notifications of this right to a request for reconsideration and any public documents should also reflect this change. 2. Counties Should Publicize Reconsideration Requests Rights at the Outset of the Complaint Process including on Posters at County Offices and On Complaint Forms. Notify Users of Reconsideration Requests Rights via Posters at County Offices: CDSS and counties should inform users of their right to request reconsideration on posters visible at county offices. From a visit to a Santa Clara County welfare office, we learned that county offices do not mention reconsideration request rights on posters that notify users of the complaints process. In addition to further publicizing the complaint process through better positioning posters (see Step Zero), CDSS should add a notification of reconsideration request rights to the posters and counties should maintain copies of reconsideration request forms at greeters’ desks. A visible poster including appeals language could state: If you wish to file a civil rights complaint, please call ____ or pick up a complaint form at the greeter’s desk. If you have already filed a complaint and you disagree with the decision, you can file a request for reconsideration by calling ___ or picking up a reconsideration request form at the greeter’s desk. Notify Users of Reconsideration Request Rights in the Complaint Form: CDSS should add to the bottom of complaint forms a notification that complainants can request reconsideration of their complaint if they are dissatisfied with an initial decision. Overall, notifying users of reconsideration request rights at the outset of the complaint process will prime users early-on with the knowledge that an initial determination is not the last chance for review or redress of their complaints. 3. To Improve Accessibility of Reconsideration Requests, Counties Should Be Required Both to Enclose Reconsideration Request Forms in Determination Letters and to Provide Accessible Instructions and Guidance for Filing a Reconsideration Request. Enclose Reconsideration Request Form in Determination Letters: To increase ease of filing appeals, counties should be required to enclose reconsideration request forms with determination letters. North Carolina attaches their reconsideration request form to the initial determination letter sent to complainants. (Id. at 116.) Also, for eligibility denials, the denial letter contains information 36 about applicants’ appeals rights, the deadline, and the appeals form on the reverse side. This practice should be applied to the civil rights complaint denials. Attaching reconsideration request forms to determination letters removes the extra step for complainants of requesting the form. Moreover, it would enable complainants to learn immediately upon review of their determination letters what the reconsideration request process entails. Provide Accessible Instructions for Filing a Reconsideration Request: CDSS should provide sample language that can be used in determination letters. Accessible instructions could include stating, If you disagree [or are dissatisfied] with this decision, you can request reconsideration of your complaint. A reconsideration request form is enclosed with this letter. Provide Checkboxes or Examples of Grounds for Requesting Reconsideration: Complainants likely struggle with not understanding the bases to file appeals. To address this ambiguity, forms should provide a list of potential bases for requesting reconsideration of a complaint. For example, forms could state: What are your reasons for disagreeing with this decision? Reasons can include (among others): an insufficient investigation having been conducted, decision being based on wrong facts, missing information in the findings, etc. Forms should provide checkboxes of potential reasons along with a space in which complainants can explain the context for their reason. If the checkbox approach is used, it is critical that forms remind complainants that they can mark more than one reason and that they can provide a reason not listed. Maintain a Low Threshold for Filing a Reconsideration Request: Given the extremely low number of appeals being filed and for procedural justice purposes, CDSS should enforce a low threshold (e.g., dissatisfaction with an initial finding) for a complainant filing a reconsideration request versus a higher standard that requires certain grounds for filing a reconsideration request. Notify Complainants that Accommodations Can Be Provided in Filing a Request for Reconsideration: Reconsideration request forms should remind complainants in plain language that they can request accommodations in the process. The request form should incorporate affirmative screening language similar to Massachusetts’ intake processes. (Id. at 20-21.) The notification could state: If you have a physical, mental, and\/or emotional health problem that may make it hard for you to file this reconsideration request, you can ask for help. For an accommodation in filing this request, please call ____ , visit ____[county office], or fill out the questions below. (Id.) Below this notification, the reconsideration request form could include checkboxes of accommodations that could be provided including, but not limited to large print, a computer diskette, a language interpreter, Braille, someone to call and explain the appeals process, etc. There should also be blank space for complainants to request other accommodations that are not listed. List Resources for Help with Filing Appeals on the Request for Reconsideration Form: Determination letters should provide a phone number for a complainant to call with questions 37 about the findings and filing a reconsideration request. Appeal forms could also contain a list of legal aid offices that complainants can turn to for help in filing reconsideration requests. Remind Complainants of Non-Retaliation Policy: Complainants may be afraid to file appeals due to fear of retaliation by county workers, so reconsideration request forms should remind complainants of counties’ non-retaliation policy. Minnesota notifies users of its non-retaliation policy and provides instructions for reporting retaliation in its instructions for filing a complaint. CDSS should incorporate this practice in reconsideration request forms. (Id. at 91.) 4. To Facilitate Complainants Filing Requests for Reconsideration in a Timely Manner, Counties Should Develop Alternative Methods for Sending Determination Letters. Provide Alternative Ways for a Complainant to Receive Notice that a Determination Letter Has Been Sent: One issue with the appeal process is that complainants may receive their determination letters after the deadline or when there is insufficient time for them to adequately launch an appeal. For example, a complainant who is homeless may have listed a community service center as her mailing address and may have checked her mail days or weeks after receiving a determination letter, when the deadline for filing an appeal has already passed. To address this issue, complaint forms should request complainants’ back-up contacts and provide a list of opt-in methods through which the complainant can be contacted. (See Step Four.) Counties should email or text complainants that their determination letter is in the mail. According to advocates, many clients use text messaging as their primary mode of communication and have unstable physical addresses. Regardless of the communication method(s) used, counties should be required to attempt to notify a complainant that her determination letter has been sent at least three times and should record each attempt. If this recommendation is adopted, CDSS should add these communication requirements to the regulations and also incorporate them in an ACL. Inform Complainants of New Deadline for Reconsideration Requests: Another issue with appeals is the strict 30-day deadline. Currently, complainants must file appeals 30 days from when the CWD mails the determination letter. But complainants may not access the mailed letter until weeks after it is sent, for reasons ranging from memory issues to being homeless and lacking consistent access to the mail. After receiving the notice, complainants may need to seek assistance from legal aid organizations regarding the request for reconsideration procedure. CDSS should change the regulations to (i) extend the 30-day deadline and (ii) allow complainants who give good cause to file a request for reconsideration past the deadline. CDSS should require counties to notify complainants of this new deadline and the good cause allowance in determination letters and reconsideration request forms. 38 To Prevent the Appeals Process Duplicating the Original Investigation, Assign Appeal to CDSS Analyst Who Did not Conduct the Pre-Decision Review of the Complaint At Issue. Assign Reconsideration Request Review to CDSS Analyst Who Has Not Touched the Initial Complaint Being Reconsidered: One challenge to the appeal process is that CDSS both signs off on the local determination of an initial complaint and then conducts appellate review of that same complaint. One way to address this issue and foster trust in the accuracy and integrity of the reconsideration request process is to assign a reconsideration request to a CDSS analyst who did not review the initial complaint. CDSS analysts are assigned to complaints by county. An analyst from a different county, who did not conduct the pre-closure review of the complaint being reconsidered, should be assigned the appeal. This practice would ensure a fresh set of eyes on the complaint and decrease duplication of the original analysis. Salesforce could help in assigning reconsideration requests to a team member who has not engaged with the initial complaint. An alternative recommendation is to designate one team member to be a reconsideration request specialist, whose job is to analyze reconsideration requests and initial complaints for a handful small counties unlikely to generate a large number of requests for reconsideration. Reconsideration requests from that analysts’ counties could be assigned to other team members. Notably, this problem of duplicating the original investigation and findings is partially resolved if our earlier recommendation to review only a sampling of resolutions is adopted. (See Step Four for more context.) 6. In the Long Term, Leveraging Appeals Data Could Help CDSS Gauge Patterns in Counties and Common Areas of Weakness in Investigation. Assess Appeals Data to Ascertain Common Problem-Areas in the Complaint Process: Upon receiving a request for reconsideration, a CDSS analyst should input the following data into Salesforce: the type of complaint, the county and office of the original incident, the resolution requested, the reasons for the denial, the grounds for the request, and the outcome of the request. (For a deeper discussion of data tracking, see Section III, Data Tracking.) Tracking this data (using Salesforce reporting functions) can inform CDSS as to common grounds for requests for reconsideration, counties with high percentages of both total requests and successful requests for reconsideration, and the overall success rate of reconsideration requests. CDSS should then apply this data in tailoring trainings to address gaps in investigation, addressing problem-counties, and improving the reconsideration request process to avoid denials of meritorious reconsideration requests. An additional data-tracking practice should be using Salesforce as a ticketing system to track status of reconsideration requests and ensure they are resolved in a timely manner, similar to Ohio’s ticketing system of customer service complaints discussed in Section VI, Other States Memo. 39 II. PARALLEL PROCESS (REASONABLE) ACCOMMODATION\/AUXILIARY AID GRIEVANCE) Alternative Grievance Process for Accommodation\/Auxiliary Aid Complaint (Based on Recommendations by National Advocates And Massachusetts Model) We recommend that CDSS implement a parallel process that allows for expedited action on grievances regarding requests for reasonable accommodations and auxiliary aids for users with disabilities. This process has been strongly recommended by national advocacy organizations as a way to ensure that users with disabilities are provided full access to services by providing them with required accommodations and auxiliary aids without delay. This process has been implemented in Massachusetts, and other states, including Minnesota and Georgia, and some counties in New York are also working towards implementation of this process. This section outlines this parallel disability grievance process. Screening Every Applicant The first step in this parallel process to ensure full and fair access for users with disabilities is screening every benefits applicant for disabilities. We recommend adopting similar language to that which is used in Massachusetts: There are things [CDSS] will ask you to do in order to get or keep your benefits. If you have a health problem that makes it hard for you to do something [CDSS] asks, you can ask for help. This is called an accommodation. This could be because of a physical or mental or emotional health problem. Some of the things we’ll ask you to do are: \u25cf Read notices we send and follow instructions in them \u25cf Fill out forms \u25cf Come to the office for appointments \u25cf Get and give us documents to prove whether you can get benefits \u25cf Tell us about changes in your household\/case \u25cf Meet deadlines Do you think you might need help with any of these things, or something else, because of a health problem? CWDs should track when users ask for support in response to the screening. Upon a request for support, counties should engage in an interactive process to determine the appropriate reasonable accommodation. CWDs cannot force someone to accept a specific accommodation. Primary consideration should be given to the requests of the person seeking an accommodation or auxiliary aid. CWDs should provide a formal accommodation communication that explains what the accommodation is and gives the contact information for the disability coordinator in case the individual wants to file a grievance regarding their accommodation\/auxiliary aid. 40 Conciliation When an adverse action is pending against a user who has been identified as a person with a disability and who has received an accommodation, CWDs should be required to contact the users to ensure that her disability was not the reason for her triggering the adverse action. This conciliation process is used in Massachusetts and stakeholders report that it improves efficiency and conserves resources by preventing time consuming closure and reopening of cases and issues, which has happened frequently in cases of users with disabilities. Grievance Users who request accommodations or auxiliary aids should be notified in writing that they have the right to complain if they are dissatisfied with the support offered. Users should be provided with a form that asks the following: 1. What accommodation\/auxiliary aid did you ask for? (with examples of common ones) 2. What support did you receive instead? 3. What do you need to make this right? Review\/Investigation Grievances should be reviewed by the disability coordinator who should attempt to seek quick resolution. Disability coordinators should be armed with additional knowledge about what kinds of accommodations may help and research options. Disability coordinators can require workers to implement the accommodation that the coordinator comes up with the client’s input Resolution Once a decision is made by the disability coordinator, the client would receive an accommodation\/auxiliary aid communication explaining the accommodation\/aid they will be receiving. This letter could also notify the user of appeal rights, as in the civil rights complaint process. Appeal to CDSS Users dissatisfied with the resolution proposed by the disability coordinator should have the right to appeal the decision to CDSS. 41 III. DATA TRACKING As all parties interviewed as part of this project have made clear, the dearth of consistent, actionable data renders nearly impossible the task of tracking broad trends in the civil rights complaint process. This makes the system opaque, leaving anecdotal evidence from advocates, CRU analysts, and county workers as the primary source of information about compliance and the effectiveness of the complaint process. To increase understanding of the civil rights complaint process and civil rights compliance among CDSS, county staff, and advocates, this section lays out recommended data collection and tracking practices. Goals and Challenges One major goal in this area is to consistently track data across as many indicators as possible regarding the civil rights complaint process. Doing so will allow CDSS to assess how to best allocate training and compliance monitoring resources: the data may demonstrate that specific county offices receive a higher share of complaints, or that intellectual disabilities take up far more county resources than realized. The ability to analyze both macro and micro trends will help CDSS better identify issues and target resources. Of course, the current challenges to achieve this goal are numerous. County data tracking practices vary tremendously, as a barebones complaint log is all the regulations currently require and some counties may not accurately implement this requirement. The regulations do not specify format, so, in the best case, these complaint logs are in Excel (others are handwritten). This lack of consistency across counties makes comparing data difficult, if not impossible. Without regular communication and oversight from the state, counties often fall behind on data collection. Moreover, the data currently tracked by counties is very limited. Sample Excel complaint logs from two counties only included a complainant’s name, the date the complaint was received, the benefit program involved, the basis of the complaint, the nature of complaint, the resolution, decision, and resolution date. Also, the counties used these complaint logs in very different ways: one county understood basis of complaint to constitute a description of the incident, while the other interpreted it to mean type of discrimination (e.g., by race, sex, intellectual disability). These limited, inconsistent logs, which represent the best version of civil rights complaint data tracked by counties, are a major obstacle to operationalizing data collection and analysis. A final, notable challenge is that, due to low rates of engagement with the civil rights process, whatever data is collected will almost certainly reflect a severe undercount of users’ actual experiences. The second goal for data tracking is to analyze and operationalize the data that counties collect. This goal encompasses not just the state’s use of the data, but also sharing of that data, to the extent possible, with counties and advocates to ensure that parties using the complaint process can improve the user experience. The biggest challenge here, of course, is that no system currently 42 exists to share information. Once a more robust data collection process is put in place, CDSS will need to determine what data it can provide counties and advocates, and how often. Solutions 1. Require All Counties to Track a Wide Variety of Indicators for All Civil Rights Complaints. Complainant Demographics. Demographic data would help CDSS flesh out patterns in who accesses the complaint process that might be lost by simply collecting information about the type of discrimination that forms the basis of a complaint. One advocate explained that breaking down data by demographic lines would help him better target his advocacy to those users who most often utilize the process. Potential demographic information to collect includes: age, race(s), ethnic group identification, gender identity, sexual orientation, immigration status, national origin, language, disability status (including both mental and physical disabilities), participant status, and whether a user is currently experiencing homelessness. Discrimination Type (list ALL implicated protected classes). This indicator should capture the bases on which the complainant believes they were discriminated. As one expert explained, it is critical that this indicator captures discrimination across multiple dimensions. For example, a black indigent woman facing discrimination by a county worker could file a complaint on any or all of those three bases. For ease of recording and to account for the complex ways bases of discrimination can intersect, we advise using checkboxes for this indicator. Complaint Details. This indicator should capture, as described by the complainant, the incident(s) that led to the complaint being filed in narrative form. Date. This indicator should capture when the incident(s) at issue occured. Location. This indicator should capture where the complaint occurred, on the county office level. As one advocate suggested, this would help all parties target resources to particular offices that are posing challenges in counties with multiple offices. Type of Complaint Filed. This indicator should capture how the complaint is originally made (e.g., by phone, in person, etc.), to track trends in which types of complaints on which bases are made through which avenues. As one advocate explained, this would help both CDSS and advocates tailor outreach and resources. Employee(s) Involved. This indicator should be considered for CDSS internal purposes only, to help with internal monitoring of, for example, employees who face repeated complaints regarding certain types of discrimination. 43 Case Updates (initial response, communication with complainant, investigation, languages used by complainants, resolution). This indicator should track each case update by date, with a new entry for each additional step taken. This indicator should include: civil rights coordinators’ initial response; whether users respond to a letter (or not, after a set period of time); the method and language of each user contact initiated; the investigative steps taken; and the ultimate resolution of the case. Resolution Date. This indicator should track the date a complaint is resolved. Type of Resolution (Both Resolution Requested and Resolution Granted). This indicator should capture the type of resolution that the complainant requested. There should also be an indicator for whether a resolution was granted and if so, what type of resolution was granted. CDSS could track this data to assess if certain types of resolution requests are disproportionately denied compared to others, as well as patterns in types of resolutions granted by county. Reason(s) For the Denial of a Complaint. This indicator should capture why a complaint a denied. It should include checkboxes with general reasons for denial followed by a text box in which the CRC could specify the grounds for the denial of the complaint. Grounds for Requests for Reconsideration (Appeal). This indicator applies to requests for reconsideration (appeals) and should capture why a complainant appealed the decision. This data could be leveraged to assess common reasons for complainants filing reconsideration requests (e.g., insufficient investigation, lack of clarity in findings letters, etc.). Outcome of Requests for Reconsideration. This indicator should capture the date a request for reconsideration is resolved and whether the request for reconsideration was granted or denied. If a reconsideration request is denied, there should be checkboxes for general reasons for denials followed by a text box in which the reconsideration request specialist at CDSS could explain why the request was denied. 2. Standardize and Integrate Data Collection to Ensure Ease of Analysis. First, requiring all counties to collect the same data in the same format, ideally in Salesforce, but perhaps in Excel for the time being, would be a substantial step in achieving these data tracking goals. Second, it is critical that counties receive more guidance about precisely what each indicator should entail to avoid repeating the current situation, in which counties interpret their data collection requirements in dramatically different fashions. Third, and relatedly, guidance to counties should ensure that whatever data is received is relatively easy to code for analysis through using checkboxes or other binary data collection tools. 44 3. Regularly Analyze and Share Data to More Efficiently Allocate Resources and Provide Greater Transparency. A quarterly analysis of county data across each of the indicators mentioned above would assist CDSS in discovering patterns and targeting particular issues. Sharing these analyses with counties and advocates to the extent possible (given legal and political concerns) would allow counties to better inform their work serving users by highlighting areas for improvement, and assist advocates serving users accessing benefits. This level of transparency would also build greater trust in the process among advocates, promoting greater cooperation and buy-in. 4. Consider Bolstering Civil Rights Complaint Process with Anonymous System to Address Under-Counting Concerns. While undercounting concerns were addressed in Step Zero above, one of the solutions suggested, considering an anonymous complaint process to ensure users who fear retaliation will still register their civil rights complaints, would help address the ever-present concern about undercounting complaints. Collecting data in an anonymous complaint system would also help CDSS understand precisely who is using the system, and may assist with identifying patterns with the type of users who decide to complain anonymously. 5. Track Disability Status and Reasonable Accommodation Requests and Status of Eligibility Decisions to Determine Impact of Disabilities on Eligibility Determinations. CDSS should track data about users with disabilities including: (i) whether a user’s disability is mental and\/or physical, (ii) the type of reasonable accommodation or auxiliary aid requested, (iii) whether the accommodation request was granted or denied, (iv) whether a user’s eligibility case was granted or denied, and (v) the reason for the denial of her eligibility. We advise checkboxes for each of these indicators, as well as text boxes in which county workers can further specify why the accommodation request was denied, why the eligibility case was denied, etc. For example, checkboxes for reasons why eligibility was denied should include failure to return forms in a timely manner, failure to satisfy technical requirements, missed appointments, loss of contact. This practice could help collect data to determine what changes are necessary in disability screening and accommodation procedures. A key reason for the outcome of the Harper suit and settlement in Massachusetts was that from 2006-2009, Massachusetts’ Department of Transitional Assistance gathered this disability- related data and determined that approximately 27, 289 eligibility applications were denied for users known to be disabled due to technical reasons, such as missed appointments or incomplete paperwork. (Appendix at 68.) Also, Massachusetts’ data collection uncovered 118,816 eligibility cases that were terminated for clients known to be disabled due to technical reasons such as missed appointments or incomplete paperwork. (Id.) Similar to Massachusetts, CDSS should adopt this 45 practice of collecting data on barriers to the eligibility process for users with disabilities and leverage this data to determine what reforms are necessary in screening and the reasonable accommodation process. IV. CHILD PROTECTIVE SERVICES Child Welfare System Because of the unique nature of the child welfare system, civil rights complaints regarding this system confront different challenges than complaints regarding public benefits. The civil rights complaint process plays a critical role in the child welfare space. In this memorandum, we identify the unique challenges of these types of complaints, recommend solutions to those challenges, and note areas ripe for legislative advocacy or policy change. Structure Advocates and county workers alike observed that people involved with the child welfare system have many places to turn for relief, and they rarely see them use the civil rights complaint process.10 Like most states, California has established a special office to handle and investigate complaints from families involved in the child welfare system.11 The office of the Ombudsman operates within CDSS, but maintains some autonomy from the department’s normal processes. Cal. Welfare And Institutions Code 16160-16167 established the California Ombudsman for Foster Care and the Office of the Foster Case Ombudsman (FCO.)12 CDSS’s public communications indicate that FCO is the proper forum for complaints regarding the child welfare system: CDSS directs complainants with issues regarding county agencies that provide child welfare services to the FCO13 while pointing non-child welfare complaints to the public assistance program complaint process. Advocates also direct parents experiencing discrimination within the child welfare system to contact FCO for guidance in navigating the complaint process.14 Beyond FCO, parents and other people involved in the child welfare system often use other forums to air complaints. Because most of their grievances stem from child dependency and 10 Based on our meeting with CDSS CRU specialists, we know that complaints are coming to CDSS regarding the child welfare system. However, the advocates and county workers we spoke to were largely unaware of them, potentially indicating complainants are filing these complaints without representation. 11 Children’ Ombudsperson Office FAQs. http:\/\/www.ncsl.org\/research\/human-services\/childrens-ombudsman- offices.aspx (last visited March 12, 2019). 12 Office of the Foster Care Ombudsman. http:\/\/www.fosteryouthhelp.ca.gov\/OMBprog.html (last visited Mar. 12, 2019). 13 CDSS Complaint Instructions. http:\/\/www.cdss.ca.gov\/Reporting\/File-a-Complaint\/County-Complaints 14 AdvoKids, Legal Tools, https:\/\/www.advokids.org\/legal-tools\/discrimination\/; advocates in interviews mentioned these affirmative processes. http:\/\/www.ncsl.org\/research\/human-services\/childrens-ombudsman-offices.aspx http:\/\/www.ncsl.org\/research\/human-services\/childrens-ombudsman-offices.aspx 46 removal proceedings in which all parties are represented, many people raise their discrimination and civil rights issues through the Office of Administrative Hearings.15 Goals The CDSS civil rights complaint process and CRU oversight of child welfare issues remain critical to children, parents, family members, and foster parents involved with Child Protective Services (CPS). Dependency court hearings may offer representation to families and a forum to lodge their civil rights grievances, but these grievances are useful to them only in their ultimate goal of getting their child back. Dependency hearings are not built to solve broader civil rights problems; they can only remedy specific placement issues. CDSS’s civil rights complaint process allows state intervention into systemic threats and broader solutions to families’ civil rights challenges. It also offers an additional forum to meet the access and accommodation needs of disabled parents. The challenges and solutions recommended below are meant to provide context to CDSS on the particularized needs of child welfare complainants. Ultimately, we believe CDSS can best serve these clients by meeting civil rights training needs of county child welfare workers, addressing personnel problems based on complaints, and using compliance monitoring to assess current discrimination and prevent future discrimination. Challenges The length of the process is the major challenge of the CDSS complaint process in the child welfare context. When the custody of a child is at stake, parents are reticent to engage in a protracted complaint process. Advocates explained that many clients prefer the quickest resolution to getting their children back, and they fear how filing a complaint might disrupt that process. Many of the people in the dependency process rarely ascribe an issue they are experiencing to a civil rights violation. Most clients would not identify their complaints as civil rights issues, but rather as interpersonal issues with their social worker or attorney. Child welfare advocates don’t even think about the complaint process 16 while in the midst of a removal proceeding. The area where people most need the CDSS civil rights complaint process arises outside of the court hearings in which parents are so engrossed. In dependency hearings, all parties are represented and civil rights grievances become part of the determination: dependency courts decide discrimination claims as part of their assessment of removal.17 Theoretically, parents’ 15 Office of Administrative Hearings, https:\/\/www.dgs.ca.gov\/OAH (last visited March 12, 2019). 16 Conversation with child legal advocate, February 5, 2019. 17 Welf. and Inst. Code 303, http:\/\/leginfo.legislature.ca.gov\/faces\/codes_displaySection.xhtml?lawCode=WIC&sectionNum=303 (last visited March 12, 2019). https:\/\/www.dgs.ca.gov\/OAH http:\/\/leginfo.legislature.ca.gov\/faces\/codes_displaySection.xhtml?lawCode=WIC&sectionNum=303 47 lawyers would raise issues of discrimination when arguing against removal or negotiating class and counseling mandates. Once an investigation is started or a child is removed, parents face a series of hurdles, including but not limited to parenting classes and drug rehabilitation. Very little consideration is given to barriers faced by parents to successfully clear those hurdles. The attorneys that represent parents during hearings are there for court appearances, but they rarely speak with the parents outside of court. Despite these circumstances, County Civil Rights Coordinators (CRCs) may be unable to fully consider civil rights complaints regarding child welfare because of the challenges they face in investigation. Child Protective Services is tight with their information, 18 refusing to allow CRCs access to documentation of home visits. Records from dependency hearings are also sealed. Because CRCs cannot follow their usual methods of investigation, they rely on the accounts of CPS managers and workers, rendering their investigations incomplete. Potential Solutions Some solutions to these challenges dovetail with the solutions we recommended for complaints regarding public benefits.19 Advocates note their clients need some indication that the system is responsive to them, that their complaints are being heard. Complainants also want faster response times to their complaints, particularly due to the unique challenges of child removal. We reiterate here the communication practices and structural changes we provide in our main memorandum. Other challenges of child welfare complaints require more targeted solutions. A major problem with these complaints is whether parents or others involved in child welfare proceedings know to file them or have the bandwidth to do so. While we recommend the same procedures we list in Step Zero of our Complaint Process Memorandum, we also encourage CDSS and CRU to create more resources for advocates who are positioned to refer clients with these complaints. We also recommend basic training for both advocates and county workers to keep the civil rights complaint process in mind as they serve clients. CDSS should also consider policy measures and communications that protect the complainants from jeopardizing their dependency cases by filing these complaints. Several advocates expressed concern that CRU as a part of CDSS would receive complaints from people currently in child welfare proceedings. These advocates expressed a preference for complaints to 18 Conversation with County Civil Rights Coordinator, February 13, 2019. 19 See Complaint Process Design Memorandum, Step Four: Resolution. 48 go to FCO rather than CRU to preserve independence. We see that CRU could provide a critical service to parents and others who have nowhere else to turn for civil rights remedies, so we encourage CRU to make clear in their communications to advocates and potential complainants that the office is a separate entity from the child welfare agency. Further Research and Advocacy Throughout this research, we identified several areas in the nexus between civil rights and child welfare that extend beyond the civil rights complaint process. We identify and discuss those issues here as well as recommend contacts for future consideration. 1. Investigation of Child Welfare Complaints Proper investigation of civil rights complaints relating to the child welfare system may require legislative change. County CRCs reported to us that Child Protective Services does not disclose records relating to removal, and dependency court records are similarly sealed. Federal law requires that states receiving federal funding for child protective services keep investigative information confidential, except in limited circumstances.20 California law seems to allow some record access to state employees of CDSS in a limited set of roles.21 Further research is required to assess whether CDSS must seek legislative change to access these records. 2. Vulnerable Groups: Foster Care and Diversion When asked where they see the most civil rights violations in the child welfare system, advocates repeatedly pointed to foster parents. While parents and children all have representation in dependency hearings, foster parents often struggle to assert their entitlements to benefits and services for themselves or their foster child. This problem is especially acute in diversion cases, where child welfare employees informally place children with family members outside of the procedures of the foster care system in an effort to avoid dependency proceedings. Because these placements do not have the protections of a formal placement, family members and the children they house are left without stability: they cannot receive benefits for the child, the child may not be able to enroll in school, the child cannot claim financial independence for purposes of college tuition, reunification services are limited, and the biological parent may be able to take the child away at any time. 20 Children’s Bureau, Disclosure of Confidential Child Abuse and Neglect Records. https:\/\/www.childwelfare.gov\/pubpdfs\/confide.pdf. Current through 2017. 21 Welf. and Inst. Code 827, https:\/\/leginfo.legislature.ca.gov\/faces\/codes_displaySection.xhtml?sectionNum=827.&lawCode=WIC. 49 Diversion cases are ripe for several civil rights abuses, including coercion of the placement relative and ensuing degradation of the civil rights of the child, the foster parent, and the biological parent. We recommend further research into whether or how the CDSS civil rights complaint process could serve as a refuge for people facing these abuses. 3. Racial Disparity and Disproportionality Initiatives Washington State has developed a promising model for tracking, addressing, and attempting to remedy disparity and disproportionality in their child welfare system. Beginning with a report in 2008 on racial disparity and disproportionality, they have launched a taskforce charged with tracking data, implementing outcome-based initiatives, and reporting on progress. (See Appendix at 154-67.) 4. Future Research Follow up with California’s parents’ advocates: Most of the advocates we spoke to were children’s advocates who had never filed a civil rights complaint before. Some of them recommended we locate parents’ advocates but during the timeframe of this policy lab, we were not able to connect with any parents’ advocates. Based upon the experiences parents endure in these processes, they are likely to have important insights into how the complaint process could improve for people involved with the child welfare system. V. ALTERNATIVE DISPUTE RESOLUTION Alternative Dispute Resolution: Remedies First and Mediation We have identified two ways in which CDSS could potentially incorporate alternative dispute resolution (ADR) into its civil rights complaint process. First, CDSS could require counties to expand on existing informal resolution practices, through which some CRCs attempt to promptly address a complainant’s programmatic or personnel issue separate from the civil rights complaint process. For example, a CRC could reassign a user to a different caseworker or provide a disability accommodation immediately after receiving a complaint, while the civil rights process is ongoing. Second, CDSS could incorporate a formal mediation option into its main civil rights complaint process. Unlike with the informal fixes described above, CDSS would likely want to design a mediation program as a full alternative that can formally close a civil rights complaint if successful. This memo describes the insights that we have gathered from research into other agencies’ practices, as well as interviews with California county Civil Rights Coordinators (CRCs), advocates, and mediation experts. 50 A. Remedies First : Informal Resolutions of Claims Many of the CRCs whom we interviewed shared that they try to resolve problems such as a lack of accommodations or need for translation immediately, separate from the complainant’s decision to proceed with the civil rights complaint process. Likewise, disability advocates expressed that, in counties where they have a good relationship with the social services agency, they often negotiate accommodations for their clients through informal discussion with county workers. However, other advocates indicated that workers in the counties where they have the most clients were not amenable to such informal resolution. Expanding and formalizing the practice of remedies-first resolutions of civil rights complaints could help improve outcomes for users. To implement this suggestion, CDSS could direct all CRCs to attempt to fix a complainant’s underlying problem first, regardless of the formal legal merits of their complaint. This approach would include both a process change (to focus on remedies first) and, ideally, an attitude change (to see the user’s needs as paramount). To help CRCs problem-solve, CDSS could provide examples of remedies that CRCs can provide before the civil rights complaint is resolved, such as switching a caseworker, providing an accommodation, or providing an interpreter or translator. However, the only real way to reorient CRCs toward user needs is through comprehensive training. Advocates identified changing the approach and attitude of county workers generally as one of the most important goals for improving their clients’ experience with public benefits in California. In the meantime, directing CRCs to focus on client needs can help to encourage change where it is needed and reinforce existing good practices. To ensure full data for tracking purposes, CDSS should require that all complaints resolved informally be tracked in the main complaint system. To avoid the potential for informal resolution to coerce users into dropping a formal civil rights complaint, CDSS should require that county workers clearly inform users that they can still pursue a formal complaint. If counties comply with CDSS’s directives, informal resolution could help users get the relief they need promptly and efficiently. B. Formal Mediation Incorporating formal mediation into CDSS’s civil rights complaint process would be a far more ambitious project than expanding informal resolution. As a first step to investigating that possibility, this part of the memo describes (1) current mediation practices at the San Francisco Human Rights Commission (HRC) and the California Department of Fair Employment and Housing (DFEH) and (2) some potential advantages and disadvantages of using mediation in CDSS’s civil rights complaint process. The analysis in this section is based on interviews with mediation experts and a disability advocate. 1. Mediation at San Francisco HRC and California DFEH 51 San Francisco HRC and DFEH both use voluntary mediation programs to resolve civil rights complaints, and both leverage community partners, such as law school clinics, to provide mediation services. HRC’s process is the less formal of the two and is used mostly by pro se complainants. Complainants typically challenge housing and employment issues such as denial of a rental or firing. The mediation process begins when a staff screener identifies a case as a good candidate for mediation, either during intake or later in the process. If the complainant agrees, the matter can be mediated in-house by staff trained in mediation or by outside parties such as law school clinics. If mediation resolves the issue, the case is considered closed. If not, traditional investigation proceeds. Remedies include a public finding of discrimination, which has serious consequences for respondents who have city contracts. DFEH’s system is similar to HRC’s, but it includes more formal safeguards, such as complete separation between the investigation and mediation divisions. DFEH’s system is used by represented complainants in addition to pro se complainants. For example, an advocate described doing a lawyer-to-lawyer DFEH mediation in which he negotiated with a county counsel and CDSS staff counsel. He described the process as lengthy but ultimately satisfactory, and he thought the DFEH staff mediators were competent and fair. The complaint concluded with a written agreement for an ongoing disability accommodation. Like HRC, DFEH will proceed with a traditional investigation if mediation fails. If DFEH finds discrimination, its enforcement division can bring suit against the county. Both HRC and DFEH use phone mediation at least some of the time. Advocates described finding phone mediation acceptable as an alternative to in-person meetings. They noted that, although it poses challenges by cutting off nonverbal communication, it can also be preferable for clients who are intimidated by facing the respondent in person. Based on our limited interviews, the mediation systems at HRC and DFEH appear to be working reasonably well from a logistical standpoint. However, we do not know how pro se complainants are faring in these systems. Moreover, information from advocates about delays and the length of mediations indicate that there may be significant delays for users. 2. Incorporating Mediation into CDSS’s Civil Rights Complaint Process A full evaluation of mediation as an alternative track in CDSS’s new civil rights complaint process is beyond the scope of this memo. However, our research has suggested some considerations that CDSS can use as a starting point for evaluating and designing a potential mediation option. The main advantage of mediation, according to a mediation expert, is the control and sense of agency that it allows the parties. She also mentioned that it could potentially speed claim resolution, although our other interviews suggested that might not be true in practice. 52 The most serious disadvantage that several interviewees raised was the potential for coercion given power imbalances between the mediators, the county, and the complainant. A mediation expert noted that mediators are trained to reach agreement first and foremost, so they need special training to avoid inadvertently coercing the complainant’s agreement. She also mentioned a potential for cultural miscommunication. An advocate noted that mediation can potentially be more intrusive than traditional investigations, because the scope of the conversation typically expands beyond a single incident. From the agency perspective, training or hiring mediators would likely require significant expenditures, although phone mediation could reduce costs. A mediation expert indicated that noncoercive mediation requires a government agency to provide counsel, which would represent another significant expense. Finally, mediation is potentially less transparent and more difficult to monitor than traditional investigation. Because both parties agree to any resolution, it is difficult to assess the quality of outcomes for users and may be harder to uncover patterns of disparate outcomes based on protected classes. The decentralized structure of CDSS’s complaints process potentially exacerbates oversight problems. If CDSS decides to pursue a formal ADR option, it should consider a centralized mediation program so that it more directly controls the quality of the user experience. In deciding whether to invest in mediation, CDSS should also consider that the advocates we interviewed seemed to universally prioritize compliance over improving the complaint process in their suggestions. That suggests that adding a mediation system might not be the best way to meet the needs of represented benefits users. However, the experience and priorities of pro se applicants might be different. Pro se applicants are also the most vulnerable to the potential coercive effects of mediation. CDSS should therefore prioritize understanding their needs and interests as it gathers further information to evaluate a mediation option for its complaint process. VI. PROMISING PRACTICES FROM OTHER STATES’ CIVIL RIGHTS COMPLAINT PROCESSES A. MASSACHUSETTS In 2013, Greater Boston Legal Services (GBLS) settled a federal class-action lawsuit (Harper et al. v. Massachusetts Department of Transitional Assistance (DTA)) regarding DTA’s and county offices’ ADA violations. (Appendix at 66-83.) Specifically, the suit centered on disabled clients repeatedly losing or being denied DTA benefits, often because their disabilities prevented them from following DTA processes, and DTA not having a system to accommodating clients with disabilities. (Id. at 62.) These findings were based on the extremely high number of applications that were denied for clients known to be disabled due to procedural issues such as 53 missed appointments, as well as the high number of terminated cases for disabled clients due to procedural reasons. (Id. at 66.) The settlement led to multiple initiatives aimed at decreasing discrimination at county welfare offices, and improving access and quality of services for those with disabilities. These initiatives included: (i) affirmative screening for disability; (ii) on-site client assistance coordinators; (iii) recording information about disabilities and accommodations; (iv) readability of written materials; (v) improvements to RA system; and (vi) auxiliary aids. (Id. at 71-72.) 1. On-the-Ground Client Assistance Coordinators at Local County Welfare Offices As part of its ADA settlement, Massachusetts DTA has 1to 3 ADA coordinators at local county welfare offices. (Id. at 85.) These coordinators assist both clients and county workers, including supervisors. On the client-side, coordinators answer questions and provide immediate assistance in filling out forms. (Id.) Clients can opt to speak with these coordinators rather than a worker about their disability-related issues. (Id.) On the worker-side, coordinators advise workers and supervisors when they have ADA and reasonable accommodation (RA) questions. (Id.) To offset costs, these coordinators are often SNAP supervisors with reduced caseloads. (Id.) According to one Massachusetts advocate, ADA coordinators being located in county offices is critical, as it allows coordinators to more readily assist with individual disputes, as well as identify patterns of non-compliance and address these patterns systematically. 2. Mandatory Affirmative Screenings to Identify Clients with Disability and Facilitate the Accommodations Process Another settlement-related implementation has been mandatory affirmative screening. (Id. at 75-77.) Under the affirmative screening process, workers explain and public benefits applications list the tasks associated with applications, as well as potential accommodations. (Id.) For example, an application will state: There are things DTA will ask you to do in order to get or keep your benefits. If you have a health problem that makes it hard for you to do something DTA asks, you can ask for help. This is called an accommodation. This could be because of a physical or mental or emotional health problem. Some of the things we’ll ask you to do are: Read notices we send and follow instructions in them Fill out forms Come to the office for appointments Get and give us documents to prove whether you can get benefits Tell us about changes in your household\/case Meet deadlines Do you think you might need help with any of these things, or something else, because of a health problem? (Id. at 76.) 54 Affirmative screening is a mandatory policy. (Id. at 75.) County workers are required to orally explain the tasks involved in applications, as well as the availability of reasonable accommodations. (Id. at 75-77.) An affirmative screening statement is included on all applications for public benefits. (Id. at 19-21.) The screening is framed around tasks. (Id. at 76.) That is, rather than immediately requesting persons to identify their disabilities, the statement lists tasks required in the application process. (Id.) This approach enables persons to more easily identify if their disabilities may impair their ability to apply for benefits and also aids in screening for mental disabilities. Moreover, the language of the statement (e.g. This [impaired ability to apply] could be because of a physical or mental or emotional health problem ) helps clarify that accommodations at county offices encompass mental disabilities in addition to physical disabilities. (Id. at 76.) In addition to increasing identification and accommodations of users with disabilities, the screening process also aims to improve data tracking. The more easily counties can report the number of clients with disabilities, the more easily the state can identify areas of need, tailor trainings, and identify patterns of disparate outcomes. 3. Accommodations Chart for County Workers Massachusetts DTA provides guides (in chart form) to county workers listing commonly- needed accommodations for users with disabilities. (Id. at 59-60.) These charts list examples of barriers disabled users encounter in accessing benefits e.g. difficulty meeting deadlines, difficulty coming into the DTA office. (Id.) They then list possible disability-related reasons for these difficulties such as mobility or other physical issue [and\/or] psychiatric issue e.g. anxiety, agoraphobia. (Id.) Lastly, the chart lists corresponding accommodations for these barriers. (Id.) For example, listed accommodations for agoraphobia include handling the case by phone, priority handling of the case to ensure a short waiting time at the office, or a home visit. (Id.) In addition to being remedy-oriented and reader-friendly, the accommodations guides are helpful in improving county workers’ knowledge of mental disabilities and accommodations, as well as improving users’ experiences by streamlining the accommodations process. (Id.) Table C1: Excerpt of Commonly Needed Accommodations For Clients Working with 55 DTA Chart 4. Department of Transitional Assistance (DTA) Monthly Scorecards Massachusetts DTA produces monthly score cards for their program that lists: (i) the average caller wait time; (ii) the number of households on TAFDC; (iii) the number of monthly SNAP and TAFDC applications received; (iv) the percentage of SNAP applications processed timely; (v) the average number of processing days for SNAP applications; and (vi) the average lobby wait time. (Id. at 91-99.) These score cards are publicly available online on the state website. (Id.) The score cards initiative was not required by the settlement but rather the product of a collaboration between legal advocates and the director of the SNAP program in an effort to increase data collection and transparency. 5. General Advice from Massachusetts Advocate According to one Massachusetts advocate, the key to improving the civil rights complaint process is analyzing the current process at every stage from how users learn about complaints to resolutions of such complaints. With respect to spreading awareness, she recommended displaying visible posters in officers, as well as plain language in large font concerning the complaint process of the state website. She also emphasized clearly communicating scaling back as much as possible what is required to file a complaint to reduce barriers to the process. Lastly, a Massachusetts advocate stated that if complainants are going to be contacted by an investigator, then the state must ensure they have accommodations throughout these communications. B. NEW YORK STATE New York State has a complaint form just for ADA complaints. (Id. at 100-101.) This complaint form can likely be used by CDSS as a template for civil rights complaints with respect to its user-friendliness and formatting. The top of the form immediately explains the four ways to file a complaint\u2014phone, fax, email, mail. (Id. at 100.) It also provides plenty of writing space on which a complainant can describe the conduct at issue. (Id. at 100-10\u00a1.) Ways this form can be improved would be expanding the form to cover other kinds of discrimination, providing a checklist of bases of discrimination, and requesting a back-up contact. New York State can be instructive for CDSS’s re-design of the complaint process in not only its complaint form but also its publicly available library of accessible public benefits documents and its publicizing of the appeal process. (Id. at 105.) We describe these measures below: 56 1. The ADA Complaint Form Asks if the Discriminating Conduct is Ongoing The New York State discrimination complaint form asks users if the circumstances of [their] complaint is continuing. (Id. at 100.) This question could be a valuable addition to CDSS’s revised complaint intake form, as it captures users who may struggle pinpointing one date for the conduct at issue because the conduct is ongoing. Moreover, this inquiry better frames the investigation if the conduct is a pattern of repeated civil rights violations, rather than one discrete event. 2. Hiring Third-Party Vendors to Provide Accessible Documents New York advocates secured accessible documents for users (audio, braille, large font) by negotiating with the state to have contracted vendors establish a library of public-benefits documents in accessible formats. According to one national advocate, in a lawsuit concerning ADA non-compliance for public benefits lawsuits, the state did not fight back on the merits but rather the practicability of offering documents in Braille. Specific arguments were that few workers were literate in Braille and that it was too expensive to offer documents in Braille. Ultimately, part of the settlement agreement was to hire third-party vendors to build up a library of accessible documents to accommodate users with disabilities, while at the same time minimizing the cost of converting documents from scratch with each accommodation request. Now, users can (i) click the disability accommodations indicator on the state website, (ii) request documents in alternative forms (audio disc, data disc, large print, Braille), and (iii) either access the documents on-the-spot from the library or request such documents be mailed to them. 3. Notifying Users of Appeals in the Grievance Procedure Notice The state provides instructions online for filing a complaint and in doing so, incorporates language regarding resolutions, accommodations for filing complaints, and appeals for complaints. (Id. at 105-106.) First, the instructions seem more geared to the remedy-first model discussed in our general complaints process memo. Indeed, the instructions state that within 15 calendar days of receiving the complaint, the ADA coordinator will meet with the complainant to discuss the complaint and the possible resolution. (Id.) And the initial determination letter both explains OTDA’s position and offer options for substantive resolution of the complaint. (Id.) Second, the instructions expressly state that the initial determination letter may be in an accessible format and lists such accommodations (e.g., large print, Braille, or audio tape). (Id.) Third, the instructions emphasize that if the ADA Coordinator does not satisfactorily resolve the issue, the complainant may appeal the decision. (Id.) The framing of these instructions emphasizes a remedy-oriented approach in that it requires that the determination letters not just explain OTDA’s position but also list options for substantive resolution[s]. (Id.) Moreover, the investigations call seems to contemplate both discussion of the 57 complaint and possible resolutions. (Id.) With respect to accommodations, the benefits of these instructions are that they provide tangible examples of accommodations that could be provided for the complaint process, albeit these instructions could be improved by expanding this list and emphasizing that it is not an exhaustive list. (Id.) Lastly, the complaint instructions notifying users of appeals rights could also be instructive for CDSS. (Id.) 4. General Advice from New York State Advocate According to one New York advocate, training geared toward the nuts and bolts of what county workers will encounter on the ground is critical to combatting discrimination in county offices. Indeed, this advocate stated that trainings should cover not just ADA basics but also day to day examples of reasonable accommodations that could be provided. The training should cover the following questions: What do accommodations look like? What are the mechanics for users obtaining accommodation? What are the timelines for reasonable accommodation decisions? Additionally, according to one national advocate who specializes in disability-related discrimination in the public benefits space, annual trainings are insufficient. Trainings must be offered throughout the year and integrated into staff and supervisor meetings. One recommendation is to break trainings into modules such as an introduction module for new workers, a reasonable accommodations module, a module on invisible disabilities, etc. C. NEW YORK CITY New York City has a city agency that enforces human rights law called the Commission on Human Rights (CHR). This agency manages a civil rights complaint process that is mostly aimed at private parties but includes some complaints against welfare offices. Users learn of this complaint option primarily through community groups and organizers, as well as legal services providers. Upon receiving a complaint, CHR follows up with the county office and gives them a warning regarding the discriminatory conduct. If the worker continues discriminating after this warning, then the penalties for such conduct escalate. In addition to executing informal measures of resolution such as warnings, CHR also conducts investigations and tracks complaints to assess patterns by office and\/or worker. According to one CHR attorney, CHR has multiple promising practices that could potentially be applied at CDSS. Such practices include: (i) partnering with legal and community organizations to spread knowledge about the complaint process; (ii) triaging complaints to ensure immediate resolutions; (iii) posting a frequently asked questions (FAQ) sheet to help users navigate complaints; and (iv) continuing investigation\/resolutions of discriminatory conduct after a complaint has been dropped. 58 1. Partnerships with Legal Service Providers and Community Groups According to a CHR attorney we interviewed, partnering with legal service providers and community groups has been by the far the most helpful way to spread awareness of the civil rights complaint process. This method has been effective because these groups are the ones that have regular interactions with users and can inform users about the complaint process via their staff and through flyers posted around their offices. Additionally, CHR has been able to train community groups, including independent living centers and P&A groups, about how to file a complaint on behalf of a client and how to alert welfare offices about problematic incidents. CHR also has posted on YouTube a 2-minute how-to guide for filing complaints.22 The video instructions are easy to follow and user-intuitive. Moreover, legal advocates and community organizers can use the video as a resource for explaining the complaint process. 2. Triaging a Complaint : Finding More Immediate Fixes The first thing CHR does with a complaint is to try to find an immediate resolution to the issue. The investigation process takes a long time (years in some cases). To avoid a protracted process for complainants in need of short-term fixes, CHR triages complaints. According to a CHR lawyer, many complainants are individuals who are homeless and often face extremely time- sensitive, physical security issues that need to be deal with immediately. To accommodate these needs, CHR has a 24-hour response time; that is, every complaint gets some type of response within 24 hours by a dedicated response unit. This quick turn-around is one of the strongest features of this process, according to the advocate. Short-term measures include calling the discriminating party and warning them to cease the conduct at issue, as well as calling and working out an accommodation on behalf of a complainant. 3. The Complaint Intake Forms Request an Emergency Contact and How the Complainant Learned of the Complaint Process. Emergency Contact: The complaint intake form requests complainants’ emergency contacts. (Id. at 109.) Given the fact that many complainants are homeless and lack consistent access to a mailbox or phone, we recommend that CDSS include a similar request on the complaint intake form. That way, county workers and\/or the ADA coordinator can more easily reach complainants to follow up on complaints. Rather than requesting an emergency contact, perhaps use the language back-up contact. 22 NYC Human Rights, How To File A Discrimination Complaint in New York City – Explained In 2.5 Minutes, YouTube (June 7, 2017), https:\/\/www.youtube.com\/watch?v=-_iv8Dwfr0w. https:\/\/www.youtube.com\/watch?v=-_iv8Dwfr0w 59 How the Complainants Learned of the Commission: The New York City CHR complaint intake form asks complainants how they became aware of the Commission. (Id. at 109.) This information can be helpful for learning what methods of spreading awareness are most effective. In the early stages of redesigning the complaint process, CDSS should consider asking complainants how they learned of the complaint process on the complaint intake form. Doing so could help CDSS track how complainants most commonly learn about the process, so that CDSS could accordingly dedicate resources toward those methods and further increase awareness of complaints. 4. New York City Provides a User-Friendly Frequently Asked Questions (FAQ) Sheet Online About the Complaint Process. Another promising practice is that New York City provides providing a user-friendly frequently asked questions ( FAQ ) sheet online. (Id. at 108-109). The FAQ sheet includes answers to the following questions: \u25cf What is the first step for filing a complaint? \u25cf I am a lawyer and I would like to file a complaint on behalf of my client: what do I do? \u25cf What happens after the complaint is filed? \u25cf What are the possible results of the investigation? \u25cf Can I file a complaint if I am undocumented? \u25cf Can I remain anonymous while filing a complaint? \u25cf Is my complaint available in the public record? \u25cf Are there any costs or fees connected to filing a complaint with the NYC Commission on Human Rights? \u25cf I need an accommodation for a disability in filing a complaint or attending an \u25cf appointment or hearing, what should I do? The FAQ sheet can serve as a model for a CDSS FAQ sheet. (Id.) The FAQ sheet lists these questions, among others, on which the user can click one of these questions and a drop down answer will appear. (Id.) This format is more user-friendly than listing all the questions and answers online; this way, users can see all the inquiries on one page and then click only on those questions that are applicable to them. Moreover, the questions are both general educational explanations on the process and questions specific to certain complainants e.g. accommodations for complainants with disabilities and interpreters for LEP complainants. (Id.) 60 5. CHR Continues Working on A Discrimination Complaint Even If The Complainant Drops the Complaint. If a complainant does not want to proceed with the complaint process anymore, CHS has the independent power to bring a suit. This authority is useful if CHS sees a pattern of discrimination by a certain party, but no complainants want to continue their complaints. This avenue is also useful if a complainant wants to report discrimination but does not want to be involved further than that e.g. due to fear of retaliation, limited time, fear due to undocumented status, etc. This practice could be instructive for CDSS in addressing patterns of discriminations by certain parties or offices. Based on our review of the complaint spreadsheet, multiple complaints are dropped due to no response from the complainant. If CDSS or individual counties were empowered to continue following up on a complaint, then counties losing touch with an individual complainant would not preclude a more generalized remedy that could reduce discrimination against both the complainants and individuals similarly situated to the complainant. Additionally, this practice would facilitate CDSS addressing systematic instances of discrimination by offices and could help inform trainings. D. OHIO 1. The State Conducts the Investigation and Outsources Specific Tasks to Counties In Ohio, even though benefits and welfare programs are administered at the county level, investigations of civil rights complaints are centralized in a state civil rights department. The state determines the scope of the investigation, conducts interviews, and monitors each step, while outsourcing specific parts of the investigation process (typically administrative-type work) to county CRCs. (Interview with Ohio CRC; see also Appendix at 138.) Specifically, the state sends discrete tasks and\/or questions to CRCs and the CRCs are required to complete these tasks\/respond to these questions within 14 days. (Interview with Ohio CRC.) Such tasks include reviewing internal information such as case notes and application records. (Id.) The CRC then sends their review of these items to the state, who completes the investigation and makes the complaint determination. (Id.) Centralizing investigation and resolution at the state-level helps ensure consistency in the quality of complaint investigation, while offloading some work to counties. 2. Using a Cloud-Based Ticket System to Track Complaints According to an Ohio CRC, her county uses a cloud-based customer relationship management ( CRM ) system that tracks every complaint. This system creates tickets for each 61 complaint that enables her and her team of specialists to monitor the status of complaints and follow up as necessary. 3. Notifying Users of the Complaint Process on Each Benefits Application The last page of every applications for benefits in Ohio notifies users of the civil rights complaint process and instructs them on how to file a complaint. (Id. at 135.) Incorporating this practice in California could help spread awareness of the complaint process. 4. Complaint Specialists at County Offices Ohio has a complaint specialist at every local office. According to an Ohio CRC, these specialists conduct intakes for all types of complaints including civil rights, customer service, and programmatic complaints. One idea would be to train one person at local offices in California to be complaint specialists, on top of their other duties, given the limited budget and staffing capacities in many counties. One consideration, however, is actively working to prevent such a measure from being coercive to address a user being afraid to be candid with a specialist, who is also the co-worker of the party being complained about or a specialist pressuring users not to file a complaint against a coworker. 5. Affirmation Statements At the end of trainings, one CRC requires that county workers sign affirmation statements that confirm they have completed training on LEP accommodations. (Id. at 80.) Workers signing the document confirm that they will provide Limited English Proficiency customers access to all services provided. . . through agency bilingual staff and\/or our contracted provider for interpretation services in a timely manner at no cost to the customer. (Id.) The statement also confirms that they will contact a supervisor if they have any questions or need help providing these services. (Id.) The Ohio CRC said that these affirmation statements help inform county workers of their legally-mandated responsibility regarding LEP accommodations and help holding them accountable to these obligations. E. MISCELLANEOUS PROMISING STATE PRACTICES 1. Washington Anti-Discrimination Notice Washington’s poster notifying users of county offices’ anti-discrimination policy is a solid example of an eye-catching, clear notice that is language-inclusive. (Id. at 57.) In addition to specifying the anti-discrimination policy in numerous languages, the poster briefly describes the non-discrimination policy, informs readers that they can file a civil rights complaint, and provides 62 a phone number to do so. (Id.). One addition we would include is notifying users that they can also pick up a complaint form at the greeter’s desk. 2. North Carolina Complaint Intake Form and Appeals Language North Carolina’s complaint intake form expressly asks complainants if they will need accommodations for communicating with the county about the complaints. (Id. at 122.) It then lists accommodations including Braille, email, language interpreter, TDD, etc. (Id.) This practice of asking if complainants will need accommodations and listing examples could make California’s complaint process more accessible to complainants with disabilities or whose primary language is not English. Moreover, this practice could reduce the number of times counties lose touch with complainants. Recommendations for CDSS would be to: (1) emphasize that the list of accommodations is not exhaustive and provide an other option and (2) incorporate the affirmative screening language from Massachusetts by listing tasks involved in filing complaints and then asking if the complainant foresees any difficulties meeting these tasks due to physical, mental, or emotional health issues. (See id. at 76.) North Carolina also uses the term request for reconsideration for an appeal. (Id. at 116- 117.) This practice seems more informal and accessible to complainants, many of whom may associate appeals with a formal, distant process of which they have had minimal success in other contexts. Additionally, request for reconsideration seems more explanatory of what the appeals process entails than the general term, appeal. In addition to using this language, the state encloses a request for reconsideration form with their determination letters. (Id. at 116.) 3. North Dakota Complaint Form Language: Informing Complainants of Right to Cite More than One Basis of Discrimination and Inclusive List of Bases of Discrimination North Dakota’s complaint intake form instructs complainants to check all [the bases of the discrimination] that apply. (Id. at 126.) This instruction is a promising practice for California’s complaint process, as it captures intersectional forms of discrimination and prevents complainants from having to choose just one basis when the discrimination was actually rooted in multiple bases. Additionally, North Dakota lists status with respect to marriage or public assistance, as a basis of discrimination. (Id.) Multiple advocates cited their clients’ statuses regarding public benefits as a ground for discrimination. Including this checkbox could help capture such instances of discrimination. 63 4. Minnesota Non-Retaliation Notification Minnesota’s Department of Human Services notifies users of its non-retaliation policy (and how to report retaliation) in its instructions for filing a civil rights complaints. (Id. at 146.) Also, Minnesota notifies users that it can provide reasonable accommodations and interpreters for users who want to submit complaints. (Id.) Specifically, the instructions provide that MN DHS can provide a reasonable modification, auxiliary aids\/services, or provide accessible formats for a disability, such as a sign language interpreter, Braille or large print materials. (Id.) VII. UPDATE OF DIVISION 21 REGULATIONS Introduction The focus of the regulations updating project was to ensure that the regulations comport with current federal and state civil rights laws. Attached as Appendix G is a redlined version of Division 21, Nondiscrimination in Federally Assisted Programs, which reflects these updates, incorporating language from relevant statutes, regulations, and law. (Appendix at 170.) This section describes the proposed changes contained in Appendix G and also highlights additional changes that could be adopted to strengthen the effectiveness of the regulations for a variety of stakeholders, including state and county employees, users of CDSS programs, and advocates, with particular attention to users with disabilities and those who are limited-English proficient. Goals and Challenges The primary goals of this aspect of the policy lab were to: (1) update the regulations interpreting and guiding implementation of Division 21 to reflect current law, (2) create cohesion and clarification regarding the overall reach of the regulations, including which government employees are and (3) clarify the meaning and impact of the definitions of what constitutes discrimination. In drafting the updated regulations, we faced challenges in balancing being too specific against not being specific enough, or too general. This aligned with our concerns about the different roles as well as force of regulations and All County letters. In addition, we acted from the understanding that many county workers use the regulations as a guide to what is required within their job duties. Solutions General Updates and Revisions 64 Scope of Division 21 Coverage The Division applies to county welfare departments, and all other agencies receiving federal or state financial assistance through CDSS for the administration of public assistance, food stamps, child support enforcement, fraud investigation and social services. (Section 21-102) This statement of scope should also state that the civil rights obligations apply to the Special Investigation Unit (SIU), specifically, even though fraud investigations are listed. Based upon our interviews, it appears that SIU investigators have failed to comply with Division 21 (such as by refusing to accommodate disabilities and provide interpreters), telling benefits recipients during interviews that civil rights obligations do not apply to them. More Comprehensive Regulations County workers do not consistently understand the scope of federal laws such as the ADA. More comprehensive regulations that make direct references to and incorporate federal regulations and guidances would allow county workers to more faithfully apply the law. Relatedly, providing federal resources such as the ADA Title II handbook23 would provide concrete suggestions to county workers implementing nondiscrimination laws. In the attached redlined regulations document, we have proposed updates to the definition section to track current federal and state law regarding protected classes, definitions of physical and mental disability, definitions and types of accommodations and auxiliary aids, and definitions related to language access. This update also incorporates the updated definitions in the current draft of the 11135 regulations being drafted by the FEHC, paying particular attention to definitions of disability, gender identity and sexual orientation, LEP-related definitions. We have also proposed updates to the description of prohibited discriminatory practices based on the current draft of 1135 regulations. Page Numbers Several interviewees requested that CDSS add page numbers to the Division 21 handbook to make it easier to refer to and locate specific regulations. Currently, the table of contents contains sections but no page numbers. Miscellaneous Issues Related to the Complaint Process Conflicts of Interest When an individual files a complaint against a CRC, some counties are confused about potential conflict of interest issues related to assignment of an employee to conduct investigations. Section 21-203.31 should be clarified to address this confusion. This circumstance is particularly salient 23 https:\/\/www.ada.gov\/taman2.html https:\/\/www.ada.gov\/taman2.html 65 where there are small county offices. If feasible, the regulations could ask that an employee from a different CWD be assigned to conduct an investigation of an allegation of discrimination. Investigation of Complaints Incorporating additional, specific investigation requirements and investigator training guidelines to the regulations or in an All County Letter is essential to improving the quality and effectiveness of county complaint investigations. We recommend that CRCs be required to review the complainant’s entire county record to look for information that points to different treatment or sheds light on the subject of the complaint. In addition, we recommend that CDSS develop training guidelines for core competencies of investigation (e.g., understanding what constitutes a nexus, interviewing skills) in order to ensure consistency and quality of investigations. Contact with Complainant Accounts from advocates and county workers alike indicate that communication between counties and complainants during the complaint process is severely lacking under the current system. Complainants receive little contact and many fall out of touch during the process. We recommend revising Section 21-203.224 to require county workers to contact complainants a minimum number of time and specific intervals. In addition, the regulations should require counties to change their contact practices to include more varied forms and methods of communication in order to ensure complainants are not dismissed from the complaint process unnecessarily. Specifically, we recommend the following for communication with claimants during investigation as well as when communicating resolution notices: a. County workers must attempt to contact the complainant a minimum number of times. b. These efforts should occur at different times of the day and week. c. Communication should be attempted through different methods, beginning with the method the complainant notes as preferable and followed by other methods, such as: text, email, phone call, written mail, contact with designated alternative contact. Time Limit for an Appeal Several advocates mentioned that the 30 day time limit to appeal a CWD decision to CDSS is too short (see Section 21-203.261), especially for individuals who are displaced or whose disabilities impede them from filing an appeal on time. We recommend extending the 30 day deadline to 60 days and recommend including a good-cause clause that allows an individual to appeal after 30 days if the individual shows good cause for missing the 30-day deadline. State Hearing Jurisdiction Division 21, Section 21-203.1 addresses the right of a complainant to request a state hearing involving program issues in addition to discriminatory treatment. We recommend that the language should clarify that administrative law judges (ALJs) have jurisdiction to resolve allegations regarding civil rights violations, limited to their effect on the adjudication of the eligibility, benefits or services issue that is the subject of the state hearing. During a state hearing 66 that challenges a county welfare department’s denial of a benefits application, ALJs have ruled that they lack jurisdiction over civil rights claims, such as reasonable accommodation claims, thus forcing recipients to separately address the issue through the civil rights complaint process when the accommodation itself could have resolved the problems leading to denial. This change would also require modifying the language of Division 22, Section 22-062.5, which requires ALJs to remand complaints that arise during state hearings to CWDs for investigation and resolution. We recommend that this Division 22 language be changed to clarify that in addition to reporting complaints to CWDs, ALJs have jurisdiction to resolve allegations of discrimination and denial of reasonable accommodations as they relate to the determination of eligibility issues that are the subject of state fair hearings. In addition, the current language of Division 21, Section 21-203.1 and Division 22, Section 22- 062.5 give inconsistent instructions regarding the procedure for ALJs remanding civil rights complaints. These sections should be modified to agree with each other. Currently, Division 21, Section 21-203.1 instructs ALJs to remand discrimination complaints to CDSS civil rights bureau (CRB), while Division 22, Section 22-062.5 instruct ALJs to remand complaints to the CWD. We recommend that Division 21, Section 21-203.1 be modified so that complaints are remanded to CWDs for investigation and resolution. Complaint Logs In addition to Division 21’s current minimum requirements for discrimination complaint logs (Section 21-203.2), Ohio and Washington require the complainant’s telephone number and address. CDSS should also require that these logs include the date that the alleged discrimination occurred (currently, regulations require only logging the date a complaint was received). Types of Evidence in Intentional Discrimination Complaints The current draft of the Section 11135 regulations contains detailed guidance regarding the type of evidence and standards of proof necessary to prove intentional discrimination complaints. These standards should be used to develop trainings for county workers who are receiving and investigating discrimination complaints. These standards could also be included in an All County Letter related to intake and investigation of complaints. In particular, trainings should include explanation of the following evidence related standards: 1) While admissions, expressions of bias or other direct evidence of discrimination often are probative of discriminatory purpose or intent, they are not necessary to prove intentional discrimination; 2) Circumstantial evidence may be relied upon to demonstrate intentional discrimination (e.g., information concerning the disproportionate or adverse effect of a practice on a protected class or decisions on comparable matters, departures from normal procedures, and the use of presumptions and comparisons between a protected class and other individuals). 67 Issues Related to Applicants and Recipients with Disabilities Timing of Reasonable Accommodation Claim The regulations should clarify that an individual can make a reasonable accommodation request at any time, including during an administrative hearing, and that an ALJ can adjudicate the issue. In one reported example, an individual made a reasonable accommodation request at a benefits hearing, and the ALJ said that she would not adjudicate the issue because the request was made too late; the judge did not provide a statutory or regulatory basis for this time limit. The following cases from the housing context hold that accommodation requests may be made at any time and we recommend that the same principle should apply to administrative hearings: (1) Douglas v. Kriegsfield Corp., 884 A.2d 1109 (D.C. App. 2005) (see footnote 14 for caselaw support) and (2) Sinisgallo v. Town of Islip Housing Authority, 865 F.Supp.2d 307 (E.D.N.Y. 2012). Screening All Clients for Potential Disabilities at Intake Advocates in other states strongly urged that, in order to comply with the ADA’s nondiscrimination mandate, all individuals interacting with state benefits services be screened to identify whether they need accommodations in their interactions with the agencies. This dovetails with the tracking requirements discussed in the other memorandum regarding the complaint process. We include recommended language in Section 21-109.2. Plain Language Section 21-203.32 provides guidance regarding interviewing a complainant. The information sought in an interview with a complainant in accordance should be gained through questions asked in plain language. Based upon our interviews and feedback from advocates, we are told that, at times, interviewers read verbatim off a form with language from the regulations. This legalistic and generic language can be difficult for complainants to understand, especially without proper context. The regulations can be clarified to encourage a plain language interview and to explain that the regulatory language simply includes categories of information to discuss, not the exact questions to ask. Additionally, we recommend distribution of an All County Letter that includes interview questions in clear, plain language that can be used for interviewing complainants. Pamphlets\/Notice of Rights and Disability Notices of rights should also be accessible to individuals with disabilities. Any auxiliary aid or communication accommodation identified for a person with a disability should also be applied in this context. This may require that benefits workers orally provide information about anti- discrimination rights to most\/all clients similar to the screening process we recommend. Clarity surrounding notice requirements would improve county workers’ knowledge of client’s rights as well. We recommend that an All County Letter provide a script of how to give notice in plain 68 language and explain what it would look like to use an accommodation or auxiliary aid to give notice. Relationships between disability coordinators and county benefits offices Disability Coordinators should be playing a more robust role in ensuring that applicants and recipients with disabilities are able to access benefits. This may be outside the scope of the regulations, but might help alleviate the strain on CRCs while increasing meaningful access for people with disabilities. The parallel process outlined in Section II for users with grievances regarding disability accommodations and auxiliary aids describes the role disability coordinators can play in addressing grievances by users with disabilities. Language Access, Division 21, Section 21-115 Individuals with Limited English Proficiency ( LEP ) The regulations should refer to non-English speaking individuals as individuals with limited English proficiency. 24 We have edited the regulations to include the most comprehensive definition of LEP from the Fair Employment and Housing Council’s draft of changes to Section 1135. The definition for LEP includes non-English speakers. Meaningful Access25 Most model language access plans and federal guidance stress providing LEP individuals with meaningful access to programs and activities. CDSS should incorporate this language into Section 21-115.26 Identifying LEP Individuals Division 21 or an All County Letter should provide guidance on how to identify LEP individuals. For example, the U.S. Department of Veteran Affairs’ 2016 Language Access Plan provides: At the point of first contact with an LEP individual, VA staff should make reasonable efforts to conduct or arrange for an initial assessment of the need for language assistance services and make reasonable efforts to obtain such services if they are needed to effectively communicate with the individual. \u25cb Inquiring if the individual identifies him\/herself as a non-English speaker, LEP individual, or companion thereof; 24 LEP individuals or LEP persons is also appropriate. 25 The definition of meaningful access in the redlined version of Division 21 comes from a April 2015 U.S. Department of Justice Civil Rights Division Language Access Plan Memo, https:\/\/www.justice.gov\/sites\/default\/files\/crt\/legacy\/2015\/05\/04\/crtlap.pdf, at 3. 26 See The Department of Health and Human Services, Language Access Plan, (2013), https:\/\/www.hhs.gov\/sites\/default\/files\/hhs-language-access-plan2013.pdf, at 9 ( HHS agencies must provide oral language assistance services to ensure meaningful access to and an equal opportunity to participate fully in the services, activities, program. . . . ) https:\/\/www.justice.gov\/sites\/default\/files\/crt\/legacy\/2015\/05\/04\/crtlap.pdf https:\/\/www.hhs.gov\/sites\/default\/files\/hhs-language-access-plan2013.pdf 69 \u25cb Inquiring as to the primary language of the individual who identified him\/herself as needing language assistance services; \u25cb Asking a multilingual staff or qualified interpreter to verify an individual’s primary language; \u25cb Observing the individual’s use of an ‘I speak … [language]’ identification card or poster. 27 \u25a0 HHS guidance explains: To be effective, the cards28 . . . must invite the LEP person to identify the language he\/she speaks. This identification must be recorded in the LEP person’s file. 29 Designating the Primary Language Section 21-115 should clarify that LEP applicants\/recipients have the right to designate their primary language, such as with an I speak card. Notice of No Cost The regulations should explain that CWD employees must convey to LEP persons that language assistance is available at no cost. HHS guidance explains: A vital part of a well-functioning compliance program includes having effective methods for notifying LEP persons regarding their right to language assistance and the availability of such assistance free of charge. 30 Similarly, CWDs should provide notice about its language assistance services in languages LEP persons will understand, free of charge. Relatives\/Friends as Interpreters 27 U.S. Department of Veteran Affairs, Language Access Plan, (2016), https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_50 8.pdf, at 7-8. 28 See e.g., Office of Criminal Justice Services, Language Identification Guide: I speak . . . https:\/\/publicsafety.ohio.gov\/links\/CJS0007.pdf. 29 Office for Civil Rights Policy Guidance, 65 Fed. Reg 52762 (2000), Department of Health and Human Services, Office for Civil Rights, Policy Guidance on the Prohibition Against National Origin Discrimination As It Affects Persons With Limited English Proficiency, (August 30, 2000), https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08- 30\/pdf\/00-22140.pdf, at 52768; See Ramsey County Health and Wellness Administrative Division, Comprehensive Civil Rights Plan (2017), https:\/\/www.ramseycounty.us\/sites\/default\/files\/Departments\/Community%20Human%20Services\/Civil%20Rights %20Plan%2009_11_17.pdf, at 18 ( Limited English proficient applicants and recipients can indicate their need for language assistance by pointing to their language on a 12-sided pop-up dome located at any reception or information\/help desk in the Department. The pop-up dome says ‘I need a [specific language] interpreter’ in Hmong, Spanish, Khmer, Russian, Korean, Vietnamese, Arabic, Lao, Somali, Mandarin, Cantonese, and Amharic. ) 30 Office for Civil Rights Policy Guidance, 65 Fed. Reg 52762 (2000), Department of Health and Human Services, Office for Civil Rights, Policy Guidance on the Prohibition Against National Origin Discrimination As It Affects Persons With Limited English Proficiency, (August 30, 2000), https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08- 30\/pdf\/00-22140.pdf, at 52768 https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_508.pdf https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_508.pdf https:\/\/publicsafety.ohio.gov\/links\/CJS0007.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf https:\/\/www.ramseycounty.us\/sites\/default\/files\/Departments\/Community%20Human%20Services\/Civil%20Rights%20Plan%2009_11_17.pdf https:\/\/www.ramseycounty.us\/sites\/default\/files\/Departments\/Community%20Human%20Services\/Civil%20Rights%20Plan%2009_11_17.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf 70 Section 21-115.16 should clarify that CWDs should not encourage the use of friends, family, and minor children as interpreters.31 \u25cb HHS OCR guidance explains: A recipient\/covered entity may expose itself to liability under Title VI if it requires, suggests, or encourages an LEP person to use friends, minor children, or family members as interpreters, as this could compromise the effectiveness of the service. . . . \u25a0 If after a recipient\/covered entity informs an LEP person of the right to free interpreter services, the person declines such services and requests the use of a family member or friend, the recipient\/covered entity may use the family member or friend, if the use of such a person would not compromise the effectiveness of services or violate the LEP person’s confidentiality. \u25a0 The recipient\/covered entity should document the offer and declination in the LEP person’s file. Even if an LEP person elects to use a family member or friend, the recipient\/covered entity should suggest that a trained interpreter sit in on the encounter to ensure accurate interpretation. 32 Translating Vital Documents33 Model language access plans explain that departments should prioritize translating vital documents to ensure program’s most frequently encountered LEP communities have meaningful access to important written information.34 \u25cb What’s Vital? A document will be considered vital if it contains information that is critical for accessing [] program[s] or activities, or is required by law. 35 31 U.S. Department of Veteran Affairs, Language Access Plan, (2016), https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_50 8.pdf, at 7-8. ( Strictly limit and do not encourage the use of friends or family as interpreters. Permit such use only after meeting all of the following conditions: The LEP person declines the right to free interpreter services and requests the use of a family member or friend; The use of such a person will not compromise the effectiveness of services or violate the LEP person’s confidentiality; and The LEP person’s file documents the offer and declination of free interpreter services. ) 32 Office for Civil Rights Policy Guidance, 65 Fed. Reg 52762 (2000), Department of Health and Human Services, Office for Civil Rights, Policy Guidance on the Prohibition Against National Origin Discrimination As It Affects Persons With Limited English Proficiency, (August 30, 2000), https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08- 30\/pdf\/00-22140.pdf, at 52769. 33 Federal Coordination and Compliance Section of U.S. Department of Justice’s Civil Rights Division, Common Language Access Questions, Technical Assistance, and Guidance for Federally Conducted and Federally Assisted Programs, August 2011, https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf, at 10. 34 See LEP.gov, Limited English Proficiency: A Federal Interagency Website, https:\/\/www.lep.gov\/faqs\/faqs.html#OneQ1, at Question 9. 35 Federal Coordination and Compliance Section of U.S. Department of Justice’s Civil Rights Division, Common Language Access Questions, Technical Assistance, and Guidance for Federally Conducted and Federally Assisted Programs, August 2011, https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf, at 8, 12 ( Vital written documents include, but are not limited to, consent and complaint forms; intake and application forms with the potential for important consequences; written notices of rights; notices of denials, losses, or decreases in benefits or services; notice of disciplinary action; signs; and notices advising LEP individuals of free language assistance services. ) https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_508.pdf https:\/\/www.lep.gov\/guidance\/2016_VA_Limited_English_Proficiency_Statement_and_Language_Access_Plan_508.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf https:\/\/www.govinfo.gov\/content\/pkg\/FR-2000-08-30\/pdf\/00-22140.pdf https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf https:\/\/www.lep.gov\/faqs\/faqs.html#OneQ1 https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf 71 \u25cb When to Translate? Vital documents must be translated when a significant number or percentage of the population eligible to be served, or likely to be directly affected by the program\/activity, needs services or information in a language other than English to communicate effectively. 36 \u25cb Safe Harbor: On the federal level, a ‘safe harbor’ provision creates a presumption of compliance with a recipient’s written-translation obligations under Title VI whenever a recipient provides written translations of vital documents for each eligible LEP language group that constitutes five percent or 1,000, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. 37 Typically, according to HHS, persons ‘eligible to be served, or likely to be directly affected, by’ a recipient’s program or activity are those who are served or encountered in the eligible service population. 38 \u25cb Less Frequently Encountered Languages: Federal guidance recommends that agencies put in place processes for handling written communication with LEP individuals in less frequently encountered languages. 39 Bilingual Employee Requirement Section 21-115.1 explains that [a] sufficient number of qualified bilingual employees shall be assigned to public contact positions in each program and\/or location serving a substantial number of non-English-speaking persons. And \”substantial number\” is defined as five percent or more persons of a program\/location who are non-English speaking, deaf, or hearing-impaired. It is unclear whether or how this five percent threshold should be changed.40 However, CDSS should 36 Id. 37 Health Resources & Services Administration, Written Translation https:\/\/www.hrsa.gov\/sites\/default\/files\/hrsa\/grants\/manage\/technicalassistance\/written-translation-LEP.pdf, at 2; see also Office for Civil Rights Policy Guidance, Department of Health and Human Services, 68 Fed. Reg 153 (2003), Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, https:\/\/www.hhs.gov\/civil-rights\/for- individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title- vi\/index.html 38 Office for Civil Rights Policy Guidance, Department of Health and Human Services, 68 Fed. Reg 153 (2003), Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, https:\/\/www.hhs.gov\/civil-rights\/for- individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title- vi\/index.html 39 Federal Coordination and Compliance Section of U.S. Department of Justice’s Civil Rights Division, Common Language Access Questions, Technical Assistance, and Guidance for Federally Conducted and Federally Assisted Programs, August 2011, https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf, at 9. 40 A recently proposed bill in the New York State Assembly proposes using the same five percent threshold for defining a substantial number, https:\/\/assembly.state.ny.us\/leg\/?default_fld=&bn=A06067&term=2019&Summary=Y&Actions=Y&Text=Y&Com mittee%26nbspVotes=Y&Floor%26nbspVotes=Y; San Francisco’s Office of Civic Engagement & Immigrant Affairs defines a substantial number for the purposes of hiring bilingual employees as either 10,000 City residents, or 5 percent of those persons who use the Department’s services, https:\/\/sfgov.org\/oceia\/sites\/default\/files\/FileCenter\/Documents\/12824-SF%20LAO%202015%20FINAL2-edit-3- 26-15.pdf, at C2. https:\/\/www.hrsa.gov\/sites\/default\/files\/hrsa\/grants\/manage\/technicalassistance\/written-translation-LEP.pdf https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.hhs.gov\/civil-rights\/for-individuals\/special-topics\/limited-english-proficiency\/guidance-federal-financial-assistance-recipients-title-vi\/index.html https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf https:\/\/assembly.state.ny.us\/leg\/?default_fld=&bn=A06067&term=2019&Summary=Y&Actions=Y&Text=Y&Committee%26nbspVotes=Y&Floor%26nbspVotes=Y https:\/\/assembly.state.ny.us\/leg\/?default_fld=&bn=A06067&term=2019&Summary=Y&Actions=Y&Text=Y&Committee%26nbspVotes=Y&Floor%26nbspVotes=Y https:\/\/sfgov.org\/oceia\/sites\/default\/files\/FileCenter\/Documents\/12824-SF%20LAO%202015%20FINAL2-edit-3-26-15.pdf https:\/\/sfgov.org\/oceia\/sites\/default\/files\/FileCenter\/Documents\/12824-SF%20LAO%202015%20FINAL2-edit-3-26-15.pdf 72 clarify the meaning of five percent or more persons of a program\/location (emphasis added). In other words, what does of a program and\/or location mean? Providing language assistance services in multiple languages On the federal level, most guidance explains: The extent of an agency’s obligation to provide language assistance services in multiple languages is determined by the agency on a case-by-case basis, looking at the totality of the circumstances in light of four factors: \u25cb the number or proportion of LEP persons served or encountered in the eligible service population; \u25cb the frequency with which LEP individuals come in contact with the program; \u25cb the nature and importance of the program, activity, or service provided by the program; and, \u25cb the resources available to the agency and costs 41 Additional Resources See California State Departments’ Bilingual Services Report.42 The website LEP.gov provides the most comprehensive list of language access resources. 41 Federal Coordination and Compliance Section of U.S. Department of Justice’s Civil Rights Division, Common Language Access Questions, Technical Assistance, and Guidance for Federally Conducted and Federally Assisted Programs, August 2011, https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf, at 10. 42 http:\/\/www.dot.ca.gov\/hq\/bep\/downloads\/pdf\/bspreport42301.pdf https:\/\/www.lep.gov\/resources\/081511_Language_Access_CAQ_TA_Guidance.pdf http:\/\/www.dot.ca.gov\/hq\/bep\/downloads\/pdf\/bspreport42301.pdf APPENDIX TABLE OF CONTENTS APPENDIX A 1 Complaint Process Poster Santa Clara County Welfare Office APPENDIX B 3 Santa Clara County Commonplace Handbook Section 36 APPENDIX C 50 Santa Clara County Disability Screening Guide APPENDIX D 53 Flowchart of Initial Intake and pleading standard APPENDIX E 55 Materials from Other States APPENDIX F 153 Child Protective Services APPENDIX G 170 Division 21 Proposed Changes APPENDIX A Complaint Process Poster: Santa Clara County Welfare Department Office Page 1 Page 2 shelbyhart-armstrong Rectangle APPENDIX B Santa Clara County Commonplace Handbook : Section 36, Civil Rights Page 3 Common-Place Handbook page 36-1 Civil Rights 36. Civil Rights This handbook chapter contains policy on reasonable accommodations and on language access, including procedures for requesting interpreters and translations. Although some of the business processes may be more specific, as is the case for collecting language information at the point of benefits intake, or providing a reasonable accommodations for benefits appointments, the policy contained in this chapter applies to all workers, including Employment Counselors, Social Workers, Clerical, and all other staff who have contact with clients such as contractors. 36.1 Disability and Non-Discrimination Requirements 36.1.1 Non Discrimination Statement The Santa Clara County Social Services Agency (SSA), hereby agrees that it will comply pursuant to Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act; Title II of the Americans with Disabilities Act (ADA); the Age Discrimination Act; Title VII of the Civil Rights Act of 1964; Section 504 of the Rehabilitation Act of 1973 as amended; the Age Discrimination Act of 1975; the Food Stamp Act of 1977 – Section 272.6; the Americans with Disabilities Act of 1990; Section 1557 of the Patient Protection and Affordable Care Act; and other applicable federal and state laws, including Cal. Gov’t. Code 7290 et seq, and Cal. Gov’t. Code 11135 et seq; as well as their implementing regulations, including Parts 80, 84, and 91 of the 45 Code of Federal Regulations (CFR); 7 CFR Part 15, and 28 CFR Part 42. It is the policy of the SSA and the administration of public assistance and social services that programs are nondiscriminatory to the effect that no person shall, because of race, color, national origin, ethnicity, political affiliation, religion, marital status, sex, sexual orientation, gender identity, gender expression, age or disability [Refer to Services to People with Disabilities, page 36-2.], be excluded from participation in or be denied the benefits of, or be otherwise subject to discrimination under any program or activity receiving federal or state assistance; and HEREBY GIVE ASSURANCE THAT it will immediately take any measures necessary to effectuate this agreement. THIS ASSURANCE is given in consideration of, and for the purpose of, obtaining any and all federal and state assistance; and THE SSA HEREBY GIVES ASSURANCE THAT administrative methods and procedures which have the effect Update # 16-23 Revised: 08\/29\/16 Page 4 page 36-2 Common-Place Handbook Civil Rights of subjecting the individuals to discrimination or defeating the objective of the California Department of Social Services (CDSS) Manual of Policies and Procedures (MPP) Chapter 21, is prohibited. BY MAKING THIS ASSURANCE, the SSA agrees to compile data, including data on primary language; maintain records and submit reports as required; permit effective enforcement of the aforementioned laws and regulations; and permit authorized CDSS and\/or federal government personnel, during normal working hours, to review such records, books and accounts as needed to ascertain compliance. If there are any violations of this Assurance, CDSS will have the right to invoke fiscal sanctions or other legal remedies in accordance with California’s Welfare and Institutions Code Section (WIC) Section 10605, or Government Code Sections 11135 – 11139, or any other laws, or the issue may be referred to the appropriate federal agency for further compliance action and enforcement of this Assurance. This Assurance also applies to SSA contractors who help administer SSA programs to clients. The County has an obligation to ensure that contractors administering programs to clients comply with these policies and applicable civil rights laws. For information on filing complaints refer to Section 504\/ADA Coordinator on page 36-13 and Disability\/Special Accommodation Review Form on page 36-14. 36.2 Services to People with Disabilities 36.2.1 Accessibility Pursuant to Section 504c of the Rehabilitation Act, Title II of the ADA, and California Government Code 11135, SSA is required to provide equal access to its programs, services and benefits for qualified applicants and recipients with disabilities. All staff who have client contact, including Eligibility Workers, Employment Counselors, clerical, contractors, etc, are required to provide reasonable accommodations or program modifications, as needed, to assist people with disabilities in any way reasonably possible in order to help them establish eligibility or maintain public benefits so they have equal access to our services. These services should not be provided in a separate setting or different manner; unless doing so is required to ensure that the person with a disability gets services that are as effective as those provided to people without disabilities. Reasonable accommodations should be provided in the most integrated setting possible to meet the client’s needs. Revised: 08\/29\/16 Update # 16-23 Page 5 Common-Place Handbook page 36-3 Civil Rights All SSA staff have an affirmative obligation to determine whether a beneficiary or applicant needs additional assistance due to a disability and to reach out to help them. If staff notice that a beneficiary or applicant is having difficulty doing something, such as filling out forms correctly or making it to appointments on time, staff should ask the client if there is anything that SSA can do to help them, and offer to help them complete the Need Additional Assistance (SCD 2371) form [Refer to Disability\/Special Accommodation Review Form, page 36-14 for additional information]. SSA staff are also obligated to provide reasonable accommodations to family members of clients as needed to allow the client access to SSA services. The definition of a disability is broad and includes people who do not necessarily qualify for disability benefits. A disability includes conditions that limit one or more major life activities. Major life activities are basic activities that most people in the general population can perform with little or no difficulty. Examples of major life activities include: caring for oneself, performing manual tasks, seeing, hearing, thinking, standing, and communicating. Disabilities that impair the life activities include, but are not limited to, hearing impairments or deafness, vision impairments or blindness, learning disabilities including ones that may cause illiteracy, physical impairments such as conditions that limit one’s movement, and mental impairments such as mood disorders. Example: A client walks in to the Agency’s lobby with required forms not filled out and states he\/she needs help completing the forms because he\/she is illiterate as a result of a learning disability and does not understand the forms. The worker will assist the individual to complete the forms at the time of the face-to-face interview. It is the Agency’s policy to provide reasonable accommodations to any individual who identifies a need and requests accommodation for that need. A reasonable accommodation is a change in the agency’s policies or procedures that is necessary to help a person with a disability access our services or the programs we administer. For various reasons, individuals with disabilities might not request special accommodations; however, staff must inquire of the need for such accommodations when the need is obvious or suspected, and if accepted, provide a reasonable accommodation. Staff should make it clear that people are not required to disclose whether they have a disability or what that disability is. When the need for a reasonable accommodation is obvious, staff should provide the reasonable accommodation without requesting documentation proving the need for one. However, during the application process, reasonable accommodations should be provided regardless of whether or not the applicant has documentation proving their need for a reasonable accommodation. When determining what reasonable Update # 16-23 Revised: 08\/29\/16 Page 6 page 36-4 Common-Place Handbook Civil Rights accommodation to provide, SSA must consider what the client expresses will best meet their needs and information from treating medical providers should be given consideration. Example: An 85-year-old woman who appears to have a visual impairment and is walking with the help of a walker, comes in to our office to apply for assistance. Staff should talk with her about what assistance she needs to expedite the application process. Examples of reasonable accommodations that staff can provide include assisting this woman so she does not have to wait in line, helping her complete her forms, and providing any other assistance deemed necessary and reasonable. Example: A CalWORKs applicant with a disability of quadriplegia has his redetermination due this month. Due to his disability, he is unable to complete or sign the forms. His disability and need for a reasonable accommodation are recorded in the case record. The EW may conduct a home visit to ensure applicant meets all program requirements. A mark, name stamp, or verbal assent may be accepted in place of a signature. Example: A General Assistance recipient fails to submit quarterly report or complete the Annual reinvestigation redetermination, and her benefits are going to be discontinued. After she receives her discontinuance notice, she calls and says that she was overwhelmed by the paperwork and forgot to turn it in. A good cause inquiry reveals the client has an anxiety disorder and a learning disability. The EW offers her an extension to finish the paperwork and ask if she needs help completing the forms. 36.2.2 General Tips The following are general communications tips and examples of accommodations described in the proceeding head subsections (which are not exhaustive and can almost always be provided) to be used when communicating and working with people with disabilities: When offering assistance and the person declines, do not insist. If the person accepts, ask how you can best help him or her, and follow his or her directions. If someone with a disability is accompanied by another individual, address the person with a disability directly rather than speaking through the other person. Revised: 08\/29\/16 Update # 16-23 Page 7 Common-Place Handbook page 36-5 Civil Rights Use people-first language: Avoid referring to people by their disability or diagnosis. For instance, do not call a person an epileptic or refer to the blind. Instead, say a person with epilepsy or people who are blind. Note: Sample Reasonable Accommodations and Tips for Communicating with People with Disabilities (SCD 2431) form has been created with Hints and Tips when working with individuals with disabilities and includes sample reasonable accommodations that can be provided. 36.2.3 Visual Impairments Should the worker become aware that an individual who has a visual impairment needs assistance, or requests assistance, to read or have SSA forms completed, the worker must assist as needed to complete the forms. Alternatively, the SSA can offer to provide auxiliary aids that will help the individual to complete the required forms if such aids are available and will meet the individual’s needs. The assistance provided must be effective for the individual. For instance, not all people with vision impairments read Braille. As needed, staff can work with Program staff to provide DEBS Form Library correspondence in larger font and\/or double space (not italicized). Braille When a client requests services in Braille, refer client to Section 504\/ADA Coordinator. [Refer to Section 504\/ADA Coordinator, page 36-13 for contact information.] Communication Tips When greeting a person who has vision loss, identify yourself and others who are with you. Face the person and speak directly to him or her in a normal tone of voice. Let the person know if you will be moving from one place to another or leaving the area. Never pet or otherwise distract a guide dog unless the owner gives you permission. When offering directions, be as specific as possible and describe any obstacles in the path of travel, such as the door is at 2 o’clock. Update # 16-23 Revised: 08\/29\/16 Page 8 page 36-6 Common-Place Handbook Civil Rights 36.2.4 Hearing Impairments Should the worker become aware that an individual who has a hearing impairment needs assistance, or requests assistance, the worker must provide the client the necessary accommodation, such as providing a sign language interpreter, the use of auxiliary aids when available, and other required accommodations [Refer to Interpreter and Translations Services, page 36-24 for language access], or the use of TTY\/ Video Relay: http:\/\/ddtp.cpuc.ca.gov\/default1.aspx?id=1484. The worker is to document in the case file the use of these services. Refer to Chapter 26 of this handbook for community services available for the hearing impaired. [Refer to Confidential Post Office (P.O.) Box Process, page 26-3] for additional information.] Communication Tips Talk the same way as you would with anyone else. Ask the person how he or she prefers to communicate. When speaking through an interpreter, remember the interpreter may lag a few words behind, so pause occasionally to allow him or her time to translate completely and accurately. Talk directly to the person who is deaf or who has difficulty hearing, not to the interpreter. Look directly at the person and speak clearly, naturally and slowly. Do not over-enunciate or exaggerate words. Unless requested, do not raise your voice. To facilitate speech-reading, place yourself facing the light source and keep hands, etc. away from your mouth when speaking. Face the person while you are speaking. 36.2.5 Auxiliary Aids As per Code of Federal Regulations (CFR) Section 102.103, auxiliary aids include but are not limited to services or devices that enable persons with impaired sensory (example: visual or hearing impairment) or speaking skills to have an equal opportunity to participate in, and enjoy the benefits of programs conducted by an agency. Auxiliary aids useful for persons with impaired hearing include telephone handset amplifiers, telephones compatible with hearing aids, Telecommunication devices for deaf persons (TDD’s), interpreters, note takers, written materials, and Revised: 08\/29\/16 Update # 16-23 Page 9 Common-Place Handbook page 36-7 Civil Rights other similar services and devices. For example, auxiliary aids useful for persons with impaired vision include readers, Brailled materials, audio recordings, and other similar services and devices to be used. 36.2.6 Assistance from Third Parties If an applicant or beneficiary requests the assistance of a third party, the third party assistance can be provided as a reasonable accommodation. However, staff cannot assume that every client with special needs has a third party individual who can assist them. It is important to remember limitations associated with third parties. [Refer to Interpreter Services, page 36-27 for additional information.] Sometimes it may be appropriate to provide referrals to other agencies for assistance. Referrals to another organization for assistance in, for example, in completing forms, is not a substitute for the SSA’s responsibility to provide a reasonable accommodation. 36.2.7 Mental, Cognitive, Literacy or Learning Disability Impairments Should the worker become aware of a mental, cognitive, or learning disability, the worker is to allow client to record conversation if requested by client. Other types of accommodations may include scheduling appointment after hours, reading documents out loud, providing oral explanations of written documents and allowing extra time for information to be fully understood, and repeating phrases as needed if worker is not sure if client understood. Other accommodations for clients who have difficulty waiting in office lobbies may include scheduling appointment at client’s preferred time; or for clients sensitive to noise and distractions, use appropriate meetings rooms; offer breaks during longer meetings. Example: Example of a SSA accommodation that was provided: A human trafficking victim who suffers from mental impairment (severe Post Traumatic Stress Disorder and anxiety) prevents her from being around large groups of people. Client applied for TCVAP and requested a reasonable accommodation. The assigned case worker scheduled the interview at an off site location, and since there is no available portable fingerprinting unit, the fingerprinting occurred after hours at the SSA office, during a time when the office is closed to the general public. Update # 16-23 Revised: 08\/29\/16 Page 10 page 36-8 Common-Place Handbook Civil Rights Use highlighters to color-code documents to facilitate client’s understanding. As appropriate, divide complex tasks or instructions into shorter parts, and allow client to complete one at a time. Communication Tips Always respond in a calm and relaxed manner even if the person makes unusual statements. If someone is having trouble understanding you, use language that is concrete, not abstract. Allow time for information to be fully understood. Some people who have processing and mental health disabilities will need more time to process and respond to information. Check for understanding by asking questions such as, Did I explain that clearly? or Do you have any questions about what I told you? 36.2.8 Physical Impairments For applicants who are not able to come to the office in person due to having a physical disability or being housebound, the worker is to accommodate the client by having the appointment in the client’s home. Communication Tips Do not make assumptions about what a person can and cannot do. A person with a physical disability is the best judge of his or her own capabilities. Be aware that some people using wheelchairs may choose to transfer themselves out of their wheelchairs and into an office chair during an interview When speaking to a person in a wheelchair or on crutches for more than a few minutes, sit in a chair. Place yourself at the person’s eye level to facilitate conversation. 36.2.9 Service Animals A service animal is any animal trained to perform a task for an individual with a disability. The animal need not have a harness to be a service animal. Clients cannot be required to provide certification of the service animal. The ADA defines a Revised: 08\/29\/16 Update # 16-23 Page 11 Common-Place Handbook page 36-9 Civil Rights service animal as any guide dog, signal dog, or other animal individually trained to provide assistance to an individual with a disability. If the animal meets this definition, the animal is considered a service animals under the ADA, regardless of whether they have been licensed or certified by a state or local government. Service animals perform some of the functions and tasks that the individual with a disability cannot perform for him or herself. Guide dogs are one type of service animal, which are used by some individuals who are blind. This is the type of service animal with which most people are familiar. But there are service animals that assist persons with other kinds of disabilities in their day-to-day activities. If it is not obvious whether an animal is a service animal, SSA staff can ask if the animal is required because of a disability and what task the animal has been trained to perform. 36.2.10 Reasonable Accommodations Poster A Reasonable Accommodations poster title Need Additional Assistance (SCD 2372) is required to be displayed at office lobbies. The poster informs clients of their rights to notify county staff of a disability such as hearing or speaking impairment; difficulty walking, sitting, or standing for a long time; the need for a sign language interpreter; the need for information in Braille; assistance with completing a form or understanding complicated instructions. Staff is required to work with the client to find a way to help and accommodate the client. The contact information for SSA’s Civil Rights Coordinator is included in the reasonable accommodations office poster. The poster is also available in the DEBS Form’s Library. In addition to the SCD 2372 poster, the Your Rights Under California Welfare Programs is required to be at office lobbies and included in Intake\/RRR packets. [Refer to Intake\/RRR Packets, page 24-1 for additional information.] 36.2.11 Special Accommodation Indicators At the point of contact with the client, SSA staff must identify individuals who may require a reasonable accommodation. This identification is done through the selection of Special Characteristics in CalWIN that are linked to Special Accommodation (SA) indicators, which ensures that SSA staff offer and continue to provide reasonable accommodations without the client having to re-request the accommodation, or the worker having to re-identify the client’s need for an accommodation. When the indicator is entered in the Collect Special Characteristics Detail Accommodation window, a yellow color yield sign indicator is displayed on the window headers (Case, Individual, Application and Contact). The following are the SA indicators: Update # 16-23 Revised: 08\/29\/16 Page 12 page 36-10 Common-Place Handbook Civil Rights Visual Accommodation (Examples: Requires large font, or braille services.) Audio Accommodation (Examples: Requires hearing devices and\/or tape recorders, or is hearing impaired and needs other audio aids.) Physical Accommodation (Examples: Requires client be seen sooner when standing in line using crutches, or needs a home visit, or comes into office with service animal.) Literacy Accommodation (Examples: Due to cognitive, learning disability, requires reading out loud and\/or repeating phrases; or due to inability to read\/write in their primary language, needs an accommodation.) Language Accommodation (Examples: Requires language line or other interpreter services; or due to speech impediment, needs other accommodations.) 36.2.12 Sensitive Information Indicators Similar to how Special Accommodation Indicators are linked to Special Characteristics, Sensitive Information (SI) Indicators are used to help SSA staff identify other individuals with sensitive information. When the indicator is entered, a red color exclamation mark indicator is displayed on the window headers (Case, Individual, Application and Contact). The following are the SI indicators: Domestic Abuse (Used to identify present victims and survivors of Domestic Abuse\/Domestic Violence) Household Awareness (Used to identify potentially disruptive individuals, or to become aware of other sensitive information about the case.) Mental Health Accommodation (Indicator is associated with both Special Accommodation and Sensitive Information, to identify individuals requiring special accommodation, such as offering appropriate meeting rooms for clients sensitive to noises or other distractions) Revised: 08\/29\/16 Update # 16-23 Page 13 Common-Place Handbook page 36-11 Civil Rights Note: When there is no indicator associated to a SA or SI type, a gray color check mark displays on the window headers. 36.2.13 Documentation SSA staff must document in the Maintain Case Comments window, using Special Accomm\/Sensitive Info Case Comments Type, the following information: The client’s disability (if disclosed by the applicant\/recipient, other wise, not required to be disclosed); The client’s requests for special accommodations; Reminder: Under the ADA, for a Reasonable Accommodation, the client only needs to disclose that they are disabled; they are not required to disclose the specific disability. They only need to mention they need an accommodation. For example, they can say, I have a disability that makes it hard for me to read small print. They cannot be asked what the disabling condition is, whether dyslexia, a brain tumor or glaucoma, etc. The specific accommodations provided, such as auxiliary aids, special language needs, and other services to meet the request; When selecting a Sensitive Information Indicator, document pertinent information. [Refer to Special Accommodation Indicators, page 36-9 and Sensitive Information Indicators on page 36-10], for entering Special Indicators in addition to documenting through Case Comment type.] Reminder: CalWIN has functionality to search for case comments by sorting by Case Comments Type. 36.2.14 Staff Training The SSA will: Provide Civil Rights training, and assistance to staff to evaluate practices and policies in order to ensure that discrimination does not occur on the basis of disability. Trainings, including ones in Reasonable Accommodations, are provided to all new staff who will have client contact. Refresher trainings are also provided every two years. Update # 16-23 Revised: 08\/29\/16 Page 14 page 36-12 Common-Place Handbook Civil Rights Ensure that each program is readily accessible to people with disabilities. In choosing available methods for meeting the requirements of this section, the SSA will give priority to those methods that offer programs and activities to people with disabilities in the most integrated setting appropriate. 36.2.15 Physical Facilities In the event that structural modifications are required to provide program accessibility, the agency will conform to accessibility standards approved by the Office of the State Architect, pursuant to Title XXIV of the California Administrative Code. Where structural modifications are not practical, the SSA will provide services at an alternate accessible site. When a face-to-face interview is required, staff is to conduct home visits as part of the Intake business process. Where appropriate, clients also have option for applying on-line and contacting staff by phone as an alternative to coming to an office. As part of the process for alternative site accommodations for Intake Process, the Identification and Intake Record (SCD 41) form, Part II is completed to indicate need for Home Visit. All SSA office sites work to maintain compliance with relevant building codes and statutes. 36.3 Civil Rights Compliance\/Complaints Section 504 of the Rehabilitation Act requires public agencies, such as SSA have a Civil Rights Compliance Plan. 36.3.1 General Client Complaints General client complaints that are related to business process or program policy are directed to an ESI management analyst who coordinates with district offices, as needed, to address the complaint. For general community related complaints\/inquiries [Refer to Complaints \/ Inquiries, page 39-1 for additional information.] Revised: 08\/29\/16 Update # 16-23 Page 15 Common-Place Handbook page 36-13 Civil Rights If the complaint is related to Civil Rights, refer to sections on state complaint and Section 504\/ADA Coordinator procedures. 36.3.2 State Complaint Procedures In addition to filing a complaint directly with the County’s Civil Rights Coordinator, the client may also contact CDSS to file a discrimination complaint. The CDSS can be reached at (916) 654-2107, or toll free at 1-866-741-6241, or emailed at [email protected], or through TDD\/TYY at (916) 654-2098 or 1-800-688-4486 for collect calls, or via the relay services operator at 1-800-735-2929. Information pertaining to above contact information is available in the district office lobby posters: Need Additional Assistance and Everyone is Different But Equal Under the Law. SSA Staff are to direct client to above contact phone numbers when client expresses request to file a complaint. Clients may also file a discrimination complaint at a district office. The SSA staff taking the complaint is required to take the client’s information and forward the information to the County’s Civil Rights Coordinator. 36.3.3 Section 504\/ADA Coordinator The coordinator’s role is to oversee ADA compliance and provide resolution to grievances, assist in handling individual’s cases and address systemic problems. The ADA coordinator has authority to make decisions on grievances. All complaints of discrimination are investigated. Complaints can be filed orally or in writing in a County office or directly with the Civil Rights Coordinator. Oral complaints are to be documented in writing. Regardless of their origin, all discrimination complaints are referred to the Civil Rights Coordinator who evaluates them for a link to a civil rights protection. Complaints that are linked to civil rights protections are investigated according to Div. 21 guidelines. If no link, they are referred back to the department for resolution. Note: If the accommodation was denied, the worker is to notify Civil Rights\/ADA Coordinator of denial and inform client to contact Civil Rights\/ADA Coordinator if they disagree with the denial. The coordinator is based in the Social Services Equal Opportunity\/Civil Rights Office and reachable at (408) 755-7298. The Equal Opportunity\/Civil Rights Office is located at 333 West Julian Street, San Jose, Building 1 on the 2nd Floor. To file a complaint of discrimination, clients are to contact the Civil Rights Coordinator. Upon receipt of the complaint, the Civil Rights Coordinator will follow up with the client. Update # 16-23 Revised: 08\/29\/16 Page 16 page 36-14 Common-Place Handbook Civil Rights This follow up may include scheduling a face-to-face appointment with the client and\/or scheduling an office visit to make a determination on whether an investigation is necessary. If appropriate, a findings report is submitted to the California Department of Social Services and a copy is provided to the client. The complainant receives a Letter of Findings at the conclusion of the investigation. The letter summarizes the allegation and the evidence in relation to the allegations that led to the determination. 36.3.4 Disability\/Special Accommodation Review Form A review form titled Need Additional Assistance (SCD 2371) for special accommodations is to be used by the EW\/Worker to obtain information pertaining to any additional help requested by the client due to a disability (physical, mental\/emotional or learning), or other type of accommodation. The form functions as a triage form, soliciting responses to various questions. It should be made clear to clients that whether or not they disclose a disability is voluntary and they can always choose to disclose a disability, or request for a special accommodation, at a later time. If client discloses a disability during any first contact with any employee, the employee must immediately share the information with appropriate staff, who can take steps to explore a reasonable accommodation. The SCD 2371 is available on the DEBS Form’s Library. 36.3.5 SCD 2371 Process Each district office lobby will have a Need Additional Assistance poster (SCD 2372) which would prompt the applicant\/client to inform the clerical of his\/her disability in order to receive some form of accommodation. In addition to the Poster, the workflow below is the process to follow for identifying clients who require a Reasonable Accommodation: Who Action Clerical If the applicant… Then… Has a visible disability, Follows current district office process. States he\/she has a disability, or requires a special accommodation, Issues SCD 2371 to the client, or attaches SCD 2371 with client’s application forms. Follows current district office business process for assigning applications to Eligibility Workers (EWs). Revised: 08\/29\/16 Update # 16-23 Page 17 Common-Place Handbook page 36-15 Civil Rights EW\/ Worker Receives application forms If SCD 2371 form… Then… Is attached to application forms and\/or MEDS screens, Completes SCD 2371 form. Selects one of the following Special Accommodations Indicators in CalWIN: Visual Accommodation Audio Accommodation Physical Accommodation Literacy Accommodation Language Accommodation Mental Health Accommodation Documents in Maintain Case Comments using case comment Type – Special Accomm\/Sensitive Info. Follows current district office business process for the application, or process. Is not attached to application forms and\/or MEDS screens, Asks applicant – Do you have a disability (physical, mental\/emotional, or learning), or need a special language, or other accommodation that makes it difficult for you to do anything we might ask you to do? NOTE: For a 2-parent household, a SCD 2371 form would be needed for each parent. EW cont.\/ EC If client says… Then… Yes, Completes SCD 2371 form. Selects a Special Accommodations Indicators. Documents in Maintain Case Comments using case comment Type – Special Accomm\/Sensitive Info. Follows current district office business process for the application. No, Signs the SCD 2371 form and asks the client to sign the form. Provides a copy of the SCD 2371 form to the client. Documents in Maintain Case Comments using case comment Type – Special Accomm\/Sensitive Info. Follows current district office business process for the application. Inform the client that she or he can request an accommodation at any point in the future, including with continuing EW, or another worker. Reasonable Accommodations must be provided on an ongoing basis. Who Action Update # 16-23 Revised: 08\/29\/16 Page 18 page 36-16 Common-Place Handbook Civil Rights 36.3.6 Special Accommodations Request Process Requests for a Reasonable Accommodations can almost always be provided to the client. All requests must be approved or denied within 5 working days. The workflow below is the process to follow by all SSA staff for approving or denying requests for reasonable accommodations: Step Who Action Eligibility Worker\/EC\/ Worker Receives request for a Reasonable Accommodation. Discusses request with Supervisor, as needed. If Request is… Then… Approved, Informs client that request was approved. Adds CalWIN Special Accommodations Indicator, and updates Status to Approved. Documents in Maintain Case Comments the accommodation. Eligibility Worker\/EC\/ Worker Supervisor\/ Consults with ADA Coordinator if believes that request should be denied, or if not sure the request can be provided. If Request is… Then… Eligibility Worker\/EC Approved, Informs client that request was approved. Adds CalWIN Special Accommodations Indicator, and updates Status to Approved. Documents in Maintain Case Comments the accommodation. Eligibility Worker\/EC\/ Worker Supervisor Denied completely, or in part, Provides written denial to client. Informs client of right to contact ADA coordinator. Documents in Maintain Case Comments and submits written denial to IDM. 36.3.7 CalWIN – Other Sub Systems SSA Staff have access to enter Reasonable Accommodation and Sensitive Information indicators types via other CalWIN sub-systems (Employment Services, Application Registration, and Traffic Log), by double clicking the window header color indicator. In addition to the SCD 2371 process used at Application, the 1. 2. 3. 4. Revised: 08\/29\/16 Update # 16-23 Page 19 Common-Place Handbook page 36-17 Civil Rights indicator(s) is\/are to be entered through these sub-systems at the point of contact with client, when the need is identified. In Employment Services, the need, or request for accommodation may also be identified via the development of the Welfare-to-Work Plan Activity Assignment (WTW 2), and or the Online California Appraisal Tool (OCAT). [Refer to Special Accommodation Indicators, page 36-9.] 36.4 Language Access Needs 36.4.1 County Policy Per Section 21-115, Santa Clara County has a legal requirement to provide language-appropriate services to individuals with limited English proficiency and to individuals with disabilities. Further, the county has policy on providing oral interpretation services and written document translations for clients with limited English proficiency. [Refer to Interpreter Services, page 36-27 for policy on the use of interpreters] and [Refer to Document Translation Services, page 36-36 for policy on form translations.] County specific client correspondence is available in translated languages spoken by five percent (5%) or more of the population served by DEBS or for Medi-Cal threshold languages as identified by DHCS. SSA provides translations that are available from the state. When state or county-specific correspondence is not available in the client’s language of preference, a GEN 1365 is to be included with the English correspondence. The GEN 1365 informs the client to contact their worker if they do not understand the information on their correspondence and that they have the right to interpreter services provided by the county at no cost to the client. District Offices must place signs near any reception desk or window and other initial points of contact that advise Limited English Proficient (LEP) applicants and beneficiaries of their right to access free oral or interpreter services in their primary language and\/or translated documents. All such signs must be clearly visible for clients to read. Some useful tools include posters stating that free interpreter services and translated material will be provided in many languages and language identification brochures are available from telephone language line services. Update # 16-23 Revised: 08\/29\/16 Page 20 page 36-18 Common-Place Handbook Civil Rights Office Lobby Poster The poster titled, Everyone is Different But Equal Under the Law must be in all district offices posted in visible location for clients. Staffing Needs Reports DEBS generates quarterly statistical reports on public assistance families, which includes information on individual language demographics. These reports are used to assist with language staffing needs. 36.4.2 State Law Under the California Dymally-Alatorre Bilingual Services Act, Government Code Section 7290 et seq., accessible at http:\/\/www.spb.ca.gov\/bilingual\/dymallyact.htm, a local public office or facility is required to translate materials explaining their services into languages spoken by five percent or more of the population they serve and to employ a sufficient number of bilingual persons to ensure access to Limited English Proficient individuals. These requirements are available within CDSS MPP Chapter 21. Under Welf. & Inst. Code 15926, all forms and notices developed pursuant to this section shall be developed using plain language and shall be provided in a manner that affords meaningful access to limited-English-proficient individuals, in accordance with applicable state and federal law, and at a minimum, provided in the same threshold languages as required for Medi-Cal managed care plans. The state Department of Health Care Services (DHCS) also requires the counties to translate certain forms, notices, and\/or other written materials that must be used if provided by DHCS for those preferring non-English materials. 36.4.3 Federal Law Federal law 42 U.S. C. & 2000(d) require that Santa Clara County Social Services Agency (SCCSSA) provide meaningful access to Limited English Proficiency (LEP) persons, which includes language assistance services, such as oral interpreter services and translation or written service, including translation of documents and forms to all LEP clients, regardless of how many LEP clients reside in the SCCSSA services area. Federal law, Reg. 47311-23 (August 8, 2003) prohibits discrimination based on national origin, including as it affects LEP individuals. Revised: 08\/29\/16 Update # 16-23 Page 21 Common-Place Handbook page 36-19 Civil Rights 36.4.4 We Speak Your Language (SCD 2334) The SCD 2334 is to be readily available for non-English speaking individuals who are not able to communicate in English the purpose of the visit. If the individual approaches the front desk, and front desk staff is unable to communicate with or understand the visitor, the front desk is to provide the visitor with the SCD 2334 so the visitor can point to his or her language. If there is no staff member available to provide interpreter services in the visitor’s language, front desk staff is to request interpreter services via the designated telephone Language Line. 36.5 Required Form – SCD 1264 Although the language designation on the Language Survey – Interpreter\/ Translation Request (SCD 1264) must to be selected and completed by the client to meet Federal Law and Civil Rights Mandates, the EW should assist the beneficiary and answer any questions about it. The information from the SCD 1264 is used to input the client’s primary language into the CalWIN Data Collection System. [Refer to Translated Forms, page 36-44 for language listing.] The SCD 1264 is required at: Intake At each application. Continuing When there is no SCD 1264 on file, Whenever the caretaker\/relative changes, When the client requests a change, and When the client has been active, without interruption, for three (3) consecutive years, a new SCD 1264 must be completed during the Redetermination\/ Recertification conducted in the third year. Note: The county may not complete the form on behalf of the client, unless the client is unable to write because of illiteracy or disability. Update # 16-23 Revised: 08\/29\/16 Page 22 page 36-20 Common-Place Handbook Civil Rights 36.5.1 Processing the SCD 1264 The SCD 1264 is completed at the initial Benefits Intake appointment by clerical, but the client must complete the language section. The Eligibility Worker is responsible for processing the SCD 1264 in continuing. When processing the SCD 1264, the EW\/Clerical must: Determine the primary oral and written language of the client. Print the appropriate language version of the SCD 1264 off of the intranet. Sign and date the form with the client. Ensure the appropriate language is selected from the drop down language menu in CalWIN. Scan the SCD 1264 into the IDM system under F1 – Application. Determine if other language services are required: What type of language services does the applicant\/recipient require (i.e., bilingual staff, interpreter, use of own interpreter family member, or friend, translated materials, etc.). [Refer to Clients Own Interpreter Arrives, page 36-30 because the use of 3rd party interpreters should be discouraged.] Check appropriate box that pertains to language preference used on written communication and forms. Sign and date the form with the client and interpreter, if an interpreter is used. Document thoroughly on the Maintain Case Comments window how language assistance, both interpreter and translation services were provided to the client. When the client has a unique language need, such for example, understands oral Vietnamese, but is not be able to read it (written) and does not understand English, the case is coded Vietnamese with a case comment clearly documenting that client does not read Vietnamese and does not understand English but understand Vietnamese (oral). The client correspondence would be issued in Vietnamese but the bilingual worker is required to explain the Vietnamese form to client. Revised: 08\/29\/16 Update # 16-23 Page 23 Common-Place Handbook page 36-21 Civil Rights 36.5.2 Mail-In Process When the (re)application is completed via the mail-in process or by another entity, and the SCD 1264 is not included with the paperwork, the EW must: Review any other documents to determine the client’s primary oral and written language. Contact the client and confirm the client’s preferred oral and written language. Sign the SCD 1264 indicating the client’s oral and written preference. Forward the SCD 1264 to the client for signature. Document Maintain Case Comments in CalWIN indicating the client’s preferred oral and written language. Submit the EW signed copy of the SCD 1264 to clerical to be scanned into IDM. Note: The case may be transferred out of intake and\/or continuing pending the return of the original SCD 1264. 36.6 Special Language Access Instructions Benefits staff is to use the following guidelines for special language assistance situations: IF the client… THEN code the case… Is bilingual and declares English as a primary language, English speaking. Declares English as his\/her language, and based on experience, the EW believes that the client cannot understand English, In the language the client believes he\/she needs to use to communicate effectively. And Request an interpreter, if appropriate. Document on the Maintain Case Comments window what action is being taken and why. Update # 16-23 Revised: 08\/29\/16 Page 24 page 36-22 Common-Place Handbook Civil Rights At Intake, Foster Care EWs must review documentation provided by DFCS or Juvenile Probation Department (JPD) (such as DFCS Intake Form SCZ 203) to determine the common language of both parent(s)\/guardian(s) and code the case appropriately. Note: The Form\/NOA language field in the Collect Case Summary Detail window in CalWIN will reflect the provider’s language as entered by Intake EW. The referring agency is responsible for noting the language on documentation. If a language is not specified on the documentation, code the case as English. When there are two common languages (English being one of those) code the case as English. Example: If one parent\/guardian speaks Spanish only and the other speaks both Spanish and English, code the case Spanish as this is the common language between the parents. Example: If both parents\/guardians speak Vietnamese and English, the case will be coded as English. In Continuing, the worker will change the Form\/NOA language field from the Collect Case Summary Detail window in CalWIN if\/when the Social Worker (SW) or Probation Officer (PO) provides information that the language need of the provider has changed. This information may be indicated on the Foster Child’s Data Record and AFDC-FC Certification form SOC 158A. Cases will be coded as English if the SOC 158A indicates the placement is a facility or Foster Family Agency. Declares a language other than English as his\/her language, Based on the client’s declaration of his\/her language. And Request an interpreter, if appropriate. Document on the Maintain Case Comments window the method used to provide language access services. IF the client… THEN code the case… Revised: 08\/29\/16 Update # 16-23 Page 25 Common-Place Handbook page 36-23 Civil Rights Note: In a situation that differs from the scenarios above the worker will speak to their supervisor for direction. 36.6.1 Bilingual Certification Bilingual staff must document on the Maintain Case Comments window that they have been certified by county when servicing clients who do not understand English. 36.6.2 Your Rights Under California Welfare Programs (PUB 13) REMINDER: Eligibility Workers must give the PUB 13 to ALL clients at Intake and annually at each Reinvestigation\/Redetermination\/Recertification (RRR). The PUB 13 includes information on client’s rights to language access services, including oral and interpreter services and written or translation services which county welfare departments are to provide. The PUB 13 must also be available at district office lobbies. 36.6.3 Special Indicators for Language Needs Accommodations One or more of the following CalWIN Case Indicators must be entered to identify clients who require language accommodations as follows: Illiterate (Is not able to read and write well in their own primary language and may need disability accommodations). Note: Illiteracy may be related to a learning disability or other disability, and people who have been identified as unable to read and\/or write may need reasonable accommodations of disabilities in addition to language assistance. [Refer to Services to People with Disabilities, page 36-2]. Hearing Impaired (Communication may be more difficult because the person has difficulty hearing in his\/her own primary language, and may need disability accommodations in addition to translation services). [Refer to Services to People with Disabilities, page 36-2.] Update # 16-23 Revised: 08\/29\/16 Page 26 page 36-24 Common-Place Handbook Civil Rights Speech Impediment (Communication may be more difficult because the person has difficulty speaking in his\/her primary language and may need disability accommodations in addition to interpretation or translation services). [Refer to Services to People with Disabilities, page 36-2.] Note: The above Special Indicators are used in conjunction with the appropriate language code inputted into CalWIN. For clients who are Limited English Proficient, the EW must code the case with the appropriate language as identified through the SCD 1264. 36.7 Interpreter and Translations Services County policy on form’s translations and interpreter services is based on state and federal law. SSA contracts with various community agencies and individuals to provide interpreter services in most languages. Through the Language Line and bilingual staff, SSA provides interpreter services to all clients in their language of preference. Interpreters provided by contract agencies have been language-certified and advised of the regulations regarding client confidentiality. Workers may request interpreter services after it has been determined that the case cannot be assigned to existing certified bilingual staff with the required language skill. 36.7.1 Language Requirement Civil Rights regulations mandate that counties obtain and document specific information regarding the client’s preferred language. Completion of the Language Survey – Interpreter\/Translation Request (SCD 1264) form meets the client’s language declaration requirement. The language selection page and the signature page of the SCD 1264 must be scanned into the IDM system. When the forms are available in the client’s preferred language, the worker must document whether the client accepts or refuses the forms available in their preferred language. Revised: 08\/29\/16 Update # 16-23 Page 27 Common-Place Handbook page 36-25 Civil Rights 36.8 Other Language Forms and Notices The Manual of Policies and Procedures (MPP) requires that if an individual has requested written communications in his or her primary language and the CDSS has made the form or notice available in that language, then the CDSS translation must be provided to the individual, even if the translation is not available through the county’s automated system (i.e. CalWIN). The California Department of Health Services (CDHS) also requires that if an individual has requested written communications in his or her primary language and the CDHS has made the form or notice available in that language, then the CDHS translation must be provided to the individual, even if the translation is not available through the county’s automated system (i.e. CalWIN). The requirement to provide CDSS\/CDHS translated forms must be met, either by automated or manual means. When the CalWIN system incorrectly issues a form or notice in English, rather than in the applicants\/recipients primary language, then the worker must manually issue the form or notice in the applicants\/recipients primary language using shelf stock and\/or the DEBS on-line Form’s Library. If a translated form or notice contains spaces in which information is inserted that is unique to the applicant\/recipient, the inserted information must be in the applicant\/recipient’s primary language. If a form or notice is not available in a client’s preferred language, the client has a right to request and receive an oral translation of the notice. CalWIN is programmed to issue the GEN 1365 for cases where translations are not available. When manual forms and notices are sent, SSA must notify applicants and beneficiaries of that right by providing the Notice of Language Services (GEN 1365) when translations are not available. 36.8.1 Semi-Annual Report (SAR 7) A commonly used periodic report that is available in languages other than English is the Semi-Annual Report (SAR) 7. The SAR 7 can be generated through CalWIN currently in the following languages: English Spanish Vietnamese Chinese Update # 16-23 Revised: 08\/29\/16 Page 28 page 36-26 Common-Place Handbook Civil Rights Russian The SAR 7 is available from CDSS in the following languages at this time: English Spanish Vietnamese Chinese Russian Arabic Hmong Japanese Korean Lao Mien Portuguese Tagalog Ukrainian Punjabi Therefore, when the SAR 7 is not available in CalWIN in the client’s language of preference but the state version is available, the state translated version is to be used. One Mid-Year SAR 7 in the client’s language of preference (with the respective months and years entered) must be explained and provided at Intake and RRR to those clients coded as speaking languages where the correspondence is not available in CalWIN. Document on the Maintain Case Comments window that these forms have been provided to the client. The SAR 7 is located in the DEBS online Form’s Library. 36.8.2 Midyear Status Report (MC 176 S) The MC 176S can be generated through CalWIN currently in the following languages: English Spanish Vietnamese Chinese Farsi Hmong Laotian Russian Armenian Korean Revised: 08\/29\/16 Update # 16-23 Page 29 Common-Place Handbook page 36-27 Civil Rights Tagalog. The Mid-Year Status Report (MC 176 S) is available from CDHS in the following languages at this time: English Spanish Vietnamese Chinese Russian Armenian Korean Farsi Hmong Arabic Tagalog Khmer\/Cambodian. Therefore, a Mid-Year Status report (with the REPORT month and year entered) must be provided at Intake and RRR to those clients coded as speaking languages that are not available in CalWIN. Document on the Maintain Case Comments window that these forms have been provided to the client. The MC 176 S is located in the DEBS online Form’s Library. Online forms are to be printed on an as needed basis ONLY. 36.9 Interpreter Services Staff must inform an applicant\/recipient providing his or her own interpreter of potential problems of ineffective communication caused by using his or her own interpreter. Interpreters must be offered by the agency free of cost to the client, if the individual needs interpreter services. 36.9.1 Interpreter Services Requirement The CDSS Manual of Policies and Procedures (MPP) Chapter 21 regulations require: The provision of meaningful and effective language services to all applicants\/recipients in their primary language without undue delay. Update # 16-23 Revised: 08\/29\/16 Page 30 page 36-28 Common-Place Handbook Civil Rights The county to offer and provide an interpreter at EACH client contact once the need for an interpreter is identified by the county or the client. That applicants\/recipients NOT be compelled or encouraged to use their own interpreters and should not use minors to interpret, unless under extenuating circumstances. [Refer to Use of Minors as Interpreters, page 36-31 for additional information.] That substantive, program-related conversations with the applicant\/recipient shall NOT be conducted until qualified interpretive services are available. 36.9.2 Interpreter Services Documentation The method(s) used to document compliance requirements (State Chapter 21) must be noted on the Maintain Case Comments window of CalWIN. In order to meet the Federal and State Law and Civil Rights Mandates, documentation of language assistance services provided must be thoroughly documented on the Maintain Case Comments window in CalWIN. Cultural competency is very important for accurate understanding. Using an interpreter who speaks a different dialect of the language may lead to misunderstandings. To mitigate this, the worker shall double check that the client understands the interpreter before proceeding with the interview. The state requires the following information be documented in the case record for each contact with the applicant\/recipient: The applicant\/recipient was offered free interpretive services. Who provided the interpretive services such as: The assigned case worker is bilingual, An outside contracted interpreter (Name) acted as the interpreter, The client provided his\/her own interpreter (Name), A volunteer interpreter (Name) was used, Another employee (Name) acted as the interpreter. A minor temporarily acted as an interpreter due to extenuating circumstances, with an explanation of those circumstances. [Refer to Use of Minors as Interpreters, page 36-31 for requirements and limitations.] Revised: 08\/29\/16 Update # 16-23 Page 31 Common-Place Handbook page 36-29 Civil Rights Documentation that clients denied the county’s offer of interpreter service when offered and beneficiary insisted on providing their own interpreter, and\/or if the Social Services Agency needs to provide one for them throughout the interactive process. That the applicant\/recipient was informed of potential problems of using his or her own interpreter including: The possibility of ineffective communication, Inaccurate interpretations, and The need to disclose private information to the interpreter. Note: If staff determines that their own interpreter is not competent to provide quality and accurate interpretations, and\/or issues of confidentiality, privacy, or conflict of interest arise, staff shall provide competent interpreter services and allow the family member or friend to remain as a patient advocate. County-provided interpretive services were offered when the applicant\/recipient provided interpreter is not available. The applicant\/recipient was informed of his\/her right to accept county-provided interpretive services at any time, even when a client provided interpreter is present. The County provided interpretive services even where an applicant\/recipient-provided interpreter is present. 36.9.3 Interpreter Release of Information In order to meet the confidentiality requirements for applicants\/recipients when individuals other than agency employees are used as interpreters, a Certification of Confidentiality-Non-SSA Interpreter & Authorization to Release Information (SCD 2362) must be obtained. The case record must be thoroughly documented on the Maintain Case Comments window, and indicated that a release form was completed and signed. A copy must be scanned into the IDM system under the F2 – CASE VERIF\/CHILD SUPPORT tab. Note: The SCD 2362 does not need to be completed when the Language Line or Contract staff are used. However, documentation that any interpreter services were used needs to be entered into the Maintain Case Comments window. Update # 16-23 Revised: 08\/29\/16 Page 32 page 36-30 Common-Place Handbook Civil Rights 36.9.4 Responsibility for Scheduling Interpreter services will be requested by the person who is actually scheduling the appointment. (i.e., The receptionist for the first intake appointment, or the worker for any other appointments). 36.9.5 Clients Own Interpreter Arrives If the client arrives with his or her own interpreter, SSA should advise client that agency provides certified language interpreters. [Refer to Use of Minors as Interpreters, page 36-31, and Interpreter Release of Information, page 36-29 and The Language Line (Interpreter Services), page 36-33 for additional information when using own interpreter.] Note: Staff are to follow all other procedures as if an interpreter had been requested, such as inputting CalWIN Case Comments and\/or Special Indicators. 36.9.6 Phone Call Interpretations If the worker calls an interpreter and the interpreter calls the client, the Interpreter\/Translator Services – Detailed Service Record (SC1257) must be completed for the telephone call and a copy sent to the interpreter. [Refer to Requesting Interpreter Services, page 36-30.] 36.9.7 Requesting Interpreter Services Use the following guide to request interpreter\/translator services: Who Step Action Worker or Receptionist 1. Determines interpreter\/translator services are required. 2. Completes top portion of Interpreter\/Translator Services – Detailed Service Record (SC 1257) form. 3. Gives SC 1257 to Supervisor for approval\/denial. Supervisor or Approving Authority 1. If approved, signs in the Approver’s box. 2. Returns SC 1257 to Worker\/receptionist. Revised: 08\/29\/16 Update # 16-23 Page 33 Common-Place Handbook page 36-31 Civil Rights 36.9.8 Use of Minors as Interpreters It is Santa Clara County’s policy that the use of minors is PROHIBITED, unless used under extenuating circumstances. If a minor is used for interpreter services, this must be thoroughly documented on the Maintain Case Comment window and the reason why a minor was used. Worker or Receptionist 1. Phones appropriate agency or individual interpreter. The official Interpreter list is available on the SSA intranet website under Policies and Procedures -In the Community section: http:\/\/intranet.ssa.co.santa-clara.ca.us\/main\/policies\/interpreters.pdf 2. Schedules appointment and advises the interpreter of the reporting location. Receptionist: Advises the interpreter to check in at the Reception Desk upon arrival. NOTE: If the telephone number for an interpreter has changed or is now disconnected, please notify the Equal Opportunity\/Civil Rights Office, at (408) 755-7298. 3. Records the Interpreter\/Translator’s Name and Organization Name on the appropriate lines on the form. Enter the appointment date and times in the Approver’s box. Interpreter 1. Comes in for scheduled appointment. If intake appointment, see special procedure below [Refer to Use of Minors as Interpreters, page 36-31.] Worker 1. Completes the bottom portion of the SC 1257 at the conclusion of the interview beginning with Total Time with Client. 2. Sets up time with the interpreter for a return appointment, if needed, and initiates another SC 1257 3. Notes the date, interpreter’s name and time of services on the Maintain Case Comments window. 4. Makes a photocopy of the SC 1257 and have it scanned into the IDM System under the F2 – CASE VERIF\/CHILD SUPPORT tab. Note: The form is located in the Intranet Departmental General form’s section: http:\/\/intranet.ssa.co.santa-clara.ca.us\/forms\/department.html 5. Give the original Interpreter\/Translator Services Request Form (SC 1257) to the Interpreter at the time of services. Who Step Action Update # 16-23 Revised: 08\/29\/16 Page 34 page 36-32 Common-Place Handbook Civil Rights Examples of Extenuating Circumstances warranting the temporary use of a minor as an interpreter include, but are not limited to: The worker telephones or visits the applicant\/recipient’s home for initial contact and finds a non-English or limited-English speaking client. Under these circumstances, the minor can be used as an interpreter ONLY to determine the language of the client and to schedule a date and time to call\/return with a county provided interpreter. A non-English or limited-English speaking applicant\/recipient comes to the office with a minor child who speaks English and the county does not immediately have access to a county provided interpreter in the applicant\/recipient’s primary language. Under these circumstances, the minor can be used as an interpreter ONLY to schedule a date and time for the client to return to the office when a county provided interpreter will be available. When a county employee encounters a health\/safety issue, such as a car accident or crime scene, where immediate communication is imperative, a minor may be used temporarily UNTIL a qualified interpreter arrives at the scene or communicates with the applicant\/recipient via phone, etc. 36.9.9 Special Intake Appointment Instructions The instructions for requesting Interpreter Services are outlined below when an assigned interpreter shows up for a special intake appointment: Who Step Action Interpreter 1. Explains to the Receptionist they are there to assist in completing the Identification and Intake Record (SCD 41) process. Receptionist 1. Gives the interpreter and applicant the SCD 41 and appropriate application(s) to complete. 2. Marks off the appointment on the blotter. 3. Calls the worker for the intake appointment. Worker 1. Follows instructions for completion of SC 1257: [Refer to Requesting Interpreter Services, page 36-30] for instructions. If a second appointment is needed, the second SC 1257 is logged in and attached to the SCD 41. Revised: 08\/29\/16 Update # 16-23 Page 35 Common-Place Handbook page 36-33 Civil Rights 36.10The Language Line (Interpreter Services) The Language Line is an over-the-phone interpreter service provided to Social Services employees 24 hours a day, seven days a week. 36.10.1 Bilingual Languages Provided The Language Line provides bi-lingual services in the following languages: REGION LANGUAGES Africa Amharic Arabic Bambara French Hausa Italian Portuguese Portuguese Creole Somali Swahili Tigrinya Wolof Yoruba REGION LANGUAGES Asia Burmese Hmong Indonesian Japanese Khmer (Cambodian) Korean Laotian Malay Mien Thai Vietnamese China Cantonese Chaochow Fukienese Mandarin Shanghai Taiwanese Toishanese Europe Albanian Armenian Bulgarian Catalan Croatian Czech Danish Dutch Estonian French German Greek Hungarian Italian Lithuanian Macedonian Norwegian Polish Portuguese Romanian Russian Serbian Slovak Spanish Swedish Ukrainian Yiddish Update # 16-23 Revised: 08\/29\/16 Page 36 page 36-34 Common-Place Handbook Civil Rights 36.10.2 Procedures for Accessing Language Line Services Language Line Services may be accessed when staff are in need of interpreter services when speaking to a client: Via telephone (interpreter services would be utilized as a third party line), or In person, when staff require immediate interpreter services, and no other interpreter is available. A phone with special features for three-way calling may be utilized with the client present and the interpreter will translate via telephone. India, Pakistan and Southeast Asia Bengali Bhojpuri Guajarati Hindi Malayalam Nepali Punjabi Sinhalses Tamil Urdu Middle East Arabic Armenian Assyrian Dari Farsi Hebrew Kurdish Pashto Turkish North America, South America and Caribbean French Haitian Creole Navajo Portuguese Spanish Pacific Islands Akian Fijian Ilocano Indonesian Malay Samoan Tagalog Tongan Revised: 08\/29\/16 Update # 16-23 Page 37 Common-Place Handbook page 36-35 Civil Rights Who Action Client Contacts SSA via telephone or appears in District Office. Note: No staff member is available to provide interpreter services in the client’s native language. Staff Member (Eligibility and\/or Clerical) Explains to the client that interpreter services will be requested. Dials 1-844-276-1697 or 1-844-234-0156. Note: If the client contacts the Agency via telephone, the transfer button must be utilized. Follows Prompts. Note: Enter a Personal Identification Number (PIN) based on your office location (see list of offices and PINs following this chart) and your employee ID number. When the interpreter is on the line, states: I have a client on the line (here in the office). Please ask the client how I can be of assistance. Interpreter Asks the client what assistance is being required. Relates request to staff member. Staff Member Assists the client via the interpreter. Update # 16-23 Revised: 08\/29\/16 Page 38 page 36-36 Common-Place Handbook Civil Rights DISTRICT OFFICE PIN BENEFITS SERVICE CENTER 2018 APPLICATION ASSISTANCE CENTER 2249 CENTRAL BUSINESS SERVICES 2435 NORTH COUNTY 2825 SOUTH COUNTY 3269 CALWORKS EMPLOYMENT SERVICES 4123 DEPARTMENT OF AGING & ADULT SERVICES 4623 DEPARTMENT OF FAMILY & CHILDREN SERVICES 2071 SECOND HARVEST FOOD BANK 5408 VALLEY MEDICAL CENTER 7806 GENERAL ASSISTANCE 9315 FOSTER CARE 9975 DISTRICT OFFICE PERSONAL IDENTIFICATION NUMBERS (PINS) 36.11Document Translation Services 36.11.1 Requesting Translation of Forms Submit requests for translations of written correspondence or forms other than Spanish, Vietnamese or Chinese to the Language Access Coordinator at (408) 755-7298 or FAX (408) 755-7926. 36.11.2 Procedures for Requesting Translations Non-Program Related Each district office has their own internal process for requesting translations that are non-program related. The district office’s requests are given to the SSPM or their designee. The SSPM\/designee forwards needed translations to the Equal Opportunity\/Civil Rights Officer or translation committee, as appropriate. Revised: 08\/29\/16 Update # 16-23 Page 39 Common-Place Handbook page 36-37 Civil Rights Program Related Translations Program related translation requests will be sent by the SSPM\/designee to the appropriate Program Application & Decision Support Specialist (ADSS). The Program ADSS will handle the request to the translation committee(s). 36.11.3 Translation Committees There are currently three translation committees in DEBS whose function it is to provide accurate and uniform translation of all DEBS forms, documents, client information notices and warrant stuffers. The three translation committees are: Spanish Vietnamese Chinese 36.11.4 Composition of Committees Committee members are composed of representatives from the various district offices and divisions of DEBS. All members are certified and have the ability to write competently in their respective language. 36.11.5 Meetings of Translation Committees Regular Schedule Committees will meet on a regular schedule for one-half day, twice a month. When the volume for translation requests is high they may meet more frequently. Overtime Overtime may be approved in the following situations: When a document is needed prior to the next scheduled meeting time, or For large projects (for example: large legal documents, translation of forms for CalWIN implementation, etc.). Update # 16-23 Revised: 08\/29\/16 Page 40 page 36-38 Common-Place Handbook Civil Rights The chairpersons of the committees will jointly discuss the need for overtime and decide upon the amount of time they determine is needed to complete the translation(s). The request for overtime shall be made by the chairperson who will submit the request to administration, who will make the final decision regarding approval of overtime and the amount of time authorized. 36.11.6 Identifying Translated Documents All documents translated by the approved translation committee will be identified by a logo. Translated documents without the logo have not been authorized by the translation committee. Existing authorized translations will have the logo added as forms are reordered. The logo looks like a stack of forms with a curved arrow on each side. It will be located next to the revision date on the document. Example: SCD 1264 (3\/92) Logo 36.11.7 Bootleg Forms All translated forms being utilized by staff that are not authorized translations must be referred to the chairperson(s) of the Translation Committee(s). The chairperson(s) will follow the procedures in [Refer to Document Translation Services, page 36-36 upon receiving bootleg forms.] 36.11.8 Committee Requests for Forms\/Documents Translations The Translation Committee(s) may want to request that a form\/document be translated because the item needs to be available in other languages. In order to prevent the committee from translating forms that may be under revision or being deleted in the near future, a process has been established with Application and Decision Support Specialists (ADSS). Revised: 08\/29\/16 Update # 16-23 Page 41 Common-Place Handbook page 36-39 Civil Rights When the committee wishes to translate existing documents, the following process is used. WHO: ACTION: Translation Committee Establishes a priority list of forms\/documents to be translated. Sends the list to the Forms Desk clerical support staff within the Program Bureau; the phone number is 408-755-7540. The list should be top priority SCD forms\/documents that the Committee determines they can translate within a two-month time period. Sends copies of the actual SCD forms\/documents with the list. Forms Desk Designee Receives the list with copies of priority forms\/documents to be translated. Sends forms\/documents to appropriate Program ADSS with Approval For Translation list attached. Program ADSS Receives priority list with the Approval for Translation attached. Determines whether or not the form should be translated at this time. Completes the sections of the Approval for Translation form and indicates: Yes, the translation should be completed, or No, briefly explaining why this may not be a good time to translate the item (i.e. in process of being revised). If possible give a time frame when this might be available for translation. Signs in the appropriate area if the form will be their responsibility to order later. Returns the Approval for Translation to the Forms Coordinator, who will coordinate requests and return the list to the committee. Translation Committee Receives the list with approval\/denial status to translate forms\/documents. Spanish\/Vietnamese\/Chinese In-House Committees: Translates approved forms\/documents. Reviews the final draft and sends the item to the appropriate Program ADSS. Update # 16-23 Revised: 08\/29\/16 Page 42 page 36-40 Common-Place Handbook Civil Rights Note: Online forms are to be printed on an as needed basis ONLY. 36.12Translation Requests by DEBS Staff Each district office follows their internal process for requests for forms translations. All translation requests must come to the translation committee from the SSPM or their designated person. Program-related translation requests must be sent by the SSPM or their designee to the appropriate Program ADSS who, after review, will send it to the appropriate committee\/person. All documents needing translation must be referred to the appropriate translation person, using the SCD 970, as follows: Designated Program ADSS Receives the final draft of the translated form\/document. Based on usage determines whether the form should be put online on the DEBS Forms Library and\/or be printed. For forms that are to be printed: Attaches the translated form\/document to the DEBS Program Request (SCD 293) and sends to Publishing for reproduction. For forms that are to be put online: Sends a soft copy of the form, along with a DEBS Forms Online Posting Request (SCD 2224) to the Forms Desk requesting it be loaded on the SSA intranet website. Language: Person to Contact: Spanish Spanish Translation Committee Chairperson: Eric Acha, ER2A DFCS 373 West Julian Street, 2nd Floor San Jose, CA 95110 Phone: (408) 501-6300 WHO: ACTION: Revised: 08\/29\/16 Update # 16-23 Page 43 Common-Place Handbook page 36-41 Civil Rights Note: For translation of other languages not listed above, contact an interpreter on the Interpreters List for assistance. An Interpreter\/Translator Services Request Form (SC 1257) will need to be completed and given to the interpreter. The form with instructions are located in the Intranet Departmental General form’s section: http:\/\/intranet.ssa.co.santa-clara.ca.us\/forms\/department.html If the document that needs translation is program-related, submit the translation request to Program Bureau via the SCD 116 Program Bureau Request for Services process. Vietnamese Vietnamese Translation Committee Chairperson: Nhu-Hanh Tonnu Employment Support Initiative (ESI) 333 West Julian Street San Jose, CA 95110 Phone: (408) 755-7744 Chinese Chinese Translation Committee Chairperson: Alex Choy, A7G2 Benefit Service Center 1867 Senter Rd. San Jose, CA 95112 Phone: (408) 758-3656, FAX: (408) 792-1894 Language: Person to Contact: Update # 16-23 Revised: 08\/29\/16 Page 44 page 36-42 Common-Place Handbook Civil Rights 36.12.1 Referral Procedures All referrals for translation will use the following procedures. All requests must be submitted AT LEAST ONE WEEK PRIOR TO THE DUE DATE. WHO: ACTION: Requestor Completes and forwards\/emails a copy of the SCD 970 with the document to be translated to the appropriate chairperson. Spanish – Eric Acha, @ 373 West Julian St. Phone: (408) 501-6300, FAX: (408) 292-3166 Vietnamese – Nhu-Hanh Tonnu @ 333 W. Julian, 5th Floor Phone: (408) 755-7744, FAX: 755-7966 Chinese – Alex Choy, @ 1867 Senter Road BSC Phone: (408) 758-3656, FAX: 792-1894 Indicates whether the document is to be processed through publishing services, or if the rough draft is to be returned to the person requesting the translation. Chairperson of Translation Committee Reviews the SCD 970 and translation. Notifies requestor of any potential problems and\/or clarifies any issues. Translation Committee Translates the document. IF: THEN THE CHAIRPERSON: The documents are to be processed through Publishing Services, Forwards the document to Publishing Services. The committee edits the document until the translation is finalized. The document is to be returned to the requestor, Returns the draft to the requestor. The requestor notes any additional edits needed to the document and returns to the Chairperson. The committee edits the document until the translation is finalized. Chairperson of Translation Committee Signs off and returns the SCD 970 with a final copy of the translation to the originator\/requestor. Files copy of document for committee’s records. Revised: 08\/29\/16 Update # 16-23 Page 45 Common-Place Handbook page 36-43 Civil Rights 36.12.2 Time Allowance Routine Referrals A routine referral gives the translation committee 30 days to complete. This allows the committee time to schedule the translation(s) into one of their regularly scheduled meetings and to complete any necessary word processing. Follow the SCD 970 procedures in [Refer to Referral Procedures, page 36-42]. Other Referrals Other referrals are any translations that don’t fit into the routine referral process of 30 days. This includes large projects, numerous documents, emergency stuffers, etc. Other referrals are made by a telephone call to the appropriate chairperson(s), or the EO\/CR coordinator at (408) 755-7298. A due date will be negotiated at that time. The EO\/CR will coordinate all translations that the Spanish, Vietnamese, and Chinese Translation Committees cannot translate. The telephone call is to be followed up with the SCD 970 procedures. Big Projects A big project is defined as one that requires several translations to be done at once in order to accommodate a major program change or other changes the agency may be undergoing. Example: If in August it is known that in October 12 forms\/documents need to be translated, let the chairperson(s) know as much in advance as possible about the upcoming need. This way the committee can then plan their meeting times accordingly. This is imperative even if the English versions are not yet available. Update # 16-23 Revised: 08\/29\/16 Page 46 page 36-44 Common-Place Handbook Civil Rights 36.13Translated Forms Any information needed regarding the availability of translated forms, large print and Braille, as available, can be obtained by calling Publishing Services at 758-4558. As needed, Publishing Services will coordinate with Program Form’s Desk at 755-7541. 36.14Language Designation in CalWIN Correct language coding is essential for statistical data. Obtaining demographics on client’s primary language is essential to ensuring appropriate interpreters and translators are available which ensure clients receive services in their primary language. Under Case Data Systems (CDS), a language coding system was established and had been used for decades. The CDS language coding system became obsolete with CalWIN. [Refer to Required Form – SCD 1264, page 36-19 for instructions on collecting language data.] In CalWIN, the following language names are available for designation the client’s primary language name that is declared by the client on the SCD 1264. This is to be used when forms require that a language name be identified (e.g., when gathering statistical data for ad-hoc listings, completing intake tallies, etc.): LANGUAGE NAME CODE Afghani 1A American Sign Language SL Amharic 1B Arabic AR Armenian AE Bosnian BO Cambodian CA Cantonese CN Revised: 08\/29\/16 Update # 16-23 Page 47 Common-Place Handbook page 36-45 Civil Rights English EN Ethiopian 1I Farsi FA French FR German 1F Hebrew HE Hmong HM Ilocano IL Italian IT Japanese JA Korean KO Lao LA Mandarin MA Mien ME Oromo 1D Other Chinese Language OC Other Non-English OT Other Sign Language AM Polish PO Portuguese PR Romanian RM Russian RU Samoan SA Serbo-Croatian 1H Somali 1E Spanish SP Swahili 1C Tagalog FI Thai TH Tigrigna 1G LANGUAGE NAME CODE Update # 16-23 Revised: 08\/29\/16 Page 48 page 36-46 Common-Place Handbook Civil Rights Turkish TU Vietnamese VI LANGUAGE NAME CODE Revised: 08\/29\/16 Update # 16-23 Page 49 APPENDIX C Santa Clara County Disability Screening Guide Page 50 Need Extra Help? (Ask applicant): Do you have a disability (physical, mental\/emotional, or learning) that makes it difficult for you to do anything we might ask you to do? (Have applicant initial\/mark the answer that applies) ______ Yes (EW\/EC completes this form) ______ No (Client signs form) (If client needs clarification, tell client): You can get help with filling out or understanding forms, getting documents, arranging appointments to fit your needs, friendly reminders of deadlines and\/or due dates, and other help as needed. EW completes below \u200b(Answer all that apply): Y ES NO 1. Do you have difficulty reading, hearing or speaking? Need information in Braille? Need a sign language interpreter? If yes, please explain: ________________________________________________________________________________ _______________________________________________________________________________________ ___________ Y ES NO 2. Do you need help arranging appointments to fit your needs or friendly reminders of deadlines or due dates. If yes, please explain: ________________________________________________________________________________ _______________________________________________________________________________________ ___________ Y ES NO 3. Do you need help filling out or understanding forms or complicated instructions? If yes, please explain: ________________________________________________________________________________ Page 51 _______________________________________________________________________________________ ___________ Y ES NO 4. Do you have difficulty walking, sitting, or standing for a long time? If yes, please explain: ________________________________________________________________________________ _______________________________________________________________________________________ ___________ Y ES NO 5. Do you need any other extra help due to a disability? If yes, please explain: _______________________________________________________________________________ By signing below, I understand that I will be given a copy of this form. I also understand that by signing this form, I am not providing a medical diagnosis nor am I prevented from later claiming I have a disability or have other special needs. _________________________________ ____________ Applicant Signature (optional) Date Signed _____________________________ ____________ _______________ County Representative Signature Date Signed Position Scan: Permanent Verification \u200bSCD 2371 – 6\/14 Page 52 APPENDIX D Flowchart of Initial Review and Application of the Pleading Standard Page 53 Ask: Do you believe the incident you described occurred because of your race, color, national origin, ancestry, ethnic group identification, political affiliation, religion, marital status, sex, age, sexual orientation, medical condition, genetic information, military and veteran status, mental disability, or physical disability (or that of someone you were with)? Complaint is not a civil rights complaint Ask: Why? Record reported reason on intake form and send to CRC CRC evaluates reason Do not investigate. Investigate If YES Complaint is a civil rights complaint. Should be reported and recorded as a civil rights complaint. Need to determine whether it is worthy of investigation. If NO If plausible If NOT plausible During intake for any type of complaint: Page 54 APPENDIX E Materials From Other States Page 55 WASHINGTON Notice of Discrimination in Multiple Languages that Lists Protective Classes Page 56 Page 57 shelbyhart-armstrong Rectangle shelbyhart-armstrong Text Box Example of eye-catching & clear non-discrimination notice w\/ notices in multiple languages & phone number on bottom for filing complaint Note: (1) would add phone number on top for filing complaint to make more visible; (2) would also add that user can pick up complaint form at greeters’ desk shelbyhart-armstrong Rectangle MASSACHUSETTS Commonly-Needed Accommodations Chart Training Slides Page 58 Commonly Needed Accommodations for Clients Working with DTA These are examples only and are not intended to limit what a client may need or request. Each accommodation must be individualized and tailored to the client’s particular circumstances. Barrier in dealing with DTA Possible disability reasons for the difficulty Possible accommodations Difficulty understanding notices and forms \u25cf Learning or cognitive impairment \u25cf Psychiatric issue (eg overwhelmed by anxiety) \u25cf Physical issue (eg vision impairment or deaf) \u25cf Client calls DTA to ask DTA to explain a notice or form (specific list of contacts) \u25cf DTA calls client to explain notices and forms \u25cf Copy of all mail sent to helper Difficulty completing forms \u25cf Learning or cognitive impairment \u25cf Psychiatric issue (eg overwhelmed by anxiety) \u25cf Physical issue (eg visual or hearing impairment or physical impairment that affects writing) \u25cf DTA discusses form with client and completes form based on client’s answers; client then reviews and signs form. Could occur by phone and mail\/fax Difficulty getting verifications \u25cf Learning or cognitive impairment \u25cf Psychiatric issue (eg overwhelmed by anxiety; unable to follow through due to depression) \u25cf Physical issue (mobility or visual or hearing impairment) DTA assists client in getting verifications; may need client to sign authorization to do so. Difficulty meeting deadlines \u25cf Psychiatric issue \u25cf Cognitive issue DTA calls client to remind of deadlines Difficulty coming into the DTA office \u25cf Mobility or other physical issue (eg walking, length of time sitting) \u25cf Psychiatric issue (eg anxiety, agoraphobia) \u25cf Handle case by phone\/fax\/email \u25cf Priority handling of case to ensure short waiting time in local office \u25cf Home visit Difficulty getting around generally \u25cf Physical issue (eg mobility limitations) \u25cf Psychiatric issue (eg anxiety in crowds) \u25cf Cognitive issue (unsure how to get to unfamiliar places) \u25cf Handle case by phone\/fax\/email \u25cf Priority handling of case to ensure short waiting time in local office \u25cf Home visit \u25cf Obtain verifications for client (who must sign releases for some verifications) Page 59 shelbyhart-armstrong Rectangle shelbyhart-armstrong Text Box This chart is a good example of guidance that could be provided to county workers for providing accommodations and affirmative screening. It will be critical to emphasize that examples are non-exhaustive and accommodation must be individualized. This chart is also great guide for accommodations for persons with mental (often \”invisible\”) disabilities shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight Difficulty communicating by phone \u25cf Hearing impairment \u25cf Cognitive impairment \u25cf Need for auxiliary aid (eg ASL or CDI interpreters; need for reader) \u25cf May need to extend deadlines to enable provision of auxiliary aid \u25cf Schedule in-person appointments to review information (without long waits). Rule Modification Examples Student will not graduate high school by age 19 Student delayed due to learning disability or behavioral health issue (eg repeated a grade or missed school due to trauma or impact of mental health issue) Extend TAFDC until child reaches age 19, whether scheduled to graduate or not Asset limit (Most common in EAEDC due to very low asset limit) Any kind of disability necessitates use of car Waive asset limit Other Any kind of disability So long as not a fundamental alteration can\/should be approved Notes: \uf0b7 DTA cannot require a client to accept any particular accommodation. \uf0b7 DTA cannot require a client to use a helper or authorized representative. \uf0b7 Although some examples of accommodations are tasks DTA can and should do regardless of disability (like explaining notices or help completing forms), if a client needs the assistance due to disability, asking for it as an accommodation due to disability confers additional protections and rights. \uf0b7 Depending on a particular case, it may be appropriate for a worker to implement the accommodation or it may be appropriate for a Client Assistance Coordinator. \uf0b7 For clients who need auxiliary aids to communicate effectively, federal law requires that the primary consideration in selecting an accommodation must be the client’s preference. 28 C.F.R. 35.160(b)(2). \uf0b7 The process through which a client requests an accommodation and the state agency decides on the request must be interactive, meaning that DTA is supposed to work out a solution with the client. \uf0b7 An agency can suggest an alternative accommodation. If a client is otherwise eligible and is considered disabled as defined by the ADA, though, there are limited circumstances and justifications an agency may use to deny a request for accommodation. If this occurs, consult GBLS Harper counsel. Page 60 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight Access to DTA Benefits for Clients with Disabilities: Accommodations & the Harper Settlement Sarah Levy & Lizbeth Ginsburg Greater Boston Legal Services Page 61 The Problem Clients with disabilities repeatedly losing or being denied DTA benefits, often because their disabilities prevented them from following DTA processes. DTA didn’t have a system to accommodate clients with disabilities. Page 62 Ms. Harper and her experience Because of my bipolar and anxiety, it’s hard to think and everything is discombobulated and confusing to me. I get hyper and aggravated and feel belligerent and can’t control it. I also hate it when DTA talks down to me like I’m an idiot. I know how things are supposed to be, and when I get talked down to, I get heated and start cussing because I feel like that’s the only way I’m going to get heard. I try to calm myself down and call GBLS. Page 63 shelbyhart-armstrong Rectangle Client voices I tried to explain both my physical and mental health problems to the worker. The interpreter told both me and the worker that I looked fine, that I didn’t have a disability and that my psychological problems were ‘nothing.’ I used to hate working with welfare because there would be a lot of fighting and they would lower my money and I wouldn’t understand why. I would cry and have to call my friends to help me buy things for my daughters. – Emilia M. Page 64 shelbyhart-armstrong Rectangle How big of a problem is this? The national numbers: 25%-33% percent of TANF (federally-funded welfare) recipients have a serious mental health illness 20% of TANF recipients are known to have a physical disability that impairs their ability to work. 25-33% of TANF recipients are known to have a learning disability. Approximately 25% of Food Stamps recipients are known to be disabled themselves or have a household member who is disabled. Many clients have multiple disabilities. Page 65 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight What those barriers translate into From 2006-2009, DTA: \uf0a7 Denied 27,289 applications for clients known to be disabled due to procedural reasons (missed appointments, incomplete paperwork). \uf0a7 Terminated 118,816 cases for clients known to be disabled and previously found eligible due to procedural reasons (missed appointments, incomplete paperwork). Page 66 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight The ADA: Reasonable Accommodation Under the ADA, a public agency must provide a reasonable accommodation to a person with a disability when: the person is otherwise eligible for the agency’s programs or services; and the accommodation is needed to ensure that the person is not excluded due to disability. Page 67 Scope of Harper Settlement All disabilities All DTA programs About accommodation About methods of administration that tend to screen out individuals with disabilities Page 68 Harper by the numbers 5 years, 8 months from filing to court approval of settlement 18 GBLS staff and interns 4 DTA Commissioners 3 Assistant Attorneys General 31,400 pages of discovery Electronic discovery: warehouse of every transaction in every case handled by DTA for four years 6 Expert reports 16 depositions over 21 days 107 court filings 28 mediation sessions + 30 meetings between parties 5,637 hours spent by GBLS staff Page 69 Page 70 Content of the Settlement Screening for disability Client Assistance Coordinators (CACs) Recording information about disability and accommodations Readability of written materials Improvements to reasonable accommodation system Auxiliary aids Page 71 shelbyhart-armstrong Rectangle Content of the Settlement Verification of eligibility factors Vendor payments Director of Disability Access (DDA) Adverse action pilot Duration Monitoring and Enforcement Page 72 Focus on Accommodations Screening Application Eligibility reviews and recertifications if interviewed If disclose disability If seeking TAFDC disability exemption or EAEDC due to disability Interactive Process Page 73 Indicators an accommodation may be appropriate Client who loses benefits because can’t follow DTA processes (appointments, paperwork, verifications) Client keeps calling you back Client who has difficulty due to disability that you can anticipate will be a problem in dealing with DTA: Going places, dealing with paperwork, reading\/writing, explaining what they need, meeting deadlines, troubleshooting. Page 74 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight What Screening Looks Like Programmed in BEACON Mandatory (but nothing’s perfect) Set questions Inquiry happens multiple times Option to discuss with Client Assistance Coordinator instead of worker Page 75 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight The Screening There are things DTA will ask you to do in order to get or keep your benefits. If you have a health problem that makes it hard for you to do something DTA asks, you can ask for help. This is called an accommodation. This could be because of a physical or mental or emotional health problem. Some of the things we’ll ask you to do are: Read notices we send and follow instructions in them Fill out forms Come to the office for appointments Get and give us documents to prove whether you can get benefits Tell us about changes in your household\/case Meet deadlines Do you think you might need help with any of these things, or something else, because of a health problem? Page 76 shelbyhart-armstrong Rectangle Examples of accommodations: Extra help or doing things differently Help getting verifications Complete form by phone and mail to client Affirmative calls to explain notices and what DTA is asking a client to do Not requiring a client to come to a DTA office Extending or reminding clients of deadlines Communicating with a helper Auxiliary aids Page 77 shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight Examples of accommodations: Modifying rules Waive the TAFDC requirement that a child must graduate high school by age 19 if the child will graduate later because of disability. Modify asset limit if need vehicle due to disability \u2192Talk to GBLS if you run into problems with this. Page 78 The Accommodation Process Discussion of barriers OR Written Request Developing request (Interactive process) Decision Page 79 shelbyhart-armstrong Rectangle Written Requests Specify disability and impact on day to day activities Make specific requests and clearly articulate connection to disability related need Specify if you want to be included in discussions about accommodation Submit to CAC Involve Director of Disability Access as needed Page 80 Key Concepts Interactive oBack and forth discussion Individualized oWhat’s right for this client? Specific oWho is responsible to do what? When and how? Page 81 shelbyhart-armstrong Highlight Key Concepts: Fundamental Alteration DTA cannot be required to make a fundamental alteration to program rules. Cost is generally not a permissible reason. \u2192Talk to GBLS if you run into this Page 82 The Accommodation Process Worker can approve but can’t deny CAC can approve or deny If CAC intends to deny, must first convene TAO Accommodation Team Page 83 shelbyhart-armstrong Rectangle Accommodation Process Decision Approved Approved in part Approved as modified Denied APPEALABLE \u2192Talk to GBLS Page 84 Role of Client Assistance Coordinators 1-3 in each office SNAP Supervisors with reduced caseloads Clients can choose to discuss disability issues with them instead of workers at any time Specific duties related to helping clients with disabilities One key role is supporting the accommodation process Director of Disability Access oversees CACs [email protected] Page 85 mailto:[email protected] shelbyhart-armstrong Rectangle Some common trouble spots Can’t force someone to have an authorized rep or to be an authorized rep If client will need help every single time, say so. Don’t put burden on client to request each time. If client needs affirmative calls from DTA due to disability, DTA has to call Use of technology- evolving Page 86 Auxiliary Aids For clients who need auxiliary aids, no effective communication unless that aid is provided. Likely need to extend deadlines until the necessary aid is provided. For clients who have hearing impairments o ASL is a different language than English. This means that deaf clients may not be fluent in English or able to understand DTA notices. o Regional VRI in: Brockton, Newmarket Square, Lawrence, Springfield Liberty and Worcester. For clients who have visual impairments o Underdeveloped area. \u2192Talk to GBLS if you run into this Page 87 shelbyhart-armstrong Rectangle Upcoming: Adverse Action Pilot Pilot in 3 DTA offices CACs have to take extra steps in TAFDC and EAEDC cases for clients known to be disabled when adverse action is about to happen Rigorous evaluation of outcomes Page 88 Please Help Us We are heavily involved in Implementation No Settlement can anticipate fully how things will play out in practice, so we need to be adept at adjusting where necessary Real cases move change Please let us know what you’re seeing and what is and isn’t working. Page 89 ABOUT DTA Our Mission The mission of the Department of Transitional Assistance is to assist and empower low-income individuals and families to meet their basic needs, improve their quality of life, and achieve long-term economic self-sufficiency. Did you know? The average SNAP benefit for a household in Massachusetts is $213.10. That means the average SNAP household has $7.01 a day to supplement food purchases. \u2713 70.2% of SNAP households in Massachusetts have gross countable income of less than 100% of the Federal Poverty Level that’s $16,240 for a household of two. \u2713 29.5% of SNAP households have at least one child. \u2713 Elderly individuals are 20.8% of Massachusetts SNAP recipients. \u2713 SNAP clients live in every city & town across the Commonwealth. \u2713 52,140 DTA clients are due for recertification or reevaluation in March. \u2713 The average monthly TAFDC grant is $448 and the average EAEDC grant is $308. The Department of Transitional Assistance is committed to providing a high level of service to all those in need of our services. We are pleased to present this scorecard, which includes several measures that are important for DTA to use in measuring our success and identifying areas for improvement. Jeff McCue Commissioner, Department of Transitional Assistance Page 90 http:\/\/www.google.com\/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCOvY45TM4sYCFQoYPgodNakAXw&url=http:\/\/www.foodsafetynews.com\/2010\/05\/usda-unveils-new-snap-consumer-information-resources\/&ei=jS6pVaveJ4qw-AG10oL4BQ&bvm=bv.97949915,d.cWw&psig=AFQjCNGeR14pnkc_zUDlfRiFdNZLfsDdjg&ust=1437237243987072 shelbyhart-armstrong Rectangle SNAP ENROLLMENT & QUALITY SNAP Recipients 762,672 SNAP Households 448,876 SNAP Enrollment | 1 in 9 MA Residents 95.96% Recipients Age 60+ 158,731 Recipients With a Disability 267,931 Recipients Age 18 or under 269,241 SNAP Caseload This is the number of households receiving SNAP benefits in Massachusetts in the prior two years. SNAP Caseload Trends This is the number of households receiving SNAP benefits in Massachusetts in the last decade. SNAP Accuracy Rate The annual percent of active payments that were completed without errors based on federal guidelines in Federal Fiscal Year 2017. 435,000 440,000 445,000 450,000 455,000 460,000 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec H o u se h o ld s 2016 2017 2018 100,000 200,000 300,000 400,000 500,000 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 H o u se h o ld s Page 91 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle LOCAL OFFICES Average Daily Walk-in Visitors This is how many people visit our offices each day to meet with a case manager. 1,650 Average Lobby Waiting Time This is how many minutes someone typically waits to see a case manager. DTA is committed to reducing the need for in-person visits from clients by expanding the ways in which services can be accessed. 21 min 0 500 1,000 1,500 2,000 2,500 3,000 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb W al k- in V is it o rs 0 5 10 15 20 25 30 35 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Lo b b y W ai t Ti m e Page 92 shelbyhart-armstrong Rectangle ASSISTANCE LINE Average Caller Wait Time This is the average length of time callers wait to speak to an agent. 20 min Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb 00:00 05:00 10:00 15:00 20:00 25:00 30:00 C al l W ai t Ti m e (M in u te s) 0 5,000 10,000 15,000 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb To ta l C al ls p er D ay Calls Ending in IVR Calls Connected Calls Unable to Connect Calls Connected Average Daily Calls to Assistance Line Calls Unable to Connect 5,173 29 3,473 Calls Ending in IVR 1,671 Page 93 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle PROCESSING Average Processing Days for New SNAP Applications This is the average number of days to approve a new application. 11.9 SNAP Application Processed Timely This is the percentage of applications that are processed within federal timeframes. 91.6% SNAP Churn This is the percentage of applicants each month that 90 days prior were active clients. 21.1% 0 5 10 15 20 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec N u m b er o f D ay s 2016 2017 2018 10% 15% 20% 25% 30% 35% Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec P er ce rn t C h u rn 2017 2018 2019 70% 80% 90% 100% Ja n u ar y 2 0 1 4 – Ju n e 2 0 1 4 A p ri l 2 0 1 4 – S ep t 2 0 1 4 Ju ly 2 0 1 4 – D e c 2 0 1 4 O ct o b e r 2 0 1 4 – M ar ch 2 0 1 5 Ja n u ar y 2 0 1 5 – Ju n e 2 0 1 5 A p ri l 2 0 1 5 – Se p te m b er 2 0 1 5 Ju ly 2 0 1 5 – D ec e m b er 2 0 1 5 O ct o b e r 2 0 1 5 – M ar ch 2 0 1 6 Ja n u ar y 2 0 1 6 – Ju n e 2 0 1 6 A p ri l 2 0 1 6 – Se p te m b er 2 0 1 6 O ct o b e r 2 0 1 6 – D ec e m b er 2 0 1 6 Ja n u ar y 2 0 1 7 – Ju n e 2 0 1 7 A p ri l 2 0 1 7 – Se p te m b er 2 0 1 7P er ce n t Ti m el y MA National Average Federal Target (95%) Page 94 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle PROCESSING Monthly SNAP Applications Received 17,513 Monthly TAFDC Applications Received 1,836 Monthly EAEDC Applications Received 1,797 0 5,000 10,000 15,000 20,000 25,000 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb # o f A p p lic at io n s p er M o n th Walk-In Drop-Off Mail-In Fax Web 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb# o f A p p lic at io n s p er M o n th In-Office Mail-In & Fax 0 500 1,000 1,500 2,000 2,500 Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb# o f A p p lic at io n s p er M o n th In-Office Mail-In & Fax Page 95 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle EAEDC ENROLLMENT EAEDC Recipients 19,699 EAEDC Households 19,498 Recipients Age 60+ 10,544 Recipients With a Disability 9,928 Recipients Age 18 or under 523 EAEDC Caseload This is the number of households receiving EAEDC benefits in Massachusetts in 2018 and 2019. EAEDC Caseload Trends This is the number of households receiving EAEDC benefits in Massachusetts in the last decade. 18,600 18,800 19,000 19,200 19,400 19,600 19,800 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec H o u se h o ld s 2018 2019 15,000 17,500 20,000 22,500 25,000 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 H o u se h o ld s Page 96 TAFDC ENROLLMENT TAFDC Recipients 59,565 TAFDC Households 29,791 Recipients Age 60+ 100 Recipients With a Disability 5,441 Recipients Age 18 or under 40,103 TAFDC Caseload This is the number of households receiving TAFDC benefits in Massachusetts for 2018 and 2019. TAFDC Caseload Trends This is the number of households receiving TAFDC benefits in Massachusetts in the last decade. 27,500 28,000 28,500 29,000 29,500 30,000 30,500 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec H o u se h o ld s 2018 2019 25,000 30,000 35,000 40,000 45,000 50,000 55,000 60,000 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 H o u se h o ld s Page 97 ADDITIONAL INFORMATION Background Measure Description SNAP Recipients This is the number of Massachusetts residents in households that receive SNAP benefits each month. These figures are finalized approximately six weeks after the end of the reporting month. SNAP Accuracy Rate Massachusetts ranks 35 out 54 states\/regions. Average Daily Walk-in Visitors Includes both cash and SNAP clients. Excludes those dropping off documents or seeking a new EBT card. Calls Ending in IVR Average calls that exited at a point in our Interactive Voice Response (IVR) or self-service menu. Likely exit reasons: client self-served successfully, client hang up. Calls Unable to Connect Average number of calls that heard a high volume message and were unable to wait for a live agent. Calls Connected Average number of calls connected to a live agent. Average Caller Wait Time On June 24, 2015, DTA introduced an improved phone system which allowed the Department to implement two new enhanced service features. Estimated wait time messaging informs callers how long they could expect to wait which allows them to decide whether to wait or to call back. DTA also increased the number of spaces in the wait queue from 100 to 200 allowing an increased number of callers to choose to wait to speak to a live agent. Due to the fact that more callers can choose to wait the caller wait time has also increased. DTA continues to monitor caller wait time and will implement strategies to improve the caller experience. SNAP Application Processed Timely The federal government measures this item on a rolling basis (note the overlap in months). Throughout the year, the federal government provides DTA with a projection for each time period. At year end the federal government finalizes the previous four quarters. SNAP Churn The SNAP program has always and will always realize some level of client churn. However reducing churn to the best of DTA’s ability eliminates disruptions in benefits and improves operational efficiency. This is measured by analyzing new applications against the active caseload 90 days previous. Recipients with a Disability Active clients who have identified as having any disability. EAEDC Caseload This is the number of Massachusetts households that receive Emergency Aid to the Elderly, Disabled, and Children (EAEDC) cash benefits each month. TAFDC Caseload This is the number of Massachusetts households that receive Transitional Aid to Families with Dependent Children (TAFDC) cash benefits each month. *To access background data right hand click on the graph and click on Edit Data . This feature only available on the Microsoft Word version. Page 98 shelbyhart-armstrong Rectangle NEW YORK STATE ADA Complaint Form Reasonable Accommodation Notice ADA Notice Grievance Procedure Under the ADA Page 99 AMERICANS WITH DISABILITIES ACT COMPLAINT FORM Please use this form to file a complaint based on disability in the provision of services, activities, programs or benefits. Please submit this form to Equal Opportunity and Diversity at: Office of Temporary and Disability assistance Equal Opportunity and Diversity 40 North Pearl Street – 13A Albany, NY 12243 Phone: 518-473-8555 Fax: 518-473-8590 Email: [email protected] COMPLAINANT INFORMATION Name: Home Address: Home Phone: E-mail Address: 1. Your claim is made against: State Agency: Name: Title: Address: Phone: 2. Location(s) and date(s) of the circumstances giving rise to your complaint Are the circumstances of your complaint continuing? Yes: No: Page 100 mailto:accessibility%40otda.ny.gov?subject= shelbyhart-armstrong Rectangle 3. Please describe the alleged denial of services, activities, programs or benefits and your reason(s) for concluding that the conduct was discriminatory. Please include the name(s) of witnesses, if any, and attach supporting data, if available. 4. A. Have you filed a claim regarding this complaint with a federal, state or local government agency? Yes: No: B. Have you hired an attorney with respect to the allegations in the complaint? Yes: No: C. Have you instituted a legal suit or court action regarding this complaint Yes: No: 5. This complaint form was completed by: ADA Coordinator: Complainant: Signature: Date: Page 101 2\/13\/2019 Reasonable Accommodation | OTDA https:\/\/otda.ny.gov\/reasonable-accommodation\/ 1\/1 Reasonable Accommodation Reasonable Accommodation The State of New York is committed to assuring equal opportunity for persons with disabilities. To this end, it is OTDA policy to provide reasonable accommodation in all its accommodations, programs and services. The Agency’s Designee for Reasonable Accommodations (DRA) and Americans with Disabilities Act Coordinator (ADA Coordinator) is identified below. If you require accommodation for an OTDA program or service, please submit a request to: Jessica Vaughn Tolle, DRA\/ADA Coordinator Bureau of Equal Opportunity and Diversity Office of Temporary and Disability Assistance Floor 13A, 40 North Pearl Street Albany, NY 12243 Phone: 518-473-8555 Fax: 518-473-8590 Email: [email protected] Notice Under the Americans with Disabilities Act Grievance Procedure Under the Americans with Disabilities Act ADA Complaint Form Office of Temporary and Disability Assistance Office of Temporary and Disability Assistance Page 102 mailto:[email protected] https:\/\/otda.ny.gov\/reasonable-accommodation\/ada-notice.asp https:\/\/otda.ny.gov\/reasonable-accommodation\/grievance-procedure.asp https:\/\/otda.ny.gov\/legal\/ADA-Complaint-Form.pdf https:\/\/otda.ny.gov\/ 2\/13\/2019 Notice Under the Americans with Disabilities Act | OTDA https:\/\/otda.ny.gov\/reasonable-accommodation\/ada-notice.asp 1\/2 Notice Under the Americans with Disabilities Act Notice Under the Americans with Disabilities Act In accordance with the requirements of title II of the Americans with Disabilities Act of 1990 (\”ADA\”), the Office of Temporary and Disability Assistance (OTDA) will not discriminate against qualified individuals with disabilities on the basis of disability in its services, programs, or activities. Employment: OTDA does not discriminate on the basis of disability in its hiring or employment practices and complies with all regulations promulgated by the U.S. Equal Employment Opportunity Commission under title I of the ADA. Effective Communication: OTDA will generally, upon request, provide appropriate aids and services leading to effective communication for qualified persons with disabilities so they can participate equally in OTDA’s programs, services, and activities, including qualified sign language interpreters, documents in Braille, and other ways of making information and communications accessible to people who have speech, hearing, or vision impairments. Modifications to Policies and Procedures: OTDA will make all reasonable modifications to policies and programs to ensure that people with disabilities have an equal opportunity to enjoy all of its programs, services, and activities. For example, individuals with service animals are welcomed in OTDA offices, even where pets are generally prohibited. Anyone who requires an auxiliary aid or service for effective communication, or a modification of policies or procedures to participate in a program, service, or activity of OTDA should contact the Bureau of Equal Opportunity and Diversity as soon as possible but no later than 48 hours before the scheduled event. The ADA does not require OTDA to take any action that would fundamentally alter the nature of its programs or services, or impose an undue financial or administrative burden. OTDA will not place a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the cost of providing auxiliary aids\/services or reasonable modifications of policy, such as retrieving items from locations that are open to the public but are not accessible to persons who use wheelchairs. Any individual who is unsatisfied with the state entity’s response to his or her needs as a person with a disability, or who is unsatisfied with the accommodation provided by the state entity, or who has been informally denied a requested accommodation, is entitled to file a formal written complaint with the agency. (28 C.F.R. 35.107(b)) Office of Temporary and Disability Assistance Page 103 https:\/\/otda.ny.gov\/legal\/ADA-Complaint-Form.pdf https:\/\/otda.ny.gov\/ 2\/13\/2019 Notice Under the Americans with Disabilities Act | OTDA https:\/\/otda.ny.gov\/reasonable-accommodation\/ada-notice.asp 2\/2 Office of Temporary and Disability Assistance Page 104 2\/13\/2019 Grievance Procedure Under the Americans with Disabilities Act | OTDA https:\/\/otda.ny.gov\/reasonable-accommodation\/grievance-procedure.asp 1\/2 Grievance Procedure Under the Americans with Disabilities Act Grievance Procedure Under the Americans with Disabilities Act This Grievance Procedure is established to meet the requirements of the Americans with Disabilities Act of 1990 (\”ADA\”). It may be used by anyone who wishes to file a complaint alleging discrimination on the basis of disability in the provision of services, activities, programs, or benefits by OTDA. Employment-related complaints of disability discrimination are covered elsewhere, in policies available from the human resources office of OTDA. The complaint should be in writing and contain information about the alleged discrimination such as name, address, phone number of complainant and location, date, and description of the problem. No particular format of the complaint is required. However, you may choose to use our form. Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint, will be made available for persons with disabilities upon request. The complaint should be submitted by the grievant and\/or his or her designee as soon as possible but no later than 60 calendar days after the alleged violation to: Jessica Vaughn Tolle, DRA\/ADA Coordinator Bureau of Equal Opportunity and Diversity Office of Temporary and Disability Assistance Floor 13A, 40 North Pearl Street Albany, NY 12243 Phone: 518-473-8555 Fax: 518-473-8590 Email: [email protected] Within 15 calendar days after receipt of the complaint, the ADA Coordinator or his or her designee will meet with the complainant to discuss the complaint and the possible resolutions. Within 15 calendar days of the meeting, the ADA Coordinator or his or her designee will respond in writing, and where appropriate, in a format accessible to the complainant, such as large print, Braille, or audio tape. The response will explain the position of OTDA and offer options for substantive resolution of the complaint. If the response by the ADA Coordinator or his or her designee does not satisfactorily resolve the issue, the complainant and\/or his or her designee may appeal the decision within 15 calendar days after receipt of the response to the agency head or his or her designee or his or her designee. Office of Temporary and Disability Assistance Page 105 https:\/\/otda.ny.gov\/legal\/ADA-Complaint-Form.pdf mailto:[email protected] https:\/\/otda.ny.gov\/ shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle 2\/13\/2019 Grievance Procedure Under the Americans with Disabilities Act | OTDA https:\/\/otda.ny.gov\/reasonable-accommodation\/grievance-procedure.asp 2\/2 Within 15 calendar days after receipt of the appeal, the agency head or his or her designee or his or her designee will respond in writing, and, where appropriate, in a format accessible to the complainant, with the agency’s final resolution of the complaint, or indicating that the matter has been returned to the ADA Coordinator for further action. If further action is indicated, the complainant will be contacted within 15 days from the written response. All written complaints received by the ADA Coordinator or his or her designee, appeals to the agency head or his or her designee or his or her designee, and responses from these two offices will be retained by OTDA for at least three years. Office of Temporary and Disability Assistance Page 106 NEW YORK CITY – Civil Rights Complaint Intake Form – Website: Assistance for the Complainant User-friendly FAQ section Page 107 TM Commission on Human Rights 22 Reade Street | New York, NY 10007 | NYC.gov\/HumanRights | @NYCCHR INTAKE FORM Your Information Name Preferred Title (e.g. Dr., Ms., Mx) Date of Birth Address City State Zip Cell Phone Other Phone Occupation Email Race\/Ethnicity Primary Language Family Status: \uf063 Married \uf063 Domestic partner \uf063 Single \uf063 Other ___________________ Emergency Contact Information About the Person or Entity that you Want to Take Action Against Name Company if any Address City State Zip Phone Second Contact Address City State Zip Phone Date of most recent incident of discrimination: Borough where incident occurred: Have you filed any complaint about this incident in any other place? \uf063 Yes \uf063 No If yes, check the place or describe below: \uf063 EEOC \uf063 NY State Division of Human Rights \uf063 HUD \uf063 HPD \uf063 NYCHA \uf063 Court \uf063 Other: ________________________________________________ My inquiry has to do with: (check one, and then fill out the next section depending on your answer) \uf063 Housing (Complete Section A and D) \uf063 Public Accommodation (store, restaurant, taxi, dentist office, etc.) (Complete Section B and D) \uf063 Employment (Complete Section C and D) \uf063 Discriminatory Harassment (Complete Section D) \uf063 Bias-based Profiling by Law Enforcement (Complete Section D) Have you ever had an appointment with the Commission before? \uf063 Yes \uf063 No List when, and the result of your inquiry: ______________________________________ ______________________________________ ______________________________________ ______________________________________ SECTION A: Housing (fill out only if your inquiry involves housing) Type of Housing: \uf063 Co-op \uf063 Commercial \uf063 Rental \uf063 Shelter \uf063 SRO \uf063 Owner-occupied \uf063 Condo Approx. Number of Units ___________________ Basis of Discrimination — Check all that apply: \uf063 Race \uf063 Color \uf063 Presence of Children \uf063 Marital Status \uf063 Gender \uf063 Gender Identity \uf063 National Origin \uf063 Sexual Orientation \uf063 Religion\/Creed \uf063 Occupation \uf063 Lawful Source of Income \uf063 Alienage\/Citizenship Status \uf063 Age \uf063 Military Service \uf063 Disability\/Failure to Accommodate \uf063 Victim of Domestic Violence, Sexual Violence, or Stalking Date: Intake #: Date of Walk-In if Applicable: Matter #, if Applicable: Page 108 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle TM Commission on Human Rights 22 Reade Street | New York, NY 10007 | NYC.gov\/HumanRights | @NYCCHR SECTION B: Public Accommodation (fill out only if your inquiry involves a public accommodation) Basis of Discrimination — Check all that apply: \uf063 Race \uf063 Age \uf063 Religion\/Creed \uf063 National Origin \uf063 Sexual Orientation \uf063 Color \uf063 Gender \uf063 Gender Identity \uf063 Marital Status \uf063 Alienage\/Citizenship Status \uf063 Disability\/Failure to Accommodate \uf063 Military Service SECTION C: Employment (fill out only if your inquiry involves employment) How many employees does your employer have? \uf063 More than 4 \uf063 More than 15 Are you in a union? \uf063 Yes \uf063 No Which union? _______________________________________________________ Basis of Discrimination — Check all that apply: \uf063 Salary History \uf063 Race \uf063 Sexual Orientation \uf063 Alienage\/Citizenship Status \uf063 Gender Identity \uf063 Gender \uf063 Credit History \uf063 Disability\/Failure to Accommodate \uf063 Marital Status \uf063 Pregnancy \uf063 National Origin \uf063 Arrest\/Conviction Record \uf063 Religion\/Creed \uf063 Age \uf063 Unemployment Status \uf063 Military Service \uf063 Caregiver Status \uf063 Color \uf063 Status as Victim of Domestic Violence, Sexual Violence, or Stalking SECTION D: Explain Briefly describe what happened: _______________________________________________________________________________________________________ _______________________________________________________________________________________________________ _______________________________________________________________________________________________________ _______________________________________________________________________________________________________ _______________________________________________________________________________________________________ OFFICE USE ONLY*****OFFICE USE ONLY *****OFFICE USE ONLY Date of Intake or Walk-In Intake Number Staff Member 1. Statute of Limitations deadline: LEB ______________________________ EEOC ___________________________ 2. How did this person hear about the Commission? (check all that apply) \uf063 CRB \uf063 Social Services \uf063 City Agency \uf063 Internet \uf063 Elected Official \uf063 Community Org. \uf063 Commissioner \uf063 CCHR Website \uf063 311 \uf063 Private Lawyer \uf063 Social Media \uf063 Legal Services Org. \uf063 Press \uf063 TV \uf063 Radio \uf063 Newspaper \uf063 Email \uf063 Flyer\/Brochure \uf063 Taxi TV \uf063 Other Complainant \uf063 Advertisement (Please specify if possible) _____________________________________________________________ Details: (If Elected Official, City Agency, Commissioner, or Other, write in the name\/more information) ______________________________________________________________________________________________________ 3. Language Access Issues: a. Limited English Proficient? \uf063 Yes \uf063 No b. Primary Language of Complainant: _________________________________________________________________ c. In which language was intake conducted? __________________________________________________________ d. Method of interpretation: \uf063 LEB staff \uf063 Phone \uf063 Volunteer \uf063 Paid Interpreter 4. Were referrals made? \uf063 Yes \uf063 No Where? ___________________________________________________ 5. Was a complaint filed? \uf063 Yes \uf063 No _________________________________________________________________________________________________________________________________________________ Approved by Page 109 shelbyhart-armstrong Rectangle shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight 3\/6\/2019 Assistance for the Complainant – CCHR https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/assistance-for-the-complainant.page 1\/2 Menu Search Complaint ProcessMediationSettlement HighlightsDecisions Select Steps in the Complaint Process Assistance for the Complainant Assistance for the Respondent Complaint Process – Flowchart Assistance for the Complainant Click a topic, or press the enter key on a topic, to reveal its answer. Expand All Collapse All 1. How do I file a claim under the NYC Human Rights Law? 2. What is the difference between filing in court and at LEB? 3. Will I be provided with a lawyer when I file a complaint? 4. Can a lawyer represent me in bringing my claim to LEB? 5. What is the first step for filing a complaint? 6. I am a lawyer and I would like to file a complaint on behalf of my client: what do I do? 7. What happens after the complaint is filed? 8. What if, after I have filed my complaint with LEB, I decide I do not want my complaint investigated by LEB? Page 110 https:\/\/www1.nyc.gov\/site\/cchr\/index.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/complaint-process.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/mediation.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/2019-settlements.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/decisions-and-orders-2018.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/steps-in-the-complaint-process.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/assistance-for-the-complainant.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/assistance-for-the-respondent.page https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/complaint-process-flowchart.page javascript:expandAll(); javascript:collapseAll(); shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle 3\/6\/2019 Assistance for the Complainant – CCHR https:\/\/www1.nyc.gov\/site\/cchr\/enforcement\/assistance-for-the-complainant.page 2\/2 9. Will there be a chance to settle my case before a trial? 10. What are the possible results of the investigation? 11. What kind of compensation or other remedies can I get from my case? 12. Can I file a complaint if I am undocumented? 13. I filed a complaint and now the respondent is taking action against me: what can I do? 14. Can I remain anonymous while filing a complaint? 15. What if I want to report discrimination, but I do not want to be involved? 16. Is my complaint available in the public record? 17. Are there any costs or fees connected to filing a complaint with the NYC Commission on Human Rights? 18. I need interpretation in order to file a complaint, what should I do? 19. I need an accommodation for a disability in filing a complaint or attending an appointment or hearing, what should I do? Page 111 shelbyhart-armstrong Rectangle NORTH CAROLINA – Grievance Procedure Explanation Complaint Form Page 112 NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES GRIEVANCE PROCEDURE Title II Americans with Disabilities Act (ADA) Section 504 Rehabilitation Act (RA) The Department of Health and Human Services ( DHHS or the Department ) has adopted the following internal grievance procedure to provide for the prompt and equitable resolution of complaints against a division within DHHS alleging an action prohibited by the U.S. Department of Justice regulations implementing Title II of the Americans with Disabilities Act, 28 CFR Part 35, or by the U.S. Department of Justice regulations implementing Section 504 of the Rehabilitation Act of 1973, 45 CFR Part 84. The Department’s rules relating to ADA Grievance Procedures RA Grievance Procedures are codified at 10A NCAC 01E .0101 et seq. This document sets out the procedures for filing and processing complaints. I. How to File a Complaint with the Department of Health and Human Services: You must file your complaint in writing within sixty (60) days of the date you become aware of the alleged violation. The complaint must contain the name and address of the person filing it, the name of the DHHS Division involved, the date(s) of the alleged violation, and a brief description of the alleged violation. If, due to a disability, you require secretarial assistance to prepare a complaint, the Department or Division ADA\/RA coordinator shall provide such assistance upon request. The Department’s Compliance Attorney is M. Terry Hodges, Esq., Office of the Secretary, 101 Blair Drive, Raleigh, NC 27603, telephone 919-855-4800. The Department’s Special Advisor on the ADA is Jessica Keith, Office of the Secretary, 101 Blair Drive, Raleigh, NC 27603, telephone 919-855-4800. The form for filing a complaint is appended to the end of this Grievance Procedure. Additionally, the form is available on the DHHS website and from the Department’s Compliance Attorney. To file a complaint, completed forms must be mailed to: DHHS ADA\/RA Complaints Office of Legal Affairs 2001 Mail Service Center Raleigh, NC 27699-2001 Page 113 NC DHHS Grievance Procedure Title II Americans with Disabilities Act\/ Section 504 Rehabilitation Act, Page 2. The following is a list of ADA\/RA coordinators for each Division and Office of DHHS, with contact information: DHHS Division or Office Division\/Office ADA\/RA Coordinator Division of Mental Health, Developmental Disabilities and Substance Abuse (DMH\/DD\/SA) Glenda Stokes 919-715-3197 Division of Medical Assistance (DMA) Sabrena Lea 919-855-4365 Division of Vocational Rehabilitation Services (DVR) Phil Protz 919-855-3567 Division of State Operated Healthcare Facilities (DSOHF) Laura White 919-855-4700 Division of Public Health (DPH) Lin Taliaferro 919-733-9744 Division of Services for the Blind (DSB) Kim Harrell 919-527-6716 Division of Child Care Development and Early Education (DCDEE) Tammy Barnes 919-527-6335 Division of Services for the Deaf and Hard of Hearing (DSDHH) Jeff Mobley 919-874-2212 Division of Aging and Adult Services (DAAS) Lynne Berry 919-855-3427 Division of Social Services (DSS) Kevin Kelley 919-527-6340 Division of Health Service Regulation (DHSR) Amy Sawyer 919-855-3750 Office of Rural Health and Community Care Office of the Secretary M. Terry Hodges, Esq. 919-855-4800 For any Division or Office which does not list an ADA\/RA Coordinator, contact the Department’s Compliance Attorney, M. Terry Hodges, Esq., 919-855-4800. Please note that the Department will only process complaints involving a Division or Office of DHHS. If you have a complaint against a different state agency, please contact that agency directly. Page 114 NC DHHS Grievance Procedure Title II Americans with Disabilities Act\/ Section 504 Rehabilitation Act, Page 3. II. Complaint Resolution by the Department A. Complaint, Investigation and Determination Within thirty (30) days of DHHS’s initial receipt of a compliant, the Division ADA\/RA Coordinator shall send written notification to the complainant of the Department’s determination as to the validity of the complaint and a description of the resolution, if any. To the extent practicable, DHHS’s internal procedure shall be the followng. 1. Upon receipt, a complaint will be logged into the Department’s database. 2. Within two (2) business days of receipt, the complaint will be assigned to the appropriate Division ADA\/RA coordinator. The Division ADA\/RA coordinator will send a letter to the complainant acknowledging receipt of the complaint. The Division ADA\/RA coordinator also will send a copy of the acknolwegment to the person or division that is the subject of the ADA\/RA complaint. A template acknowledgment letter is appended to the end of this procedure. 3. As soon as practicable, the Division ADA\/RA coordinator will assign the investigation to a Section Chief or other designee. The Section Chief or designee shall investigate the complaint. The investigation shall afford all interested persons and their representatives, if any, an opportunity to submit evidence relevant to the complaint. 4. As deemed appropriate in each case, any point during the investigation, the Section Chief or designee may consult with the Division ADA\/RA coordinator, the Office of Legal Affairs, the Office of the Special Advisor on the ADA, the North Carolina Department of Justice and\/or other knowledgeable individuals within the Department (including representatives of the Division of Services for the Deaf and the Hard of Hearing). 5. Within twenty (20) days of DHHS’s initial receipt of the complaint, the Section Chief or designess will send proposed findings, recommendations and written notification to the following: (1) the Division ADA\/RA Coordinator, (2) the Office of Legal Affairs, and (3) the Office of the Special Advisor on the ADA. The Section Chief shall not send the proposed findings, recommendations and written notification to the Division Director (as the Division Director may become involved if reconsideration is reqeusted). 6. As deemed appropriate in each case, the Division ADA\/RA Coordinator, the Office of Legal Affairs and\/or the Office of Special Advisor on the ADA may review and\/or revise the Section Chief’s proposed findings and recommendations. Page 115 NC DHHS Grievance Procedure Title II Americans with Disabilities Act\/ Section 504 Rehabilitation Act, Page 4. 7. Within thirty (30) days of DHHS’s initial receipt of a compliant, and following the review specified in Paragraph 5, the Division ADA\/RA Coordinator shall send a determination letter to the complainant. The letter shall state the Department’s determination as to the validity of the complaint and a description of the resolution, if any. The determination letter shall be sent by trackable mail. The determination letter shall notify the complaint of the following: a. If the complainant has a disability that renders a different form of communication necessary (i.e., non-written communication), then upon request the Division ADA\/RA coordinator shall make reasonable efforts to effectively communicate the determination to the complainant. b. If the complainant is dissatisfied with the Department’s determination, he\/she may request reconsideration of the determination by the Division Director. A request for reconsideration shall be filed within 30 (thirty) days after the complainant receives the Department’s determination. The determination letter shall identify the name and contact information for the appropriate Division Director. c. A Reconsideration Request form shall be attached to or enclosed with the Department’s determination letter. 8. The Division ADA\/RA Coordinator shall send a copy of the Department’s determination letter to the person or division that was the subject of the ADA\/RA complaint. The notification shall be sent by trackable mail. 9. If warranted by extenuating circumstances or good cause, the Division or Office ADA\/RA Coordinator may extend the thirty (30) day time period to send notice of the Department’s determination of the validity of the complaint and a description of the resolution, if any, provided that the Department shall send the required notice within a reasonable time as provided by federal law. Templates for a determination letter, and a reconsideration request, are appended to the end of this procedure. B. Reconsideration of Department’s Determination If a complainant is dissatisfied with the Department’s determination, he\/she may request a reconsideration by the Division Director. A request for reconsideration must be received by the Division Director within thirty (30) days after the complainant receives the Department’s written determination, or within thirty (30) days after he\/she receives the determination if it was communicated by other means. Page 116 shelbyhart-armstrong Rectangle NC DHHS Grievance Procedure Title II Americans with Disabilities Act\/ Section 504 Rehabilitation Act, Page 5. A request for reconsideration shall be submitted to the appropriate Division Director using the Reconsideration Request form that will be enclosed with the written determination. A form for submitting a reconsideration request is attached to the end of this Grievance Procedure. Additionally, the form is available on the DHHS website and from the Division ADA coordinators. Completed requests for reconsideration should be mailed to the appropriate Division Director, as identified on the reconsideration request form. Contact information for each Division Director also can be found on the DHHS website, www.dhhs.nc.gov. The Division Director, or a designee, shall issue a written determination to a request for reconsideration within thirty (30) days after the Department receives a timely request for reconsideration. The Division Director also shall send the determination to the person or division that was the subject of the complaint. The determination will be sent by trackable mail. The Division Director shall also forward a copy of the determination to the Division ADA Coordinator, the Office of Legal Affairs and the Office of Special Advisor on the ADA. Should the complainant have a known disability that renders a different form of communication necessary, the Division Director coordinator shall make reasonable efforts to effectively communicate the determination. C. Records The Department will maintain records of the complaints, investigations and resolutions as required by its approved record retention schedule. D. Revision This ADA\/RA Grievance Procedure was last revised on September 21 , 2015. E. Forms and Templates An ADA\/RA complaint form is appended below. This form is also available on the DHHS website and from the Department Compliance Attorney, M. Terry Hodges, Esq. Page 117 shelbyhart-armstrong Rectangle NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES COMPLAINT FORM Title II Americans with Disabilities Act (ADA) Section 504 Rehabilitation Act (RA) INSTRUCTIONS: Please fill out (PRINT) this form completely and mail to the address listed on page 2. NAME: _______________________________________ ADDRESS: _______________________________________ _______________________________________ _______________________________________ TELEPHONE: _______________________________________ If someone is filling out this form on your behalf, please indicate that person’s name, address and telephone number below: NAME: _______________________________________ ADDRESS: _______________________________________ _______________________________________ _______________________________________ TELEPHONE: _______________________________________ DHHS DIVISION INVOLVED: _______________________________________ DATE(s) the alleged violation(s) occurred: _____________________ DESCRIPTION OF ACTIONS YOU BELIEVE ARE PROHIBITED BY SECTION 504 of the REHABILITATION ACT OR OF TITLE II OF THE AMERICAN WITH DISABILITIES ACT. (Please list names and addresses of persons who were involved and who can be contacted to provide information relevant to this complaint. You may attach additional sheets as necessary. Please attach copies of any documents or evidence you would like DHHS to consider when investigating your request.) ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ Have efforts been made to resolve this complaint through other informal means? Page 118 NC DHHS Reconsideration Request Form Title II Americans with Disabilities Act\/ Section 504 Rehabilitation Act, Page 2. __ yes ___ no. If so, please specify those means, and provide the status. _________________________ ________________________________________________________________________ ________________________________________________________________________ Have you filed a complaint on this alleged violation with any federal office of civil rights, other agency, or in a court? ___ yes ___ no. If so, please specify, and provide the status. ______________________________ ________________________________________________________________________ ________________________________________________________________________ Have you previously filed a complaint on this alleged violation with any state agency? _____ yes _____ no. If so, please specify, and provide the status. ______________________________ ________________________________________________________________________ ________________________________________________________________________ PRINTED NAME: _____________________________ DATE: _________________ SIGNATURE: _____________________________ Mail this form and any supporting information to: DHHS ADA\/RA Complaints Office of Legal Affairs 2001 Mail Service Center Raleigh, NC 27699-2001 If you have a disability that renders a non-written form of communication necessary, the Department upon request shall make reasonable efforts to effectively communicate with you. For more information, please contact the Department’s Compliance Attorney, M. Terry Hodges, Esq., NC DHHS Compliance Attorney, Office of the Secretary, 101 Blair Drive, Raleigh, NC 27603, telephone 919-855-4800. Page 119 File # Date Received North Carolina Department of Health and Human Services, Division of Social Services Complaint Form Departamento de Salud y Servicios Humanos de Carolina del Norte, Divisi\u00f3n de Servicios Sociales Forma De Querella You have a right to file a complaint if you think that you were treated unfairly because of your race, color, national origin, sex, religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA or US HHS. You can file a complaint for yourself or for someone else. If you want to file a complaint, you may file with USDA, HHS, or NC DSS. If you want to file a complaint with NC DSS, please fill out this form and give one copy to the Title VI Compliance Officer or contact Carlotta Dixon at (919)527-6421. Please make sure to keep track of the name of the person you spoke with and the date. To file a complaint directly with USDA or HHS please refer to the statement at the bottom of page 4. To protect your rights, you must file this Complaint within 180 days of the date you believe you or someone else was treated unfairly. If you do not file your Complaint within 180 days, you may lose your right to file any Complaint. 1. Name (person filing Complaint) Nombre (persona presentando la queja) 2. Home Phone Business Phone Cell Phone Tel\u00e9fono de la casa Tel\u00e9fono del trabajo Tel\u00e9fono celular Usted tiene derecho a presentar una queja si usted piensa que le trataron injustamente por motivo de raza, color, nacionalidad, sexo, credo religioso, discapacidad, edad, creencias pol\u00edticas, o en represalia o venganza por actividades previas de derechos civiles en alg\u00fan programa o actividad realizados o financiados por el USDA o US HHS. Usted puede llenar una queja por usted o a favor de otra persona. Si usted desea presentar una queja, puede hacerlo con el Departamento de Agricultura (USDA), o con el Departamento de Salud y Servicios Humanos (HHS); o para presentar una queja con el Departamento de Servicios Sociales de NC por favor contacte a: Carlotta Dixon al (919)527-6421. Por favor conserve la informaci\u00f3n de la persona con la que habl\u00f3 y la fecha. Para presentar una queja con el Departamento de Agricultura o el Departamento de Salud y Servicios Humanos, vea las indicaciones en la parte inferior de la pagina 5. Para proteger sus derechos, usted debe presentar esta queja en el plazo de 180 d\u00edas desde la fecha que usted cree que le trataron de una forma injusta. Si usted no presenta su queja en el plazo de 180 d\u00edas, usted puede perder su derecho para someter su queja. Page 120 3. Home Address (street #, city, zip code) Direcci\u00f3n de su casa (# de calle, ciudad, c\u00f3digo postal) 4. Are you filing this Complaint for someone else? No Yes (If yes, please give that person’s name and phone number) \u00bfEst\u00e1 presentando esta queja por alguna otra persona? No S\u00ed (Si su respuesta es s\u00ed, por favor escriba el nombre de esa persona y el n\u00famero de tel\u00e9fono) 5. Who do you think treated you unfairly? (Please state the Person, Agency, or Program) \u00bfQui\u00e9n usted piensa le trat\u00f3 injustamente? (indique por favor la persona, la agencia, o el programa) 6. Address of person\/agency\/program you believe treated you unfairly: Direcci\u00f3n de persona\/agencia\/programa que usted cree le trat\u00f3 injustamente: 7. When did the unfair treatment happen? (give a date if you can) \u00bfCu\u00e1ndo sucedi\u00f3? (d\u00e9 una fecha si puede) 8. Tell what happened and why you believe you were treated unfairly because of not speaking or understanding English well (Attach additional pages as needed). Diga qu\u00e9 sucedi\u00f3 y por qu\u00e9 usted cree que fue tratado injustamente a causa de que usted no puede entender o hablar bien el ingles. (Si necesita m\u00e1s espacio puede agregar m\u00e1s hojas). Page 121 9. Please list any person(s) (if any) we may contact for more information about what happened. Name Address Phone Number Cell Phone Enumere por favor cualquier persona(s) que nos pueda(n) dar m\u00e1s informaci\u00f3n de lo qu\u00e9 sucedi\u00f3. Nombre Direcci\u00f3n Tel\u00e9fono Tel\u00e9fono Celular 10. Have you filed this Complaint with any other federal, state or local agency, or state or federal court? No Yes (If yes, please list the agency or court) \u00bfHa presentado esta queja ante alguna agencia federal, estatal o local, o corte del estado o federal? No S\u00ed (si contesta s\u00ed, por favor enumere la agencia o la corte) 11. How can this Complaint be resolved (how can the problem be corrected)? \u00bfC\u00f3mo puede esta queja ser resuelta (c\u00f3mo se puede corregir el problema)? 12. Please list anyone else we should contact. Por favor liste cualquier persona con la que debemos entrar en contacto. 13. Do you need special accommodations for us to communicate with you about this complaint (mark all that apply)? Braille Large Print Cassette Tape Computer Diskette Electronic Mail TDD Sign Language Interpreter (specify language) Foreign Language Interpreter (specify language) \u00bfNecesita arreglos especiales para hablar con usted acerca de este asunto? (Marque el medio de comunicaci\u00f3n que necesita.) Sistema Braille, Letras Impresas Grandes, Audio en Casete, Audio Disco, Correo Electr\u00f3nico, _Sistema para Sordos (TDD), Int\u00e9rprete por se\u00f1as (indique el idioma) , Int\u00e9rprete Oral (indique el idioma) . Signature: Date: Firma: Fecha Page 122 shelbyhart-armstrong Rectangle To file this complaint with the NC DSS State Agency, please mail it to: Para presentar esta queja con el Departamento de Servicios Sociales de Carolina de Norte, env\u00edela a: Carlotta Dixon, MHS, CPM Section Chief of Program Compliance Title VI\/ADA-Civil Rights Coordinator NC Division of Social Services 820 South Boylan MSC 2401 Raleigh, North Carolina 27699 In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027), found online at: http:\/\/www.ascr.usda.gov\/complaint_filing_cust.html, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410 (2) fax: (202) 690-7442; or (3) email: [email protected]. For any other information dealing with Supplemental Nutrition Assistance Program (SNAP) issues, persons should either contact the USDA SNAP Hotline Number at (800) 221-5689, which is also in Spanish or call the State Information\/Hotline Numbers (click the link for a listing of hotline numbers by State); found online at: http:\/\/www.fns.usda.gov\/snap\/contact_info\/hotlines.htm. To file a complaint of discrimination regarding a program receiving Federal financial assistance through the U.S. Department of Health and Human Services (HHS), write: HHS Director, Office for Civil Rights, Room 515-F, 200 Independence Avenue, S.W., Washington, D.C. 20201 or call (202) 619-0403 (voice) or (800) 537-7697 (TTY). Page 123 De conformidad con la Ley Federal de Derechos Civiles y los reglamentos y pol\u00edticas de derechos civiles del Departamento de Agricultura de los EE. UU. (USDA, por sus siglas en ingl\u00e9s), se proh\u00edbe que el USDA, sus agencias, oficinas, empleados e instituciones que participan o administran programas del USDA discriminen sobre la base de raza, color, nacionalidad, sexo, credo religioso, discapacidad, edad, creencias pol\u00edticas, o en represalia o venganza por actividades previas de derechos civiles en alg\u00fan programa o actividad realizados o financiados por el USDA o US HHS. Las personas con discapacidades que necesiten medios alternativos para la comunicaci\u00f3n de la informaci\u00f3n del programa (por ejemplo, sistema Braille, letras grandes, cintas de audio, lenguaje de se\u00f1as americano, etc.), deben ponerse en contacto con la agencia (estatal o local) en la que solicitaron los beneficios. Las personas sordas, con dificultades de audici\u00f3n o discapacidades del habla pueden comunicarse con el USDA por medio del Federal Relay Service [Servicio Federal de Retransmisi\u00f3n] al (800) 877-8339. Adem\u00e1s, la informaci\u00f3n del programa se puede proporcionar en otros idiomas. Para presentar una denuncia de discriminaci\u00f3n, complete el Formulario de Denuncia de Discriminaci\u00f3n del Programa del USDA, (AD-3027) que est\u00e1 disponible en l\u00ednea en: http:\/\/www.ocio.usda.gov\/sites\/default\/files\/docs\/2012\/Spanish_Form_508_Compliant_6_8_12_ 0.pdf. y en cualquier oficina del USDA, o bien escriba una carta dirigida al USDA e incluya en la carta toda la informaci\u00f3n solicitada en el formulario. Para solicitar una copia del formulario de denuncia, llame al (866) 632-9992. Haga llegar su formulario lleno o carta al USDA por: (1) correo: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410 (2) fax: (202) 690-7442; o (3) correo electr\u00f3nico: [email protected]. Para obtener informaci\u00f3n adicional relacionada con problemas con el Programa de Asistencia Nutricional Suplementaria (SNAP, por sus siglas en ingl\u00e9s), las personas deben comunicarse con el n\u00famero de l\u00ednea directa USDA SNAP Hotline al (800) 221-5689, que tambi\u00e9n est\u00e1 disponible en espa\u00f1ol, o llame a los n\u00fameros de informaci\u00f3n\/l\u00edneas directas de los estados (haga clic en el v\u00ednculo para ver una lista de los n\u00fameros de las l\u00edneas directas de cada estado) que se encuentran en l\u00ednea en: http:\/\/www.fns.usda.gov\/snap\/contact_info\/hotlines.htm Para presentar una denuncia de discriminaci\u00f3n relacionada con un programa que recibe asistencia financiera federal a trav\u00e9s del Departamento de Salud y Servicios Humanos de los EE. UU. (HHS, por sus siglas en ingl\u00e9s), escriba a: HHS Director, Office for Civil Rights, Room 515-F, 200 Independence Avenue, S.W., Washington, D.C. 20201, o llame al (202) 619-0403 (voz) o al (800) 537-7697 (sistema TTY). Page 124 NORTH DAKOTA Civil Rights Complaint Form Your Civil Rights Notification Page 125 CIVIL RIGHTS COMPLAINT NORTH DAKOTA DEPARTMENT OF HUMAN SERVICES LEGAL ADVISORY UNIT SFN 143 (7-2018) Individual or Organization Against Whom the Complaint is Made Basis of the Discrimination (check all that apply) Race Color Age Sex Religion Disability National Origin Status with Respect to Marriage or Public Assistance Political Beliefs+ Reason for Complaint – Describe in detail when, where, and how the alleged discrimination occurred. Signature (If electronically submitted, a typed name is considered a signature) Date Name Telephone Number Address City State ZIP Code Send to: Program Civil Rights Office North Dakota Department of Human Services, Legal Advisory Unit 600 E Boulevard Avenue, Department 325 Bismarck, ND 58505-0250 (701) 328-2311 TTY 1-800-366-6888; FAX (701) 328-2173 Page 126 shelbyhart-armstrong Rectangle shelbyhart-armstrong Highlight 53 CIVIL RIGHTS COMPLAINT NORTH DAKOTA DEPARTMENT OF HUMAN SERVICES LEGAL ADVISORY UNIT SFN 143 (1-2016) Individual or Organization Against Whom the Complaint is Made: Basis of the Discrimination (check all that apply): Race National Origin Color Religion Status with Respect to Marriage or Public Assistance Age Sex Disability Reason for complaint: (Describe in detail when, where, and how the alleged discrimination occurred.) Attach additional sheets, if needed. Address: Name (print): City: State: ZIP Code: Signature: Date: Telephone Number: Send to: Program Civil Rights Office North Dakota Department of Human Services, Legal Advisory Unit 600 E. Boulevard Avenue, Department 325 Bismarck, ND 58505-0250 701-328-2311 TTY 1-800-366-6888; FAX 701-328-2173 Political Beliefs+ Page 127 shelbyhart-armstrong Rectangle SFN 143 (7-2018) Page 2 of 2 NORTH DAKOTA DEPARTMENT OF HUMAN SERVICES YOUR CIVIL RIGHTS What is the policy of the North Dakota Department of Human Services (DHS)? Discrimination means treating someone differently because of a particular characteristic such as race, color, sex, age, disability, or religion. DHS makes available all services and assistance without regard to race, color, sex, age, disability, national origin, religion, political beliefs, or status with respect to marriage or public assistance. These laws must be followed by persons who contract with or receive funds to provide services for DHS, including the states eight regional human service centers, the State Hospital, the Developmental Center, and county social services. The policies of DHS also require that: You be given the chance to apply for assistance or services, or both. The same eligibility standards apply to you as those standards apply to others in similar situations. In accordance with Federal law, and U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) policy, DHS is prohibited from discriminating on the basis of race, color, sex, age, disability, national origin, religion, or political beliefs. What do I do if someone has discriminated against me? You may file a written complaint if you believe you have been discriminated against because of race, color, sex, age, disability, national origin, religion, or status with respect to marriage or public assistance, in accordance with Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Age Discrimination Act, the Americans with Disabilities Act, and the North Dakota Human Rights Act, or if you believe you have been discriminated against because of your political beliefs, in violation of USDA policy. A Civil Rights Complaint Form (SFN 143) is also available in a PDF fillable format at: http:\/\/www.nd.gov\/dhs\/misc\/nondiscrimination.html The Program Civil Rights Officer and Program ADA\/504 Coordinator work together to prevent and eliminate discrimination against individuals in the delivery of programs and services administered and supervised by DHS and to make all programs and activities accessible to people with disabilities. Where do I file a complaint? Persons who need accommodations or have questions related to discrimination and the delivery of human services may contact any of the following offices. Written complaints may be filed with your local county social service office or any of the following: Program Civil Rights Office North Dakota Department of Human Services Legal Advisory Unit 600 E. Boulevard Avenue, Department 325 Bismarck, ND 58505-0250 (701) 328-2311 TTY 1-800-366-6888; FAX (701) 328-2173 Email: [email protected] *U.S. Department of Health & Human Services Office for Civil Rights 200 Independence Avenue SW HHH Building, Room 509-F Washington, DC 20201 1-800-368-1019 TDD 1-800-537-7697; FAX (202) 619-3437 Email: [email protected] *U.S. Department of Health & Human Services Office for Civil Rights, Region VIII 1961 Stout Street, Room 08-148 Denver, CO 80294 1-800-368-1019 TDD 1-800-537-7697; FAX (202) 619-3818 Email: [email protected] * + U.S. Department of Agriculture Director, Office of Adjudication 1400 Independence Avenue SW Washington, DC 20250-9410 1-866-632-9992 TTY 1-800-877-8339; FAX (202) 690-7442 Email: [email protected] *State and local agencies are required to comply with the North Dakota Human Rights Laws that prohibit discrimination based on status with respect to marriage or public assistance. However, federal agencies are not required to investigate complaints based on the North Dakota Human Rights Laws. + Under USDA policy, discrimination is prohibited also on the basis of religion or political beliefs. When should I file a complaint? The complaint must be filed within 180 days of the incident. Include in your complaint the nature of the discrimination, where and when it took place, who discriminated against you, and all other important facts. Remember to date the form and sign your name. What happens when I file a complaint with the DHS Program Civil Rights Office? The Program Civil Rights Office will determine if the nature of the complaint is within its jurisdiction. If it is, an investigation will be conducted and you will know the outcome of the complaint within 60 business days of when it was filed. If it is not, you will receive a letter. If you file your complaint with another agency, they will notify you according to their policies. Page 128 http:\/\/www.nd.gov\/dhs\/misc\/nondiscrimination.html shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle 5149 44 DRAFT What is the policy of the Department of Human Services (DHS)? DHS makes available all services and assistance without regard to race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance. Persons who contract with or receive funds to provide services for DHS must follow these laws. The policies of DHS also require that: You be given the chance to apply for assistance and\/or services The same eligibility standards applied to you as others in similar situations In accordance with Federal law and U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) policy, ND DHS is prohibited from discriminating on the basis of You may file a written complaint using the SFN 143 Civil Rights Complaint Form on the following page if you believe you have been discriminated against because of race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance, in accordance with Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Age Discrimination Act, the Americans with Disabilities Act, and the North Dakota Human Rights Act. Where do I file a complaint? Written complaints can be filed with your local county social service office or any of the following: Beth Steffan, Program Civil Rights Officer North Dakota Department of Human Services 600 East Boulevard Ave Bismarck, ND 58505-0250 701-328-2311 or 1-800-755-2671 1-800-366-6888 (Relay ND text and voice) *US Department of Health & Human Services Office for Civil Rights, Region VIII Federal Office Building 1961 Stout Street, Room 1426 Denver, CO 80294 303-844-2024 *Health and Human Services, Director Office for Civil Rights, Room 506-F 200 Independence Avenue, S.W. Washington, D.C. 20201 202-619-0403 TDD 202-619-3257 **US Department of Agriculture, Director Office of Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410 800-795-3272 202-720-3808 (TTY) TTY 303-844-3439 *State and local agencies are required to comply with the ND Human Rights Law that include status complaints related to the ND Human Rights Laws. Civil Rights What do I do if someone has discriminated against me? race, color, national origin, sex, age, or disability. Under the Food and Nutrition Act of 2008 and USDA policy, discrimination is prohibited also on the basis of religion or political beliefs. with respect to marriage or public assistance . However, federal agencies are not required to investigate ** Under the Food and Nutrition Act of 2008 and USDA policy, discrimination is prohibited also on the basis of religion or political beliefs. Program Civil Rights Officer North Dakota Department of Human Services Legal Advisory Unit 600 E. Boulevard Avenue, Department 325 Bismarck, ND 58505-0250 701-328-2311 TTY 800-366-6888 Fax 701-328-2173 *U.S. Department of Health & Human Services Office for Civil Rights, Region VIII 999 18th Street, Suite 417 Denver, CO 80202 800-368-1019 TTY 800-537-7697 Fax 303-844-2025 *U.S. Department of Health & Human Services Office for Civil Rights 200 Independence Avenue SW HHH Building, Room 515-F Washington, DC 20201 202-619-0403 TTY 800-537-7697 Fax 202-619-3437 *U.S. Department of Agriculture Office of Adjudication 1400 Independence Avenue SW Washington, DC 20250-9410 866-632-9992 Fax 202-690-7442 TTY 800-877-8339 Email: [email protected] DRAFT What is the policy of the Department of Human Services (DHS)? DHS makes available all services and assistance without regard to race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance. Persons who contract with or receive funds to provide services for DHS must follow these laws. The policies of DHS also require that: You be given the chance to apply for assistance and\/or services The same eligibility standards applied to you as others in similar situations In accordance with Federal law and U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) policy, ND DHS is prohibited from discriminating on the basis of You may file a written complaint using the SFN 143 Civil Rights Complaint Form on the following page if you believe you have been discriminated against because of race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance, in accordance with Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Age Discrimination Act, the Americans with Disabilities Act, and the North Dakota Human Rights Act. Where do I file a complaint? Written complaints can be filed with your local county social service office or any of the following: Beth Steffan, Program Civil Rights Officer North Dakota Department of Human Services 600 East Boulevard Ave Bismarck, ND 58505-0250 701-328-2311 or 1-800-755-2671 1-800-366-6888 (Relay ND text and voice) *US Department of Health & Human Services Office for Civil Rights, Region VIII Federal Office Building 1961 Stout Street, Room 1426 Denver, CO 80294 303-844-2024 *Health and Human Services, Director Office for Civil Rights, Room 506-F 200 Independence Avenue, S.W. Washington, D.C. 20201 202-619-0403 TDD 202-619-3257 **US Department of Agriculture, Director Office of Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410 800-795-3272 202-720-3808 (TTY) TTY 303-844-3439 *State and local agencies are required to comply with the ND Human Rights Law that include status complaints related to the ND Human Rights Laws. Civil Rights What do I do if someone has discriminated against me? race, color, national origin, sex, age, or disability. Under the Food and Nutrition Act of 2008 and USDA policy, discrimination is prohibited also on the basis of religion or political beliefs. with respect to marriage or public assistance . However, federal agencies are not required to investigate ** Under the Food and Nutrition Act of 2008 and USDA policy, discrimination is prohibited also on the basis of religion or political beliefs. What is the policy of the Department of Human Services (DHS)? DHS makes available all services and assistance without regard to race, color, religion, national origin, age, sex, disability, political beliefs, or status with respect to marriage or public assistance. Persons who contract with or receive funds to provide services for DHS must follow these laws. The policies of DHS also require that: You be given the chance to apply for assistance and\/or services, or both. The same eligibility standards applied to you as others in similar situations. In accordance with Federal law and U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) policy, ND DHS is prohibited from discriminating on the basis of race, color, national origin, sex, age, disability, religion or political beliefs. What do I do if someone has discriminated against me? You may file a written complaint using the SF 143 Civil Rights Complaint Form on the following page if you believe you have been discriminated against because of race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance, in accordance with Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Age Discrimination At, the Americans with Disabilities Act, and the North Dakota Human Rights Act, or if you believe you have been discriminated against because of your political beliefs, in violation of USDA policy. Where do I file a complaint? Written complaints can be filed with your local county social service office or any of the following: What is the policy of the Department of Human Services (DHS)? DHS makes available all services and assistance without regard to race, color, religion, national origin, age, sex, disability, political beliefs, or status with respect to marriage or public assistance. Persons who contract with or receive funds to provide services for DHS must follow these laws. The policies of DHS also require that: You be given the chance to apply for assistance and\/or services, or both. The same eligibility standards applied to you as others in similar situations. In accordance with Federal law and U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) policy, ND DHS is prohibited from discriminating on the ba- sis of race, color, national origin, sex, age, disability, religion or political beliefs. What do I do if someone has discriminated against me? You may file a written complaint using the SFN143 – Civil Rights Complaint Form on the following page if you believe you have been discriminated against because of race, color, religion, national origin, age, sex, disability or status with respect to marriage or public assistance, in accordance with Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Age Discrimination Act, the Americans with Disabilities Act and the North Dakota Human Rights Act, or if you believe you have been discriminated against because of your political beliefs, in violation of USDA policy. Where do I file a complaint? Written complaints can be filed with your local county social service office or any of the following: Program Civil Rights Officer *U.S. Department of Health & Human Services North Dakota Department of Human Services Office of Civil Rights Legal Advisory Unit 200 Independence Avenue SW 600 E. Boulevard Avenue, Department 325 HHH Building, Room 515-F Bismarck, ND 58505-0250 Washington, DC 20201 701-328-2311 202-619-0403 TTY 800-366-6888 TTY 800-537-7697 Fax 701-328-2173 Fax 202-619-3437 *U.S. Department of Health & Human Services *U.S. Department of Agriculture Office for Civil Rights, Region VIII Office of Adjudication 999 18th Street, Suite 417 1400 Independence Avenue SW Denver, CO 80202 Washington, DC 20250-9410 800-368-1019 866-632-9992 TTY 800-537-7697 Fax 202-690-7442 Fax 303-844-2025 TTY 800-877-8339 Email: [email protected] Program Civil Rights Office U.S. Department of Health & Human Services Office for Civil Rights 200 Independence Avenue SW HHH Building, Room 509-F U.S. Department of Health & Human Services Office for Civil Rights, Region VIII 1961 Stout Street Room 08-148 Denver, CO 80294 800-368-1019 TDD 800-537-7697 Fax 202-619-3818 The policies of DHS also require that: You be given the chance to apply for assistance and\/or services, or both. * The same eligibility standards applied to you as others in similar situations. Page 129 52 **State and local agencies are required to comply with the ND Human Rights Law that includes status with respect to marriage or public assistance . However, federal agencies are not required to investigate complaints related to the ND Human Rights Laws. When should I file a complaint? The complaint must be filed within 180 days of the incident. Include in your complaint the nature of the discrimination; where and when it took place; who discriminated against you; and all other important facts. Remember to date the form and sign your name. What happens when I file a complaint with the ND DHS Program Civil Rights Office? The Program Civil Rights Office will determine if the nature of the complaint is within its jurisdic- tion. If it is, an investigation will be conducted and you will know the outcome of the complaint within 60 business days of when it was filed. If it is not, you will receive a letter. If you file your complaint with another agency, they will notify you accordingly. Page 130 OHIO – Civil Rights Complaint Notification on Back of Benefits Applications – Cuyahoga County Affirmation Statement Regarding Title VI and LEP Training – Discrimination Complaint – Ohio Discrimination Complaint Process Flowchart Page 131 Page 132 Page 133 Page 134 Page 135 shelbyhart-armstrong Rectangle shelbyhart-armstrong Text Box Ohio includes complaint process notification (+ how to file complaint) at the end of every application for public benefits Page 136 shelbyhart-armstrong Rectangle shelbyhart-armstrong Text Box Ohio requires county workers to sign affidavit after trainings reiterating their pledge to provide interprets to users with LEP shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight shelbyhart-armstrong Highlight Page 137 Ohio Department of Job and Family Services Bureau of Civil Rights (BCR) Discrimination Complaint Process Allegation of Discrimination, Harassment or Retaliation Must be filed 180 days from the alleged act. For MEPA 2 years from the alleged act Complaint filed with BCR BCR will review and determine to accept or reject Complaint filed with County Agency \/ One Stop County Civil Rights Coordinator will review complaint and forward it to BCR Probable Cause Finding Investigative report revealed probable cause; BCR should identify the corrective action to be taken in the investigative report. No Probable Cause Finding Investigative report revealed no probable cause. If the Complainant does not agree with the finding, Complainant can appeal to the appropriate federal agencies. Corrective Action If Respondent is not in agreement with the corrective actions, Respondent can appeal to the ODJFS Director BCR screens complaint to determine jurisdiction, if not within jurisdiction, then it will be sent to the appropriate entity BCR mediation process BCR reviews and monitor progress of the corrective actions until completed Case closed Case closed Case closed If referred to entity case closed Investigation A BCR EEO representative will investigate allegations within 90 days from the acceptance date and issue the investigative report findings to the county agency and to the complainant\/representatives. If accepted, BCR may offer the option to mediate. Successful mediation Unsuccessful mediation Page 138 OREGON – Website: Filing Customer Service or Privacy Complaints or a Report of Discrimination – Customer Service\/Civil Rights Complaint Form Page 139 Filing Customer Service or Privacy Complaints or a Report of Discrimination If you have a complaint regarding the services you received from the Department of Human Services (DHS), the protection of your private information or feel you have been discriminated against, this document will explain the process to file a report of discrimination, or a customer service or privacy complaint. Mail, fax or email completed complaint to: Department of Human Services Governor’s Advocacy Office 500 Summer Street N.E., E-17 Salem, OR 97310-1097 Fax: 503-378-6532 Email: [email protected] This document can be provided upon request in alternate formats for individuals with disabilities or in a language other than English for individuals with limited English skills. To request this form in another format or language, contact the Governor’s Advocacy Office at 503-945-5941. Do not use this form if either of the following applies to you: 1. Your complaint is with the Office of Vocational Rehabilitation Services (OVRS). If you disagree with an action or decision, contact your local OVRS office or call the OVRS dispute resolution coordinator at 503-945-6253. Free legal services are available from the Client Assistance Program (CAP), a service of Disability Rights Oregon. CAP is not a state agency or part of OVRS. Contact CAP at: Voice: 503-243-2081 Toll-free voice: 1-800-452-1694 TTY at 503-323-9161 and toll-free TTY at 1-800-556-5351 2. Your complaint is with Child Welfare Services and you disagree with a decision that was made. Please contact your DHS caseworker or local Child Welfare Office and ask what can be done about the decision. Do not use this form for such things as: Adoption committee decision; Court rulings or matters to be reviewed by the juvenile court; Child protective services actions or decisions; You have asked for a contested case hearing or started some other court action; Any other exception found in Oregon Administrative Rules 413-010-043. Page 140 DHS customer service and confidentiality expectations Good customer service is important to DHS. You have the right to: Be treated fairly and respectfully; Receive correct and complete information; Have DHS programs and benefits that you qualify for explained; Have your calls returned within one or two working days; Have your benefits or changes processed in a reasonable amount of time; Have your health and personal information kept confidential. Resolving customer service and privacy complaints DHS wants to provide quality customer service and to keep your personal information confidential. However, if you are not satisfied or have a complaint, DHS recommends that you first talk to your worker\/counselor or talk to a manager. However, you do not need to do this before you file a complaint. You can file a complaint by completing this form within 60 days after the incident happened. This form may be returned to any DHS office or forwarded directly to the Governor’s Advocacy Office (GAO), (the contact information is listed on page one). What happens after you file a customer service complaint A DHS manager will contact you as soon as possible, but no later than five business days after receiving the complaint. (This could take more than five days if you do not have a telephone.) The manager may set up a meeting with you to try to resolve the complaint. The meeting could be in person or by telephone. Complaints that are not resolved at this meeting will be reviewed by other DHS managers and you may be contacted again. If your complaint is about an employee, the employee will be notified about the complaint. The employee has the right to respond to the complaint and may be present at any meeting or phone conference that is held. The employee will be given the chance to respond in writing to your complaint. Any personnel action as a result of a complaint against an employee will remain confidential. Employees may not take action against a client for filing a complaint. All complaints will be forwarded to and reviewed by the GAO. Discrimination complaints filed with DHS Civil rights laws and DHS rules and policies state that you have the right to file a discrimination complaint if you feel that DHS has kept you from receiving equal service and benefits because of your age, race, color, national origin and disability, and in some federally funded programs, age, gender, religion, sexual orientation and political beliefs. Page 141 What happens after you file a discrimination complaint You may file a written complaint by completing this form within 60 days of the incident. A DHS civil rights investigator will contact you within 20 working days to learn more about your complaint. Within 20 working days of talking with the investigator, DHS will send you a written decision. Appeal rights are outlined in the written decision. Federal discrimination or privacy complaints Privacy violations or discrimination complaints alleging that DHS has not provided you with equal service because of your age, race, color or national origin, gender, religion or disability can also be filed with the U.S. Office for Civil Rights. Federal discrimination complaints must be submitted within 180 days of the incident. Even if you file a complaint first with DHS, you still must file a federal complaint within 180 days of the incident. Contact the specific program listed below to receive more information. Federal limitations Sexual orientation discrimination is protected by the State of Oregon but not by federal laws. Only Supplemental Nutrition Assistance Program (SNAP) benefit clients are protected against discrimination based on their political beliefs. For issues involving SNAP benefits For issues involving Vocational Rehabilitation U.S. Department of Agriculture U.S. Department of Education Voice: 1-866-632-9992 Voice: 1-800-421-3481 TTY: 1-202-720-2600 TTY: 1-800-877-8339 For issues involving all other programs U.S. Department of Health & Human Services Voice: 1-800-368-1019 TTY: 1-800-537-7697 About requesting an administrative hearing If your benefits were denied, reduced, or ended, you have the right to request a contested case hearing. You may request a hearing and file a complaint. To request a hearing, complete the Administrative Hearing Request form (DHS 0443). You may get an Administrative Hearing Request form at any DHS office, request the form from the Governor’s Advocacy Office (GAO) at 1-800-442-5238, or download the form at https:\/\/apps.state.or.us\/cf1\/FORMS. You may also call the Public Benefits Hotline at 1-800-520-5292, operated by the Oregon Law Center and Legal Aid Services of Oregon. Your hearing request form can be returned to any DHS office. A hearing request is not the same as filing a complaint. There are strict deadlines for filing a hearing request. When you file a hearing request you are asking for a Contested Case Hearing before an Administrative Law Judge. Note: Requesting a hearing about SNAP benefits can be made verbally. Page 142 https:\/\/apps.state.or.us\/cf1\/FORMS shelbyhart-armstrong Rectangle Customer Service\/Privacy Complaint or Report of Discrimination For help completing this form, you may contact any DHS office. Please print clearly: Name of person with the complaint: Phone\/TTY number: Email: Mailing address: Date of birth: City: State: ZIP: Last 4 digits of Social Security number: Are you filing on behalf of someone else? Yes No Your name: Phone: Please mark the reason for your complaint (check all that apply): You did not receive good customer service; You believe your personal information was not kept confidential; You believe you were discriminated against because of: Age Gender Sexual orientation* Political beliefs** Religion Disability Race, color or national origin *Sexual orientation is protected by the State of Oregon, but not federal laws. **SNAP clients are protected against political belief discrimination. Details of complaint: Who was involved? When did the incident happen? Date\/time: Location of complaint: Please describe your complaint (if you need more space, attach additional paper): What would you like DHS to do to resolve your complaint? What suggestions do you have? Signature: Date: For DHS use only Date received: Received by (print name): *For discrimination and privacy complaints, send to Governor’s Advocacy Office, address on page 1. *For customer service complaints, forward to the appropriate manager. Distribution: Original – GAO; Copy – Client; Copy – Manager Page 143 shelbyhart-armstrong Text Box Oregon has customer service & civil rights complaint on same intake form and allows users to check both. The drawback of this practice is that users who have discrimination complaint may just check the customer service box out of fear of retaliation or alleging an discrimination complaint MINNESOTA – Website: Civil Rights in Human Services Page 144 2\/13\/2019 Civil rights in human services \/ Minnesota Department of Human Services https:\/\/mn.gov\/dhs\/general-public\/about-dhs\/administration-management\/civil-rights.jsp 1\/5 Civil rights in human services Minnesota Department of Human Services Civil Rights Plan (PDF) (http:\/\/edocs.dhs.state.mn.us\/lfserver\/Legacy\/DHS-5362-ENG) Your right to fair treatment The Department of Human Services (DHS), county human service agencies and other service providers are committed to providing equal access to programs and services for eligible Minnesotans. It is also important for applicants and clients to know and understand their civil rights. They have the right to fair and equal treatment from service providers and the right to \ufffdle a complaint with federal, state or local human service agencies if they feel they have been treated in a discriminatory way in receiving services. Our role in preventing discrimination DHS works with county agencies and other service providers to help eligible individuals and families meet basic human needs. To make services possible, DHS receives funding from federal agencies. As a recipient of federal funding, DHS must treat all applicants and clients fairly and equally. To prevent discrimination, DHS has a civil rights plan. The plan includes an equal opportunity policy and a procedure for \ufffdling complaints. The plan also identi\ufffdes a contact person who you can call to speak about civil rights matters. The role of county human services agencies and other providers County human service agencies and other providers also receive federal funds to operate public programs. Like DHS, they must follow civil rights requirements. They must treat applicants and clients equally and have an equal opportunity policy and complaint procedure available for the public. Who to contact DHS has a civil rights contact person who makes sure that applicants and clients have equal access to services. This person is responsible for: Handling discrimination complaints Keeping civil rights records and \ufffdles Giving information about civil rights laws and other matters to human services workers and applicants, clients and members of the public Acting as liaison between DHS and federal agencies and others concerned about fair service delivery Page 145 http:\/\/edocs.dhs.state.mn.us\/lfserver\/Legacy\/DHS-5362-ENG 2\/13\/2019 Civil rights in human services \/ Minnesota Department of Human Services https:\/\/mn.gov\/dhs\/general-public\/about-dhs\/administration-management\/civil-rights.jsp 2\/5 Providing training and education to human services workers. To reach the civil rights contact person, call or write to the Equal Opportunity and Access Division. How to \ufffdle a complaint All human services agencies must treat you fairly and equally. If you believe that someone working for a human services agency discriminated against you, you may \ufffdle a civil rights complaint. The Minnesota Department of Human Services, Equal Opportunity and Access Division, prohibits discrimination in its programs because of race, color, national origin, creed, religion, sexual orientation, public assistance status, age, disability or sex (including sex stereotypes and gender identity under any health program or activity receiving federal \ufffdnancial assistance). You have one year after the unfair treatment to \ufffdle a complaint. To ask for a complaint form, contact the Equal Opportunity and Access Division directly: Minnesota Department of Human Services Equal Opportunity and Access Division P.O. Box 64997 St. Paul, MN 55164-0997 651-431-3040 (voice) or use your preferred relay service If you need help \ufffdlling out the complaint form, we can help you. We can provide spoken language interpreters for non-English speakers. We can provide a reasonable modi\ufffdcation, auxiliary aids\/services, or provide accessible formats for a disability, such as a sign language interpreter, Braille or large print materials. To arrange for an interpreter, accessible formats, a reasonable modi\ufffdcation or auxiliary aids\/services, contact the Equal Opportunity and Access Division at the above address. If you \ufffdle a complaint against a human services agency, agency workers cannot punish or retaliate against you in any way. If this happens, report it to the Equal Opportunity and Access Division. If you want to \ufffdle a complaint with your county agency, contact the agency director and ask for its complaint procedure. Other important agencies Page 146 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle 2\/13\/2019 Civil rights in human services \/ Minnesota Department of Human Services https:\/\/mn.gov\/dhs\/general-public\/about-dhs\/administration-management\/civil-rights.jsp 3\/5 The Minnesota Department of Human Rights prohibits discrimination in public services programs because of race, color, creed, religion, national origin, disability, sex, sexual orientation, or public assistance status. You have one year after the unfair treatment to \ufffdle a complaint. To ask for a complaint form, contact the Minnesota Department of Human Rights directly: Minnesota Department of Human Rights Freeman Building, 625 North Robert Street St. Paul, MN 55155 651-539-1100 (voice) 800-657-3704 (toll free) 651-296-1283 (TTY) The U.S. Department of Health and Human Services’ O\ufffdce for Civil Rights prohibits discrimination in its programs because of race, color, national origin, age, disability and in some cases religion and sex. You have 180 days after the unfair treatment to \ufffdle a complaint. To ask for a complaint form, contact the federal agency directly: U.S. Department of Health and Human Services O\ufffdce for Civil Rights, Region V 233 North Michigan Avenue, Suite 240 Chicago, IL 60601 312-886-2359 (voice) 800-368-1019 (toll free) 800-537-7697 (TTY) The U.S. Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and\/or employment activities.) If you wish to \ufffdle a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http:\/\/www.ascr.usda.gov\/complaint_\ufffdling_cust.html (http:\/\/www.ascr.usda.gov\/complaint_\ufffdling_cust.html), or at any USDA o\ufffdce, or call 866-632- 9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, O\ufffdce of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax 202-690-7442 or email at [email protected] (mailto:[email protected]). Page 147 http:\/\/www.ascr.usda.gov\/complaint_filing_cust.html mailto:[email protected] 2\/13\/2019 Civil rights in human services \/ Minnesota Department of Human Services https:\/\/mn.gov\/dhs\/general-public\/about-dhs\/administration-management\/civil-rights.jsp 4\/5 Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at 800-877-8339; or 800-845-6136 (Spanish). For any other information dealing with Supplemental Nutrition Assistance Program (SNAP) issues, persons should either contact the USDA SNAP Hotline Number at 800-221-5689, which is also in Spanish or call the state information\/hotline numbers (click the link for a listing of hotline numbers by state); found online at http:\/\/www.fns.usda.gov\/snap\/contact_info\/hotlines.htm (http:\/\/www.fns.usda.gov\/snap\/contact_info\/hotlines.htm). USDA is an equal opportunity provider and employer. Contact the Equal Opportunity and Access Division with any questions about this website page: Minnesota Department of Human Services Equal Opportunity and Access Division P.O. Box 64997 St. Paul, MN 55164-0997 651-431-3040 (voice) or use your preferred relay service Discrimination frequently asked questions Who can \ufffdle a discrimination complaint? Service recipients, employees and a\ufffdliates (i.e., a vendor or a contractor) of the Department of Human Services can \ufffdle a discrimination complaint. If I am a recipient of services, can I \ufffdle a discrimination complaint at my county human services agency? Yes, you can. Just contact your county human services agency directly. If I do not want to \ufffdle a discrimination complaint with my county human services agency, are there other agencies that I can \ufffdle a complaint? You can contact the Equal Opportunity and Access Division, part of the O\ufffdce for Equity, Performance and Development, for information about other important agencies where you can \ufffdle discrimination complaints against a human services agency or see the client’s civil rights information. Page 148 http:\/\/www.fns.usda.gov\/snap\/contact_info\/hotlines.htm shelbyhart-armstrong Rectangle 2\/13\/2019 Civil rights in human services \/ Minnesota Department of Human Services https:\/\/mn.gov\/dhs\/general-public\/about-dhs\/administration-management\/civil-rights.jsp 5\/5 Updated: 2016-04-10 If I am neither a DHS employee or a\ufffdliate, nor a recipient of services funded by DHS where can I \ufffdle a discrimination complaint? You can \ufffdle a discrimination complaint with the Minnesota Department of Human Rights (http:\/\/mn.gov\/mdhr\/), or the Equal Employment Opportunity Commission (http:\/\/www.eeoc.gov\/). Where can I get some general information about discrimination or harassment? You can review the information from the O\ufffdce for Equity, Performance and Development or contact the Equal Opportunity and Access Division at the following: Equal Opportunity and Access Division O\ufffdce for Equity, Performance and Development Minnesota Department of Human Services P.O. Box 64997 St. Paul, MN 55164-0997 Voice: 651-431-3040 TTY: 866-786-3945 Page 149 http:\/\/mn.gov\/mdhr\/ http:\/\/www.eeoc.gov\/ 2\/23\/2019 cp_guidelines \/ Minnesota.gov https:\/\/mn.gov\/mdhr\/intake\/resources\/cp-guidelines.jsp 1\/3 Soomaali (\/mdhr\/yourrights\/fact-sheets\/soomaali\/index.jsp) | Espa\u00f1ol (\/mdhr\/yourrights\/fact-sheets\/spanish\/index.jsp) | Hmoob (\/mdhr\/yourrights\/fact-sheets\/hmoob\/index.jsp) (\/mdhr\/index.jsp) File a Complaint Guidelines for Charging Parties The time limit for \ufffdling a charge with the Minnesota Department of Human Rights (MDHR) is one year from the date of the incident. If you are close to the one-year deadline, contact us immediately at 651.539.1100 or Toll Free 800.657.3704. The one-year period begins running from the date of the alleged discriminatory act. If you have questions about the terminology used on our website, visit our glossary (\/mdhr\/glossary.jsp). \uf146 Your Investigation What the Department Investigates The Department of Human Rights investigates charges of discrimination in employment, housing, public accommodations, public services, education, credit, and business contracts. It is illegal to discriminate against someone because of their race, color, creed, religion, national origin, sex, sexual orientation, marital status, physical or mental disability, use of public assistance, age, or family status. It is also illegal to aid in a violation of the Minnesota Human Rights Act or to coerce a person to violate it, obstruct compliance with the Act, or interfere with the Department’s performance of its duties. The Act also prohibits reprisal or retaliation because a person opposed a practice forbidden by the Act, \ufffdled a charge or participated in a matter brought under the Act, or because a person is associated with a person or group of persons who are disabled or of a di\ufffderent race, color, creed, religion, sexual orientation or national origin. Page 150 https:\/\/mn.gov\/mdhr\/yourrights\/fact-sheets\/soomaali\/index.jsp https:\/\/mn.gov\/mdhr\/yourrights\/fact-sheets\/spanish\/index.jsp https:\/\/mn.gov\/mdhr\/yourrights\/fact-sheets\/hmoob\/index.jsp https:\/\/mn.gov\/mdhr\/index.jsp https:\/\/mn.gov\/mdhr\/glossary.jsp 2\/23\/2019 cp_guidelines \/ Minnesota.gov https:\/\/mn.gov\/mdhr\/intake\/resources\/cp-guidelines.jsp 2\/3 Our Charge Filing Process A Department investigator or enforcement o\ufffdcer will review your information to see if you have a valid complaint for \ufffdling a charge under the Minnesota Human Rights Act. If so, the Department will write a formal, written charge and mail it to you. If not, the Department therefore does not write a charge for you, and the reasons will be explained to you. You must sign the charge before a notary public who will witness your signature. Then, you must return the signed and notarized charge for \ufffdling within one year of when the discrimination occurred. After you return the signed charge, it will be served on the respondent to provide an answer. \uf146 How You Can Help Keep Good Records If the Department \ufffdnds that you were illegally discriminated against, you could be awarded damages such as back pay or other losses directly caused by the discrimination. In employment discrimination cases, keep a record of your earnings or your e\ufffdorts to \ufffdnd work after the discriminatory action. If Your Address or Telephone Number Changes You must notify the Department in writing if your address or telephone number change. If we cannot contact you or get information from you about your case, your case may be dismissed. We send notices by regular or certi\ufffded mail, so be sure to open your mail promptly and read everything carefully so you provide an appropriate response. Notify the Department in writing if you will be away from home for more than two weeks. \uf146 After You File What You Will Receive from the Department After your charge is \ufffdled, you will receive another copy of the written charge with a case reference number written on it. Whenever you contact the Department, you should refer to your case number. Also, once the respondent submits an answer to your charge, a copy of the answer will be sent to you as required by law. How the Department Investigates a Charge When we receive the respondent’s answer along with other necessary information, the Department will collect information necessary to determine if your allegations of discrimination warrant a formal investigation. This does not mean that the Department has decided there has been a violation of the law. It simply means that you have made a complaint that the Department has authority to investigate. At this stage, the Department takes no position and looks at evidence from both sides. If Your Charge Involves Federal Laws. Your charge may be \ufffdled at the federal Equal Employment Opportunity Commission (EEOC) (http:\/\/www.eeoc.gov\/) if it meets the criteria for \ufffdling under the federal employment discrimination laws enforced by that agency. Under our work-share agreement with EEOC and if your charge is eligible, we will automatically cross \ufffdle it with EEOC. To do this, your complaint must be within the statute of limitations for the applicable federal law. Federal laws have a shorter period for \ufffdling a complaint. If the Discrimination Happened in Saint Paul or in Minneapolis. You have the option of \ufffdling with the St. Paul Human Rights Department (http:\/\/www.stpaul.gov\/index.aspx?NID=2403) Minneapolis Department of Civil Rights<> instead of \ufffdling with this Department. The Di\ufffderence between a Charge and a Lawsuit Page 151 http:\/\/www.eeoc.gov\/ http:\/\/www.stpaul.gov\/index.aspx?NID=2403 shelbyhart-armstrong Rectangle 2\/23\/2019 cp_guidelines \/ Minnesota.gov https:\/\/mn.gov\/mdhr\/intake\/resources\/cp-guidelines.jsp 3\/3 Filing a charge is not the same as \ufffdling a lawsuit. The Department does not represent either you or the party against whom you have \ufffdled. The Department will investigate both sides of the complaint and conduct a neutral investigation. You do not have to have a private attorney during this process. You may hire a private attorney to represent you while your charge is being investigated by the Department. If you want to withdraw your case from the Department and \ufffdle a civil lawsuit in district court, you may consult an attorney. What To Do if Someone \”Gets Even\” with You for Making Your Complaint If anyone takes action against you because you contacted a civil rights agency or made a complaint about illegal discrimination against them, you may \ufffdle a reprisal charge about that action. What Happens When the Department Conducts an Investigation After the Department has investigated your complaint, the Commissioner of the Department of Human Rights will decide, based on the evidence, whether discrimination probably occurred (\”probable cause\”) or not (\”no probable cause\”). The Commissioner May Find Evidence of Discrimination If the commissioner decides there is probable cause or evidence to believe discrimination occurred, the Department will invite you and the respondent to discuss settling the case. If settlement fails, the case may be refer[red] to the Minnesota State Attorney General’s O\ufffdce for further action. The commissioner may \ufffdnd no probable cause or no evidence to believe discrimination occurred. In that situation , the Department will close the case. Page 152 shelbyhart-armstrong Rectangle shelbyhart-armstrong Rectangle APPENDIX F Child Protective Services Appendix Page 153 4\/16\/2019 Racial Equity, Diversity and Inclusion | Washington State Department of Children, Youth, and Families https:\/\/www.dcyf.wa.gov\/practice\/racial-equity-diversity-inclusion 1\/4 \uf015 \uf105 OUR PRACTICE (\/PRACTICE) \uf105 RACIAL EQUITY, DIVERSITY AND INCLUSION Racial Equity, Diversity and Inclusion The Department of Children, Youth and Families (DCYF) is committed to Washington’s children and youth growing up safe, healthy, and thriving. Currently children of color are underrepresented in the percentage of children entering kindergarten with the skills they need to be successful. Children and youth of color enter and remain in the child welfare system at greater rates. Youth of color are also disproportionately represented as they enter and progress through the juvenile justice system. Underlying systems, policies and practices are driving these disparate outcomes and experiences. DCYF will transform the way we operate to promote racial equity, diversity, inclusion, and justice, so each and every child, youth and family can thrive. The Work So Far Each of the originating agencies have been engaged in the foundational e\ufffdorts necessary to make progress on our long term goals of impacting child and family outcomes. This has included building the will, skill and capacity of leaders and sta\ufffd to lead for equity, diversity, and promote inclusion. Representatives from Children’s Administration, Department of Early Learning, the O\ufffdce of Juvenile Justice and the Juvenile Rehabilitation Administration formed an Equity Workgroup, whose mission is to de\ufffdne how we bring our work together into an integrated strategy for DCYF. Initial Priorities \uf071 Select Language Search…\uf002 Top Page 154 https:\/\/www.dcyf.wa.gov\/practice javascript:void(0) 4\/16\/2019 Racial Equity, Diversity and Inclusion | Washington State Department of Children, Youth, and Families https:\/\/www.dcyf.wa.gov\/practice\/racial-equity-diversity-inclusion 2\/4 DCYF can only be successful when we collaborate with children, youth, families, communities and tribes who are most impacted and often marginalized in de\ufffdning our action plan. As we embark on that process, the following represent several initial priority strategies. 1. Pay attention to data about outcomes for children, youth, and families consistently. Disaggregate data by race, ethnicity, sexual orientation, gender identity, gender expression and geographic areas. Use both quanti\ufffdable data and individuals’ stories and experience to inform our actions and provide accountability. 2. Sta\ufffdng and leadership that re\ufffdect and are responsive to the communities we serve. Recruit, retain, promote and provide supports for people with diverse backgrounds, experiences and ideas. Create a positive workplace climate to increase job satisfaction and e\ufffdectiveness. 3. Lead for racial equity, diversity, and inclusion. Provide training and resources for DCYF sta\ufffd on taking an intersectional approach, which recognizes that people sit at the intersection of race, gender, sexual orientation, gender, and gender expression, class, and other ways of experiencing barriers and oppression. Training, coaching and support will also be provided on understanding how racism and other biases show up in our organizations and systems; applying a racial equity lens in our work; recognizing and mitigating implicit biases; and practicing cultural humility and responsiveness. What Next In the coming months, DCYF will invite communities to engage in de\ufffdning our racial equity, diversity and inclusion strategies. We look forward to partnering with you! Contact Child Welfare: Dae Shogren (mailto:[email protected]) Early Learning & Family Support: Evette Jasper (mailto:[email protected]) O\ufffdce of Juvenile Justice: Vazaskia Crockrell (mailto:[email protected]) Juvenile Rehabilitation: LaToya Holmes-Ware (mailto:[email protected]) *Note that Juvenile Rehabilitation and the O\ufffdce of Juvenile Justice formally join DCYF in July 2019. Top Page 155 mailto:[email protected] mailto:[email protected] mailto:[email protected] mailto:[email protected] 4\/16\/2019 Racial Equity, Diversity and Inclusion | Washington State Department of Children, Youth, and Families https:\/\/www.dcyf.wa.gov\/practice\/racial-equity-diversity-inclusion 3\/4 Child Welfare Racial Disproportionality and Disparity in Washington State (2016) (\/sites\/default\/\ufffdles\/pdf\/reports\/2016DisproportionalityReport-CA.pdf) Child Welfare Racial Disproportionality and Disparity in Washington State (2017) (\/sites\/default\/\ufffdles\/pdf\/reports\/2017DisproportionalityReport-CA.pdf) Early Learning Racial Equity Initiative Data Report (2017) (\/sites\/default\/\ufffdles\/pdf\/reports\/Equity_Initiative_Data_Report_1.18.2017.pdf) Racial Equity Theory of Change for Early Learning VC (http:\/\/thrivewa.org\/work\/racial-equity-2\/) Racial Equity, Diversity, and Inclusion Resources (\/sites\/default\/\ufffdles\/pdf\/REDI_Resources.pdf) (\/) \uf09a (https:\/\/www.facebook.com\/waDCYF\/) \uf099 (https:\/\/twitter.com\/waDCYF\/) \uf16a (https:\/\/www.youtube.com\/channel\/UCsRzIU1gRk6-u4JtKIDyqhQ) \uf0e1 (https:\/\/www.linkedin.com\/company\/washington-state-department-of-children-youth-and- families\/) Top Page 156 https:\/\/www.dcyf.wa.gov\/sites\/default\/files\/pdf\/reports\/2016DisproportionalityReport-CA.pdf https:\/\/www.dcyf.wa.gov\/sites\/default\/files\/pdf\/reports\/2017DisproportionalityReport-CA.pdf https:\/\/www.dcyf.wa.gov\/sites\/default\/files\/pdf\/reports\/Equity_Initiative_Data_Report_1.18.2017.pdf http:\/\/thrivewa.org\/work\/racial-equity-2\/ https:\/\/www.dcyf.wa.gov\/sites\/default\/files\/pdf\/REDI_Resources.pdf https:\/\/www.dcyf.wa.gov\/ https:\/\/www.facebook.com\/waDCYF\/ https:\/\/twitter.com\/waDCYF\/ https:\/\/www.youtube.com\/channel\/UCsRzIU1gRk6-u4JtKIDyqhQ https:\/\/www.linkedin.com\/company\/washington-state-department-of-children-youth-and-families\/ 4\/16\/2019 Racial Equity, Diversity and Inclusion | Washington State Department of Children, Youth, and Families https:\/\/www.dcyf.wa.gov\/practice\/racial-equity-diversity-inclusion 4\/4 Contact Us Contact Us (\/contact-us) DCYF O\ufffdces & Regional Map (\/sites\/default\/\ufffdles\/pdf\/DCYFMap-o\ufffdces.pdf) Media (\/about\/media) Jobs at DCYF (\/about\/jobs) Useful Links Capitol Campus Map (https:\/\/des.wa.gov\/capitol-campus-interactive-map) Department of Social & Health Services (http:\/\/dshs.wa.gov\/) Rehabilitation Administration (https:\/\/www.dshs.wa.gov\/ra) Behavioral Health Administration (https:\/\/www.dshs.wa.gov\/bha) Alliance for Child Welfare Excellence (https:\/\/allianceforchildwelfare.org\/) Prevent Child Abuse Washington (http:\/\/preventchildabuse.org\/) Rule Making (\/practice\/policy-laws-rules\/rule-making) Sole Source Contracts (\/contracts\/sole-source-contracts) Request Public Records (\/public-records) Board of Appeals (\/board-of-appeals) Outlook Webmail for State Sta\ufffd (https:\/\/mobile.wa.gov\/owa\/) Top Page 157 https:\/\/www.dcyf.wa.gov\/contact-us https:\/\/www.dcyf.wa.gov\/sites\/default\/files\/pdf\/DCYFMap-offices.pdf https:\/\/www.dcyf.wa.gov\/about\/media https:\/\/www.dcyf.wa.gov\/about\/jobs https:\/\/des.wa.gov\/capitol-campus-interactive-map http:\/\/dshs.wa.gov\/ https:\/\/www.dshs.wa.gov\/ra https:\/\/www.dshs.wa.gov\/bha https:\/\/allianceforchildwelfare.org\/ http:\/\/preventchildabuse.org\/ https:\/\/www.dcyf.wa.gov\/practice\/policy-laws-rules\/rule-making https:\/\/www.dcyf.wa.gov\/contracts\/sole-source-contracts https:\/\/www.dcyf.wa.gov\/public-records https:\/\/www.dcyf.wa.gov\/board-of-appeals https:\/\/mobile.wa.gov\/owa\/ REPORT TO THE LEGISLATURE Racial Disproportionality and Disparity in Washington State RCW 74.13.096(6) Chapter 465, Laws of 2007, Section 3 (SHB 1472) December 1, 2017 Children’s Administration Executive Staff PO Box 45710 Olympia, WA 98504-5710 (360) 902-0222 Page 158 TABLE OF CONTENTS Table of Contents Introduction …………………………………………………………………………………………………….. 1 Progress …………………………………………………………………………………………………………… 3 Achievements and Challenges …………………………………………………………………………… 5 WSRDAC Recommendations ……………………………………………………………………………… 7 Next Steps ……………………………………………………………………………………………………….. 8 Committee Members Ron Murphy, Co-Chair Jim Sherrill, Co-Chair Dr. Susan Barkan, Member Toni Lodge, Member Rick Maib, Member Paola Maranan, Member Mary O’Brien, Member Shrounda Selivanoff, Member Bob Smith, DSHS Secretary’s designee Page 159 https:\/\/www.dshs.wa.gov\/ca\/advancing-child-welfare\/committee-member-profiles Introduction Substitute House Bill 1472, enacted in 2007, created the statewide Racial Disproportionality Advisory Committee (WSRDAC) for the purposes of convening an advisory committee to analyze and make recommendations on the disproportionate representation of children of color in the Washington state child welfare system. Legislation also directed the creation of a remediation plan and performance measures for implementing the plan. The sunset date for the legislation was June 30, 2017. An analysis of disproportionality in the Washington state child welfare system was completed in 2008 by the Washington State Institute for Public Policy (WSIPP). The analysis concluded that racial disproportionality did exist in the Washington state child welfare system for Native American, Black and Hispanic children and that the greatest disproportionality occurred at the following decision points: The initial referral to Child Protective Services (CPS) The decision to remove a child from their home A child remaining in care for over two years In December 2008, WSRDAC submitted a remediation plan to then Department of Social and Health Services (DSHS) Secretary Robin Arnold-Williams. The plan included activities focused on the three decision points: Structured Decision Making\u00ae (SDM): Study SDM\u00ae to determine its impact on reducing disproportionality. Family Team Decision Making (FTDM): Assess FTDM to determine its impact on disproportionality. Kinship Care: Implement policies to ensure equitable services and supports for children and families in kinship care. Compliance with the Indian Child Welfare Act (ICWA): Comply with ICWA. Use Indian Child Welfare Case Review model as an anchor for quality improvement and compliance measurement. Enactment of Washington State Indian Child Welfare Act: Support enactment of a Washington State ICWA. Cultural Competency and Anti-Racism Training: Implement mandatory ongoing anti-racism training. Caseloads (Council on Accreditation Standards): Children’s Administration (CA) caseloads should meet COA standards Mandated reporter training: Revise mandated reporter training to increase awareness of racial disproportionality. Assessment of CA: Assess organizational cultural competency and commitment to the elimination of racial disproportionality for children of color. Page 160 Implement a Racial Equity Impact Analysis Tool: Implement the tool to review all policies and practices. Explore implementation of in-home, community-based services that will keep children safe and reduce the need for out-of-home placement: Study the impact of in-home and community-based services on reducing racial disproportionality and disparity in other states. If there was a positive impact, recommendation was to increase the availability and access to those services. In November 2011, supplemental remediation initiatives were developed. These included: Increase recruitment and licensing of caregivers of color Increase documentation of ethnic and racial background and tribal affiliation in FamLink Eliminate the use of long-term foster care for children of color 12 years or older Make disproportionality awareness training mandatory for CA staff WSRDAC, DSHS leadership, CA leadership and staff, tribes, stakeholders, state partners and philanthropic partners, such as Casey Family Programs, have continued efforts to reduce disparate outcomes for children of color in the child welfare system. WSRDAC has continued to evaluate strategies and activities and monitor progress to safely reduce racial disproportionality. CA continues to work internally and with tribes, external partners and stakeholders to reduce racial disproportionality in the Washington state child welfare system. The following report describes and summarizes the thoughtful work, accomplishments and progress in addressing disproportionality to date and next steps for continuing the work. Page 161 Progress Summary and Status: CA has continued to monitor the progress and impact of implementation of the remediation plan. As a way to institutionalize the work, it is critical that CA continue to address those outcomes that have not been achieved. The tables below list each remediation activity and its current status. INITIAL REMEDIATION INITIATIVES INITIATIVE STATUS Evaluate SDM.\u00ae The SDM\u00ae is a risk assessment tool implemented by CA in 2007 designed to assist CPS workers in making decisions regarding child safety and risk. The WSIPP study was completed and published in 2011. Results and CA response are addressed in the Report to the Legislature March 6, 2012. Evaluate FTDM. An FTDM meeting brings together family members, relatives and other supports to make decisions about safety planning, removal, changes in out-of-home placement and reunification. The WSIPP study was completed and published in 2011. Results and CA response are addressed in the Report to the Legislature March 6, 2012. Implement Kinship Care Policies Policies to support equitable services and supports for children involved in child welfare and in kinship care have been implemented and continue to be reviewed and supported. Maintain Compliance with ICWA CA completed ICW case reviews in 2007, 2009, 2012 and 2015 in collaboration with tribes and Recognized American Indian Organizations (RAIO) to support continued compliance and assess areas of strength and improvement. Enactment of a Washington state ICWA The Washington state ICWA was enacted in 2011. Implement Cultural Competency and Anti- Racism Training. Combined with supplemental initiative on training. CA implemented Building Bridges (Prejudice Reduction Workshop) as mandatory training for all staff in 2012. Beginning in 2016, CA implemented Microaggressions training as mandatory training for all staff. Implement Council on Accreditation Caseload Standards. WSRDAC rescinded this recommendation in June 2011 because it lacked a clear connection to reducing racial disproportionality and eliminating racial disparities. Implement Mandated Reporter Training CA mandated reporter training materials were updated to include information about disproportionality. Page 162 https:\/\/www.dshs.wa.gov\/sites\/default\/files\/CA\/acw\/documents\/LegRacialDispro01-2012.pdf https:\/\/www.dshs.wa.gov\/sites\/default\/files\/CA\/acw\/documents\/LegRacialDispro01-2012.pdf https:\/\/www.dshs.wa.gov\/sites\/default\/files\/CA\/acw\/documents\/LegRacialDispro01-2012.pdf https:\/\/www.dshs.wa.gov\/sites\/default\/files\/CA\/acw\/documents\/LegRacialDispro01-2012.pdf http:\/\/insideca.dshs.wa.gov\/Intranet\/feature\/mandatedreporter.html INITIAL REMEDIATION INITIATIVES INITIATIVE STATUS Conduct Assessment of CA Surveys were completed in 2011 and 2013 using the National Association of Public Child Welfare Administrators (NAPCWA)Disproportionality Diagnostic Tool. CA is interested in exploring other assessment tools that could align with the DSHS Equity, Diversity and Inclusion (EDI) work. Implement a Racial Equity Impact Analysis Tool CA leadership approved a Race Equity Analysis (REA) tool for implementation in 2014. Explore Implementation of In-Home, Community Based Services CA continues to work to improve the in-home service array available to children and families and to integrate data related to race and ethnicity to support development and availability of services to meet each family’s unique needs. SUPPLEMENTAL REMEDIATION INITIATIVES INITIATIVE STATUS Increased Recruitment and Licensing of Caregivers of Color Performance-based, regionally managed recruitment and retention contracts have been established and include performance targets related to recruitment and licensing of caregivers of color. Increased Documentation of Racial, Ethnic and Tribal Affiliation Data in FamLink Processes for ensuring that race, ethnicity and tribal affiliation are documented have been implemented. Elimination of the Use of Long-term Foster Care for Children of Color 12 years of age or older CA does not favor long-term foster care as a permanent plan. The use of long-term foster care is allowed for youth 16 and older when permanent plan options of adoption, reunification or guardianship have been ruled out through a shared planning process. CA is continuing ongoing efforts to improve permanency outcomes. Make Disproportionality Awareness Training Mandatory for Children’s Administration Staff (combined with remediation initiative on training) Beginning in 2016, CA implemented Microaggressions training as mandatory training for all staff. Page 163 Achievements and Challenges Since the enactment of the legislation and identification of the remediation initiatives, there have been achievements as well as challenges in addressing disproportionality. ACHIEVEMENTS CA has made progress in addressing disproportionality and disparities including: the development of accurate data that can be used to evaluate progress and develop strategies; engaging and responding to community voice; engaging staff and ongoing engagement of staff; increased accountability for outcomes; and integration of staff training. Examples include: Training Ongoing training is available to support understanding of disproportionality and bias at all levels of the organization. Updated mandated reporter training and resources include disproportionality awareness. Count of Native American children Improved documentation processes for tribal membership and affiliation. Established statewide Native American Identification and Research (NAIR) unit. Improving data accuracy, accessibility Documentation of race, ethnicity and tribal affiliation is occurring consistently. Processes are in place to make sure this continues. Race\/ethnicity is in standard reports available in FamLink. Race\/ethnicity categories have been aligned (Multi-racial, Multi-racial Black, Multi-racial Native American) to improve consistency of understanding and reporting. Annual statewide data is now available at the regional level to allow for locally targeted improvement strategies. ICW case reviews Successful completion of four rounds of reviews in collaboration with tribes and RAIO. Development of statewide and regionally specific action items to improve practice. Page 164 Kinship care policies Implemented the relative guardianship assistance program (RGAP) which provides subsidy to licensed relatives who establish guardianships for dependent children and youth. Supported elimination of means testing for non-licensed kinship caregivers (Chapter 20, Laws of 2017 [2ESSB 5890 Sec. 16]). Relative support funds are available for unlicensed relatives to meet concrete needs related to caring for children in out-of-home care. Established a process for CA licensors to have direct access to concrete service funds to pay for items needed to support relatives in completing their home studies and\/or becoming licensed foster parents. Recruitment and licensing of caregivers of color Established regionally based contracts for foster parent recruitment and retention. Contractors work with local teams to review data, identify recruitment needs and develop recruitment strategies. Recruitment and support materials for communities of color have been developed and implemented. Examples include Spanish radio broadcasts, video recruitment messages and Facebook pages. CHALLENGES As CA has continued to work toward remediating disproportionality, challenges have surfaced related to specific activities and initiatives including: Racial Equity Analysis Tool While the REA tool was approved for implementation, additional assessment of the tool’s use is needed to determine the best use within available resources. FTDM Analysis While the initial FTDM analysis did not reflect reduced disproportionality, the shared planning process continues to be a cornerstone of family engagement. Improvements in data collection and reporting, including data regarding race and ethnicity, will continue to provide information regarding the engagement of families to strengthen practice and support improved outcomes and address disproportionality at the key decision points. Page 165 http:\/\/lawfilesext.leg.wa.gov\/biennium\/2017-18\/Pdf\/Bills\/Session%20Laws\/Senate\/5890-S.SL.pdf WSRDAC Recommendations At the WSRDAC annual meeting held October 2017, the committee recommended three areas of focus for CA for the coming year. These include: Outcome 1: All children are equitably able to remain safely in their own homes through collaborative efforts across systems to prevent initial placements into out- of-home care (and re-entry into care post-reunification). Rationale: In order to effectively ameliorate disproportionate representation of families of color in the child welfare system it is essential to work across systems with a focus on prevention. Outcome 2: Relative caregivers have culturally appropriate services and the support they need to care for relative children placed in their care. Rationale: One great thing that CA does is place a lot of children with relative caregivers. This is good in terms of disproportionality because it means that children are placed within their own family\/culture which is generally better for the children on many levels. However, because proportionately more of the relative caregivers are caregivers of color and we know that as a group, people of color are disproportionately less financially resourced, these families who have the greatest need are likely receiving fewer resources to care for their relative children. Strengthening financial support and services may help stabilize placement and hopefully lead to a shorter time to stable permanency. Outcome 3: Disproportionality in child welfare is eliminated at all decision-points and the data are accurate and available to make it possible to document and monitor that process. Rationale: This action item touches on all decision points and is important for overall monitoring of trends in disproportionality in regions and sub-regions across the state so that we can better understand the effects of efforts to reduce disproportionality in those regions\/sub-regions. This action item could also be useful to concentrate efforts to focus specifically on the placement decision point to understand what is driving disproportionality at that decision point and potentially identify where improvements in practice or additional assistance to families might be needed. Accessible, reliable data at a variety of levels is essential to understanding and monitoring what is going on with disproportionality. CA has put a lot of work into improving the quality of and increasing access to data and understanding how it informs practice. It is important and helpful to the committee to continue to sustain and build on that. Page 166 Next Steps CA will become part of the newly formed Department of Children Youth and Families (DCYF) July 1, 2018. With this transition, new advisory structures and performance targets may be established. The work that has been completed to date and the knowledge, expertise and infrastructure that exist will continue to inform our work as we move toward eliminating racial disproportionalities and disparities in the Washington state child welfare system while maintaining child safety, permanency and well-being. Access to an array of culturally appropriate services and supports delivered by culturally competent, sensitive and informed staff and contracted service providers is a key component of this work. Next steps include: Continue to work with WSRDAC, tribal and community partners, and stakeholders to address disproportionality in the child welfare system. Strengthen the processes for monitoring implementation and outcomes related to recommendations and strategies. Continue to build infrastructure to support statewide region and field level discussion regarding race, ethnicity and disproportionality and integrate use of race and ethnicity data in decision making, program development and assessment of practice. Provide training on facilitating difficult discussions regarding race for disproportionality leads and other identified staff. Continue to focus on the development of a diverse, effective service array to meet the individual needs of children, youth and families. Integrate race and ethnicity data into program and practice reviews and discussions, including, but not limited to, advisory groups’ review of data, case reviews, program evaluations, development and implementation of new programs. Implementation of regionally specific, data driven improvement plans to address disparate outcomes related to the identified decision points. Page 167 History of Race \uf0b7 Myth of Race Debunked in 3 Minutes (video) \uf0b7 Race – The Power of Illusion (website & film) \uf0b7 How We Got Here: A Reckoning with U.S. and Tacoma history (video) \uf0b7 Seattle Civil Rights & Labor History Project (website) \uf0b7 Stamped from the Beginning by Ibram X. Kendi (book) \uf0b7 Who We Be and We Gon’ Be Alright by Jeff Chang (books) \uf0b7 A Different Mirror: A History of Multicultural America by Ronald Takaki (book) \uf0b7 A People’s History of the United States by Howard Zinn (book) Structural Racism \uf0b7 Rewrite the Racial Rules by the Roosevelt Institute (report) \uf0b7 Between the World and Me by Ta-Nehisi Coates (book) \uf0b7 Racism without Racists: Color-Blind Racism and the Persistence of Racial Inequality in America by Eduardo Bonilla-Silva (book) \uf0b7 The New Jim Crow by Michelle Alexander (book) \uf0b7 13th by Ava DuVernay (film) \uf0b7 The Talk – Race in America by PBS (film) \uf0b7 Unnatural Causes by California Newsreel (film) \uf0b7 The Disturbing History of the Suburbs by Adam Ruins Everything (video) Implicit Bias \uf0b7 How to overcome our biases? Walk boldly toward them by Verna Myers (video) \uf0b7 Kirwan Institute Implicit Bias Module Series (videos) \uf0b7 Implicit Association Test (website) \uf0b7 Facebook Managing Bias series (videos) \uf0b7 25 Mini Films for Exploring Race, Bias and Identity with Students (videos) o Implicit Bias: Peanut Butter, Jelly and Racism (video) \uf0b7 Invisibilia: The Culture Inside (podcast episode) Racial Equity in Early Childhood \uf0b7 Equity Starts Early: Addressing Racial Inequities in Child Care and Early Education Policy by CLASP (report) \uf0b7 Preventing Suspensions and Expulsions in Early Childhood Settings by SRI International (Guide) \uf0b7 Being Black is Not a Risk Factor: A Strengths-based Look at the State of the Black Child by the National Black Child Development Institute (report) Racial Equity in Child Welfare \uf0b7 National Child Welfare Workforce Institute Racial Equity Resources (website) \uf0b7 Achieving Racial Equity: Child Welfare Policy Strategies to Improve Outcomes for Children of Color by Megan Martin and Dana Dean Connelly (article) Racial Equity in Adolescence \uf0b7 The W. Haywood Burns Institute for Juvenile Justice Fairness & Equity (website) \uf0b7 Pushout: The Criminalization of Black Girls in Schools by Monique Morris (book) Page 168 https:\/\/youtu.be\/VnfKgffCZ7U http:\/\/www.pbs.org\/race\/000_General\/000_00-Home.htm https:\/\/www.youtube.com\/watch?v=bsRW81F_zR0&feature=youtu.be https:\/\/depts.washington.edu\/civilr\/ https:\/\/www.nationalbook.org\/books\/stamped-from-the-beginning-the-definitive-history-of-racist-ideas-in-america\/ http:\/\/whowebe.net\/ http:\/\/bealright.net\/ http:\/\/www.powells.com\/book\/different-mirror-a-history-of-multicultural-america-9780316831116\/7-3 http:\/\/www.powells.com\/book\/peoples-history-of-the-united-states-1492-to-present-revised-updated-edition-9780062397348\/62-0?partnerID=33733 http:\/\/rooseveltinstitute.org\/rewrite-racial-rules-building-inclusive-american-economy\/ http:\/\/www.amazon.com\/Between-World-Me-Ta-Nehisi-Coates\/dp\/0812993543\/ref=pd_bxgy_14_img_3?ie=UTF8&refRID=1BE5CVCGQGAMC08BYPBS https:\/\/www.amazon.com\/Racism-without-Racists-Color-Blind-Persistence\/dp\/1442220554\/ref=pd_lpo_sbs_14_t_1?_encoding=UTF8&psc=1&refRID=JR8YT4N9RE7791TX56GB http:\/\/newjimcrow.com\/ http:\/\/www.avaduvernay.com\/13th\/ http:\/\/www.pbs.org\/wnet\/the-talk\/ https:\/\/www.unnaturalcauses.org\/ http:\/\/www.trutv.com\/shows\/adam-ruins-everything\/videos\/the-disturbing-history-of-the-suburbs.html https:\/\/youtu.be\/uYyvbgINZkQ http:\/\/kirwaninstitute.osu.edu\/implicit-bias-training\/ https:\/\/implicit.harvard.edu\/implicit\/takeatest.html https:\/\/managingbias.fb.com\/ https:\/\/www.nytimes.com\/2017\/03\/15\/learning\/lesson-plans\/25-mini-films-for-exploring-race-bias-and-identity-with-students.html http:\/\/www.pbs.org\/video\/pov-implicit-bias-peanut-butter-jelly-and-racism\/ https:\/\/www.npr.org\/programs\/invisibilia\/532950995\/the-culture-inside?showDate=2017-06-09 https:\/\/www.clasp.org\/sites\/default\/files\/publications\/2017\/12\/2017_EquityStartsEarly_0.pdf http:\/\/preventexpulsion.org\/?utm_source=BUILD+Initiative+-+General+List&utm_campaign=bbf4422a4e-EMAIL_CAMPAIGN_2017_08_03&utm_medium=email&utm_term=0_48a0135618-bbf4422a4e-170608769 https:\/\/www.nbcdi.org\/sites\/default\/files\/NBCDI_SOTBC_FLORIDA_Report_%20Final%20(DA%2001-05-2017)_0.pdf http:\/\/ncwwi.org\/index.php\/special-collections\/ncwwi-racial-equity https:\/\/cssp.org\/wp-content\/uploads\/2018\/08\/achieving-racial-equity-child-welfare-policy-strategies-improve-outcomes-children-color.pdf https:\/\/cssp.org\/wp-content\/uploads\/2018\/08\/achieving-racial-equity-child-welfare-policy-strategies-improve-outcomes-children-color.pdf http:\/\/www.burnsinstitute.org\/ https:\/\/thenewpress.com\/books\/pushout Talking about Race Color Brave Conversations \uf0b7 Color Blind or Color Brave? by Mellody Hobson (video) \uf0b7 Color Brave Space Agreements by Heidi Schillinger and Erin Okuno (Fakequity blogpost) \uf0b7 Talking About Race Toolkit by the Center for Social Inclusion (website) \uf0b7 Talking about Race: Toward a Transformative Agenda by the Kirwan Institute \uf0b7 Code Switch by NPR (blog and podcast) \uf0b7 So you want to talk about race? by Ijeoma Oluo (book) \uf0b7 11-Step Guide to Understanding Race, Racism, and White Privilege (website) \uf0b7 White Fragility and the Rules of Engagement by Dr. Robin DiAngelo (article) Intersectionality \uf0b7 A Primer on Intersectionality by Kimberl\u00e9 Crenshaw (article) \uf0b7 How to Do Intersectionality by Rinku Sen (article) \uf0b7 #RaceAnd Videos by Race Forward Inclusion Othering and Belonging \uf0b7 The Problem of Othering: Towards Inclusiveness and Belonging by john a. powell and Stephen Menendian (article) \uf0b7 Racing to Justice: Transforming Our Concepts of Self and Other to Build an Inclusive Society by john a. powell (book) \uf0b7 Bridging: Towards A Society Built on Belonging (video) Gender \uf0b7 The Gender Unicorn from Trans Student Educational Resources \uf0b7 Why sharing gender pronouns at work matters by Alexis Croswell (article) \uf0b7 Why gender equality is good for everyone \u2014 men included by Michael Kimmel (TedTalk) \uf0b7 Transgender Children & Youth (Human Rights Campaign website) \uf0b7 What exactly does it mean to be ‘all-gender affirming?’ by Jaime Grant (article) \uf0b7 My Purple Umbrella (organization facebook account) LGBTQ+ \uf0b7 Washington State Directive for LGBTQ Inclusion (Governor’s Directive) \uf0b7 Stonewall Youth (organization) \uf0b7 Pizza Klatch (organization) \uf0b7 PFLAG (organization) \uf0b7 For LGBTQ People Of Color, Discrimination Compounds by Deena Prichep (article) Disability \uf0b7 People First Language: DisabilityisNatural.com (website) Page 169 https:\/\/youtu.be\/oKtALHe3Y9Q https:\/\/fakequity.com\/2017\/05\/26\/color-brave-space-how-to-run-a-better-equity-focused-meeting\/ http:\/\/www.centerforsocialinclusion.org\/our-work\/our-programs\/communications-testing\/ http:\/\/www.racialequitytools.org\/resourcefiles\/kirwan1.pdf https:\/\/www.npr.org\/sections\/codeswitch\/ https:\/\/www.hachettebookgroup.com\/titles\/ijeoma-oluo\/so-you-want-to-talk-about-race\/9781580056779\/ http:\/\/citizenshipandsocialjustice.com\/2017\/10\/14\/11-step-guide-to-understanding-race-racism-and-white-privilege\/ https:\/\/www.uua.org\/sites\/live-new.uua.org\/files\/diangelo-white_fragility_and_the_rules_of_engagement.pdf http:\/\/www.racialequitytools.org\/resourcefiles\/african.pdf https:\/\/www.themaven.net\/rinkusen\/politics\/how-to-do-intersectionality-VMDT82Ef0kKj0pMsNo-ulQ?full=1 https:\/\/www.raceforward.org\/videos\/RaceAnd http:\/\/www.otheringandbelonging.org\/the-problem-of-othering\/ https:\/\/haasinstitute.berkeley.edu\/racing-justice https:\/\/youtu.be\/PGcbFj4J_gc http:\/\/www.transstudent.org\/gender\/ https:\/\/blog.cultureamp.com\/why-sharing-preferred-gender-pronouns-at-work-matters https:\/\/www.ted.com\/talks\/michael_kimmel_why_gender_equality_is_good_for_everyone_men_included\/transcript#t-595535 https:\/\/www.hrc.org\/explore\/topic\/transgender-children-youth http:\/\/www.losangelesblade.com\/2017\/11\/09\/exactly-mean-gender-affirming\/ https:\/\/www.facebook.com\/mypurpleumbrella\/ https:\/\/www.governor.wa.gov\/news-media\/inslee-issues-state-directive-lgbtq-inclusion-and-safe-places-initiative http:\/\/stonewallyouth.org\/ http:\/\/pizzaklatch.org\/ https:\/\/www.pflag.org\/ https:\/\/www.npr.org\/2017\/11\/25\/564887796\/for-lgbtq-people-of-color-discrimination-compounds https:\/\/www.disabilityisnatural.com\/ APPENDIX G Division 21 CDSS Manual: Proposed Changes Redlined Version Clean Version Page 170 1 CIVIL RIGHTS NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS TABLE OF CONTENTS CHAPTER 21-100 NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS Title VI Civil Rights Act 1964 Section Purpose………………………………………………………………………………………………………………. 21-101 Scope of Division……………………………………………………………………………………………….. 21- 10323 Definitions ………………………………………………………………………………………………………… 21- 10434 Dissemination of Information ………………………………………………………………………………. 21- 10747 General Requirements ………………………………………………………………………………………………. .1 Specific Methods to Be Utilized …………………………………………………………………………………… .2 Discriminatory Practices Prohibited ……………………………………………………………………… 21- 10959 General ……………………………………………………………………………………………………………………..1 Location of Facilities………………………………………………………………………………………………….. .2 Accessibility…………………………………………………………………………………………………… 21- 11106101 Provisions for Services to Applicants and Recipients Who Are Limited English Proficient Non- English Speaking or Who Have Disabilities …………………………………………………………………….. 21- 1150715 Documentation of Applicant\/Recipient Case Records……………………………………………. 21- 1160816 Commented [A1]: Because final numbering will depend on the final additions and changes, please disregard our changes to the numbering Page 171 2 Staff Development and Training ……………………………………………………………. …21- 1170917 CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS CHAPTER 21-100 NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS Title VI Civil Rights Act 1964 Section Compliance Procedures and Reporting ………………………………………………………….. 21- 2011102001 Assignment of Resources to Implement Requirements of This Division …………………………………………………………………………………………………………. .1 Compliance Reports ………………………………………………………………………………………………….. .2 Compliance Reviews………………………………………………………………………………………………….. .3 Applicant\/Recipient Complaints of Discriminatory Treatment ……………………………… 21- 2031112013 Complainant’s Right to a State Hearing (Fair Hearing) ……………………………………………….. .1 Procedures for Processing Discrimination Complaints ……………………………………………….. .2 Procedures for Investigation Complaints …………………………………………………………………… .3 Report of Investigation…………………………………………………………………………………………….. .4 Retaliatory Acts Prohibited ……………………………………………………………………………………… .5 Confidentiality of Information ………………………………………………………………………………….. .6 Retention ………………………………………………………………………………………………………………. .7 Page 172 3 Closure of Complaint Files ………………………………………………………………………………………. .8 Corrective Action ……………………………………………………………………………………….. 21- 2051122025 CHAPTER 21-100 NONDISCRIMINATION IN STATE AND FEDERALLY ASSISTED PROGRAMS 21-101 PURPOSE 21-101 (a) The purpose of Division 21 is to effectuate the provisions of the following laws: Title VI of the Civil Rights Act of 1964, as amended; Section 504 of the RehabilitationRehabiliation Act of 1973, as amended; Title II of the Americans With Disabilities Act of 1990, as amended; the Age Discrimination Act of 1975, as amended; the Food Stamp Act of 1977, as amended; and California Civil Code, Section 51, et seq., as amended; California Government Code, Section 11135, et seq., as amended; and California Government Code, Section 4450; and other applicable federal and state laws and their implementing regulations to ensure that the administration of public assistance and social services programs are nondiscriminatory, and that no person shall, because of actual or perceived race, color, national origin, ancestry, ethnic group identification, political affiliation, religion, marital status, sex, age, gender, gender identity, gender expression, sexual orientation, medical condition, genetic information, military and veteran status, mental disability, or physical disability be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity that is conducted, operated, or administered by the state or any state agency, is funded directly by the state, or receives any financial assistance from the state.receiving federal or state financial assistance. Administrative methods\/procedures which have the effect of subjecting individuals to discrimination or defeating the objectives of these regulations are prohibited. (b) All definitions and prohibitions set forth in the statutes listed in 21-101(a) are hereby incorporated by reference. Any act or omission which is contrary to said definitions and prohibitions constitutes a violation of this subchapter and is subject to the sanctions provided for in this subchapter. In the event of any conflict between the definitions and prohibitions of the provisions incorporated by this reference and the definitions and prohibitions set forth in this subchapter, the definitions and prohibitions set forth in this subchapter shall prevail. (c) This Division and other implementing regulations provide protections independent of those in federal anti-discrimination laws. Although federal laws provide the floor of protection relating to discrimination, this Division and implementing regulations afford additional protections to provide robust protection of protected classes in state and state- supported programs and activities, including by recognizing that this Division prohibits discrimination independently of guarantees of equal protection and the prohibition Commented [A2]: source: CA Gov. Code 12926, subd. (o) clarifies that discrimination includes discrimination on the basis of perception https:\/\/leginfo.legislature.ca.gov\/faces\/codes_displaySe ction.xhtml?lawCode=GOV&sectionNum=12926 Commented [A3]: source: 11135 draft Commented [A4]: In 2013 CA added veteran\/military status as a protected class under the CA FEHA. This is not in the 11135 draft https:\/\/www.jacksonlewis.com\/resources- publication\/military-and-veteran-status-now-protected- under-california-employment-discrimination-law Commented [A5]: source: 11135 draft (except military\/veteran status) Commented [A6]: source: 11135 draft Commented [A7]: source: 11135 draft Page 173 4 against denial of full and equal access. The provisions of this Division and other implementing regulations shall be construed liberally for the accomplishment of the purposes of this part. (a)(d) This Division’s prohibition against discrimination includes intersectional discrimination, discrimination on more than one basis, harassment, coercion, intimidation, and retaliation for exercising a protected right or refusing to engage in an act prohibited by Division 21. AUTHORITYNOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Sections 4450, and 11135, 11136, and 12993, California Government Code; Title II of the American With Disabilities Act of 1990, Public Law (P.L.) 101-336; 42 USCA 2000d; as amended by the ADA Amendments Act of 2008 (ADA Amendments Act) (Pub. L. 110-325, 122 Stat. 3553 (2008)), Title II of the Americans with Disabilities Act Regulations; 28 CFR 35; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. 21-10323 SCOPE OF DIVISION 21-103 These requirements shall apply to the California Department of Social Services (CDSS), all county welfare departments, and all other agencies receiving federal or state financial assistance through CDSS for the administration of public assistance, food stamps, child support enforcement, fraud investigation, and social services. When the laws of California prescribe stronger protections and prohibitions than federal laws, the entities covered by this dDivision are subject to the stronger protections and prohibitions. .1 Civil Rights requirements addressing the Child Support Program in the county District Attorney’s offices are covered in separate plans of cooperation (see MPP Division 12 (Administrative Standards for State IV-D Agency), Appendix I, Part IX, Civil Rights Component). .2 Civil Rights requirements addressing welfare fraud investigations in the county by District Attorney’s offices are covered in separate purchase of service agreements and plans of cooperation (see MPP Division 20 (Fraud and Suspected Law Violations), Section 20-007.111). .3 CDSS reserves the right to interview staff, review, copy or obtain all data, records, reports, case files and other materials determined necessary in the conduct of discrimination complaint investigations and\/or compliance reviews involving all agencies subject to the requirements of this dDivision. .4 Contractor and Vendor Compliance: Contractors, vendors, consultants, and other providers of service who receive federal or state assistance through CDSS or through Commented [A8]: source: 11135 draft Page 174 5 agencies covered by these regulations shall comply with nondiscrimination requirements of this dDivision. .5 Written assurances of nondiscrimination in programs and activities receiving federal or state financial assistance shall be required. This requirement is fully applicable to all vendors, contractors, consultants, and other providers of service in addition to county welfare departments. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 11135(b), Government Code; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 28 CFR 42.407. 21-1043 DEFINITIONS 21-103 .1 The following definitions shall apply to the terms used in this Division: 1. a. (1) \”Accessibility\” generally refers to the usability of public facilities by individuals with disabilities. See 21.18xx for a complete definition. 2. Adverse action includes any action that harms or has a negative effect on an aggrieved person, including denial or reduction in benefits, harassment, intimidation, threats, coercion, inferior or unfavorable treatment, discrimination, or any denial of full and equal access. 3. Age means how old a person is or is perceived to be, or the number of years elapsed from the date of a person’s birth or perceived to have elapsed from that date. 4. Aggrieved person includes any person who believes that they have been injured by a discriminatory practice or denial of full and equal access, or believes that the persony will be injured by a discriminatory practice or denial of full and equal access that is about to occur. Aggrieved person shall include any applicants for or recipients of public benefits from agencies covered by these regulations. 5. Ancestry means an individual’s actual or self-identified family or ethnic origin, descent or lineage, nationality group, tribal affiliation, or geographical place of origin orr country in which the individual or the individual’s parents or ancestors originated, or the perception of the individual’s ancestry. 6. Assistance animal means an animal that is necessary as a reasonable accommodation for an individual with a disability. Assistance animals include service animals and support animals. An assistance animal is not a pet. It is an animal that works, provides assistance, or performs tasks for the benefit of an individual with a disability, or provides emotional support that alleviates one or more identified symptoms or effects of an individual’s disability. a. Service animals are animals that are trained to perform specific tasks to assist individuals with disabilities, including individuals with mental health disabilities. Service animals do not need to be professionally trained or certified, but may be trained by the individual with a disability or another individual. Specific examples include: Commented [A9]: source: 11135 draft Page 175 6 i. Guide dog, as defined at California Civil Code section 54.1, or other animal trained to guide a blind individual or individual with low vision. ii. Signal dog, as defined at California Civil Code section 54.1, or other animal trained to alert a deaf or hard-of-hearing individual to sounds. iii. Service dog, as defined at California Civil Code section 54.1, or other animal individually trained to the requirements of an individual with a disability. iv. Miniature horses meeting the requirements of 28 CFR 35.136(i) and 28 CFR 36.302(c)(9). v. Service animals in training, including guide, signal, and service dogs being trained by individuals with disabilities, persons assisting individuals with disabilities, or authorized trainers under California Civil Code sections 54.1(c) and 54.2(b). vi. Support animals are animals that provide emotional, cognitive, or other similar support to an individual with a disability. A support animal does not need to be trained or certified. Support animals are also known as comfort animals or emotional support animals. 7. Assistive technology means technology designed to be utilized in an assistive technology device or assistive technology service. a. Assistive technology device means any item, piece of equipment, or product system, whether acquired commercially, modified, or customized, that is used to increase, maintain, or improve functional capabilities of individuals with disabilities. b. Assistive technology service means any service that directly assists an individual with a disability in the selection, acquisition, or use of an assistive technology device. 1.8. Associated with means linked or related to a person who is or is perceived to be a member of a protected class, or who identifies with or advocates for a member of a protected class, or who expresses support or sympathy for, encourages, or participates in groups composed of or representing members of a protected class or groups organized for the protection or assertion of rights protected under this Division. Associated with includes an individual’s current or prior social or professional relationship with, marriage to, or domestic partnership with a member of a protected class; an individual’s familial relationship with a person who is a member of the class, including an adoptive, step, or foster care relationship; a person’s relationship as an attendant, aide, or caregiver of an individual with a disability; membership in or association with an organization identified with or seeking to promote the interests of a protected class; attendance or participation in schools, clubs, associations, organizations, churches, temples, or mosques, generally associated with a protected class; being on the premises of a facility or building owned or rented by an entity, group, or person that has, or is identified with people who have, one or more characteristics of a protected class; or actual or perceived association of a person’s name or other characteristics with a protected class. Commented [A10]: source: 11135 draft Page 176 7 2.9. (2) \”Assurance of Compliance Agreement\” is a legal agreement in which a county welfare department agrees to administer a program or activity covered by this dDivision in accordance with all applicable civil rights laws and their implementing regulations. 3.10. \”Authorized representative\” means aAn individual or group that has written authorization from the applicant\/recipient to act in his\/her behalf (see MPP, Division 19, Section 19-005.2). 11. Auxiliary aids and services include: a. cCommunicating, written or orally, in plain language, simplified English b. qualified interpreters; notetakers; real-time computer-aided transcription services; written materials; exchange of written notes; telephone handset amplifiers; assistive listening devices; assistive listening systems; telephones compatible with hearing aids; closed caption decoders; open and closed captioning, including real-time captioning; voice, text, and video-based telecommunications products and systems, including text telephones (TTYs), videophones, and captioned telephones, video relay services, video remote interpreting (VRI), or other telecommunications devices that make communication as equally effective as oral communication in English; videotext displays; accessible electronic and information technology; tactile sign language; or other equally effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing or assisting those individuals to communicate; c. qualified readers; taped texts; audio recordings; Braille materials and displays; screen reader software; magnification software; optical readers; secondary auditory programs (SAP); large print materials; accessible electronic and information technology; or other effective methods of making visually delivered materials available to individuals who are blind or have low vision or assisting those individuals to communicate; d. qualified interpreters, speech-to-speech relay services, or other effective methods of making aurally delivered information available to individuals who have speech disabilities or assisting those individuals to communicate; e. acquisition or modification of equipment or devices; and f. other similar services and actions, including newly developed forms of electronic information systems and technology as they become available. 12. Benefit means anything offered or provided with the intention of or for the purpose of contributing to an improvement in condition, maintaining a condition, or preventing anticipated deterioration of a condition over time, including aid or services offered or provided by a covered entity. 13. Color means the actual or perceived physical characteristics of an individual’s complexion, pigmentation, or skin tone. 4.14. \”Community Organization\” is any organization at the local level which interacts with applicants\/recipients, such as a community action program, civic organization, migrant group, church, neighborhood council, local chapter of a community organization (e.g., NAACP), or other similar group. 15. Contractor includes a person or recipient that receives any state support under contract Commented [A11]: source: 11135 draft Page 177 8 or subcontract. Contractor includes prime contractors and subcontractors at any tier. 16. Covered entity includes: a. the state or a state agency; b. any entity or individual involved in carrying out any program or activity that is conducted, operated, or administered by the state or by any state agency; c. any entity or individual, including local agencies, recipients, contractors, and grantees, that is funded directly by the state, or receives any state support; d. a local agency, and any entity or individual involved in carrying out any program or activity of a local agency if any part of the local agency receives state support; 17. \”Culturally aware persons\” are those who possess knowledge and understanding of cultural environments, religious beliefs, life styles, self-concepts and language characteristics of the populations they serve. Such knowledge is necessary to effectively communicate and provide the same level of service being provided to the welfare population at large. 18. Disability means a physical or mental impairment that limits one or more major life activities of an individual, a record of such an impairment, or being regarded as having such an impairment. It includes any mental or physical disability as defined in this section, and shall be construed as follows: a. This Division provides protections that are independent from those in the federal Americans with Disabilities Act of 1990 (P.L. 101-3361) and the American with Disabilities Amendments Act of 2008 (P.L. 110-325) (collectively, the ADA ), and may afford additional protections, but in no event shall be construed to provide fewer protections than the ADA. Notwithstanding the definitions of physical disability and mental disability in this section, if the definition of disability used in the ADA would result in broader protection of the civil rights of individuals with a mental disability or physical disability, or would include any medical condition not included within those definitions, then that broader protection or coverage shall be deemed incorporated by reference into, and shall prevail over conflicting provisions of, the definitions in this section. b. All definitions shall be interpreted in accordance with the expansive construction mandates of Section 12926.1 of the California Government Code. To the extent that codified definitions or interpretations are expanded in the future, such new, more expansive definitional mandates shall be incorporated into this Division. To the extent that such codified definitions or interpretations are narrowed or restricted in the future, the more expansive definitions referenced in this sub- paragraph shall nevertheless continue to govern this Division. c. Mental disability includes: i. Having any mental or psychological disorder or condition, such as intellectual disability, organic brain syndrome, emotional or mental illness, or specific learning disabilities, that limits a major life activity. ii. Any other mental or psychological disorder or condition not described in [the sentence above] that requires special education or related services. iii. Having a diagnoses, record, or history of a mental or psychological disorder or condition described in [the two sentences above]. Commented [A12]: source: 11135 draft Commented [A13]: source: 11135 draft Page 178 9 iv. Being regarded or treated as having, or having had, any mental condition that makes achievement of a major life activity difficult. v. Being regarded or treated as having, or having had, a mental or psychological disorder or condition that has no present disabling effect, but that may become a mental disability as described in [paragraphs i and ii]. d. (4) Physical Disability includes: i. (A) having any physiological disease, disorder, or condition, cosmetic disfigurement, or anatomical loss that affects one or more body systems (neurological, including immunological; musculoskeletal, special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genitourinary; hemic and lymphatic, skin; and endocrine systems), and limits a major life activity; ii. (B) any other health impairment not described in subparagraph (A)above that requires special education or related services; iii. (C) having a diagnosis, record, or history of a disease, disorder, condition, cosmetic disfigurement, anatomical loss, or health impairment described in subparagraph (iA) or (iiB) of this paragraph; iv. (D) being regarded or treated as having, or having had, any physical condition that makes achievement of a major life activity difficult; or v. (E) being regarded or treated as having, or having had, a disease, disorder, condition, cosmetic disfigurement, anatomical loss, or health impairment that has no present disabling effect but may become a physical disability as described in subparagraph immediately above in (iA) or (iiB) of this paragraph. e. (5) Having a record of such impairment means has a history of, or has been misclassified as having, an impairment that limits one or more major life activities. f. (6) Perceived as having an impairment means: i. (A) has an impairment that does not limit major life activities but that is treated or perceived as constituting a limitation; ii. (B) has an impairment that limits major life activities only as a result of the attitudes of others toward such impairment; or iii. (C) does not have an impairment but is treated or perceived as having such an impairment. g. (7) The definition of disability in this subchapter shall be construed in favor of broad coverage of individuals under this subchapter, to the maximum extent permitted by the terms of this subchapter. Disabilities include contagious and noncontagious diseases; orthopedic, visual, speech and hearing impairments; traumatic brain injuries, cerebral palsy, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, intellectual disabilities, developmental disabilities, autism or autism spectrum, emotional illness, specific learning disabilities, HIV disease (whether symptomatic or asymptomatic), tuberculosis, drug addiction, and alcoholism. Commented [A14]: source: 11135 draft Page 179 10 h. (8) Individuals are protected from discrimination and denial of full and equal access due to an actual or perceived physical or mental impairment that is disabling, potentially disabling, or perceived or regarded as disabling or potentially disabling (even if it has no present disabling effect), including when an individual is erroneously or mistakenly believed to have any physical or mental condition that limits a major life activity, whether or not the impairment actually limits or is perceived to limit a major life activity. i. (9) Physical and mental disabilities include chronic or episodic conditions, such as HIV\/AIDS, hepatitis, epilepsy, seizure disorder, diabetes, clinical depression, bipolar disorder, multiple sclerosis, and heart disease. An impairment that is episodic or in remission is a disability if it would limit a major life activity when active. j. (10) The definitions of physical disability and mental disability require a limitation upon a major life activity, but do not require, as does the ADA, a substantial limitation. This distinction is intended to result in broader coverage under this subchapter than under the ADA. k. (11) Major life activities shall be broadly construed and include physical, mental, and social activities; caring for one’s self; performing manual tasks, walking, seeing, hearing, speaking, breathing, eating, sleeping, standing, lifting, bending, learning, reading, concentrating, thinking, communicating, and working. Working is a major life activity, regardless of whether the actual or perceived working limitation implicates a particular employment or a class or broad range of employment. l. (12) For purposes of subparagraph (f6), a major life activity also includes the operation of a major bodily function, including functions of the immune system, normal cell growth, digestive, bowel, bladder, cardiovascular, genitourinary, hemic, neurological, lymphatic, brain, respiratory (including speech organs), circulatory, endocrine, and reproductive functions. m. (13) A disability limits a major life activity if it makes the achievement of the major life activity difficult. n. (14) An impairment that limits one major life activity need not limit other major life activities in order to be considered a disability. o. (15) The determination of whether an impairment limits a major life activity shall be made without regard to the ameliorative effects of mitigating measures, unless the mitigating measure itself limits a major life activity, regardless of federal law under the ADA. Mitigating measures include: i. (A) medication, medical supplies, equipment, or appliances, low-vision devices (which do not include ordinary eyeglasses or contact lenses), prosthetics including limbs and devices, hearing aids and cochlear implants or other implantable hearing devices, mobility devices, or oxygen therapy equipment and supplies; ii. (B) use of assistive technology and devices; iii. (C) reasonable accommodations or auxiliary aids or services; or (D) learned behavioral or adaptive neurological modifications. Page 180 11 p. (16) The ameliorative effects of the mitigating measures of ordinary eyeglasses or contact lenses shall be considered in determining whether an impairment limits a major life activity. As used in this subparagraph: i. (A) the term ordinary eyeglasses or contact lenses means lenses that are intended to fully correct visual acuity or eliminate refractive error; and ii. (B) the term low-vision devices means devices that magnify, enhance, or otherwise augment a visual image. q. (17) Disability does not include sexual behavior disorders, compulsive gambling, kleptomania, pyromania, or psychoactive substance use disorders resulting from the current unlawful use of controlled substances or other drugs. Sexual behavior disorders means pedophilia, exhibitionism, and voyeurism. r. (18) Current unlawful use of controlled substance or drugs does not include an individual who: i. (A) has successfully completed a supervised drug rehabilitation program and is no longer engaging in the illegal use of drugs, or has otherwise been rehabilitated and is no longer engaging in such use; ii. (B) is participating in a supervised rehabilitation program and is no longer engaging in such use; iii. (C) is erroneously regarded as engaging in such use; or iv. (D) is using drugs taken under the supervision of a licensed health care professional, or other uses authorized by law. s. (19) Notwithstanding other provisions of this subchapter, an individual shall not be denied health services, or services provided in connection with drug rehabilitation, on the basis of current unlawful use of drugs if the individual is otherwise entitled to such services. 19. Effective Communication means communication sufficient to provide the LEP individual with substantially the same level of services received by individuals who are not LEP. For example, staff must take reasonable steps to ensure communication with an LEP individual is as effective as communications with others when providing similar programs and services. 20. Ethnic group identification means the actual or self-identified possession of the physical, cultural, or linguistic characteristics associated with a racial, cultural, or ethnic group or country, geographical place of origin, or the status of being a descendent of someone with such actual or self-identified characteristics, or the perception of a person’s ethnic group identification. Ethnic Group Identification includes ancestry, color, national origin, and race. 21. Gender means sex, and includes a person’s gender identity and gender expression, or a perception of any of the aforementioned. 22. Gender identity means each person’s internal understanding of their gender, or perception of a person’s gender identity, which may include male, female, a combination of male and female, neither male nor female, a gender different from the person’s sex assigned at birth, or transgender. Commented [A15]: source: 11135 draft Commented [A16]: source: U.S. DOJ Civil Rights Division Language Access Plan Memo (2015) https:\/\/www.justice.gov\/sites\/default\/files\/crt\/legacy\/201 5\/05\/04\/crtlap.pdf Page 181 12 23. Gender expression means a person’s gender-related appearance or behavior, or the perception of such appearance or behavior, whether or not stereotypically associated with the person’s sex assigned at birth. 5.24. Genetic Information means information about an individual’s genetic tests, the genetic tests of an individual’s family members, the manifestation of a disease or disorder in the individual’s family members, or the perception of any of the aforementioned. Genetic information includes any request for, or receipt of, genetic services, or participation in clinical research that includes genetic services, by an individual or any family member of the individual. Genetic information does not include information about the sex or age of any individual. 25. Includes or including has the same meaning as includes, but not limited to or including, but is not limited to. 6.26. \”International Symbol of Accessibility\” is the symbol specified in Title 24 of the California Code of Regulations (Access Code) Section 3105A.(e) used to identify facilities, restrooms, parking spaces, etc. as accessible to individuals with disabilities. 27. Intersectional Discrimination means discrimination on the basis of a combination of protected classes, i.e., where two or more bases for discrimination are alleged. Thus, an entity that is not unlawfully discriminating solely on the basis of race or gender still may be discriminating against individuals who are perceived as or identified as having a combination of more than protected basis, such as, Asian males. 7.28. \”Individual with a disability\” is any person who has a physical or mental impairment which substantially limits one or more major life activities, has a record of such impairment or is regarded as having such an impairment. 7. \”Physical or mental impairmentPhysical Disability\” meansincludes having a: 29. Any physiological disorder or condition, cosmetic disfigurement or anatomical loss affecting one or more of the following body systems: neurological, musculoskeletal, special sense organs, respiratory including speech organs, cardiovascular, reproductive, digestive, genitourinary, hemic and lymphatic, skin and endocrine. . Mental Disability includes ; orhaving a 30. Any mental or psychological disorder, such as an intellectual disabilitymental retardation, organic brain syndrome, emotional or mental illness and specific learning disabilities or any other mental or psychological disorder or condition not that requires special education or related services. . . 10.31. \”Major life activities\” include functions such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. 11.32. \”Has a record of such an impairment\” means has a history of, or has been misclassified as having, a mental or physical impairment that substantially limits one or more major life activities. 12.33. \”Is regarded as having an impairment\” means: a. Has a physical or mental impairment that does not substantially limit major life activities, but that is treated by the agency as constituting such a limitation; b. Has a physical or mental impairment that substantially limits major life activities only as a result of the attitudes of others toward such impairment; or Commented [A17]: source: 11135 draft Commented [A18]: source: 11135 draft Commented [A19]: source: 11135 draft Commented [A20]: UPDATE Page 182 13 c. Has none of the impairments defined in this section but is treated by an agency as having such an impairment. 34. \”Major Occupational Group\” Groups shall include, but are not limited to, the following general positions\/classifications: Social Service Supervisors, Eligibility Supervisors, Social Workers, Eligibility Workers, Welfare Aids, Receptionists, Clerical Employees. Agency personnel whose position\/classification is not included, but whose primary duties\/responsibilities correspond to any one of the above shall be included in that major occupational group. 35. Marital status means an individual’s actual or perceived pending state of marriage, non-marriage, domestic partnership, divorce or dissolution, separation, widowhood, annulment, or other marital state. 36. Meaningful Access is language assistance that results in accurate, timely, and effective communication at no cost to the LEP individual. For LEP individuals, meaningful access denotes access that is not significantly restricted, delayed, or inferior as compared to programs or activities provided to English proficient individuals. 37. Medical Condition means any actual or perceived health impairment related to or associated with a diagnosis, record, or history of cancer; or genetic characteristics known to be a cause of a disease or disorder or associated with a statistically increased risk of developing a disease or disorder. Genetic characteristics means either of the following: a. any scientifically or medically identifiable gene or chromosome, or combination or alteration thereof, that is known to be a cause of a disease or disorder in a person or that person’s offspring, or that is determined to be associated with a statistically increased risk of development of a disease or disorder, and that is presently not associated with any symptoms of any disease or disorder; or b. inherited characteristics that may derive from the individual or family member, that are known to be a cause of a disease or disorder in a person or that person’s offspring, or that are determined to be associated with a statistically increased risk of development of a disease or disorder, and that are presently not associated with any symptoms of any disease or disorder. 38. Military and veteran status means a member or veteran of the United States Armed Forces, United States Armed Forces Reserve, the United States National Guard, and the California National Guard. 39. National origin includes: a. the individual’s or ancestors’ actual or perceived: i. physical, cultural, or linguistic characteristics, or name associated with a national origin group; ii. marriage to or association with persons of a national origin group; iii. tribal affiliation; iv. membership in or association with an organization identified with or seeking to promote the interests of a national origin group; and v. attendance or participation in schools, churches, temples, mosques, or other religious institutions generally used by persons of a national origin group; Commented [A21]: source: 11135 draft Commented [A22]: source: U.S. DOJ Civil Rights Division Language Access Plan Memo (2015) https:\/\/www.justice.gov\/sites\/default\/files\/crt\/legacy\/201 5\/05\/04\/crtlap.pdf Commented [A23]: source: 11135 draft Commented [A24]: source: Cal. Civ. Code 12920 https:\/\/www.jacksonlewis.com\/resources- publication\/military-and-veteran-status-now-protected- under-california-employment-discrimination-law Page 183 14 b. National origin groups include ethnic groups or people from particular geographic places of origin and countries, whether or not they are presently in existence. 13.c. National origin includes possessing a driver’s license or identification card granted under Sections 12801.6, 12801.8, or 12801.9 of the Vehicle Code, or a driver’s license or identification card identified with the term Federal Limit Apply. 40. \”Non-English Speaking\” persons are defined as those whose primary language is other than English or those who have identified a need for interpretive services. Sign language is subject to this definition. 14.41. Perceived membership in a protected class means being regarded as, perceived as, or treated as a member of a protected class or as having the characteristics associated with being a member of a protected class, regardless of whether the perception is accurate. 15.42. Practice or Practices includes any action or failure to act, rule, law, ordinance, regulation, guideline, decision, standard, project, policy, process, or procedure, whether written or unwritten or singular or multiple. 43. Program or activity includes all of the operations and facilities of, or services, benefits or aid provided by, a covered entity, directly or indirectly. 44. Protected class and protected basis are used interchangeably. They refer to the bases on which individuals are entitled to protections against discrimination and denial of full and equal access. Protected bases include sex, race, color, religion, ancestry, national origin, ethnic group identification, age, disability (including mental and physical disability), medical condition, genetic information, marital status, gender, gender identity, gender expression, and sexual orientation. In the event the Legislature in the future recognizes a protected class or protected basis by legislation or regulation, that basis will be considered a protected class or protected basis pursuant to this Division, unless specifically excluded by the Legislature. All protected bases include a perception that a person is a member of a protected class or has any of those characteristics, or that a person is associated with a person who is, or is perceived to be a member of a protected class. Discrimination or the denial of full and equal access on the basis of a protected class includes discrimination or denial of full and equal access on the basis of a stereotype about members of the protected class. 16.45. \”Public contact positions\” include, but are not limited to, the following positions and activities, regardless of particular job classification or title: CWD employees assigned to the front desk or registration counter, telephone operators, eligibility workers\/supervisors, social service workers\/supervisors, welfare service aides, vocational counselors, homemakers, fraud investigators, and any employee providing interpretive service on a continuing or as needed basis. 46. \”Qualified bilingual employee\” is defined as an employee who, in addition to possessing the necessary qualifications for the particular classification, is certified through a process approved or administered by CDSS to be proficient in oral and\/or written communication in the non-English language of the persons to be served. This definition shall also apply Commented [A25]: source: 11135 draft Commented [A26]: source: 11135 draft Commented [A27]: source: 1135 draft Commented [A28]: consider defining program or activity; this is part of the definition from the 11135 draft, though their complete definition seems geared towards their context Commented [A29]: source: 11135 draft Page 184 15 to an employee who is certified in the use of sign language to communicate with individuals who are deaf or hearing-impaired.’ 47. Qualified individual with a disability means: a. an individual with a disability who, with or without reasonable accommodations to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity or contractor, or recipient of a public entity. 17.b. with respect to employment, a qualified individual with a disability is an applicant or employee who, with or without reasonable accommodations, can perform the essential functions of the job in question. 48. \”Qualified interpreter\” means a person qualified and capable of effective, accurate, and impartial rendition of spoken or signed communication from one language to another between people who speak, sign, read, or write in a different language, both receptively and expressively, using any necessary specialized vocabulary and with appropriate cultural relevance, either simultaneously or consecutively. Interpretation is the act of listening to spoken word, visual or tactile transmission of manual language, or reading something written in one language (source language) and expressing it accurately and with appropriate cultural relevance into another language (target language), either simultaneously or consecutively. Whether an interpreter is qualified to provide services requires more than self-identification as bilingual or multilingual. To be qualified an interpreter must: (i) demonstrate proficiency in and ability to communicate information accurately in both the source and target language; (ii) have knowledge in both languages of any specialized term, concepts, or any particularized vocabulary and phraseology peculiar to the program or services; (iii) understand and follow interpreters’ and translators’ confidentiality, ethics and impartiality rules; and (iv) understand and adhere to their roles as interpreters or translators. Qualified interpreters include, for example, sign language interpreters, oral transliterators, and cued-language transliterators. Also, to be qualified an interpreter must have received adequate education and training in interpreter ethics, conduct, practice, and confidentiality. In some circumstances, effective communication may require that an individual be provided more than one interpreter.means an interpreter who is able to interpret effectively, accurately, and impartially both receptively and expressively, using any necessary specialized vocabulary. 18.49. Qualified reader means a person who is able to read effectively, accurately, and impartially using any necessary specialized vocabulary. 50. Race refers to the identification of a group of people as distinct from other groups based on supposed or presumed physical, cultural, or genetic characteristics, or the perception of an individual’s race, without regard to whether those characteristics are immutable. Race is construed broadly to include classifications that might otherwise appear to be covered only by other protected bases, such as national origin or religion. 51. Religion, religious creed, religious observance, religious belief, and creed are used interchangeably under this subchapter to mean any actual or perceived traditionally Commented [A30]: ICE’s 2015 language access plan https:\/\/www.ice.gov\/sites\/default\/files\/documents\/Docu ment\/2015\/LanguageAccessPlan.pdf defines bilingual person (not qualified bilingual employee) as \”A person who is bilingual is fluent in two languages and is able to conduct the business of the workplace in either of those languages. This is to be distinguished from proficiency in more than one language. An individual who is proficient in a language may, for example, be able to greet an LEP individual in his or her language, but not conduct agency business in that language. Interpretation and translation require the interpreter or translator to be fluently bilingual, and also require additional specific skills for interpretation and translation as described below.\” Commented [A31]: Covered California’s Bilingual Services Policy https:\/\/www.coveredca.com\/PDFs\/bilingual- services\/Bilingual-Services-Policy.pdf defines qualified bilingual employee as \”A CC staff member who is certified by the California Department of Human Resources Bilingual Services Program, or by any Department if that Department has delegated authority to conduct bilingual fluency examinations, and who uses this bilingual skill to serve CC consumers.\” Commented [A32]: source: 11135 draft Commented [A33]: source: 11135 draft Commented [A34]: source: 11135 draft Page 185 16 recognized religion as well as beliefs, observances, or practices, which an individual sincerely holds and which occupy in their life a place of importance parallel to that of traditionally recognized religions. This includes all aspects of religious belief, observance, and practice, such as duties of the clergy or elders, and religious dress and grooming practices. Religion includes atheism, agnosticism, and an individual’s choice not to adopt a traditional or specific religious belief. a. Religious dress practices shall be construed broadly to include the wearing or carrying of religious clothing, head or face coverings, jewelry, artifacts, and any other item that is part of an individual’s religious observance. b. Religious grooming practice shall be construed broadly to include forms of head, facial, and body hair, or body markings, that are part of an individual’s religious observance. 52. Sex includes pregnancy, childbirth, and breastfeeding; medical conditions related to pregnancy, childbirth, or breast feeding; recovery from childbirth or termination of pregnancy, or other conditions related to the capacity to bear children; gender; transgender; intersex; transitioning; sex stereotype; gender identity; gender expression; and perception by a third party of any of the aforementioned. 53. Sexual Orientation includes actual or perceived heterosexuality, homosexuality, bisexuality, and asexuality. This refers to a person’s emotional, romantic, or sexual attraction toward other people, and may be described by terms including gay, lesbian, bisexual, straight, asexual, or queer. 54. \”Sign Language\” means the use of fingers and hands to communicate with individuals who are deaf or hard of hearing. There are multiple sign languages including: a. American Sign Language (ASL), a visual language that does not share grammar, word order, or sentence structure with English. b. Manually Coded English, signs that are a visual code for spoken English. 19.c. Pidgin Signed English, a visual language combining ASL and English that does not follow English grammatical structures exactly. 20.55. Stereotype means a belief about a person’s appearance or behavior, gender roles, gender expression, or gender identity, or other roles, expressions or identities, or about an individual’s ability or inability to perform certain kinds of work or to participate in or benefit from programs or activities, or receive health or other services, based on a myth, bias or prejudice, assumption, social expectation, convention, statistical probabilities, or generalization about the individual or about other persons in a protected class. 56. \”Substantial Number\” is defined as five percent or more persons of a program\/location, who are non-English speaking, deaf, or hearing-impaired (see Section 21-115.12). 57. Transgender is a general term that refers to a person whose gender identity differs from the person’s sex assigned at birth. A transgender person may or may not have a gender expression that is different from the social expectations of the sex assigned at birth. A transgender person may or may not identify as transsexual. 58. Transitioning is a process some transgender people go through to begin living as the gender with which they identify, rather than the sex assigned to them at birth. This Commented [A35]: source: 11135 draft Commented [A36]: source: 11135 draft Commented [A37]: Advocates recommended adding \”or 1,000, whichever is less\” in order to cover populous LEP groups that don’t meet the 5% threshold because the county is so large Page 186 17 process may include, changes in name and pronoun usage, facility usage, or undergoing hormone therapy, surgeries, or other medical procedures. 59. Ultimate beneficiary means a person in a protected class who receives, applies for, participates in, or benefits from, or is unlawfully deterred or excluded from benefiting from, full and equal access to the benefits of, or employment with, or is subjected to discrimination under a program activity or service that is conducted, operated or administered by any covered entity. 60. Video remote interpreting ( VRI ) service means an interpreting service that uses video conference technology over dedicated lines or wireless technology offering high-speed, wide-bandwidth video connection that delivers high-quality video. 21.61. (iii) Wheelchair means a manually-operated or power-driven device designed primarily for use by an individual with a mobility disability for the main purpose of indoor or of both indoor and outdoor locomotion. t. Reserved u. Reserved v. Reserved w. Reserved x. Reserved y. Reserved z. Reserved NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11139.5, Government Code. 11136, 11137, 11139, 11139.8, 12901, 12903, 12926, 12926.1,12940, and 12960, Government Code. Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 11135, et seq., California Government Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7 Part IV, B. and K.; 28 CFR 35.104; and Title 24 of the California Code of Regulations (Access Code) Section 3105A(e). 21-10747 DISSEMINATION OF INFORMATION 21-107 .1 General Requirements Each county welfare department shall take appropriate steps to inform all applicants, recipients, community organizations, and other interested persons, including those whose primary language is other than English, and those with impaired hearing or vision or other disabling conditions, of the provisions of this dDivision and its applicability to the programs and activities for which the county welfare department receives federal or state financial assistance. Such notification shall also identify the name, email address, office telephone number, and office address of the employee(s) responsible for the county welfare department’s compliance with this dDivision (see Section 21-201.1). If not immediately available, this information must be provided within ten (10) calendar days of the date requested. .2 Specific Methods to be Utilized .21 Posters Commented [A38]: source: 11135 draft Commented [A39]: source: 11135 draft Page 187 18 .211 Posters on nondiscrimination provided by CDSS shall be prominently displayed in all waiting rooms and reception areas. The county welfare department shall place on the posters the name, email address, office telephone number, and office address of the person(s) in the CWD who is responsible for processing discrimination complaints. Posters dealing specifically with nondiscrimination in the Food Stamp Program shall be prominently posted in all certification and issuance offices. All posters and other public documents should be translated into appropriate languages to address the needs of LEP applicants\/recipients. .212 All instructional and directional signs posted in waiting areas and other places frequented by a substantial number of non-English-speaking LEP applicants\/recipients shall be translated into appropriate languages. Such signs, or an additional sign, shall state that applicants\/recipients may request aid or services in their primary language. .22 Pamphlets .221 Pamphlets supplied by CDSS, entitled \”Your Rights Under California Welfare Programs,\” shall be made available in all CWD waiting rooms and reception areas and shall be distributed and explained to each applicant\/recipient at intake and reinvestigation of eligibility. The pamphlets shall be in the primary languages of the CWD’s applicant\/recipient population, including alternate formats (e.g., cassette tapes or CDs, large print, Braille etc.). .23 Photographs and Illustrations Photographs and other illustrations used to provide program information conveying the message of equal opportunity shall display applicants\/recipients of different races, national origin, sexes, disabilities, etc., covered by this dDivision. .24 Notice The CWD shall implement procedures to ensure that applicants\/recipients, community organizations, and other interested persons, including persons with impaired vision or hearing or other disabling conditions, are notified of and can obtain information about programs or program changes including, but not limited to, the following: .241 Existence and location of benefits and services, and hours or days of operation; .242 Activities and services accessible to individuals with disabilities; .243 Basic eligibility requirements for public assistance; .244 Prohibited acts of discrimination; .245 Procedures for filing discrimination complaints; Page 188 19 .246 Rights and responsibilities of applicants\/recipients; and .247 The CWD’s policy of nondiscrimination. .25 Notice may be given by, but not limited to, the following methods: oral group presentations, face-to-face interviews, and printed materials, e.g., posters, pamphlets, etc. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7, Part VI, B. 1, 2, and 3; 28 CFR 35.106 and .107; 28 CFR 42.405(c); 45 CFR 80.6(d); 45 CFR 84.8; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and Title II of the American With Disabilities Act of 1990, P.L. 101-336. 21-10959 DISCRIMINATORY PRACTICES PROHIBITED 21-109 .1 In administering programs to which this division applies, county welfare departments may not, on the basis of race, color, national origin, religion, political affiliation, marital status, sex, age or disability, directly or through contractualcontractural, licensing, or other arrangements: .11 Provide aid, benefits, or services to an individual or group which is different than that provided to others unless such action is necessary to provide otherwise qualified individuals or groups with aid, benefits, or services that are as effective as those provided to others. The exclusion of an individual or group is not prohibited when the benefits or services of a program or activity are limited by federal statute or executive order to a specific class of individuals or group. Deny an individual any benefit or service. Subject an individual to separate treatment in any matter related to his\/her receipt of any benefit or service. Restrict an individual in any way in the enjoyment of any advantage or privilege enjoyed by others. HANDBOOK BEGINS HERE .111 The exclusion of an individual or group is not prohibited when the benefits or services of a program or activity are limited by federal statute or executive order to a specific class of individuals or group. HANDBOOK ENDS HERE .12 Deny an individual any benefit or service. Page 189 20 .13 Subject an individual to separate treatment in any matter related to his\/her receipt of any benefit or service. .14 Restrict an individual in any way in the enjoyment of any advantage or privilege enjoyed by others. .15 Treat an individual differently, whether he\/she satisfies any admission, enrollment, eligibility, or other requirement or condition which individuals must meet in order to be provided any benefit or service. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-109 DISCRIMINATORY PRACTICES PROHIBITED 21-109 .16 Programs Deny an individual an opportunity to participate in any program or activity through the provision of services or otherwise afford him\/her an opportunity to do so which is different from that afforded others under the program or activity. .17 Use criteria or methods of administration which have the effect of defeating or impairing the objectives of a program or activity. .18 Deny an individual the opportunity to be a member of an advisory board which is an integral part of any program. It is a prohibited practice for county welfare departments, in carrying out or failing to carry out any program or activity or providing, denying, or delaying any services or benefits directly or indirectly, through contractual, licensing or other arrangements, to treat in purpose or effect any person less unfavorably without legal justification on the basis of the protected class of the person, including by: 1. denying a person the opportunity or right to apply for, receive the benefits of, or participate in a program or activity; 2. affording a person the opportunity or right to apply for, receive the benefits of, or participate in a program or activity that is not full and equal to the program or activity afforded others; 3. providing a program or activity to a person that is not as effective in affording a full and equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement as that provided to others. In some situations, identical treatment may be discriminatory; 4. providing different or separate programs or activities to a person, or to any class of persons, than is provided to others, or providing programs or activities at a different time, Page 190 21 unless such action is clearly necessary to provide such persons with full and equal access as truly effective a program or activity as that provided to others; 5. aiding or perpetuating discrimination against a person by providing or transferring state support to a covered entity that discriminates in conduct, operation, or administration of any program or activity; 6. excluding a person from participation as a member of a planning or advisory board. Under this requirement, it is a discriminatory practice for a covered entity to fail to make reasonable efforts to achieve a representative board. However, such requirement is not deemed to impose adherence to a quota system; 7. limiting a person in the exercise or enjoyment of any right, privilege, advantage or opportunity enjoyed by others participating in or receiving any aid, benefit, or service resulting from a program or activity; 8. denying a person the opportunity to participate in programs or activities that are not separate or different, despite the existence of permissibly separate or different programs or activities; 9. utilizing criteria or methods of administration that: a. subject a person to discrimination on the basis of membership in, perception of membership in, or association with someone in a protected class; b. defeat or substantially impair the accomplishment of the objectives of the covered entity’s program or activity with respect to membership in a protected class. The objectives of a program or activity shall include its overall mission or purpose as reflected in sources, such as, relevant statutes, legislative intent and history, and regulations; c. create, increase, reinforce, or perpetuate discrimination or segregation by another recipient covered entity based on membership in a protected class; or d. create, increase, reinforce, or perpetuate discrimination or segregation based on membership in a protected class. 10. making or allowing selections or closures of sites or locations of facilities, or making, issuing, or denying permits for programs, services, activities or facilities that: a. exclude from, denies the benefits of, or otherwise subject persons to discrimination under any program or activity; b. defeat or substantially impair the accomplishment of the objectives of the program or activity with respect to membership in a protected class. 11. interfering with admittance to or enjoyment of public facilities or the rights of an individual with a disability under any program or activity. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11139, 12926, 12926.1, and 12940, Government Code. .2 Disability 1. Failure to take appropriate steps including providing accommodations or auxiliary aids to ensure that communications with applicants, participants, members of the public, and companions with disabilities are as effective as communications with others constitutes discrimination based on either disability or language proficiency. Commented [A40]: source: 11135 draft Page 191 22 a. For purposes of this section, companion means a family member, friend, or associate of an individual seeking access to a service, program, or activity of a public entity, who, along with such individual, is an appropriate person with whom the public entity should communicate. b. Primary consideration should be given to the disabled individual’s choice of auxiliary aid. 2. To ensure compliance with the nondiscrimination mandate, CWDs shall: a. Screen each client for disabilities and language access needs, using the following script or something substantially similar: There are things [agency name] will ask you to do in order to get or keep your benefits. If you have a health problem that makes it hard for you to do something [agency] asks, you can ask for help. This is called an accommodation. This could be because of a physical or mental or emotional health problem or learning disability. Some of the things we’ll ask you to do are: \u25cf Read notices we send and follow instructions in them \u25cf Fill out forms \u25cf Come to the office for appointments \u25cf Get and give us documents to prove whether you can get benefits \u25cf Tell us about changes in your household or \/case circumstances \u25cf Meet deadlines Do you think you might need help with any of these things, or something else, because of a health problem, disability, learning disability, or other issue? b. Track individual’s requested accommodation, reason for accommodation, and accommodation provided. i. CWDs shall engage in an interactive process to determine accommodations if they cannot provide the requested accommodation because it would entail an undue hardship or fundamentally alter the program according to the most up-to-date controlling interpretations of the ADA. ii. If an individual is covered under the ADA, the only reason for not providing an accommodation is undue burden or fundamental alteration. c. Give the individual oral and written notice of the accommodation they will receive and explaining the procedure for requesting an alternative accommodation. .32 Location of Facilities In determining the location of a facility, county welfare departments shall not make selections which have the effect of excluding individuals from, denying them the benefits of, or subjecting them to, discrimination under any programs to which this regulation applies. Commented [A41]: 11135 Page 192 23 .21 When units of the total available services are relocated to a new facility beyond the present facility’s program area, the CWD shall ensure that services are provided in a manner equally as effective as were provided in the central facility. .22 Prior to relocating a facility or units of a facility, a determination shall be made of other alternative services that will remain in the area, and the effect of the proposed relocation on the community. .23 When selecting the location for a facility, the CWD shall consider the availability of transportation (public and private) used by the recipient population. .24 When selecting the location for a public facility, the CWD shall select a building accessible to individuals with disabilities and persons who are elderly. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Section 11135, Welfare and Institutions Code; Section 51, California Civil Code; Section 10000, California Government Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101- 336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 45 CFR 80.1 and 80.3. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS .3 Practices Prohibited on the Basis of Age. .31 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived age; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular age; or 3. discriminate against of deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a specific age. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .4 Practices Prohibited on the Basis of Ancestry, Ethnic Group Identification, and National Origin .41 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived ancestry, ethnic group identification, or national origin, including a person’s primary language or accent; Page 193 24 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular ancestry, ethnic group identification, or national origin; 3. discriminate against a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a particular ancestry, ethnic group identification, or national origin, or because a person’s name, or that of their spouse, is believed to reflect a particular ancestry, ethnic group identification or national origin; 4. to fail to take appropriate steps to ensure that alternative communication services are available to ultimate beneficiaries. .42 Definitions: Alternative communication services means the method used for purposes of communicating effectively with a person with limited English proficiency who is unable to read or speak or write in the English language. Alternative communication services include, but are not limited to, the provision of the services of a multilingual employee or an interpreter for the benefit of an ultimate beneficiary; the provision of written materials in a language other than English; the provision of written materials in a format other than standard font written print, such as Braille, large font print, sign language visual formats and electronic formats; auxiliary aids and services; and notice to the limited English proficient person of the availability of free alternative communication services, including interpreter and translation services and where to file complaints if appropriate services are not provided. Multilingual employee means a qualified employee of a covered entity who, in addition to their duties, is also proficient in oral communication skills in English and the target languages, as are necessary to accurately and readily interpret in a second language, and has received education and training in interpreter ethics, conduct, practice, and confidentiality. A multilingual employee need not be proficient in reading or writing skills in a second language except where such skills are a job-related necessity or necessary for orally interpreting a written document. Limited English proficient persons ( LEP ) includes: a. persons who are non-English speaking or who do not speak English as their primary language or have limited ability to read, write, speak, or understand English; b. persons with developmental, mental health, or intellectual disabilities who have limited ability to understand English; and c. persons with manual or sensory disabilities, such as manual dexterity impairments, hearing or vision impairments, who have limited functional ability to read, write, or speak English presented in standard visual or oral formats;. d. persons who are competent in English for certain types of communication (e.g., speaking or understanding) but are LEP for other purposes (e.g., reading or writing). Primary language means the language used most frequently by a person to communicate, including sign language, or tactile sign language. Commented [A42]: source: https:\/\/www.justice.gov\/sites\/default\/files\/crt\/legacy\/201 5\/05\/04\/crtlap.pdf Page 194 25 Translator means a person qualified and capable of translating a language in writing or sign. A qualified translator has received education and training in translator best practices, including ethics, conduct, practice, and confidentiality. Translation is the replacement of a written text or sign, or recorded image, from one language (source language) into an equivalent written text or sign, or recorded image in another language (target language), accurately and with appropriate cultural relevance, and at the appropriate grade level. Although many of the same requirements apply to translators as for interpreters, the skill of translators is very different from that of interpreting. Competency of translations can often be ensured by: (i) having a second independent translator to check the work of the primary translator, including using a community review process to ensure the correct reading and literacy level and understandability of the document, and (ii) using back translation by having one translator translate the documents and a second one translate it back to English or the source language to check the appropriate meaning. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .5 Practices Prohibited on the Basis of Color and Race .51 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived color or race; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular color or race; 3. discriminate against of deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a specific color or race, or because a person’s name, or that of their spouse, is believed to reflect a given color or race. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .6 Practices Prohibited on the Basis of Marital Status .61 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of a person’s actual or perceived marital status; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular marital status; or Page 195 26 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular marital status. .7 Practices Prohibited on the Basis of Religion It is a discriminatory practice for a recipient of state support to discriminate against an ultimate beneficiary based on the nature of the ultimate beneficiary’s religious beliefs. .71 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived religion;. 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular religion; 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular religion; or. 4. to fail to make reasonable accommodation to the religious belief of an ultimate beneficiary where such accommodation can be made without undue hardship on the covered entity. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .8 Practices Prohibited on the Basis of Sex or Sexual Orientation .81 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s sex or sexual orientation, as defined in section XXX201-4; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular sex or sexual orientation, as defined in sections XXX201-4; or 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular sex or sexual orientation, as defined in sections XXX201-4. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .9 Personal Information In determining whether a person satisfies any criteria for receipt of an aid or benefit or participation in a program or activity, it is a prohibited practice for a covered entity to differentiate Page 196 27 on the basis of sex in inquiring about the family or marital status of such person. However, such person may be required to provide information relevant and necessary for determining whether such person satisfies validly imposed criteria for the aid or benefit, or participation in the program or activity in question. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .10 Pregnancy, Childbirth or Termination of Pregnancy. Any practice of a covered entity concerning disability due to pregnancy, childbirth, recovery from childbirth or termination of pregnancy, or other physiological conditions related to the capacity to bear children not applied under the same terms and conditions, and in the same manner, as any other practice relating to any other temporary disability is a prohibited practice; except as otherwise provided by the Fair Employment Practice Act. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139 and 11139.5, Government Code. .11 Parental, Family or Marital Status Any practice of a covered entity concerning the actual or potential parental, family or marital status of an ultimate beneficiary which has the purpose or effect of differentiating on the basis of sex is a prohibited practice. Note: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .12 Inquiries Rregarding and Recording of Gender and Name. 1. Inquiries by a covered entity that directly or indirectly identify a person on the basis of sex, including gender, gender identity, or gender expression, or sexual orientation, are unlawful unless the covered entity establishes a permissible defense, including whether such a practice is required by state or federal law or an order of a state or federal court. For recordkeeping purposes, a covered entity may request a person to provide this information solely on a voluntary basis. 2. It is discrimination under this Division, if an ultimate beneficiary requests to be identified with a preferred gender, name, and\/or pronoun, including gender- neutral pronouns, and a covered entity fails to abide by the person’s stated preference. Page 197 28 3. A covered entity is permitted to use a person’s gender or legal name as indicated in a government-issued identification document only if it is necessary to meet a legally-mandated obligation, but otherwise must identify the person in accordance with their gender identity and preferred name. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .13 Additional Rights 1. It is unlawful for a covered entity to inquire about or require documentation or proof of a person’s sex, gender, gender identity, or gender expression as a condition of application or eligibility for, or receipt of, any benefit, program, activity, or service provided by the covered entity. 2. It is unlawful for a covered entity to deny any benefit, program, activity, or service to an individual based wholly or in part on the individual’s sex, gender, gender identity, or gender expression. 3. It is unlawful for a covered entity to discriminate against or deny full and equal access to an individual who is transitioning, has transitioned, or is perceived to be transitioning. 4. It is unlawful for a covered entity to refuse any individual access to facilities that correspond to that individual’s gender identity or gender expression, regardless of the individual’s sex assigned at birth. Covered entities may not require individuals to undergo, provide proof or any medical treatment or procedure, provide any identity document, or to use facilities designated for use by a particular gender. Note: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, 11139, 12920, 12921, 12926, and 12940, Government Code. 21-106 Standards for Determining Discrimination and Unlawful Denial of Full and Equal Access In order to determine whether a practice is discriminatory or unlawfully denies full and equal access, all sources of information may be used, including the sources of information and methods used by state and federal courts and agencies in determining whether a practice is discriminatory or denies full and equal access. The sources of information and methods used by federal courts and agencies shall be considered a floor and not a ceiling, consistent with the objective of Division 21 to provide the broadest protections for civil rights. .1 Practices prohibited include facial discrimination, intentional discrimination, disparate impact discrimination, and denial of full and equal access. 1. Facial discrimination, sometimes referred to as express discrimination, is unlawful per se. Such discrimination includes and practices that classify individuals and provide them Commented [A43]: source: 11135 draft Page 198 29 aid, benefits, or services on the basis of their inclusion or exclusion from a protected class, except to the extent they lawfully benefit members of a protected class, such as by being part of a lawful affirmative action plan. 2. Practices that intentionally discriminate against individuals on the basis of membership in a protected class are prohibited. Intentional discrimination is established when a protected basis is a motivating factor in taking an adverse action even though other factors may have also motivated the practice. Intentional discrimination may be proved by direct or circumstantial evidence. Intentional discrimination includes purposeful discrimination. 3. Disparate impact discrimination is prohibited. Disparate impact, discriminatory effect, and adverse impact are used interchangeably. Disparate impact occurs when a facially neutral act or practice, regardless of intent, a. has an adverse or disproportionate impact, or predictably results in an adverse or disproportionate impact, on members of a protected class; b. creates, increases, reinforces, or perpetuates discrimination or segregation of members of a protected class; or c. has the effect of violating any of the other prohibitions against discrimination. A practice with a disparate impact may nevertheless still be lawful if supported by a legally sufficient justification, as set out in California Government Code Ssection 14029. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1,12940, 12955,12955.8, 14029 Government Code. 21-111 ACCESSIBILITY 21-111 .1 The CWD shall ensure that programs and activities are readily accessible to individuals with disabilities. HANDBOOK BEGINS HERE .11 The U.S. Department of Justice implementing regulations for Title II of the ADA are contained in 28 CFR Part 35. Appendix A of 28 CFR Part 36 contains the ADA Accessibility Guidelines (ADAAG), which govern the physical accessibility requirements for state and local governments. Title 24 of the California Code of Regulations (CCR), Parts 1, 2, 3, 5, 8, and 12 contains the regulations governing structural accessibility for individuals with disabilities in public facilities in the State of California. The above federal and state regulations provide the accessibility requirements for new construction, alterations, and for existing facilities. .111 Some examples of architecturalarchitectual changes in federal and state regulations that would make facilities accessible to individuals with disabilities are: (a) Installing ramps and handrails; Page 199 30 (b) Making curb cuts in sidewalks and entrances; (c) Widening doors and\/or installing accessible door hardware; (d) Creating accessible parking spaces; (e) Installing visual and auditory emergency alarms; (f) Installing exterior signs at all inaccessible facility entrances directing individuals with disabilities to an accessible entrance or to a location where information about accessible facilities can be obtained. (g) Affixing signs of appropriate size and contrast to identify a CWD to assist individuals with a visual impairment in locating offices. .12 Each CWD, with instructions and assistance provided by the CDSS, shall evaluate its practices and policies to ensure they do not discriminate on the basis of disability. .13 In choosing available methods for meeting the requirements of this section, the CWD shall give priority to those methods that offer programs and activities to individuals with disabilities in the most integrated setting appropriate. .14 Each county welfare department shall establish procedures to ensure that communications with applicants\/recipients and members of the public with disabilities are as effective as communications with others (see Section 21-115.41). .2 When public areas (e.g., reception areas, waiting rooms, interview booths, public restrooms, and public drinking fountains) are provided, they shall be accessible to individuals with disabilities and identified by the international symbol of accessibility in compliance with Title 24 of the California Code of Regulations. .3 When parking is provided to the general public, it shall be accessible to individuals with disabilities pursuant to local ordinance and\/or Title 24 of the California Code of Regulations. .4 CWDs may provide alternative methods that would be equally effective in making programs and activities accessible to individuals with disabilities, with prior written approval from CDSS. .41 When alternative methods are proposed, the county welfare department director or his\/her designee shall submit a written statement supporting their reasons for reaching that conclusion. This statement must be submitted to CDSS for review and approval prior to the implementation of this decision. Page 200 31 NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Sections 4450 and 11135, California Government Code; Title 24 of the California Code of Regulations, Parts 1, 2, 3, 5, 8, and 12; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Appendix A, 28 CFR Part 36; and 28 CFR 35.150 and .151. 21-115 PROVISION FOR SERVICES TO APPLICANTS AND RECIPIENTS 21-115 WHO ARE WITH LIMITED ENGLISH PROFICIENCY NON-ENGLISH SPEAKING OR WHO HAVE DISABILITIES County welfare departments shall ensure that effective bilingual\/interpretive services are provided to serve the needs of individuals with limited English proficiency non-English speaking population and individuals with disabilities. The provision of bilingual\/interpretive services shall be prompt without undue delays. This need shall be met as indicated below. .1 A sufficient number of qualified bilingual employees shall be assigned to public contact positions in each program and\/or location serving a substantial number of limited English proficient non-English-speaking persons. These employees shall have the language skills and cultural awareness necessary to communicate fully and effectively and provide the same level of service to non-English speaking limited English proficient applicants\/recipients as is provided to the client population at large. .11 The number of public contact positions in each major occupational group shall be determined for each program and\/or location whose non-English limited English proficient language cases equal or exceed five percent of the total cases for each program or location. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-115 PROVISION FOR SERVICES TO APPLICANTS AND RECIPIENTS 21-115 WHO ARE NON-ENGLISH SPEAKING OR WHO HAVE DISABILITIES .12 In determining this percentage, primary language groups shall be considered individually, rather than cumulatively. .13 To determine the percentage of non-English-language limited English proficient cases in any program and\/or location, divide the number of ongoing (continuing) non-English-language limited English proficient cases for each primary language group by the total ongoing (continuing) cases in that program and\/or location. Page 201 32 .14 To determine the required number of bilingual employees in a program and\/or location, multiply the percentage of non-English-language cases by the number of public contact positions in each major occupational group in that program and\/or location. If application of the formula results in a whole number plus a fraction of less than one-half, it shall be rounded to the next lower number, e.g., 1.49 = 1.0. If the resultant fraction is one-half or greater, it shall be rounded to the next higher number, e.g., 1.50 = 2.0. HANDBOOK BEGINS HERE EXAMPLE AFDC Program – Main Office 20 Eligibility Workers (EW) x.08 Spanish Language Case Percentage 1.60 Equals Two Qualified Spanish Speaking EW Contact Positions HANDBOOK ENDS HERE .141 When the computation (to determine required bilingual staffing) results in a need for less than one full-time position for a major occupational group in a program and\/or location, the agency may provide services through the use of a qualified bilingual employee from another program within the same location. EXAMPLE: District Office AFDC NAFS SOCIAL SERVICES Spanish Language Spanish Language Spanish Language Cases 20% Cases 25% Cases 10% Total EWs x1 Total EWs x2 Total EWs x1 Required .2 Required .50 Required .1 In the example above, one full time Spanish-speaking worker in any program would satisfy the requirements for all programs, provided that the worker would be available to interpret for the other two programs. Page 202 33 .15 When the percentage of non-English limited English proficient cases in a program and\/or location is less than five percent, the agency shall ensure that effective bilingual services are provided. This requirement may be met through utilization of paid interpreters, qualified bilingual and multilingual employees, contract interpreters (including telephonic interpreters), qualified employees of other agencies, or interpreters from community organizations, or volunteer interpreter programs community resources. .16 Applicants\/recipients may provide their own interpreter; however, the CWD shall not require them to do so. Only under extenuating circumstances or at the specific request of the applicant\/recipient shall a CWD allow a minor (under the age of 18 years) to temporarily act as an interpreter. This provision does not apply to interpretive services for persons who are deaf. .2 Forms and other written materials required for the provision of aid or services shall be available and offered to the applicant\/recipient in the individual’s primary language when such forms and other written material are provided by CDSS. When such forms and other written material contain spaces (other than \”for agency use only\”) in which the CWD is to insert information, this inserted information shall also be in the individual’s primary language. .3 Each CWD shall ensure that administrative practices do not have the effect of denying individuals with limited English proficiency non-English speaking persons and individuals with disabilities equal access to and participation in the available programs and activities. .4 Auxiliary Aids .41 .41 CWDs shall provide appropriate auxiliary aids and services where necessary to afford qualified individuals with disabilities, including applicants, participants, companions, and members of the public, an equal opportunity to participate in, and enjoy the benefits of, a service, program, or activity of a public entity.to persons who are deaf or hearing impaired, or persons with impaired speech, vision or manual skills where necessary to afford such persons an equal opportunity to participate in, and enjoy the benefits and services of programs or activities. Auxiliary aids and services may include: brailled material, taped text, qualified interpreters, large print materials, telecommunication devices for the deaf (TDDs) and other effective aids and services for persons with impaired hearing, speech, vision or manual skills. Compliance with this section can be accomplished through use of volunteer services from community organizations and individuals who are able to provide prompt effective services without undue delays using qualified interpreters. .42 1. CWDs shall provide an opportunity for individuals with disabilities to request auxiliary aids and services of their choice. CWDs shall give primary consideration to the requests of individuals with disabilities. 28 CFR 35.160 (Section by Section Analysis) provides that public entities, \”shall honor the choice [of individuals with disabilities for auxiliary aids and services] unless it can demonstrate that another effective means of Commented [A44]: New York: \”Upon request. an LEP individual may also be permitted to use a minor, a family member or friend as an interpreter for routine matters, such as asking the location of the office, hours of operation or rescheduling an appointment.\” https:\/\/drive.google.com\/drive\/u\/0\/folders\/1wemv470O whiWyDOE6zNUP8aBnLn6XQc4 Page 203 34 communication exists or that use of the means chosen would not be required under [28 CFR Section 35.164]. 2. The type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. In determining what types of auxiliary aids and services are necessary, a public entity shall give primary consideration to the requests of individuals with disabilities. In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability. 3. It is the covered agency’s responsibility to provide the auxiliary aid. Therefore it shall not: a. require an individual with a disability to bring another individual to interpret for him or her. b. rely on an adult accompanying an individual with a disability to interpret or facilitate communication except\u2014 i. iIn an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available; or ii. wWhere the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances. rely on a minor child to interpret or facilitate communication, except in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available, and with affirmative consent provided. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-115 PROVISION FOR SERVICES TO APPLICANTS AND RECIPIENTS 21-115 WHO ARE NON-ENGLISH SPEAKING OR WHO HAVE DISABILITIES HANDBOOK BEGINS HERE Commented [A45]: Language could be added indicating that the county worker should be provided some assurances re competency. Page 204 35 .421 28 CFR 35.160 (Section by Section Analysis) provides that public entities, \”shall honor the choice [of individuals with disabilities for auxiliary aids and services] unless it can demonstrate that another effective means of communication exists or that use of the means chosen would not be required under [28 CFR Section 35.164].\” HANDBOOK ENDS HERE c. .423 When telephone contact is necessary CWDs shall use a TDD, or equally effective telecommunications systems, to communicate with individuals with impaired hearing or speech. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 28 CFR 35.160 and .161. 21-116 DOCUMENTATION OF APPLICANT\/RECIPIENT CASE RECORDS 21-116 .1 Each agency shall maintain case record documentation in sufficient detail to permit a reviewer to determine the agency’s compliance with the requirements of Division 21. .2 Each agency shall ensure that case record documentation identifies the applicant’s\/recipient’s ethnic origin and primary language in accordance with Section 21-201.21. In those cases where the applicant\/recipient is non-English speakinglimited English proficient, the agency shall: .21 Document the individual’s acceptance or refusal of forms or other written material offered in the individual’s primary language (HANDBOOK: see Section 21-115.2)]. .22 Document the method used to provide bilingual services, e.g., assigned worker is bilingual, other bilingual employee acted as interpreter, volunteer interpreter was used, or client provided interpreter. When a minor (under 18 years of age) is used as an interpreter, the CWD shall so document the circumstances requiring temporary use of minors in the case record. .23 When applicants\/recipients provide their own interpreter, the CWD shall ensure that the applicants\/recipients are informed of the potential problems for ineffective communication. The CWD shall document in the case record that the applicants\/recipients were so informed. Page 205 36 .24 Consent for the release of information shall be obtained from applicants\/recipients when individuals other than CWD employees are used as interpreters and the case record shall be so documented. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-116 DOCUMENTATION OF APPLICANT\/RECIPIENT CASE RECORDS 21-116 .3 Upon obtaining information that identifies an applicant\/recipient as disabled or upon identifying someone as needing an accommodation because of disability through the screening procedure outlined above in XXXX21-109, each CWD shall ensure that the case record is so documented. The CWD shall document, in writing, an applicant’s\/recipient’s request for auxiliary aids and services (see Section 21-115.4). NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; and 28 CFR 35.160(a) and (b)(2). 21-117 STAFF DEVELOPMENT AND TRAINING 21-117 .1 Each public contact employee shall receive training in the requirements of Division 21. These requirements of Division 21 shall be incorporated into the content of the CWD’s orientation and continuing training programs. This shall include familiarization with the discrimination complaint process. CDSS will provide program guidelines and technical assistance upon request. .2 Each CWD shall develop and\/or provide cultural awareness training programs for all public contact employees. Cultural awareness training shall pertain to specific cultural characteristics of cultural groups served by the CWD to provide a better understanding of, and sensitivity to, the various cultural groups, including individuals with disabilities to ensure equal delivery of services. Whenever possible, training shall involve community organizations familiar with a specific culture. HANDBOOK BEGINS HERE .21 In presenting materials relating to specific cultural characteristics, all efforts should be made to avoid stereotypes. HANDBOOK ENDS HERE Page 206 37 .3 Appropriate agency staff shall be instructed in the investigation of discrimination complaints. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; 28 CFR 35.160(a) and Subpart B; 80 CFR 80.1; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-201 COMPLIANCE PROCEDURES AND REPORTING 21-201 .1 Assignment of Resources to Implement Requirements of This Division Responsibility for the implementation of nondiscrimination requirements shall be centralized within each agency. Each agency shall designate an employee as the Civil Rights Coordinator, and shall allocate adequate personnel and resources to implement the provisions of this dDivision and ensure nondiscrimination in the delivery of services. Methods and staff used to meet Division 21 requirements may vary from county to county. To determine agency compliance, the following factors will be considered: .11 Level and quantity of personnel assigned to activities related to this dDivision. .12 Comparison of the civil rights unit’s workload, actual or anticipated, to the workload of other administrative units. .13 Extent to which the existence and responsibilities of the civil rights unit has been publicized within the agency and to the public. .14 Comparison of physical space and equipment assigned to civil rights personnel with that assigned to other offices of similar level in the agency. .2 Compliance Reports Each CWD shall keep timely and accurate compliance records. This information shall be submitted to CDSS whenever, and in such form as, CDSS may determine necessary. The information includes, but is not limited to, the following: Page 207 38 .21 Each CWD shall collect primary language and ethnic origin data by district offices in all AFDC, nonassistance food stamps, and social services programs covered by this dDivision. This data shall be collected for each head of household or, in social services cases, each primary recipient. .211 Ethnic origin and primary language shall be determined by the applicant\/recipient completing the appropriate section of the application forms. Should he\/she decline to make a self-declaration, the worker will make a visual determination and record the information in the appropriate place on the form. .212 Each CWD shall submit this information by countywide total to CDSS annually. Source data substantiating the compliance report is to be maintained by the district office. .22 County Civil Rights Plans All county welfare departments shall submit to CDSS an initial Civil Rights Plan and subsequent annual updates. Each plan shall function as a guide in developing the CWD’s policy of providing equal delivery of benefits and services. The Civil Rights Plan and updates will be in such format and will contain such information as CDSS may determine necessary. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-201 COMPLIANCE PROCEDURES AND REPORTING 21-201 .23 County Civil Rights Impact Studies HANDBOOK BEGINS HERE .231 The USDA requires that civil rights impact studies be completed \”[b]efore making decisions that would substantially alter individual’s access to [county] welfare offices…\” to ensure against discrimination. This requirement is outlined in the USDA Administrative Notice 93-11, State Agency Local Welfare Hours, dated December 4, 1992. The Notice requires that the impact studies be available for review. .232 The USDA, Office of Civil Rights Enforcement, issued Departmental Regulation #4300-4, Civil Rights Impact Analysis, dated September 22, 1993. The Regulation requires county welfare departments \”…to establish internal systems to identify and address the civil rights implications of proposed policy actions before those actions are approved and implemented.\” The regulation identifies \”policy actions\” as those actions including but not limited to reorganizations, office consolidations, closures or relocations. \”Major civil rights implications\” are defined as \”…those consequences of proposed policy actions which, if implemented, will Page 208 39 negatively or disproportionately affect minorities, women, or persons with disabilities who are employees, program beneficiaries or applicants for employment or program benefits in USDA- conducted or assisted programs by virtue of their race, color, sex, national origin, religion, age, disability, marital or familial status.\” The Regulation requires agencies to: \”(1) Identify and address major civil rights impacts of proposed actions on minorities, women, and persons with disabilities before the actions are approved and implemented. \”(2) Establish internal procedures which implement this policy…[Examples are provided here.] \”(3) Refer proposed policy actions and supporting documentation which contain major civil rights impacts that cannot be resolved at the agency level to the Office of Advocacy and Enterprise for review…[Examples are provided here as to situations when a referral will be made.] \”(4) Certify to the Assistant Secretary for Administration that procedures to implement this policy have been established within 90 days of the effective date of this regulation.\” HANDBOOK ENDS HERE CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-201 COMPLIANCE PROCEDURES AND REPORTING 21-201 .3 Compliance Reviews HANDBOOK BEGINS HERE .31 In order to ensure compliance with civil rights laws and regulations, CDSS conducts routine on- site reviews of county welfare departments. The review includes, but is not limited to, the following: .311 A review of case records for applicants\/recipients who are non-English speaking or disabled and other case records as appropriate. .312 Interviews with CWD staff. .313 A contact with at least one community organization. .314 A review of the program’s or activity’s accessibility to persons with disabilities. Page 209 40 .315 A review of program or activity information being provided to applicants\/recipients, community organizations, or other interested persons. .316 A review of applications, application instruction sheets, pamphlets, or other materials available to the public. .317 A review of the CWD’s complaint log to determine if civil rights complaints are processed in accordance with procedures outlined in Section 21-203. .318 A review of appropriate documents to confirm an assurance of compliance agreement is included. .32 On occasion, special compliance reviews may be necessary. These reviews may be unannounced and are conducted when: .321 There is a need to follow up on noncompliance findings from a routine review requiring additional information and an in-depth examination of specific aspects of program operations and activities. .322 Statistical data indicates that a particular group of people is not participating in or benefitting from a program or activity to the extent indicated by the population characteristics of that area. .323 The Director of CDSS requests a review. HANDBOOK ENDS HERE CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-201 COMPLIANCE PROCEDURES AND REPORTING 21-201 .324 Reports of noncompliance by federal, state, or other agencies need to be substantiated. .325 A pattern of complaints of discrimination has developed. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Program Instruction 113-7, Parts V, VII, and VIII; Page 210 41 USDA Departmental Regulation, Office for Civil Rights Enforcement, #4300-4, September 22, 1993; USDA, Administrative Notice 93-11, dated December 4, 1992 (State Agency Local Welfare Office Hours); 7 CFR 15.3(b)(3); 28 CFR 35.130(b)(4); 28 CFR 42.406(a), (b), (b)(4), (b)(6), (c), and (d); 28 CFR 42.407(b); 28 CFR 42.410; 45 CFR 80.3(b)(3); 45 CFR 80.6(b); and 45 CFR 84.4(b)(5). 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 TREATMENT. 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATION County welfare departments are responsible for investigating discrimination complaints made by applicants\/recipients or by their authorized representatives, and for investigating complaints remanded by CDSS, the U.S. Department of Health and Human Services, or the U.S. Department of Agriculture. An applicant\/recipient or his\/her authorized representative may file a complaint of discrimination with the state or local county welfare department involved or directly with the appropriate agency of the federal government. Information concerning the complaint process shall be available to applicants\/recipients and other interested persons and shall include procedures for filing complaints or appeals with CDSS, the U.S. Department of Health and Human Services or the U.S. Department of Agriculture. The complaint must be received not later than 180 days from the date of the alleged discriminatory act unless the filing date is extended by CDSS or the responsible federal agency. When CDSS or the CWD lack jurisdiction over a complaint, CDSS or the CWD shall, whenever possible, refer the complaint to the appropriate governmental agency and\/or advise the complainant of the lack of jurisdiction and explain the reason why it is outside the jurisdiction. .1 Complainant’s Right to a State Hearing (Fair Hearing) This regulation does not limit or restrict a complainant’s right to request a state hearing in accordance with Division 22. Should the complaint involve program issues, in addition to allegations of discriminatory treatment, program issues may be subject to a state hearing. It is the CWD’s responsibility to advise the complainant of his\/her right to a state hearing and the necessity to request such a hearing within 90 days as prescribed in Section 22-009, in addition to the filing of a complaint of discriminatory treatment. The complainant shall also be advised of the 10-day limitation for filing a request for a state hearing to receive aid paid pending. .11 Should a complaint of discrimination arise during a state hearing, the Administrative Law Judge shall remand the complaint to the CWD for the preparation of a report in accordance with Section 21-203.12 and CDSS’s Civil Rights Bureau (CRB) to be handled ininvestigation and handling in accordance with Division 21 regulations. Commented [A46]: See recommendations in accompanying memo suggesting modifying this language to provide that ALJs have jurisdiction to address discrimination complaints that arise during fair hearings and limiting this jurisdiction to the effect the alleged discrimination had on the eligibility issue that is the subject of the state hearing. Page 211 42 CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATIONORY 21-203 .2 Procedures for Processing Discrimination Complaints All complaints of discrimination will be addressed in accordance with the following procedures: .21 The CWD shall maintain a control log in which all complaints of discrimination are entered by year and date the complaint was received. At a minimum the log shall provide: .211 Complainant’s name. .212 Date complaint was received and the date of the alleged discriminatory act(s).. .213 CDSS\/CRB case number, if any. .214 Program(s) involved. .215 Basis of discrimination: age, race, sex, etc. .216 Nature of the complaint. .217 Resolution: completed investigation, withdrawal, failure to pursue, etc. .218 Decision: discrimination or no discrimination. .219 Date investigation completed or date complaint resolved. .22 A complaint of discrimination shall be filed either verbally orally or in writing. .221 The CWD shall be permitted to ask the complainant to fill out a complaint form but shall not make it a condition of filing a complaint. .222 The CWD shall accept complaints of discrimination filed anonymously. .223 When a complainant refuses to put their complaint in writing because of fear of retribution or to maintain anonymity, or due to illiteracy, or is physically unable to put their complaint in writing, the person to whom the allegation is being made shall put the elements of the complaint in writing. Page 212 43 .224 The CWD shall make a reasonable effort to make contact with the complainant by mail and\/or telephone to follow up on the initial complaint. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 .23 Within 20 calendar days of receipt of a complaint, the CWD\/CDSS shall acknowledge the complaint by informing the complainant in writing that an investigation will be conducted. .24 For those complaints requiring investigation by the CWD, the investigation, including any attempted resolution, shall be completed within sixty (60) calendar days following the receipt of the complaint. Within twenty (20) calendar days following the completion of the investigation, the CWD shall: .241 Inform the complainant in writing of the results of the investigation, clearly stating the reason for the decision. .242 Inform CDSS\/CRB of the case resolution and of any corrective actions taken. .243 Forward a complete copy of the investigation report to CDSS\/CRB and attach copies of all correspondence sent to the complainant. .25 For those complaints not requiring an investigation, the CWD shall: .251 Inform the complainant, in writing, within 40 calendar days of receipt of the complaint that the complaint shall not be investigated and the reason(s) for not investigating. .252 Inform CDSS\/CRB of the case resolution, including a copy of the withdrawal form, letter to the complainant, etc. .26 The complainant shall be informed of his\/her rights as follows: .261 The CWD shall inform the complainant that he\/she may appeal a CWD decision to CDSS within 30 calendar days of the date on which the CWD mails, or otherwise provides the complainant with the decision. .262 The CWD shall, in addition to informing the complainant of his\/her appeal rights set forth in Section 21-203.261, also inform the complainant that he\/she may appeal a CWD decision Page 213 44 resulting from a complaint based on race, color, national origin, political affiliation, religion, sex, age or disability to the United States Department of Agriculture (USDA), if the complaint involves the Food Stamp Program, within 30 calendar days of the date on which the CWD mails, or otherwise provides the complainant with the decision. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 .263 The CWD shall, in addition to informing the complainant of his\/her appeal rights set forth in Section 21-203.261, also inform the complainant that, after a CWD decision resulting from a complaint based on race, color, national origin, age or disability he\/she may file his\/her complaint with the United States Department of Health and Human Services (HHS), if the complaint involves programs other than the Food Stamp Program that receive financial assistance through HHS, within 180 calendar days of the alleged discriminatory act unless the filing date is extended by HHS. .264 CDSS shall inform the complainant that a CDSS decision on a complaint or appeal, pursuant to Section 21-203.261, may similarly be appealed to the USDA pursuant to Section 21- 203.262 and\/or filed with HHS pursuant to Section 21-203.263. .27 Nothing in these regulations shall preclude a complainant’s pursuing remedies through civil proceedings. .3 Procedures for Investigation Complaints In order to maintain consistency in the conduct of investigations, the following procedures shall apply. .31 The CWD\/CDSS shall designate an employee to conduct investigations. In no case shall an employee be assigned to investigate a complaint involving actions taken by him\/her or by an employee under his\/her immediate supervision, or where that designated employee’s responsibilities in another program or capacity within CWD\/CDSS may result in a conflict of interest. .32 Interview with Complainant A face-to-face interview shall be conducted by the assigned investigator unless the client and CWD mutually agree it is neither necessary nor practical. When scheduling an interview with the complainant, the complainant shall be advised that a representative or counsel may be present at the interview. In addition, the complainant shall be requested to sign a consent form informing Page 214 45 the complainant that the information pertinent to the processing of a complaint will be shared with the appropriate CWD\/CDSS and federal civil rights personnel in the investigation of the complaint as necessary. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 .321 Prior to beginning the interview, the person assigned to investigate the case shall explain confidentiality requirements, and make reasonable efforts to ensure that the complainant is able to communicate effectively (refer to Section 21-115.4), using interpreters, readers, etc., if necessary. The following information shall be obtained during the interview: (a) Complainant’s name, case number, address, email address, and telephone number. (b) Names of individuals responsible for the action, decision, or condition alleged to be discriminatory. (c) Date and place of alleged discriminatory treatment. (d) Basis of discrimination (e.g., race, sex, disability, etc.). (e) Nature of the action, decision, or conditions of the alleged discrimination. (f) Information known to the complainant in support of his\/her allegation. (g) Names and contact information of pPossible witnesses whom the complainant wishes to have interviewed. (h) Other information specific to the complaint. (i) Any indications of reprisal, intimidation, or harassment as a result of the complaint. (j) Relief sought by the complainant. .33 Interview with the employee alleged to have acted in a discriminatory manner. When scheduling an interview with the employee, the employee shall be advised of the right to have a representative or counsel present. Page 215 46 .331 The investigator should identify the complainant and describe the nature of the complaint. The employee’s statement should be taken concerning the complaint issues. The employee should be advised that such statements will be available to the complainant as part of the investigation. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 .34 Review of Issues Specific to the Complaint In reviewing the issues involved in the applicant\/recipient complaint, the investigator shall: .341 Review Division 21 regulations which pertain to the issues in the complaint and, if necessary, obtain clarification from CDSS. .342 Review complaint documents concerning the discrimination issues. .343 Interview witnesses as indicated by circumstances or the nature of the allegation. .35 Investigation of the General Environment In evaluating the general environment in which the alleged discriminatory action occurred, the investigator may: .351 Select and review cases to compare the treatment of individuals with disabilities, members of the same race, national origin, etc., with cases selected from the general welfare population. .352 Compare the treatment of recipients by the individual who allegedly discriminated with the treatment provided by other employees for a similar group. .353 Interview the employee alleged to have discriminated. .354 Interview the supervisor of the employee named in the complaint and survey the general environment in which the complaint arose. Record details which may indicate needed corrective action or exonerate the employees alleged to have discriminated. .355 Review other supporting documents as appropriate. .4 Report of Investigation Page 216 47 The investigation report shall address all issues raised by the complainant. Where there is insufficient evidence to make a decision whether discrimination occurred or not, further investigation shall be conducted until a decision can be made. The investigator shall ensure that such issues are fairly represented in the report. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY 21-203 .5 Harassment, Coercion, Intimidation, and Retaliatory Acts Prohibited No official or employee shall intimidate, threaten, harass, coerce or discriminate against any individual for the purpose of interfering with any right or privilege secured by these regulations or because he or she has made a complaint, testified, assisted or participated in any manner in any investigation, proceeding or hearing. .51 Harassment Prohibited (a) Harassment by a covered entity, related to any program or activity, on any protected basis is an unlawful practice. (b) Harassment includes quid pro quo harassment and hostile environment harassment. The same conduct may constitute both quid pro quo and hostile environment harassment. (1) Quid pro quo harassment. Quid pro quo harassment refers to an unwelcome request or demand to engage in conduct where submission to the request or demand, either explicitly or implicitly, is made a condition related to the attainment of any benefit, as defined in Section 14020 of this subchapter. An unwelcome request or demand may constitute quid pro quo harassment even if an individual acquiesces in the unwelcome request or demand. (2) Hostile environment harassment. Hostile environment harassment refers to unwelcome conduct that interferes with or prevents the attainment of any benefit, constitutes any kind of adverse action, or creates a hostile, offensive, oppressive, or intimidating environment. Hostile environment harassment does not require a change in the terms, conditions, or privileges afforded by a covered program. Commented [A47]: source: 11135 draft Page 217 48 (A) Whether hostile environment harassment existed or exists depends on the totality of the circumstances. (i) Factors to be considered in determining whether hostile environment harassment existed or exist include: the nature of the conduct; the context in which the incident(s) occurred; the severity scope, frequency, duration, and location of the conduct; and the relationship of the persons involved. (ii) Neither psychological nor physical harm must be demonstrated to prove that a hostile environment existed or exists. However, evidence of psychological or physical harm may be relevant in determining whether a hostile environment exists or existed, and the amount of damages to which an aggrieved person may be entitled. (iii) Whether unwelcome conduct created a hostile environment is viewed from the perspective of a reasonable person in the aggrieved person’s position. (3) Types of conduct. Quid pro quo and hostile environment harassment may be written, verbal, or communicated in other ways, and do not require physical contact. Such harassment includes: (A) verbal harassment, including epithets, derogatory comments, or slurs; (B) physical harassment directed at an individual, including assault, impeding or blocking movement, or any physical interference with normal movement; (C) visual forms of harassment, including derogatory posters, cartoons, drawings, or other documents. (D) unwelcome sexual conduct, or other unwelcome conduct, which need not be based on sexual desire, linked to an individual’s sexual orientation or sex, including: pregnancy or medical conditions related to pregnancy, childbirth or medical conditions related to childbirth, breastfeeding or medical conditions related to breastfeeding; gender identity; and gender expression; Page 218 49 (E) any coercion, intimidation, threats, or interference with a person’s exercise or enjoyment of any benefit secured by rights protected under the Act, this subchapter, or implementing regulations. (F) taking any adverse action against a person in a manner that constitutes quid pro quo or hostile environment harassment, such as, representing to a person that a benefit is not available because of the person’s response to a request or demand for a sexual favor; (G) revealing private information to a third party about a person, without their consent, in a manner that constitutes quid pro quo or hostile environment harassment, unless such disclosure is required by federal or state law; or (c) A single incident of harassment based on an individual’s membership in a protected class may be sufficient to constitute hostile environment harassment or quid pro quo harassment. (d) The fact that an alleged perpetrator may be a member of the same protected class as the aggrieved person is not by itself a defense to a claim of harassment. (e) A covered entity shall be liable for harassment of a beneficiary by a third party if the covered entity knows or should have known of the conduct and fails to take immediate and appropriate corrective action. (f) Persons protected. The prohibition on harassment extends to conduct that is based on an individual’s membership in a protected class, being perceived as a member of a protected class, being associated with a member of a protected class or someone who is perceived to be a member of a protected class, or on account of having aided or encouraged any person in the exercise of the rights. .52 Retaliation Generally (a) It shall be unlawful for any covered entity to take adverse action against an aggrieved person because the person has engaged in protected activity. (1) Because of means that the retaliation was a motivating factor in causing harm. Retaliation need not be the sole motivating factor. (2) The adverse action need not be related directly to the nature of the protected activity. Page 219 50 (3) Retaliation may be established by direct evidence or circumstantial evidence, including the temporal proximity between the protected activity and the adverse action. (b) Persons Protected. For purposes of a retaliation claim, an aggrieved person includes any person who has alleged that they have been subjected to adverse action due to engagement in a protected activity. (1) A person does not have be a member of a protected class in order to assert a claim for retaliation. (2) A person does not need to allege or prove discrimination or denial of full and equal access, or prevail on a separate claim under any provision of the Act or these regulations, in order to assert a claim for retaliation. (3) An aggrieved person may prevail on a retaliation claim even if: (A) the aggrieved person was engaged in a protected activity challenging practices which the aggrieved person reasonably believed to be unlawful, whether or not those practices are determined to be unlawful, or (B) the aggrieved person was participating in an activity which was perceived by the respondent as protected activity, whether or not it was so intended by the aggrieved person. (c) Protected activity includes: (1) making a complaint, testifying, assisting or participating in any manner in a proceeding, including any proceeding under Division 21-100, the California Fair Employment and Housing Act, California Civil Code Ssections 51, 51.5, 51.7, 54 54.1, or 54.2, the Americans with Disabilities Act, the federal Civil Rights Act, Section 504 of the Rehabilitation Act, or any other state or federal civil right statutes; (2) opposing practices prohibited by the Americans with Disabilities Act, the federal Civil Rights Act, or Section 504 of the Rehabilitation Act, including seeking the advice of the state, any state or local agency, the Department or Council, or a person employed or retained by a recipient who has authority to receive, transmit, investigate, or discover a complaint, or correct an alleged violation, whether or not a complaint is filed, and if a complaint is filed, whether or not the complaint is found to have merit; Page 220 51 (3) assisting or advising any person in seeking the advice of the state, any state or local agency, the Department or Council, or a person employed or retained by a recipient who has authority to receive, transmit, investigate, or discover a complaint, or correct an alleged violation, whether or not a complaint is filed, and if a complaint is filed, whether or not the complaint is found to have merit; (4) participating in an activity that is perceived by the state, any state or local agency, or a recipient as opposition to discrimination or denial of full and equal access, whether or not so intended by the individual participating in the activity; (5) contacting, communicating with or participating in a proceeding of a human rights or civil rights agency regarding discrimination or denial of full and equal access on a basis enumerated in this Division; (6) assisting with or participating in the proceedings of the state, any state agency, or a recipient including involvement as a potential witness, which the state, any state or local agency, or a recipient perceives as participation in a proceeding alleging a violation of this Division; (7) seeking information, formally under a Public Records Act request, or informally, regarding programs or activities of a state, any state agency, or a recipient; or (8) requesting a reasonable accommodation or reasonable modification for an individual with a disability, or requesting an interactive process meeting, whether or not the request was granted. (d) Violations of this section are considered a discriminatory practice. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11136, 11137, 11139, 12926, 12926.1, and 12940, Government Code. .6 Confidentiality of Information The identity of any complainant and the employee or official alleged to have discriminated must be confidential, except to the extent necessary to carry out the complaint process including the conduct of any investigation, hearing, or judicial proceeding arising thereunder. (See Division 19.) (a) Information concerning a request for a reasonable accommodation for a disability, or other information concerning disability, medical condition, or genetic information, shall be kept confidential by covered entities in accordance with the privacy protections afforded to medical Page 221 52 information under state and federal law, including the Confidentiality of Medical Information Act, California Civil Code sections 56-56.37, unless confidentiality is waived by the individual with a disability or disclosure is required by law. (b) To the extent necessary to review a request for an accommodation, or to implement an accommodation, confidential information may be disclosed only to the covered entity’s staff who are directly involved in the accommodation process or who are necessary to implement the accommodation. In the context of an adjudication, parties to the proceeding other than the .7 Retention The CWD shall retain the written complaint, a record of its disposition, the investigation report, and related documents for a minimum of three (3) years from final disposition. All such records shall be maintained in a secure location with access limited to personnel assigned to the Civil Rights Program. .8 Closure of Complaint Files .81 Once CDSS receives notification of resolution of a discrimination complaint from a CWD, CDSS shall either approve final closure or request further action be taken before closure. .811 If the CWD obtains a withdrawal of the complaint from the complainant or the complainant fails to cooperate in pursuing the complaint, the CWD may request final closure without a final report of investigation. .82 The CWD shall not close out a complaint case without the approval of CDSS. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Section 11135, California Government Code; USDA, Food and Nutrition Service, FNS Instruction 113-7 Part X (A); 28 CFR 42.408(b), (c) and (d); and Title II of the Americans With Disabilities Act of 1990, P.L. 101-336. . 2 Types of Evidence and Proof in Intentional Discrimination Complaints Admissions, expressions of bias, or other direct evidence of discrimination often are probative of purpose or intent, but are not necessary to demonstrate that a practice is intentional discrimination. Circumstantial evidence may be relied upon to demonstrate intentional discrimination. Probative sources of information or methods for determining whether discrimination has occurred include: information concerning the disproportionate or adverse effect of a practice on a protected class or decisions on comparable matters; the historical background of the challenged practice; specific antecedent events leading to the challenged practice; departures from normal procedures or Commented [A48]: source: 11135 Draft Page 222 53 substantive conclusions; contemporary statements of decision-makers and other legislative or administrative history; a pattern of harm to the protected classes; information showing discrimination against members of a protected class based on statistical data that the practice has a disproportionate or adverse effect on members of the protected class and supporting anecdotal evidence; and the use of presumptions, burden shifting, and comparisons between a protected class and other individuals. Statistical data is one form of circumstantial evidence, but statistical evidence is not necessary to demonstrate that a program or activity constitutes intentional discrimination. Evidence of disparate impact discrimination, such as that set forth below in section 14029(a), may also be circumstantial evidence of intentional discrimination. Proof regarding different treatment of similarly situated persons is one way of raising an inference of intentional discrimination, but such proof is not the only way required to make a showing of intentional discrimination. Burdens of Proof in Intentional Discrimination Cases Based on Circumstantial Evidence A complainant, plaintiff, or petitioner first has the burden of establishing a prima facie case of discrimination by showing that the aggrieved individual or individuals: (A) belong to a protected class; (B) were subject to adverse action; and (C) a causal connection or link exists between the individual’s or individuals’ protected class and the adverse action. A prima facie case establishes a rebuttable presumption of discrimination If the complainant, plaintiff, or petitioner satisfies the burden of proof set forth in paragraph (c)(1) of this subsection, the respondent or defendant must then establish a legitimate, non- discriminatory reason for the adverse action. If the respondent or defendant satisfies the burden of proof set forth in paragraph (c)(2) of this subsection, the burden shifts back to the complainant, plaintiff, or petitioner to demonstrate that the non-discriminatory reason(s) asserted by the respondent are pretextual or are false. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1, 12940, 12955, and 12955.8, Government Code; Mixon v. Fair Employment and Housing Comm.(1987) 192 Cal.App.3d 1306; Guz v. Bechtel National Inc. (2000) 24 Cal.4th 317; McDonnell-Douglas Corp. v. Green (1973) 411 U.S. 792; Village of Arlington Heights v. Metropolitan Housing Devel. Corp.(1977) 429 U.S. 252; Heard v. Lockheed Missiles & Space Co. (1990) 44 Cal.App.4th 1735; Pacific Shores Properties, LLC v. City of Newport Beach (9th Cir. 2013) 730 F.3d 1142. Types of Evidence and Proof in Disparate Impact Discrimination Cases (a) Evidence of disparate impact may include statistical or anecdotal evidence that: Page 223 54 (1) a group of individuals, other than members of a protected class, and\/or that they concurrently receive better or more effective benefits of the program or activity than members of a protected class, or that the same benefits are more burdensome to obtain for members of a protected class; (2) the benefits of the program were reduced, less effective, or more burdensome to obtain when members of a protected class were eligible for, or participated in, a program or activity to a greater extent than in the past; (3) the program or activity creates, increases, reinforces, or perpetuates segregation on the basis of membership in a protected class; or (4) a particular condition to receiving benefits of the program disproportionately excludes individuals on the basis of membership in a protected class from participation in or receipt of the benefits of the program. (b) Burdens of Proof in Disparate Impact Discrimination Cases. (1) The aggrieved person or the Department has the burden of proving that an action, practice or practices caused or predictably will cause a disparate impact. (2) Once the aggrieved person or the Department satisfies the burden of proof set forth in paragraph (1) of this subsection, the respondent has the burden of proving that the respondent had a legally sufficient justification under subsection (C) in this section. (3) If the respondent satisfies the burden of proof set forth in paragraph (2) of this subsection, the aggrieved person or the Department may still prevail upon proving that the purpose for the challenged action or practice can be equally served by an action or practice that has a less discriminatory effect. (c) Legally Sufficient Justification. (1) A legally sufficient justification exists when the respondent proves that the action or practice is necessary to achieve a substantial, legitimate, and nondiscriminatory purpose sufficiently compelling to override the disparate impact, and that the action or practice effectively carries out the purpose it is alleged to serve. (2) A legally sufficient justification must be supported by evidence and may not be hypothetical or speculative. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1, 12940, 12955, and 12955.8, Government Code; Olmstead v. L.C. ex rel. Zimring (1999) 527 U.S. 581; Lau v. Nichols (1974) 414 U.S. 563; Committee Concerning Community Improvement v. City of Modesto (9th Cir. 2009) 583 F.3d 690. Page 224 55 Other Proof Provisions. (a) A legally sufficient justification, as described in subsection 14029(c), is not a defense against a claim of intentional discrimination. (b) The same information may be probative of more than one form of discrimination. (c) The evidence and methods of proof described in this Article shall be construed as illustrative and not as limitations on the enforcement of Article 9.5, this subchapter, or other implementing regulations. Note: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1, 12940, 12955, and 12955.8, Government Code. CALIFORNIA-DSS-MANUAL-CFC CIVIL RIGHTS Regulations NONDISCRIMINATION 21-205 21-205 CORRECTIVE ACTION 21-205 .1 Corrective action may be required as a result of an investigation, compliance review, or other determination by CDSS that a CWD is not in compliance with the requirements of Division 21. .11 Such corrective action shall accomplish the following: .111 Resolution of the problem which initiated, or was discovered as a result of an investigation or compliance review. .112 Development of a policy or plan to ensure that problems of a similar nature do not reoccur. .2 A CWD shall implement corrective action determined necessary as a result of an investigation, compliance review, or other determination within a reasonable time, as determined by CDSS after conferring with the CWD. In no event shall initial implementation be extended beyond 60 days. .3 Sanctions for Noncompliance Attempts shall be made at the outset to secure compliance by voluntary means, if such method is reasonably possible. The CWD and CDSS shall enter into a voluntary compliance agreement. When a county welfare department fails to voluntarily comply with the requirements imposed by Division 21 or with applicable sections of state or federal statutes and regulations, fiscal sanctions or other legal remedies may be invoked in accordance with Welfare and Institutions Page 225 56 Code Section 10605, or Government Code Sections 11135 through 11139, when state financial assistance is involved, or the issue may be referred to the appropriate federal agency for further compliance action when federal financial assistance is involved. .31 CDSS may also initiate procedures which include, but are not limited to: .311 Actions to suspend or terminate CWDs from further program participation when state financial assistance is involved. .312 Recommending appropriate sanctions to other state or local agencies whose jurisdiction is involved. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553, 10554, and 11475.1, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7, Part XI, B and C; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. CALIFORNIA-DSS-MANUAL-CFC This page is intentionally left blank. Page 226 1 CIVIL RIGHTS NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS TABLE OF CONTENTS CHAPTER 21-100 NONDISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS Title VI Civil Rights Act 1964 Section Purpose………………………………………………………………………………………………………………. 21-101 Scope of Division……………………………………………………………………………………………….. 21-103 Definitions ………………………………………………………………………………………………………… 21-104 Dissemination of Information ………………………………………………………………………………. 21-107 General Requirements ………………………………………………………………………………………………. .1 Specific Methods to Be Utilized …………………………………………………………………………………… .2 Discriminatory Practices Prohibited ……………………………………………………………………… 21-109 General ……………………………………………………………………………………………………………………..1 Location of Facilities………………………………………………………………………………………………….. .2 Accessibility…………………………………………………………………………………………………… 21-111 Provisions for Services to Applicants and Recipients Who Are Limited English Proficient or Who Have Disabilities …………………………………………………………………….. 21-115 Documentation of Applicant\/Recipient Case Records……………………………………………. 21-116 Staff Development and Training ……………………………………………………………. …21-117 Compliance Procedures and Reporting ………………………………………………………….. 21-201 Page 227 2 Assignment of Resources to Implement Requirements of This Division …………………………………………………………………………………………………………. .1 Compliance Reports ………………………………………………………………………………………………….. .2 Compliance Reviews………………………………………………………………………………………………….. .3 Applicant\/Recipient Complaints of Discriminatory Treatment ……………………………… 21-203 Complainant’s Right to a State Hearing (Fair Hearing) ……………………………………………….. .1 Procedures for Processing Discrimination Complaints ……………………………………………….. .2 Procedures for Investigation Complaints …………………………………………………………………… .3 Report of Investigation…………………………………………………………………………………………….. .4 Retaliatory Acts Prohibited ……………………………………………………………………………………… .5 Confidentiality of Information ………………………………………………………………………………….. .6 Retention ………………………………………………………………………………………………………………. .7 Closure of Complaint Files ………………………………………………………………………………………. .8 Corrective Action ……………………………………………………………………………………….. 21-205 CHAPTER 21-100 NONDISCRIMINATION IN STATE AND FEDERALLY ASSISTED PROGRAMS 21-101 PURPOSE (a) The purpose of Division 21 is to effectuate the provisions of the following laws: Title VI of the Civil Rights Act of 1964, as amended; Section 504 of the Rehabilitation Act of 1973, as amended; Title II of the Americans With Disabilities Act of 1990, as amended; the Age Discrimination Act of 1975, as amended; the Food Stamp Act of 1977, as amended; California Civil Code, Section 51, et seq., as amended; California Government Code, Section 11135, et seq., as amended; California Government Code, Section 4450; and other applicable federal and state laws and their implementing regulations to ensure that the administration of public assistance and social services programs are Page 228 3 nondiscriminatory, and that no person shall, because of actual or perceived race, color, national origin, ancestry, ethnic group identification, political affiliation, religion, marital status, sex, age, gender, gender identity, gender expression, sexual orientation, medical condition, genetic information, military and veteran status, mental disability, or physical disability be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity that is conducted, operated, or administered by the state or any state agency, funded directly by the state, or receives any financial assistance from the state.. Administrative methods\/procedures which have the effect of subjecting individuals to discrimination or defeating the objectives of these regulations are prohibited. (b) All definitions and prohibitions set forth in the statutes listed in 21-101(a) are hereby incorporated by reference. Any act or omission which is contrary to said definitions and prohibitions constitutes a violation of this subchapter and is subject to the sanctions provided for in this subchapter. In the event of any conflict between the definitions and prohibitions of the provisions incorporated by this reference and the definitions and prohibitions set forth in this subchapter, the definitions and prohibitions set forth in this subchapter shall prevail. (c) This Division and other implementing regulations provide protections independent of those in federal anti-discrimination laws. Although federal laws provide the floor of protection relating to discrimination, this Division and implementing regulations afford additional protections to provide robust protection of protected classes in state and state- supported programs and activities, including by recognizing that this Division prohibits discrimination independently of guarantees of equal protection and the prohibition against denial of full and equal access. The provisions of this Division and other implementing regulations shall be construed liberally for the accomplishment of the purposes of this part. (d) This Division’s prohibition against discrimination includes intersectional discrimination, discrimination on more than one basis, harassment, coercion, intimidation, and retaliation for exercising a protected right or refusing to engage in an act prohibited by Division 21. AUTHORITY Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Sections 4450, 11135, 11136, and 12993, California Government Code; Title II of the American With Disabilities Act of 1990, Public Law (P.L.) 101-336; 42 USCA 2000d; as amended by the ADA Amendments Act of 2008 (ADA Amendments Act) (Pub. L. 110-325, 122 Stat. 3553 (2008)), Title II of the Americans with Disabilities Act Regulations; 28 CFR 35; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. 21-103 SCOPE OF DIVISION These requirements shall apply to the California Department of Social Services (CDSS), all county welfare departments, and all other agencies receiving federal or state financial Page 229 4 assistance through CDSS for the administration of public assistance, food stamps, child support enforcement, fraud investigation, and social services. When the laws of California prescribe stronger protections and prohibitions than federal laws, the entities covered by this Division are subject to the stronger protections and prohibitions. .1 Civil Rights requirements addressing the Child Support Program in the county District Attorney’s offices are covered in separate plans of cooperation (see MPP Division 12 (Administrative Standards for State IV-D Agency), Appendix I, Part IX, Civil Rights Component). .2 Civil Rights requirements addressing welfare fraud investigations in the county by District Attorney’s offices are covered in separate purchase of service agreements and plans of cooperation (see MPP Division 20 (Fraud and Suspected Law Violations), Section 20-007.111). .3 CDSS reserves the right to interview staff, review, copy or obtain all data, records, reports, case files and other materials determined necessary in the conduct of discrimination complaint investigations and\/or compliance reviews involving all agencies subject to the requirements of this Division. .4 Contractor and Vendor Compliance: Contractors, vendors, consultants, and other providers of service who receive federal or state assistance through CDSS or through agencies covered by these regulations shall comply with nondiscrimination requirements of this Division. .5 Written assurances of nondiscrimination in programs and activities receiving federal or state financial assistance shall be required. This requirement is fully applicable to all vendors, contractors, consultants, and other providers of service in addition to county welfare departments. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 11135(b), Government Code; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 28 CFR 42.407. 21-104 DEFINITIONS .1 The following definitions shall apply to the terms used in this Division: 1. . \”Accessibility\” generally refers to the usability of public facilities by individuals with disabilities. See 21.18 for a complete definition. 2. Adverse action includes any action that harms or has a negative effect on an aggrieved person, including denial or reduction in benefits, harassment, intimidation, threats, coercion, inferior or unfavorable treatment, discrimination, or any denial of full and equal Page 230 5 access. 3. Age means how old a person is or is perceived to be, or the number of years elapsed from the date of a person’s birth or perceived to have elapsed from that date. 4. Aggrieved person includes any person who believes that they have been injured by a discriminatory practice or denial of full and equal access, or believes that they will be injured by a discriminatory practice or denial of full and equal access that is about to occur. Aggrieved person shall include any applicants for or recipients of public benefits from agencies covered by these regulations. 5. Ancestry means an individual’s actual or self-identified family or ethnic origin, descent or lineage, nationality group, tribal affiliation, or geographical place of origin or country in which the individual or the individual’s parents or ancestors originated, or the perception of the individual’s ancestry. 6. Assistance animal means an animal that is necessary as a reasonable accommodation for an individual with a disability. Assistance animals include service animals and support animals. An assistance animal is not a pet. It is an animal that works, provides assistance, or performs tasks for the benefit of an individual with a disability, or provides emotional support that alleviates one or more identified symptoms or effects of an individual’s disability. a. Service animals are animals that are trained to perform specific tasks to assist individuals with disabilities, including individuals with mental health disabilities. Service animals do not need to be professionally trained or certified, but may be trained by the individual with a disability or another individual. Specific examples include: i. Guide dog, as defined at California Civil Code section 54.1, or other animal trained to guide a blind individual or individual with low vision. ii. Signal dog, as defined at California Civil Code section 54.1, or other animal trained to alert a deaf or hard-of-hearing individual to sounds. iii. Service dog, as defined at California Civil Code section 54.1, or other animal individually trained to the requirements of an individual with a disability. iv. Miniature horses meeting the requirements of 28 CFR 35.136(i) and 28 CFR 36.302(c)(9). v. Service animals in training, including guide, signal, and service dogs being trained by individuals with disabilities, persons assisting individuals with disabilities, or authorized trainers under California Civil Code sections 54.1(c) and 54.2(b). vi. Support animals are animals that provide emotional, cognitive, or other similar support to an individual with a disability. A support animal does not need to be trained or certified. Support animals are also known as comfort animals or emotional support animals. 7. Assistive technology means technology designed to be utilized in an assistive technology device or assistive technology service. a. Assistive technology device means any item, piece of equipment, or product system, whether acquired commercially, modified, or customized, that is used to Page 231 6 increase, maintain, or improve functional capabilities of individuals with disabilities. b. Assistive technology service means any service that directly assists an individual with a disability in the selection, acquisition, or use of an assistive technology device. 8. Associated with means linked or related to a person who is or is perceived to be a member of a protected class, or who identifies with or advocates for a member of a protected class, or who expresses support or sympathy for, encourages, or participates in groups composed of or representing members of a protected class or groups organized for the protection or assertion of rights protected under this Division. Associated with includes an individual’s current or prior social or professional relationship with, marriage to, or domestic partnership with a member of a protected class; an individual’s familial relationship with a person who is a member of the class, including an adoptive, step, or foster care relationship; a person’s relationship as an attendant, aide, or caregiver of an individual with a disability; membership in or association with an organization identified with or seeking to promote the interests of a protected class; attendance or participation in schools, clubs, associations, organizations, churches, temples, or mosques, generally associated with a protected class; being on the premises of a facility or building owned or rented by an entity, group, or person that has, or is identified with people who have, one or more characteristics of a protected class; or actual or perceived association of a person’s name or other characteristics with a protected class. 9. \”Assurance of Compliance Agreement\” is a legal agreement in which a county welfare department agrees to administer a program or activity covered by this Division in accordance with all applicable civil rights laws and their implementing regulations. 10. \”Authorized representative\” means an individual or group that has written authorization from the applicant\/recipient to act in his\/her behalf (see MPP, Division 19, Section 19- 005.2). 11. Auxiliary aids and services include: a. communicating, written or orally, in plain language, simplified English b. qualified interpreters; notetakers; real-time computer-aided transcription services; written materials; exchange of written notes; telephone handset amplifiers; assistive listening devices; assistive listening systems; telephones compatible with hearing aids; closed caption decoders; open and closed captioning, including real-time captioning; voice, text, and video-based telecommunications products and systems, including text telephones (TTYs), videophones, and captioned telephones, video relay services, video remote interpreting (VRI), or other telecommunications devices that make communication as equally effective as oral communication in English; videotext displays; accessible electronic and information technology; tactile sign language; or other equally effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing or assisting those individuals to communicate; c. qualified readers; taped texts; audio recordings; Braille materials and displays; screen reader software; magnification software; optical readers; secondary Page 232 7 auditory programs (SAP); large print materials; accessible electronic and information technology; or other effective methods of making visually delivered materials available to individuals who are blind or have low vision or assisting those individuals to communicate; d. qualified interpreters, speech-to-speech relay services, or other effective methods of making aurally delivered information available to individuals who have speech disabilities or assisting those individuals to communicate; e. acquisition or modification of equipment or devices; and f. other similar services and actions, including newly developed forms of electronic information systems and technology as they become available. 12. Benefit means anything offered or provided with the intention of or for the purpose of contributing to an improvement in condition, maintaining a condition, or preventing anticipated deterioration of a condition over time, including aid or services offered or provided by a covered entity. 13. Color means the actual or perceived physical characteristics of an individual’s complexion, pigmentation, or skin tone. 14. \”Community Organization\” is any organization at the local level which interacts with applicants\/recipients, such as a community action program, civic organization, migrant group, church, neighborhood council, local chapter of a community organization (e.g., NAACP), or other similar group. 15. Contractor includes a person or recipient that receives any state support under contract or subcontract. Contractor includes prime contractors and subcontractors at any tier. 16. Covered entity includes: a. the state or a state agency; b. any entity or individual involved in carrying out any program or activity that is conducted, operated, or administered by the state or by any state agency; c. any entity or individual, including local agencies, recipients, contractors, and grantees, that is funded directly by the state, or receives any state support; d. a local agency, and any entity or individual involved in carrying out any program or activity of a local agency if any part of the local agency receives state support; 17. \”Culturally aware persons\” are those who possess knowledge and understanding of cultural environments, religious beliefs, life styles, self-concepts and language characteristics of the populations they serve. Such knowledge is necessary to effectively communicate and provide the same level of service being provided to the welfare population at large. 18. Disability means a physical or mental impairment that limits one or more major life activities of an individual, a record of such an impairment, or being regarded as having such an impairment. It includes any mental or physical disability as defined in this section, and shall be construed as follows: a. This Division provides protections that are independent from those in the federal Americans with Disabilities Act of 1990 (P.L. 101-3361) and the American with Disabilities Amendments Act of 2008 (P.L. 110-325) (collectively, the ADA ), and may afford additional protections, but in no event shall be construed to provide fewer protections than the ADA. Notwithstanding the definitions of physical Page 233 8 disability and mental disability in this section, if the definition of disability used in the ADA would result in broader protection of the civil rights of individuals with a mental disability or physical disability, or would include any medical condition not included within those definitions, then that broader protection or coverage shall be deemed incorporated by reference into, and shall prevail over conflicting provisions of, the definitions in this section. b. All definitions shall be interpreted in accordance with the expansive construction mandates of Section 12926.1 of the California Government Code. To the extent that codified definitions or interpretations are expanded in the future, such new, more expansive definitional mandates shall be incorporated into this Division. To the extent that such codified definitions or interpretations are narrowed or restricted in the future, the more expansive definitions referenced in this sub- paragraph shall nevertheless continue to govern this Division. c. Mental disability includes: i. Having any mental or psychological disorder or condition, such as intellectual disability, organic brain syndrome, emotional or mental illness, or specific learning disabilities, that limits a major life activity. ii. Any other mental or psychological disorder or condition not described above that requires special education or related services. iii. Having a diagnoses, record, or history of a mental or psychological disorder or condition described above. iv. Being regarded or treated as having, or having had, any mental condition that makes achievement of a major life activity difficult. v. Being regarded or treated as having, or having had, a mental or psychological disorder or condition that has no present disabling effect, but that may become a mental disability as described in [paragraphs i and ii]. d. Physical Disability includes: i. having any physiological disease, disorder, or condition, cosmetic disfigurement, or anatomical loss that affects one or more body systems (neurological, including immunological; musculoskeletal, special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genitourinary; hemic and lymphatic, skin; and endocrine systems), and limits a major life activity; ii. any other health impairment not described in above that requires special education or related services; iii. having a diagnosis, record, or history of a disease, disorder, condition, cosmetic disfigurement, anatomical loss, or health impairment described in subparagraph (i) or (ii) of this paragraph; iv. being regarded or treated as having, or having had, any physical condition that makes achievement of a major life activity difficult; or v. being regarded or treated as having, or having had, a disease, disorder, condition, cosmetic disfigurement, anatomical loss, or health impairment Page 234 9 that has no present disabling effect but may become a physical disability as described in subparagraph (i) or (ii) of this paragraph. e. Having a record of such impairment means has a history of, or has been misclassified as having, an impairment that limits one or more major life activities. f. Perceived as having an impairment means: i. has an impairment that does not limit major life activities but that is treated or perceived as constituting a limitation; ii. has an impairment that limits major life activities only as a result of the attitudes of others toward such impairment; or iii. does not have an impairment but is treated or perceived as having such an impairment. g. The definition of disability in this subchapter shall be construed in favor of broad coverage of individuals under this subchapter, to the maximum extent permitted by the terms of this subchapter. Disabilities include contagious and noncontagious diseases; orthopedic, visual, speech and hearing impairments; traumatic brain injuries, cerebral palsy, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, intellectual disabilities, developmental disabilities, autism or autism spectrum, emotional illness, specific learning disabilities, HIV disease (whether symptomatic or asymptomatic), tuberculosis, drug addiction, and alcoholism. h. Individuals are protected from discrimination and denial of full and equal access due to an actual or perceived physical or mental impairment that is disabling, potentially disabling, or perceived or regarded as disabling or potentially disabling (even if it has no present disabling effect), including when an individual is erroneously or mistakenly believed to have any physical or mental condition that limits a major life activity, whether or not the impairment actually limits or is perceived to limit a major life activity. i. Physical and mental disabilities include chronic or episodic conditions, such as HIV\/AIDS, hepatitis, epilepsy, seizure disorder, diabetes, clinical depression, bipolar disorder, multiple sclerosis, and heart disease. An impairment that is episodic or in remission is a disability if it would limit a major life activity when active. j. The definitions of physical disability and mental disability require a limitation upon a major life activity, but do not require, as does the ADA, a substantial limitation. This distinction is intended to result in broader coverage under this subchapter than under the ADA. k. Major life activities shall be broadly construed and include physical, mental, and social activities; caring for one’s self; performing manual tasks, walking, seeing, hearing, speaking, breathing, eating, sleeping, standing, lifting, bending, learning, reading, concentrating, thinking, communicating, and working. Working is a major life activity, regardless of whether the actual or perceived working limitation implicates a particular employment or a class or broad range of employment. Page 235 10 l. For purposes of subparagraph (f), a major life activity also includes the operation of a major bodily function, including functions of the immune system, normal cell growth, digestive, bowel, bladder, cardiovascular, genitourinary, hemic, neurological, lymphatic, brain, respiratory (including speech organs), circulatory, endocrine, and reproductive functions. m. A disability limits a major life activity if it makes the achievement of the major life activity difficult. n. An impairment that limits one major life activity need not limit other major life activities in order to be considered a disability. o. The determination of whether an impairment limits a major life activity shall be made without regard to the ameliorative effects of mitigating measures, unless the mitigating measure itself limits a major life activity, regardless of federal law under the ADA. Mitigating measures include: i. medication, medical supplies, equipment, or appliances, low-vision devices (which do not include ordinary eyeglasses or contact lenses), prosthetics including limbs and devices, hearing aids and cochlear implants or other implantable hearing devices, mobility devices, or oxygen therapy equipment and supplies; ii. use of assistive technology and devices; iii. reasonable accommodations or auxiliary aids or services; or (D) learned behavioral or adaptive neurological modifications. p. The ameliorative effects of the mitigating measures of ordinary eyeglasses or contact lenses shall be considered in determining whether an impairment limits a major life activity. As used in this subparagraph: i. the term ordinary eyeglasses or contact lenses means lenses that are intended to fully correct visual acuity or eliminate refractive error; and ii. the term low-vision devices means devices that magnify, enhance, or otherwise augment a visual image. q. Disability does not include sexual behavior disorders, compulsive gambling, kleptomania, pyromania, or psychoactive substance use disorders resulting from the current unlawful use of controlled substances or other drugs. Sexual behavior disorders means pedophilia, exhibitionism, and voyeurism. r. Current unlawful use of controlled substance or drugs does not include an individual who: i. has successfully completed a supervised drug rehabilitation program and is no longer engaging in the illegal use of drugs, or has otherwise been rehabilitated and is no longer engaging in such use; ii. is participating in a supervised rehabilitation program and is no longer engaging in such use; iii. is erroneously regarded as engaging in such use; or iv. is using drugs taken under the supervision of a licensed health care professional, or other uses authorized by law. s. Notwithstanding other provisions of this subchapter, an individual shall not be denied health services, or services provided in connection with drug Page 236 11 rehabilitation, on the basis of current unlawful use of drugs if the individual is otherwise entitled to such services. 19. Effective Communication means communication sufficient to provide the LEP individual with substantially the same level of services received by individuals who are not LEP. For example, staff must take reasonable steps to ensure communication with an LEP individual is as effective as communications with others when providing similar programs and services. 20. Ethnic group identification means the actual or self-identified possession of the physical, cultural, or linguistic characteristics associated with a racial, cultural, or ethnic group or country, geographical place of origin, or the status of being a descendent of someone with such actual or self-identified characteristics, or the perception of a person’s ethnic group identification. Ethnic Group Identification includes ancestry, color, national origin, and race. 21. Gender means sex, and includes a person’s gender identity and gender expression, or a perception of any of the aforementioned. 22. Gender identity means each person’s internal understanding of their gender, or perception of a person’s gender identity, which may include male, female, a combination of male and female, neither male nor female, a gender different from the person’s sex assigned at birth, or transgender. 23. Gender expression means a person’s gender-related appearance or behavior, or the perception of such appearance or behavior, whether or not stereotypically associated with the person’s sex assigned at birth. 24. Genetic Information means information about an individual’s genetic tests, the genetic tests of an individual’s family members, the manifestation of a disease or disorder in the individual’s family members, or the perception of any of the aforementioned. Genetic information includes any request for, or receipt of, genetic services, or participation in clinical research that includes genetic services, by an individual or any family member of the individual. Genetic information does not include information about the sex or age of any individual. 25. Includes or including has the same meaning as includes, but not limited to or including, but is not limited to. 26. \”International Symbol of Accessibility\” is the symbol specified in Title 24 of the California Code of Regulations (Access Code) Section 3105A.(e) used to identify facilities, restrooms, parking spaces, etc. as accessible to individuals with disabilities. 27. Intersectional Discrimination means discrimination on the basis of a combination of protected classes, i.e., where two or more bases for discrimination are alleged. Thus, an entity that is not unlawfully discriminating solely on the basis of race or gender still may be discriminating against individuals who are perceived as or identified as having a combination of more than protected basis, such as, Asian males. 28. \”Individual with a disability\” is any person who has a physical or mental impairment which substantially limits one or more major life activities, has a record of such impairment or is regarded as having such an impairment. 29. \”Physical Disability\” includes having any physiological disorder or condition, cosmetic disfigurement or anatomical loss affecting one or more of the following body systems: Page 237 12 neurological, musculoskeletal, special sense organs, respiratory including speech organs, cardiovascular, reproductive, digestive, genitourinary, hemic and lymphatic, skin and endocrine. 30. Mental Disability includes having any mental or psychological disorder, such as an intellectual disability, organic brain syndrome, emotional or mental illness and specific learning disabilities or any other mental or psychological disorder or condition not that requires special education or related services. 31. \”Major life activities\” include functions such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. 32. \”Has a record of such an impairment\” means has a history of, or has been misclassified as having, a mental or physical impairment that substantially limits one or more major life activities. 33. \”Is regarded as having an impairment\” means: a. Has a physical or mental impairment that does not substantially limit major life activities, but that is treated by the agency as constituting such a limitation; b. Has a physical or mental impairment that substantially limits major life activities only as a result of the attitudes of others toward such impairment; or c. Has none of the impairments defined in this section but is treated by an agency as having such an impairment. 34. \”Major Occupational Group\” shall include, but are not limited to, the following general positions\/classifications: Social Service Supervisors, Eligibility Supervisors, Social Workers, Eligibility Workers, Welfare Aids, Receptionists, Clerical Employees. Agency personnel whose position\/classification is not included but whose primary duties\/responsibilities correspond to any one of the above shall be included in that major occupational group. 35. Marital status means an individual’s actual or perceived pending state of marriage, non-marriage, domestic partnership, divorce or dissolution, separation, widowhood, annulment, or other marital state. 36. Meaningful Access is language assistance that results in accurate, timely, and effective communication at no cost to the LEP individual. For LEP individuals, meaningful access denotes access that is not significantly restricted, delayed, or inferior as compared to programs or activities provided to English proficient individuals. 37. Medical Condition means any actual or perceived health impairment related to or associated with a diagnosis, record, or history of cancer; or genetic characteristics known to be a cause of a disease or disorder or associated with a statistically increased risk of developing a disease or disorder. Genetic characteristics means either of the following: a. any scientifically or medically identifiable gene or chromosome, or combination or alteration thereof, that is known to be a cause of a disease or disorder in a person or that person’s offspring, or that is determined to be associated with a statistically increased risk of development of a disease or disorder, and that is presently not associated with any symptoms of any disease or disorder; or b. inherited characteristics that may derive from the individual or family member, that are known to be a cause of a disease or disorder in a person or that person’s Page 238 13 offspring, or that are determined to be associated with a statistically increased risk of development of a disease or disorder, and that are presently not associated with any symptoms of any disease or disorder. 38. Military and veteran status means a member or veteran of the United States Armed Forces, United States Armed Forces Reserve, the United States National Guard, and the California National Guard. 39. National origin includes: a. the individual’s or ancestors’ actual or perceived: i. physical, cultural, or linguistic characteristics, or name associated with a national origin group; ii. marriage to or association with persons of a national origin group; iii. tribal affiliation; iv. membership in or association with an organization identified with or seeking to promote the interests of a national origin group; and v. attendance or participation in schools, churches, temples, mosques, or other religious institutions generally used by persons of a national origin group; b. National origin groups include ethnic groups or people from particular geographic places of origin and countries, whether or not they are presently in existence. c. National origin includes possessing a driver’s license or identification card granted under Sections 12801.6, 12801.8, or 12801.9 of the Vehicle Code, or a driver’s license or identification card identified with the term Federal Limit Apply. 40. \”Non-English Speaking\” persons are defined as those whose primary language is other than English or those who have identified a need for interpretive services. Sign language is subject to this definition. 41. Perceived membership in a protected class means being regarded as, perceived as, or treated as a member of a protected class or as having the characteristics associated with being a member of a protected class, regardless of whether the perception is accurate. 42. Practice or Practices include any action or failure to act, rule, law, ordinance, regulation, guideline, decision, standard, project, policy, process, or procedure, whether written or unwritten or singular or multiple. 43. Program or activity includes all of the operations and facilities of, or services, benefits or aid provided by a covered entity, directly or indirectly. 44. Protected class and protected basis are used interchangeably. They refer to the bases on which individuals are entitled to protections against discrimination and denial of full and equal access. Protected bases include sex, race, color, religion, ancestry, national origin, ethnic group identification, age, disability (including mental and physical disability), medical condition, genetic information, marital status, gender, gender identity, gender expression, and sexual orientation. In the event the Legislature in the future recognizes a protected class or protected basis by legislation or regulation, that basis will be considered a protected class or protected basis pursuant to this Division, unless specifically excluded by the Legislature. All protected bases include a perception that a Page 239 14 person is a member of a protected class or has any of those characteristics, or that a person is associated with a person who is, or is perceived to be a member of a protected class. Discrimination or the denial of full and equal access on the basis of a protected class includes discrimination or denial of full and equal access on the basis of a stereotype about members of the protected class. 45. \”Public contact positions\” include, but are not limited to, the following positions and activities, regardless of particular job classification or title: CWD employees assigned to the front desk or registration counter, telephone operators, eligibility workers\/supervisors, social service workers\/supervisors, welfare service aides, vocational counselors, homemakers, fraud investigators, and any employee providing interpretive service on a continuing or as needed basis. 46. \”Qualified bilingual employee\” is defined as an employee who, in addition to possessing the necessary qualifications for the particular classification, is certified through a process approved or administered by CDSS to be proficient in oral and\/or written communication in the non-English language of the persons to be served. This definition shall also apply to an employee who is certified in the use of sign language to communicate with individuals who are deaf or hearing-impaired.’ 47. Qualified individual with a disability means: a. an individual with a disability who, with or without reasonable accommodations to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity or contractor, or recipient of a public entity. b. with respect to employment, a qualified individual with a disability is an applicant or employee who, with or without reasonable accommodations, can perform the essential functions of the job in question. 48. \”Qualified interpreter\” means a person qualified and capable of effective, accurate, and impartial rendition of spoken or signed communication from one language to another between people who speak, sign, read, or write in a different language, both receptively and expressively, using any necessary specialized vocabulary and with appropriate cultural relevance, either simultaneously or consecutively. Interpretation is the act of listening to spoken word, visual or tactile transmission of manual language, or reading something written in one language (source language) and expressing it accurately and with appropriate cultural relevance into another language (target language), either simultaneously or consecutively. Whether an interpreter is qualified to provide services requires more than self-identification as bilingual or multilingual. To be qualified an interpreter must: (i) demonstrate proficiency in and ability to communicate information accurately in both the source and target language; (ii) have knowledge in both languages of any specialized term, concepts, or any particularized vocabulary and phraseology peculiar to the program or services; (iii) understand and follow interpreters’ and translators’ confidentiality, ethics and impartiality rules; and (iv) understand and adhere to their roles as interpreters or translators. Qualified interpreters include, for example, sign language interpreters, oral transliterators, and cued-language Page 240 15 transliterators. Also, to be qualified an interpreter must have received adequate education and training in interpreter ethics, conduct, practice, and confidentiality. In some circumstances, effective communication may require that an individual be provided more than one interpreter. 49. Qualified reader means a person who is able to read effectively, accurately, and impartially using any necessary specialized vocabulary. 50. Race refers to the identification of a group of people as distinct from other groups based on supposed or presumed physical, cultural, or genetic characteristics, or the perception of an individual’s race, without regard to whether those characteristics are immutable. Race is construed broadly to include classifications that might otherwise appear to be covered only by other protected bases, such as national origin or religion. 51. Religion, religious creed, religious observance, religious belief, and creed are used interchangeably under this subchapter to mean any actual or perceived traditionally recognized religion as well as beliefs, observances, or practices, which an individual sincerely holds and which occupy in their life a place of importance parallel to that of traditionally recognized religions. This includes all aspects of religious belief, observance, and practice, such as duties of the clergy or elders, and religious dress and grooming practices. Religion includes atheism, agnosticism, and an individual’s choice not to adopt a traditional or specific religious belief. a. Religious dress practices shall be construed broadly to include the wearing or carrying of religious clothing, head or face coverings, jewelry, artifacts, and any other item that is part of an individual’s religious observance. b. Religious grooming practice shall be construed broadly to include forms of head, facial, and body hair, or body markings, that are part of an individual’s religious observance. 52. Sex includes pregnancy, childbirth, and breastfeeding; medical conditions related to pregnancy, childbirth, or breast feeding; recovery from childbirth or termination of pregnancy, or other conditions related to the capacity to bear children; gender; transgender; intersex; transitioning; sex stereotype; gender identity; gender expression; and perception by a third party of any of the aforementioned. 53. Sexual Orientation includes actual or perceived heterosexuality, homosexuality, bisexuality, and asexuality. This refers to a person’s emotional, romantic, or sexual attraction toward other people, and may be described by terms including gay, lesbian, bisexual, straight, asexual, or queer. 54. \”Sign Language\” means the use of fingers and hands to communicate with individuals who are deaf or hard of hearing. There are multiple sign languages including: a. American Sign Language (ASL), a visual language that does not share grammar, word order, or sentence structure with English. b. Manually Coded English, signs that are a visual code for spoken English. c. Pidgin Signed English, a visual language combining ASL and English that does not follow English grammatical structures exactly. 55. Stereotype means a belief about a person’s appearance or behavior, gender roles, gender expression, or gender identity, or other roles, expressions or identities, or about an individual’s ability or inability to perform certain kinds of work or to participate in or Page 241 16 benefit from programs or activities, or receive health or other services, based on a myth, bias or prejudice, assumption, social expectation, convention, statistical probabilities, or generalization about the individual or about other persons in a protected class. 56. \”Substantial Number\” is defined as five percent or more persons of a program\/location, who are non-English speaking, deaf, or hearing-impaired (see Section 21-115.12). 57. Transgender is a general term that refers to a person whose gender identity differs from the person’s sex assigned at birth. A transgender person may or may not have a gender expression that is different from the social expectations of the sex assigned at birth. A transgender person may or may not identify as transsexual. 58. Transitioning is a process some transgender people go through to begin living as the gender with which they identify, rather than the sex assigned to them at birth. This process may include, changes in name and pronoun usage, facility usage, or undergoing hormone therapy, surgeries, or other medical procedures. 59. Ultimate beneficiary means a person in a protected class who receives, applies for, participates in, or benefits from, or is unlawfully deterred or excluded from benefiting from, full and equal access to the benefits of, or employment with, or is subjected to discrimination under a program activity or service that is conducted, operated or administered by any covered entity. 60. Video remote interpreting ( VRI ) service means an interpreting service that uses video conference technology over dedicated lines or wireless technology offering high-speed, wide-bandwidth video connection that delivers high-quality video. 61. (iii) Wheelchair means a manually-operated or power-driven device designed primarily for use by an individual with a mobility disability for the main purpose of indoor or of both indoor and outdoor locomotion. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11139.5, Government Code. 11136, 11137, 11139, 11139.8, 12901, 12903, 12926, 12926.1,12940, and 12960, Government Code.Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 11135, et seq., California Government Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7 Part IV, B. and K.; 28 CFR 35.104; and Title 24 of the California Code of Regulations (Access Code) Section 3105A(e). 21-107 DISSEMINATION OF INFORMATION .1 General Requirements Each county welfare department shall take appropriate steps to inform all applicants, recipients, community organizations, and other interested persons, including those whose primary language is other than English, and those with impaired hearing or vision or other disabling conditions, of the provisions of this Division and its applicability to the programs and activities for Page 242 17 which the county welfare department receives federal or state financial assistance. Such notification shall also identify the name, email address, office telephone number, and office address of the employee(s) responsible for the county welfare department’s compliance with this Division (see Section 21-201.1). If not immediately available, this information must be provided within ten (10) calendar days of the date requested. .2 Specific Methods to be Utilized .21 Posters .211 Posters on nondiscrimination provided by CDSS shall be prominently displayed in all waiting rooms and reception areas. The county welfare department shall place on the posters the name, email address, office telephone number, and office address of the person(s) in the CWD who is responsible for processing discrimination complaints. Posters dealing specifically with nondiscrimination in the Food Stamp Program shall be prominently posted in all certification and issuance offices. All posters and other public documents should be translated into appropriate languages to address the needs of LEP applicants\/recipients. .212 All instructional and directional signs posted in waiting areas and other places frequented by a substantial number of LEP applicants\/recipients shall be translated into appropriate languages. Such signs, or an additional sign, shall state that applicants\/recipients may request aid or services in their primary language. .22 Pamphlets .221 Pamphlets supplied by CDSS, entitled \”Your Rights Under California Welfare Programs,\” shall be made available in all CWD waiting rooms and reception areas and shall be distributed and explained to each applicant\/recipient at intake and reinvestigation of eligibility. The pamphlets shall be in the primary languages of the CWD’s applicant\/recipient population, including alternate formats (e.g., cassette tapes or CDs, large print, Braille etc.). .23 Photographs and Illustrations Photographs and other illustrations used to provide program information conveying the message of equal opportunity shall display applicants\/recipients of different races, national origin, sexes, disabilities, etc., covered by this Division. .24 Notice The CWD shall implement procedures to ensure that applicants\/recipients, community organizations, and other interested persons, including persons with impaired vision or hearing or other disabling conditions, are notified of and can obtain information about programs or program changes including, but not limited to, the following: Page 243 18 .241 Existence and location of benefits and services, and hours or days of operation; .242 Activities and services accessible to individuals with disabilities; .243 Basic eligibility requirements for public assistance; .244 Prohibited acts of discrimination; .245 Procedures for filing discrimination complaints; .246 Rights and responsibilities of applicants\/recipients; and .247 The CWD’s policy of nondiscrimination. .25 Notice may be given by, but not limited to, the following methods: oral group presentations, face-to-face interviews, and printed materials, e.g., posters, pamphlets, etc. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7, Part VI, B. 1, 2, and 3; 28 CFR 35.106 and .107; 28 CFR 42.405(c); 45 CFR 80.6(d); 45 CFR 84.8; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and Title II of the American With Disabilities Act of 1990, P.L. 101-336. 21-109 DISCRIMINATORY PRACTICES PROHIBITED It is a prohibited practice for county welfare departments, in carrying out or failing to carry out any program or activity or providing, denying, or delaying any services or benefits directly or indirectly, through contractual, licensing or other arrangements, to treat in purpose or effect any person less unfavorably without legal justification on the basis of the protected class of the person, including by: 1. denying a person the opportunity or right to apply for, receive the benefits of, or participate in a program or activity; 2. affording a person the opportunity or right to apply for, receive the benefits of, or participate in a program or activity that is not full and equal to the program or activity afforded others; 3. providing a program or activity to a person that is not as effective in affording a full and equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement as that provided to others. In some situations, identical treatment may be discriminatory; 4. providing different or separate programs or activities to a person, or to any class of persons, than is provided to others, or providing programs or activities at a different time, Page 244 19 unless such action is clearly necessary to provide such persons with full and equal access as truly effective a program or activity as that provided to others; 5. aiding or perpetuating discrimination against a person by providing or transferring state support to a covered entity that discriminates in conduct, operation, or administration of any program or activity; 6. excluding a person from participation as a member of a planning or advisory board. Under this requirement, it is a discriminatory practice for a covered entity to fail to make reasonable efforts to achieve a representative board. However, such requirement is not deemed to impose adherence to a quota system; 7. limiting a person in the exercise or enjoyment of any right, privilege, advantage or opportunity enjoyed by others participating in or receiving any aid, benefit, or service resulting from a program or activity; 8. denying a person the opportunity to participate in programs or activities that are not separate or different, despite the existence of permissibly separate or different programs or activities; 9. utilizing criteria or methods of administration that: a. subject a person to discrimination on the basis of membership in, perception of membership in, or association with someone in a protected class; b. defeat or substantially impair the accomplishment of the objectives of the covered entity’s program or activity with respect to membership in a protected class. The objectives of a program or activity shall include its overall mission or purpose as reflected in sources, such as relevant statutes, legislative intent and history, and regulations; c. create, increase, reinforce, or perpetuate discrimination or segregation by another recipient covered entity based on membership in a protected class; or d. create, increase, reinforce, or perpetuate discrimination or segregation based on membership in a protected class. 10. making or allowing selections or closures of sites or locations of facilities, or making, issuing, or denying permits for programs, services, activities or facilities that: a. exclude from, denies the benefits of, or otherwise subject persons to discrimination under any program or activity; b. defeat or substantially impair the accomplishment of the objectives of the program or activity with respect to membership in a protected class. 11. interfering with admittance to or enjoyment of public facilities or the rights of an individual with a disability under any program or activity. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11139, 12926, 12926.1, and 12940, Government Code. .2 Disability 1. Failure to take appropriate steps including providing accommodations or auxiliary aids to ensure that communications with applicants, participants, members of the public, and companions with disabilities are as effective as communications with others constitutes discrimination based on either disability or language proficiency. Page 245 20 a. For purposes of this section, companion means a family member, friend, or associate of an individual seeking access to a service, program, or activity of a public entity, who, along with such individual, is an appropriate person with whom the public entity should communicate. b. Primary consideration should be given to the disabled individual’s choice of auxiliary aid. 2. To ensure compliance with the nondiscrimination mandate, CWDs shall: a. Screen each client for disabilities and language access needs, using the following script or something substantially similar: There are things [agency name] will ask you to do in order to get or keep your benefits. If you have a health problem that makes it hard for you to do something [agency] asks, you can ask for help. This is called an accommodation. This could be because of a physical or mental or emotional health problem or learning disability. Some of the things we’ll ask you to do are: \u25cf Read notices we send and follow instructions in them \u25cf Fill out forms \u25cf Come to the office for appointments \u25cf Get and give us documents to prove whether you can get benefits \u25cf Tell us about changes in your household or case circumstances \u25cf Meet deadlines Do you think you might need help with any of these things, or something else, because of a health problem, disability, learning disability, or other issue? b. Track individual’s requested accommodation, reason for accommodation, and accommodation provided. i. CWDs shall engage in an interactive process to determine accommodations if they cannot provide the requested accommodation because it would entail an undue hardship or fundamentally alter the program according to the most up-to-date controlling interpretations of the ADA. ii. If an individual is covered under the ADA, the only reason for not providing an accommodation is undue burden or fundamental alteration. c. Give the individual oral and written notice of the accommodation they will receive and explain the procedure for requesting an alternative accommodation. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Section 11135, Welfare and Institutions Code; Section 51, California Civil Code; Section 10000, California Government Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101- 336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 45 CFR 80.1 and 80.3. Page 246 21 .3 Practices Prohibited on the Basis of Age. .31 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived age; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular age; or 3. discriminate against of deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a specific age. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .4 Practices Prohibited on the Basis of Ancestry, Ethnic Group Identification, and National Origin .41 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived ancestry, ethnic group identification, or national origin, including a person’s primary language or accent; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular ancestry, ethnic group identification, or national origin; 3. discriminate against a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a particular ancestry, ethnic group identification, or national origin, or because a person’s name, or that of their spouse, is believed to reflect a particular ancestry, ethnic group identification or national origin; 4. fail to take appropriate steps to ensure that alternative communication services are available to ultimate beneficiaries. .42 Definitions: Alternative communication services means the method used for purposes of communicating effectively with a person with limited English proficiency who is unable to read or speak or write in the English language. Alternative communication services include, but are not limited to, the provision of the services of a multilingual employee or an interpreter for the benefit of an ultimate beneficiary; the provision of written materials in a language other than English; the provision of written materials in a format other than standard font written print, such as Braille, large font print, sign language visual formats and electronic formats; auxiliary aids and services; and notice to the limited English proficient person of the availability of free alternative communication services, including Page 247 22 interpreter and translation services and where to file complaints if appropriate services are not provided. Multilingual employee means a qualified employee of a covered entity who, in addition to their duties, is also proficient in oral communication skills in English and the target languages, as are necessary to accurately and readily interpret in a second language, and has received education and training in interpreter ethics, conduct, practice, and confidentiality. A multilingual employee need not be proficient in reading or writing skills in a second language except where such skills are a job-related necessity or necessary for orally interpreting a written document. Limited English proficient persons ( LEP ) includes: a. persons who are non-English speaking or who do not speak English as their primary language or have limited ability to read, write, speak, or understand English; b. persons with developmental, mental health, or intellectual disabilities who have limited ability to understand English; and c. persons with manual or sensory disabilities, such as manual dexterity impairments, hearing or vision impairments, who have limited functional ability to read, write, or speak English presented in standard visual or oral formats; d. persons who are competent in English for certain types of communication (e.g., speaking or understanding) but are LEP for other purposes (e.g., reading or writing). Primary language means the language used most frequently by a person to communicate, including sign language, or tactile sign language. Translator means a person qualified and capable of translating a language in writing or sign. A qualified translator has received education and training in translator best practices, including ethics, conduct, practice, and confidentiality. Translation is the replacement of a written text or sign, or recorded image, from one language (source language) into an equivalent written text or sign, or recorded image in another language (target language), accurately and with appropriate cultural relevance, and at the appropriate grade level. Although many of the same requirements apply to translators as for interpreters, the skill of translators is very different from that of interpreting. Competency of translations can often be ensured by: (i) having a second independent translator check the work of the primary translator, including using a community review process to ensure the correct reading and literacy level and understandability of the document, and (ii) using back translation by having one translator translate the documents and a second one translate it back to English or the source language to check the appropriate meaning. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .5 Practices Prohibited on the Basis of Color and Race Page 248 23 .51 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived color or race; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular color or race; 3. discriminate against of deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons of a specific color or race, or because a person’s name, or that of their spouse, is believed to reflect a given color or race. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .6 Practices Prohibited on the Basis of Marital Status .61 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of a person’s actual or perceived marital status; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular marital status; or 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular marital status. .7 Practices Prohibited on the Basis of Religion It is a discriminatory practice for a recipient of state support to discriminate against an ultimate beneficiary based on the nature of the ultimate beneficiary’s religious beliefs. .71 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s actual or perceived religion; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular religion; 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular religion; or 4. to fail to make reasonable accommodation to the religious belief of an ultimate beneficiary where such accommodation can be made without undue hardship on the covered entity. Page 249 24 AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .8 Practices Prohibited on the Basis of Sex or Sexual Orientation .81 Among other prohibited practices, it is prohibited for a covered entity to: 1. discriminate against or deny full and equal access to a person because of the person’s sex or sexual orientation, as defined in section 201-4; 2. discriminate against or deny full and equal access to a person because of such person’s association with persons of a particular sex or sexual orientation, as defined in sections 201-4; or 3. discriminate against or deny full and equal access to a person because of such person’s membership in an organization identified with, or seeking to promote the interests of persons with a particular sex or sexual orientation, as defined in sections 201-4. AUTHORITY: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .9 Personal Information In determining whether a person satisfies any criteria for receipt of an aid or benefit or participation in a program or activity, it is a prohibited practice for a covered entity to differentiate on the basis of sex in inquiring about the family or marital status of such person. However, such person may be required to provide information relevant and necessary for determining whether such person satisfies validly imposed criteria for the aid or benefit, or participation in the program or activity in question. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .10 Pregnancy, Childbirth or Termination of Pregnancy. Any practice of a covered entity concerning disability due to pregnancy, childbirth, recovery from childbirth or termination of pregnancy, or other physiological conditions related to the capacity to bear children not applied under the same terms and conditions, and in the same manner, as any other practice relating to any other temporary disability is a prohibited practice; except as otherwise provided by the Fair Employment Practice Act. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139 and 11139.5, Government Code. Page 250 25 .11 Parental, Family or Marital Status Any practice of a covered entity concerning the actual or potential parental, family or marital status of an ultimate beneficiary which has the purpose or effect of differentiating on the basis of sex is a prohibited practice. Note: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .12 Inquiries Regarding and Recording of Gender and Name. 1. Inquiries by a covered entity that directly or indirectly identify a person on the basis of sex, including gender, gender identity, or gender expression, or sexual orientation, are unlawful unless the covered entity establishes a permissible defense, including whether such a practice is required by state or federal law or an order of a state or federal court. For recordkeeping purposes, a covered entity may request a person to provide this information solely on a voluntary basis. 2. It is discrimination under this Division, if an ultimate beneficiary requests to be identified with a preferred gender, name, and\/or pronoun, including gender- neutral pronouns, and a covered entity fails to abide by the person’s stated preference. 3. A covered entity is permitted to use a person’s gender or legal name as indicated in a government-issued identification document only if it is necessary to meet a legally-mandated obligation, but otherwise must identify the person in accordance with their gender identity and preferred name. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, and 11139, Government Code. .13 Additional Rights 1. It is unlawful for a covered entity to inquire about or require documentation or proof of a person’s sex, gender, gender identity, or gender expression as a condition of application or eligibility for, or receipt of, any benefit, program, activity, or service provided by the covered entity. 2. It is unlawful for a covered entity to deny any benefit, program, activity, or service to an individual based wholly or in part on the individual’s sex, gender, gender identity, or gender expression. 3. It is unlawful for a covered entity to discriminate against or deny full and equal access to an individual who is transitioning, has transitioned, or is perceived to be transitioning. 4. It is unlawful for a covered entity to refuse any individual access to facilities that correspond to that individual’s gender identity or gender expression, regardless of the individual’s sex assigned at birth. Covered entities may not require Page 251 26 individuals to undergo, provide proof or any medical treatment or procedure, provide any identity document, or to use facilities designated for use by a particular gender. Note: Authority cited: Section 12935(a), Government Code. Reference: Sections 11135, 11136, 11139, 12920, 12921, 12926, and 12940, Government Code. 21-106 Standards for Determining Discrimination and Unlawful Denial of Full and Equal Access In order to determine whether a practice is discriminatory or unlawfully denies full and equal access, all sources of information may be used, including the sources of information and methods used by state and federal courts and agencies in determining whether a practice is discriminatory or denies full and equal access. The sources of information and methods used by federal courts and agencies shall be considered a floor and not a ceiling, consistent with the objective of Division 21 to provide the broadest protections for civil rights. .1 Practices prohibited include facial discrimination, intentional discrimination, disparate impact discrimination, and denial of full and equal access. 1. Facial discrimination, sometimes referred to as express discrimination, is unlawful per se. Such discrimination includes practices that classify individuals and provide them aid, benefits, or services on the basis of their inclusion or exclusion from a protected class, except to the extent they lawfully benefit members of a protected class, such as by being part of a lawful affirmative action plan. 2. Practices that intentionally discriminate against individuals on the basis of membership in a protected class are prohibited. Intentional discrimination is established when a protected basis is a motivating factor in taking an adverse action even though other factors may have also motivated the practice. Intentional discrimination may be proved by direct or circumstantial evidence. Intentional discrimination includes purposeful discrimination. 3. Disparate impact discrimination is prohibited. Disparate impact, discriminatory effect, and adverse impact are used interchangeably. Disparate impact occurs when a facially neutral act or practice, regardless of intent, a. has an adverse or disproportionate impact, or predictably results in an adverse or disproportionate impact, on members of a protected class; b. creates, increases, reinforces, or perpetuates discrimination or segregation of members of a protected class; or c. has the effect of violating any of the other prohibitions against discrimination. A practice with a disparate impact may nevertheless still be lawful if supported by a legally sufficient justification, as set out in California Government Code Section 14029. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1,12940, 12955,12955.8, 14029 Government Code. Page 252 27 21-111 ACCESSIBILITY .1 The CWD shall ensure that programs and activities are readily accessible to individuals with disabilities. .11 The U.S. Department of Justice implementing regulations for Title II of the ADA are contained in 28 CFR Part 35. Appendix A of 28 CFR Part 36 contains the ADA Accessibility Guidelines (ADAAG), which govern the physical accessibility requirements for state and local governments. Title 24 of the California Code of Regulations (CCR), Parts 1, 2, 3, 5, 8, and 12 contains the regulations governing structural accessibility for individuals with disabilities in public facilities in the State of California. The above federal and state regulations provide the accessibility requirements for new construction, alterations, and for existing facilities. .111 Some examples of architectural changes in federal and state regulations that would make facilities accessible to individuals with disabilities are: (a) Installing ramps and handrails; (b) Making curb cuts in sidewalks and entrances; (c) Widening doors and\/or installing accessible door hardware; (d) Creating accessible parking spaces; (e) Installing visual and auditory emergency alarms; (f) Installing exterior signs at all inaccessible facility entrances directing individuals with disabilities to an accessible entrance or to a location where information about accessible facilities can be obtained. (g) Affixing signs of appropriate size and contrast to identify a CWD to assist individuals with a visual impairment in locating offices. .12 Each CWD, with instructions and assistance provided by the CDSS, shall evaluate its practices and policies to ensure they do not discriminate on the basis of disability. .13 In choosing available methods for meeting the requirements of this section, the CWD shall give priority to those methods that offer programs and activities to individuals with disabilities in the most integrated setting appropriate. Page 253 28 .14 Each county welfare department shall establish procedures to ensure that communications with applicants\/recipients and members of the public with disabilities are as effective as communications with others (see Section 21-115.41). .2 When public areas (e.g., reception areas, waiting rooms, interview booths, public restrooms, and public drinking fountains) are provided, they shall be accessible to individuals with disabilities and identified by the international symbol of accessibility in compliance with Title 24 of the California Code of Regulations. .3 When parking is provided to the general public, it shall be accessible to individuals with disabilities pursuant to local ordinance and\/or Title 24 of the California Code of Regulations. .4 CWDs may provide alternative methods that would be equally effective in making programs and activities accessible to individuals with disabilities, with prior written approval from CDSS. .41 When alternative methods are proposed, the county welfare department director or his\/her designee shall submit a written statement supporting their reasons for reaching that conclusion. This statement must be submitted to CDSS for review and approval prior to the implementation of this decision. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Sections 4450 and 11135, California Government Code; Title 24 of the California Code of Regulations, Parts 1, 2, 3, 5, 8, and 12; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Appendix A, 28 CFR Part 36; and 28 CFR 35.150 and .151. 21-115 PROVISION FOR SERVICES TO APPLICANTS AND RECIPIENTS WITH LIMITED ENGLISH PROFICIENCY OR WHO HAVE DISABILITIES County welfare departments shall ensure that effective bilingual\/interpretive services are provided to serve the needs of individuals with limited English proficiency and individuals with disabilities. The provision of bilingual\/interpretive services shall be prompt without undue delays. This need shall be met as indicated below. .1 A sufficient number of qualified bilingual employees shall be assigned to public contact positions in each program and\/or location serving a substantial number of limited English proficient persons. These employees shall have the language skills and cultural awareness necessary to communicate fully and effectively and provide the same level of service to limited English proficient applicants\/recipients as is provided to the client population at large. .11 The number of public contact positions in each major occupational group shall be determined for each program and\/or location whose limited English proficient language cases equal or exceed five percent of the total cases for each program or location. Page 254 29 .12 In determining this percentage, primary language groups shall be considered individually, rather than cumulatively. .13 To determine the percentage of limited English proficient cases in any program and\/or location, divide the number of ongoing (continuing) limited English proficient cases for each primary language group by the total ongoing (continuing) cases in that program and\/or location. .14 To determine the required number of bilingual employees in a program and\/or location, multiply the percentage of non-English-language cases by the number of public contact positions in each major occupational group in that program and\/or location. If application of the formula results in a whole number plus a fraction of less than one-half, it shall be rounded to the next lower number, e.g., 1.49 = 1.0. If the resultant fraction is one-half or greater, it shall be rounded to the next higher number, e.g., 1.50 = 2.0. EXAMPLE AFDC Program – Main Office 20 Eligibility Workers (EW) x.08 Spanish Language Case Percentage 1.60 Equals Two Qualified Spanish Speaking EW Contact Positions .141 When the computation (to determine required bilingual staffing) results in a need for less than one full-time position for a major occupational group in a program and\/or location, the agency may provide services through the use of a qualified bilingual employee from another program within the same location. EXAMPLE District Office AFDC NAFS SOCIAL SERVICES Spanish Language Spanish Language Spanish Language Cases 20% Cases 25% Cases 10% Total EWs x1 Total EWs x2 Total EWs x1 Required .2 Required .50 Required .1 Page 255 30 In the example above, one full time Spanish-speaking worker in any program would satisfy the requirements for all programs, provided that the worker would be available to interpret for the other two programs. .15 When the percentage of cases in a program and\/or location is less than five percent, the agency shall ensure that effective bilingual services are provided. This requirement may be met through utilization of paid interpreters, qualified bilingual and multilingual employees, contract interpreters (including telephonic interpreters), qualified employees of other agencies, interpreters from community organizations, or volunteer interpreter programs. .16 Applicants\/recipients may provide their own interpreter; however, the CWD shall not require them to do so. Only under extenuating circumstances or at the specific request of the applicant\/recipient shall a CWD allow a minor (under the age of 18 years) to temporarily act as an interpreter. This provision does not apply to interpretive services for persons who are deaf. .2 Forms and other written materials required for the provision of aid or services shall be available and offered to the applicant\/recipient in the individual’s primary language when such forms and other written material are provided by CDSS. When such forms and other written material contain spaces (other than \”for agency use only\”) in which the CWD is to insert information, this inserted information shall also be in the individual’s primary language. .3 Each CWD shall ensure that administrative practices do not have the effect of denying individuals with limited English proficiency and individuals with disabilities equal access to and participation in the available programs and activities. .4 Auxiliary Aids .41 CWDs shall provide appropriate auxiliary aids and services where necessary to afford qualified individuals with disabilities, including applicants, participants, companions, and members of the public, an equal opportunity to participate in, and enjoy the benefits of, a service, program, or activity of a public entity. 1. CWDs shall provide an opportunity for individuals with disabilities to request auxiliary aids and services of their choice. CWDs shall give primary consideration to the requests of individuals with disabilities. 28 CFR 35.160 (Section by Section Analysis) provides that public entities, \”shall honor the choice [of individuals with disabilities for auxiliary aids and services] unless it can demonstrate that another effective means of communication exists or that use of the means chosen would not be required under [28 CFR Section 35.164]. 2. The type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. In determining what types of auxiliary aids and services are necessary, a public entity shall give primary consideration to the requests of Page 256 31 individuals with disabilities. In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability. 3. It is the covered agency’s responsibility to provide the auxiliary aid. Therefore it shall not: a. require an individual with a disability to bring another individual to interpret for him or her. b. rely on an adult accompanying an individual with a disability to interpret or facilitate communication except i. in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available; or ii. where the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances. c. rely on a minor child to interpret or facilitate communication, except in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available, and with affirmative consent provided. .42 When telephone contact is necessary CWDs shall use a TDD, or equally effective telecommunications systems, to communicate with individuals with impaired hearing or speech. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections10553 and 10554, Welfare and Institutions Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; Title VI of the Civil Rights Act of 1964, P.L. 88-352; and 28 CFR 35.160 and .161. 21-116 DOCUMENTATION OF APPLICANT\/RECIPIENT CASE RECORDS .1 Each agency shall maintain case record documentation in sufficient detail to permit a reviewer to determine the agency’s compliance with the requirements of Division 21. .2 Each agency shall ensure that case record documentation identifies the applicant’s\/recipient’s ethnic origin and primary language in accordance with Section 21-201.21. In those cases where the applicant\/recipient is limited English proficient, the agency shall: .21 Document the individual’s acceptance or refusal of forms or other written material offered in the individual’s primary language .22 Document the method used to provide bilingual services, e.g., assigned worker is bilingual, other bilingual employee acted as interpreter, volunteer interpreter was used, or client provided Page 257 32 interpreter. When a minor (under 18 years of age) is used as an interpreter, the CWD shall so document the circumstances requiring temporary use of minors in the case record. .23 When applicants\/recipients provide their own interpreter, the CWD shall ensure that the applicants\/recipients are informed of the potential problems for ineffective communication. The CWD shall document in the case record that the applicants\/recipients were so informed. .24 Consent for the release of information shall be obtained from applicants\/recipients when individuals other than CWD employees are used as interpreters and the case record shall be so documented. .3 Upon obtaining information that identifies an applicant\/recipient as disabled or upon identifying someone as needing an accommodation because of disability through the screening procedure outlined above in 21-109, each CWD shall ensure that the case record is so documented. The CWD shall document, in writing, an applicant’s\/recipient’s request for auxiliary aids and services (see Section 21-115.4). NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections10553 and 10554, Welfare and Institutions Code; Title II of the Americans With Disabilities Act of 1990, P.L. 101-336; and 28 CFR 35.160(a) and (b)(2). 21-117 STAFF DEVELOPMENT AND TRAINING .1 Each public contact employee shall receive training in the requirements of Division 21. These requirements of Division 21 shall be incorporated into the content of the CWD’s orientation and continuing training programs. This shall include familiarization with the discrimination complaint process. CDSS will provide program guidelines and technical assistance upon request. .2 Each CWD shall develop and\/or provide cultural awareness training programs for all public contact employees. Cultural awareness training shall pertain to specific cultural characteristics of cultural groups served by the CWD to provide a better understanding of, and sensitivity to, the various cultural groups, including individuals with disabilities to ensure equal delivery of services. Whenever possible, training shall involve community organizations familiar with a specific culture. .21 In presenting materials relating to specific cultural characteristics, all efforts should be made to avoid stereotypes. .3 Appropriate agency staff shall be instructed in the investigation of discrimination complaints. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections10553 and 10554, Welfare and Institutions Code; 28 CFR 35.160(a) and Subpart B; 80 CFR 80.1; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. Page 258 33 21-201 COMPLIANCE PROCEDURES AND REPORTING .1 Assignment of Resources to Implement Requirements of This Division Responsibility for the implementation of nondiscrimination requirements shall be centralized within each agency. Each agency shall designate an employee as the Civil Rights Coordinator, and shall allocate adequate personnel and resources to implement the provisions of this Division and ensure nondiscrimination in the delivery of services. Methods and staff used to meet Division 21 requirements may vary from county to county. To determine agency compliance, the following factors will be considered: .11 Level and quantity of personnel assigned to activities related to this Division. .12 Comparison of the civil rights unit’s workload, actual or anticipated, to the workload of other administrative units. .13 Extent to which the existence and responsibilities of the civil rights unit has been publicized within the agency and to the public. .14 Comparison of physical space and equipment assigned to civil rights personnel with that assigned to other offices of similar level in the agency. .2 Compliance Reports Each CWD shall keep timely and accurate compliance records. This information shall be submitted to CDSS whenever, and in such form as, CDSS may determine necessary. The information includes, but is not limited to, the following: .21 Each CWD shall collect primary language and ethnic origin data by district offices in all AFDC, nonassistance food stamps, and social services programs covered by this Division. This data shall be collected for each head of household or, in social services cases, each primary recipient. .211 Ethnic origin and primary language shall be determined by the applicant\/recipient completing the appropriate section of the application forms. Should he\/she decline to make a self-declaration, the worker will make a visual determination and record the information in the appropriate place on the form. .212 Each CWD shall submit this information by countywide total to CDSS annually. Source data substantiating the compliance report is to be maintained by the district office. .22 County Civil Rights Plans Page 259 34 All county welfare departments shall submit to CDSS an initial Civil Rights Plan and subsequent annual updates. Each plan shall function as a guide in developing the CWD’s policy of providing equal delivery of benefits and services. The Civil Rights Plan and updates will be in such format and will contain such information as CDSS may determine necessary. .23 County Civil Rights Impact Studies .231 The USDA requires that civil rights impact studies be completed \”[b]efore making decisions that would substantially alter individual’s access to [county] welfare offices…\” to ensure against discrimination. This requirement is outlined in the USDA Administrative Notice 93-11, State Agency Local Welfare Hours, dated December 4, 1992. The Notice requires that the impact studies be available for review. .232 The USDA, Office of Civil Rights Enforcement, issued Departmental Regulation #4300-4, Civil Rights Impact Analysis, dated September 22, 1993. The Regulation requires county welfare departments \”…to establish internal systems to identify and address the civil rights implications of proposed policy actions before those actions are approved and implemented.\” The regulation identifies \”policy actions\” as those actions including but not limited to reorganizations, office consolidations, closures or relocations. \”Major civil rights implications\” are defined as \”…those consequences of proposed policy actions which, if implemented, will negatively or disproportionately affect minorities, women, or persons with disabilities who are employees, program beneficiaries or applicants for employment or program benefits in USDA- conducted or assisted programs by virtue of their race, color, sex, national origin, religion, age, disability, marital or familial status.\” The Regulation requires agencies to: \”(1) Identify and address major civil rights impacts of proposed actions on minorities, women, and persons with disabilities before the actions are approved and implemented. \”(2) Establish internal procedures which implement this policy…[Examples are provided here.] \”(3) Refer proposed policy actions and supporting documentation which contain major civil rights impacts that cannot be resolved at the agency level to the Office of Advocacy and Enterprise for review…[Examples are provided here as to situations when a referral will be made.] \”(4) Certify to the Assistant Secretary for Administration that procedures to implement this policy have been established within 90 days of the effective date of this regulation.\” .3 Compliance Reviews .31 In order to ensure compliance with civil rights laws and regulations, CDSS conducts routine on- site reviews of county welfare departments. The review includes, but is not limited to, the following: Page 260 35 .311 A review of case records for applicants\/recipients who are non-English speaking or disabled and other case records as appropriate. .312 Interviews with CWD staff. .313 A contact with at least one community organization. .314 A review of the program’s or activity’s accessibility to persons with disabilities. .315 A review of program or activity information being provided to applicants\/recipients, community organizations, or other interested persons. .316 A review of applications, application instruction sheets, pamphlets, or other materials available to the public. .317 A review of the CWD’s complaint log to determine if civil rights complaints are processed in accordance with procedures outlined in Section 21-203. .318 A review of appropriate documents to confirm an assurance of compliance agreement is included. .32 On occasion, special compliance reviews may be necessary. These reviews may be unannounced and are conducted when: .321 There is a need to follow up on noncompliance findings from a routine review requiring additional information and an in-depth examination of specific aspects of program operations and activities. .322 Statistical data indicates that a particular group of people is not participating in or benefitting from a program or activity to the extent indicated by the population characteristics of that area. .323 The Director of CDSS requests a review. .324 Reports of noncompliance by federal, state, or other agencies need to be substantiated. .325 A pattern of complaints of discrimination has developed. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Program Instruction 113-7, Parts V, VII, and VIII; USDA Departmental Regulation, Office for Civil Rights Enforcement, #4300-4, September 22, 1993; USDA, Administrative Notice 93-11, dated December 4, 1992 (State Page 261 36 Agency Local Welfare Office Hours); 7 CFR 15.3(b)(3); 28 CFR 35.130(b)(4); 28 CFR 42.406(a), (b), (b)(4), (b)(6), (c), and (d); 28 CFR 42.407(b); 28 CFR 42.410; 45 CFR 80.3(b)(3); 45 CFR 80.6(b); and 45 CFR 84.4(b)(5). 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATORY TREATMENT. 21-203 APPLICANT\/RECIPIENT COMPLAINTS OF DISCRIMINATION County welfare departments are responsible for investigating discrimination complaints made by applicants\/recipients or by their authorized representatives, and for investigating complaints remanded by CDSS, the U.S. Department of Health and Human Services, or the U.S. Department of Agriculture. An applicant\/recipient or his\/her authorized representative may file a complaint of discrimination with the state or local county welfare department involved or directly with the appropriate agency of the federal government. Information concerning the complaint process shall be available to applicants\/recipients and other interested persons and shall include procedures for filing complaints or appeals with CDSS, the U.S. Department of Health and Human Services or the U.S. Department of Agriculture. The complaint must be received not later than 180 days from the date of the alleged discriminatory act unless the filing date is extended by CDSS or the responsible federal agency. When CDSS or the CWD lack jurisdiction over a complaint, CDSS or the CWD shall, whenever possible, refer the complaint to the appropriate governmental agency and\/or advise the complainant of the lack of jurisdiction and explain the reason why it is outside the jurisdiction. .1 Complainant’s Right to a State Hearing (Fair Hearing) This regulation does not limit or restrict a complainant’s right to request a state hearing in accordance with Division 22. Should the complaint involve program issues, in addition to allegations of discriminatory treatment, program issues may be subject to a state hearing. It is the CWD’s responsibility to advise the complainant of his\/her right to a state hearing and the necessity to request such a hearing within 90 days as prescribed in Section 22-009, in addition to the filing of a complaint of discriminatory treatment. The complainant shall also be advised of the 10-day limitation for filing a request for a state hearing to receive aid paid pending. .11 Should a complaint of discrimination arise during a state hearing, the Administrative Law Judge shall remand the complaint to the CWD for the preparation of a report in accordance with Section 21-203.12 and investigation and handling in accordance with Division 21 regulations. .2 Procedures for Processing Discrimination Complaints All complaints of discrimination will be addressed in accordance with the following procedures: Page 262 37 .21 The CWD shall maintain a control log in which all complaints of discrimination are entered by year and date the complaint was received. At a minimum the log shall provide: .211 Complainant’s name. .212 Date complaint was received and the date of the alleged discriminatory act(s). .213 CDSS\/CRB case number, if any. .214 Program(s) involved. .215 Basis of discrimination: age, race, sex, etc. .216 Nature of the complaint. .217 Resolution: completed investigation, withdrawal, failure to pursue, etc. .218 Decision: discrimination or no discrimination. .219 Date investigation completed or date complaint resolved. .22 A complaint of discrimination shall be filed either orally or in writing. .221 The CWD shall be permitted to ask the complainant to fill out a complaint form but shall not make it a condition of filing a complaint. .222 The CWD shall accept complaints of discrimination filed anonymously. .223 When a complainant refuses to put their complaint in writing because of fear of retribution or to maintain anonymity, or due to illiteracy, or is physically unable to put their complaint in writing, the person to whom the allegation is being made shall put the elements of the complaint in writing. .224 The CWD shall make a reasonable effort to make contact with the complainant by mail and\/or telephone to follow up on the initial complaint. .23 Within 20 calendar days of receipt of a complaint, the CWD\/CDSS shall acknowledge the complaint by informing the complainant in writing that an investigation will be conducted. .24 For those complaints requiring investigation by the CWD, the investigation, including any attempted resolution, shall be completed within sixty (60) calendar days following the receipt of the complaint. Within twenty (20) calendar days following the completion of the investigation, the CWD shall: Page 263 38 .241 Inform the complainant in writing of the results of the investigation, clearly stating the reason for the decision. .242 Inform CDSS\/CRB of the case resolution and of any corrective actions taken. .243 Forward a complete copy of the investigation report to CDSS\/CRB and attach copies of all correspondence sent to the complainant. .25 For those complaints not requiring an investigation, the CWD shall: .251 Inform the complainant, in writing, within 40 calendar days of receipt of the complaint that the complaint shall not be investigated and the reason(s) for not investigating. .252 Inform CDSS\/CRB of the case resolution, including a copy of the withdrawal form, letter to the complainant, etc. .26 The complainant shall be informed of his\/her rights as follows: .261 The CWD shall inform the complainant that he\/she may appeal a CWD decision to CDSS within 30 calendar days of the date on which the CWD mails or otherwise provides the complainant with the decision. .262 The CWD shall, in addition to informing the complainant of his\/her appeal rights set forth in Section 21-203.261, also inform the complainant that he\/she may appeal a CWD decision resulting from a complaint based on race, color, national origin, political affiliation, religion, sex, age or disability to the United States Department of Agriculture (USDA), if the complaint involves the Food Stamp Program, within 30 calendar days of the date on which the CWD mails or otherwise provides the complainant with the decision. .263 The CWD shall, in addition to informing the complainant of his\/her appeal rights set forth in Section 21-203.261, also inform the complainant that, after a CWD decision resulting from a complaint based on race, color, national origin, age or disability he\/she may file his\/her complaint with the United States Department of Health and Human Services (HHS), if the complaint involves programs other than the Food Stamp Program that receive financial assistance through HHS, within 180 calendar days of the alleged discriminatory act unless the filing date is extended by HHS. .264 CDSS shall inform the complainant that a CDSS decision on a complaint or appeal, pursuant to Section 21-203.261, may similarly be appealed to the USDA pursuant to Section 21- 203.262 and\/or filed with HHS pursuant to Section 21-203.263. .27 Nothing in these regulations shall preclude a complainant’s pursuing remedies through civil proceedings. Page 264 39 .3 Procedures for Investigation Complaints In order to maintain consistency in the conduct of investigations, the following procedures shall apply. .31 The CWD\/CDSS shall designate an employee to conduct investigations. In no case shall an employee be assigned to investigate a complaint involving actions taken by him\/her or by an employee under his\/her immediate supervision, or where that designated employee’s responsibilities in another program or capacity within CWD\/CDSS may result in a conflict of interest. .32 Interview with Complainant A face-to-face interview shall be conducted by the assigned investigator unless the client and CWD mutually agree it is neither necessary nor practical. When scheduling an interview with the complainant, the complainant shall be advised that a representative or counsel may be present at the interview. In addition, the complainant shall be requested to sign a consent form informing the complainant that the information pertinent to the processing of a complaint will be shared with the appropriate CWD\/CDSS and federal civil rights personnel in the investigation of the complaint as necessary. .321 Prior to beginning the interview, the person assigned to investigate the case shall explain confidentiality requirements, and make reasonable efforts to ensure that the complainant is able to communicate effectively (refer to Section 21-115.4), using interpreters, readers, etc., if necessary. The following information shall be obtained during the interview: (a) Complainant’s name, case number, address, email address, and telephone number. (b) Names of individuals responsible for the action, decision, or condition alleged to be discriminatory. (c) Date and place of alleged discriminatory treatment. (d) Basis of discrimination (e.g., race, sex, disability, etc.). (e) Nature of the action, decision, or conditions of the alleged discrimination. (f) Information known to the complainant in support of his\/her allegation. (g) Names and contact information of possible witnesses whom the complainant wishes to have interviewed. (h) Other information specific to the complaint. Page 265 40 (i) Any indications of reprisal, intimidation, or harassment as a result of the complaint. (j) Relief sought by the complainant. .33 Interview with the employee alleged to have acted in a discriminatory manner. When scheduling an interview with the employee, the employee shall be advised of the right to have a representative or counsel present. .331 The investigator should identify the complainant and describe the nature of the complaint. The employee’s statement should be taken concerning the complaint issues. The employee should be advised that such statements will be available to the complainant as part of the investigation. .34 Review of Issues Specific to the Complaint In reviewing the issues involved in the applicant\/recipient complaint, the investigator shall: .341 Review Division 21 regulations which pertain to the issues in the complaint and, if necessary, obtain clarification from CDSS. .342 Review complaint documents concerning the discrimination issues. .343 Interview witnesses as indicated by circumstances or the nature of the allegation. .35 Investigation of the General Environment In evaluating the general environment in which the alleged discriminatory action occurred, the investigator may: .351 Select and review cases to compare the treatment of individuals with disabilities, members of the same race, national origin, etc., with cases selected from the general welfare population. .352 Compare the treatment of recipients by the individual who allegedly discriminated with the treatment provided by other employees for a similar group. .353 Interview the employee alleged to have discriminated. .354 Interview the supervisor of the employee named in the complaint and survey the general environment in which the complaint arose. Record details which may indicate needed corrective action or exonerate the employees alleged to have discriminated. .355 Review other supporting documents as appropriate. Page 266 41 .4 Report of Investigation The investigation report shall address all issues raised by the complainant. Where there is insufficient evidence to make a decision whether discrimination occurred or not, further investigation shall be conducted until a decision can be made. The investigator shall ensure that such issues are fairly represented in the report. .5 Harassment, Coercion, Intimidation, and Retaliatory Acts Prohibited No official or employee shall intimidate, threaten, harass, coerce or discriminate against any individual for the purpose of interfering with any right or privilege secured by these regulations or because he or she has made a complaint, testified, assisted or participated in any manner in any investigation, proceeding or hearing. .51 Harassment Prohibited (a) Harassment by a covered entity, related to any program or activity, on any protected basis is an unlawful practice. (b) Harassment includes quid pro quo harassment and hostile environment harassment. The same conduct may constitute both quid pro quo and hostile environment harassment. (1) Quid pro quo harassment. Quid pro quo harassment refers to an unwelcome request or demand to engage in conduct where submission to the request or demand, either explicitly or implicitly, is made a condition related to the attainment of any benefit, as defined in Section 14020 of this subchapter. An unwelcome request or demand may constitute quid pro quo harassment even if an individual acquiesces in the unwelcome request or demand. (2) Hostile environment harassment. Hostile environment harassment refers to unwelcome conduct that interferes with or prevents the attainment of any benefit, constitutes any kind of adverse action, or creates a hostile, offensive, oppressive, or intimidating environment. Hostile environment harassment does not require a change in the terms, conditions, or privileges afforded by a covered program. (A) Whether hostile environment harassment existed or exists depends on the totality of the circumstances. (i) Factors to be considered in determining whether hostile environment harassment existed or exist include: the nature of the conduct; the context in which the incident(s) Page 267 42 occurred; the severity scope, frequency, duration, and location of the conduct; and the relationship of the persons involved. (ii) Neither psychological nor physical harm must be demonstrated to prove that a hostile environment existed or exists. However, evidence of psychological or physical harm may be relevant in determining whether a hostile environment exists or existed, and the amount of damages to which an aggrieved person may be entitled. (iii) Whether unwelcome conduct created a hostile environment is viewed from the perspective of a reasonable person in the aggrieved person’s position. (3) Types of conduct. Quid pro quo and hostile environment harassment may be written, verbal, or communicated in other ways, and do not require physical contact. Such harassment includes: (A) verbal harassment, including epithets, derogatory comments, or slurs; (B) physical harassment directed at an individual, including assault, impeding or blocking movement, or any physical interference with normal movement; (C) visual forms of harassment, including derogatory posters, cartoons, drawings, or other documents. (D) unwelcome sexual conduct, or other unwelcome conduct, which need not be based on sexual desire, linked to an individual’s sexual orientation or sex, including: pregnancy or medical conditions related to pregnancy, childbirth or medical conditions related to childbirth, breastfeeding or medical conditions related to breastfeeding; gender identity; and gender expression; (E) any coercion, intimidation, threats, or interference with a person’s exercise or enjoyment of any benefit secured by rights protected under the Act, this subchapter, or implementing regulations. (F) taking any adverse action against a person in a manner that constitutes quid pro quo or hostile environment harassment, such Page 268 43 as, representing to a person that a benefit is not available because of the person’s response to a request or demand for a sexual favor; (G) revealing private information to a third party about a person, without their consent, in a manner that constitutes quid pro quo or hostile environment harassment, unless such disclosure is required by federal or state law; or (c) A single incident of harassment based on an individual’s membership in a protected class may be sufficient to constitute hostile environment harassment or quid pro quo harassment. (d) The fact that an alleged perpetrator may be a member of the same protected class as the aggrieved person is not by itself a defense to a claim of harassment. (e) A covered entity shall be liable for harassment of a beneficiary by a third party if the covered entity knows or should have known of the conduct and fails to take immediate and appropriate corrective action. (f) Persons protected. The prohibition on harassment extends to conduct that is based on an individual’s membership in a protected class, being perceived as a member of a protected class, being associated with a member of a protected class or someone who is perceived to be a member of a protected class, or on account of having aided or encouraged any person in the exercise of the rights. .52 Retaliation Generally (a) It shall be unlawful for any covered entity to take adverse action against an aggrieved person because the person has engaged in protected activity. (1) Because of means that the retaliation was a motivating factor in causing harm. Retaliation need not be the sole motivating factor. (2) The adverse action need not be related directly to the nature of the protected activity. (3) Retaliation may be established by direct evidence or circumstantial evidence, including the temporal proximity between the protected activity and the adverse action. (b) Persons Protected. For purposes of a retaliation claim, an aggrieved person includes any person who has alleged that they have been subjected to adverse action due to engagement in a protected activity. Page 269 44 (1) A person does not have be a member of a protected class in order to assert a claim for retaliation. (2) A person does not need to allege or prove discrimination or denial of full and equal access, or prevail on a separate claim under any provision of the Act or these regulations, in order to assert a claim for retaliation. (3) An aggrieved person may prevail on a retaliation claim even if: (A) the aggrieved person was engaged in a protected activity challenging practices which the aggrieved person reasonably believed to be unlawful, whether or not those practices are determined to be unlawful, or (B) the aggrieved person was participating in an activity which was perceived by the respondent as protected activity, whether or not it was so intended by the aggrieved person. (c) Protected activity includes: (1) making a complaint, testifying, assisting or participating in any manner in a proceeding, including any proceeding under Division 21-100, the California Fair Employment and Housing Act, California Civil Code Sections 51, 51.5, 51.7, 54 54.1, or 54.2, the Americans with Disabilities Act, the federal Civil Rights Act, Section 504 of the Rehabilitation Act, or any other state or federal civil right statutes; (2) opposing practices prohibited by the Americans with Disabilities Act, the federal Civil Rights Act, or Section 504 of the Rehabilitation Act, including seeking the advice of the state, any state or local agency, the Department or Council, or a person employed or retained by a recipient who has authority to receive, transmit, investigate, or discover a complaint, or correct an alleged violation, whether or not a complaint is filed, and if a complaint is filed, whether or not the complaint is found to have merit; (3) assisting or advising any person in seeking the advice of the state, any state or local agency, the Department or Council, or a person employed or retained by a recipient who has authority to receive, transmit, investigate, or discover a complaint, or correct an alleged violation, whether or not a complaint is filed, and if a complaint is filed, whether or not the complaint is found to have merit; Page 270 45 (4) participating in an activity that is perceived by the state, any state or local agency, or a recipient as opposition to discrimination or denial of full and equal access, whether or not so intended by the individual participating in the activity; (5) contacting, communicating with or participating in a proceeding of a human rights or civil rights agency regarding discrimination or denial of full and equal access on a basis enumerated in this Division; (6) assisting with or participating in the proceedings of the state, any state agency, or a recipient including involvement as a potential witness, which the state, any state or local agency, or a recipient perceives as participation in a proceeding alleging a violation of this Division; (7) seeking information, formally under a Public Records Act request, or informally, regarding programs or activities of a state, any state agency, or a recipient; or (8) requesting a reasonable accommodation or reasonable modification for an individual with a disability, or requesting an interactive process meeting, whether or not the request was granted. (d) Violations of this section are considered a discriminatory practice. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 11136, 11137, 11139, 12926, 12926.1, and 12940, Government Code. .6 Confidentiality of Information The identity of any complainant and the employee or official alleged to have discriminated must be confidential, except to the extent necessary to carry out the complaint process including the conduct of any investigation, hearing, or judicial proceeding arising thereunder. (See Division 19.) (a) Information concerning a request for a reasonable accommodation for a disability, or other information concerning disability, medical condition, or genetic information, shall be kept confidential by covered entities in accordance with the privacy protections afforded to medical information under state and federal law, including the Confidentiality of Medical Information Act, California Civil Code sections 56-56.37, unless confidentiality is waived by the individual with a disability or disclosure is required by law. (b) To the extent necessary to review a request for an accommodation, or to implement an accommodation, confidential information may be disclosed only to the covered entity’s staff who Page 271 46 are directly involved in the accommodation process or who are necessary to implement the accommodation. In the context of an adjudication, parties to the proceeding other than the .7 Retention The CWD shall retain the written complaint, a record of its disposition, the investigation report, and related documents for a minimum of three (3) years from final disposition. All such records shall be maintained in a secure location with access limited to personnel assigned to the Civil Rights Program. .8 Closure of Complaint Files .81 Once CDSS receives notification of resolution of a discrimination complaint from a CWD, CDSS shall either approve final closure or request further action be taken before closure. .811 If the CWD obtains a withdrawal of the complaint from the complainant or the complainant fails to cooperate in pursuing the complaint, the CWD may request final closure without a final report of investigation. .82 The CWD shall not close out a complaint case without the approval of CDSS. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553 and 10554, Welfare and Institutions Code; Section 51, California Civil Code; Section 11135, California Government Code; USDA, Food and Nutrition Service, FNS Instruction 113-7 Part X (A); 28 CFR 42.408(b), (c) and (d); and Title II of the Americans With Disabilities Act of 1990, P.L. 101-336. NOTE: Authority cited: Section 12935(a), Government Code. Reference: Sections 11000, 11135, 12926, 12926.1, 12940, 12955, and 12955.8, Government Code; Olmstead v. L.C. ex rel. Zimring (1999) 527 U.S. 581; Lau v. Nichols (1974) 414 U.S. 563; Committee Concerning Community Improvement v. City of Modesto (9th Cir. 2009) 583 F.3d 690. 21-205 CORRECTIVE ACTION .1 Corrective action may be required as a result of an investigation, compliance review, or other determination by CDSS that a CWD is not in compliance with the requirements of Division 21. .11 Such corrective action shall accomplish the following: .111 Resolution of the problem which initiated, or was discovered as a result of an investigation or compliance review. .112 Development of a policy or plan to ensure that problems of a similar nature do not reoccur. Page 272 47 .2 A CWD shall implement corrective action determined necessary as a result of an investigation, compliance review, or other determination within a reasonable time, as determined by CDSS after conferring with the CWD. In no event shall initial implementation be extended beyond 60 days. .3 Sanctions for Noncompliance Attempts shall be made at the outset to secure compliance by voluntary means, if such method is reasonably possible. The CWD and CDSS shall enter into a voluntary compliance agreement. When a county welfare department fails to voluntarily comply with the requirements imposed by Division 21 or with applicable sections of state or federal statutes and regulations, fiscal sanctions or other legal remedies may be invoked in accordance with Welfare and Institutions Code Section 10605, or Government Code Sections 11135 through 11139, when state financial assistance is involved, or the issue may be referred to the appropriate federal agency for further compliance action when federal financial assistance is involved. .31 CDSS may also initiate procedures which include, but are not limited to: .311 Actions to suspend or terminate CWDs from further program participation when state financial assistance is involved. .312 Recommending appropriate sanctions to other state or local agencies whose jurisdiction is involved. NOTE: Authority cited: Sections 10553 and 10554, Welfare and Institutions Code. Reference: Sections 10553, 10554, and 11475.1, Welfare and Institutions Code; United States Department of Agriculture (USDA), Food and Nutrition Service, FNS Instruction 113-7, Part XI, B and C; and Title VI of the Civil Rights Act of 1964, P.L. 88-352. Page 273 CDSS Policy Lab – Report Cover TABLE OF CONTENTS CDSS Policy Lab Full Report final – paginated – with CDSS edits UStep Zero: User Decides to Make a Complaint Goals and Challenges Potential Solutions UStep One: Complaint Intake Goals and Challenges Potential Solutions UStep Two: Initial Review and Application of the Pleading Standard Goals and Challenges Potential Solutions UStep Three: Investigation Goals and Challenges Potential Solutions UStep Four: Resolution Goals and Challenges Potential Solutions UStep Five: Appealing an Initial Determination [ Request for Reconsideration ] Goals Challenges Potential Solutions Screening Every Applicant Conciliation Grievance Review\/Investigation Resolution Appeal to CDSS Goals and Challenges Solutions Date. This indicator should capture when the incident(s) at issue occured. Resolution Date. This indicator should track the date a complaint is resolved. Child Welfare System Structure Goals Challenges Potential Solutions Further Research and Advocacy Alternative Dispute Resolution: Remedies First and Mediation A. Remedies First : Informal Resolutions of Claims B. Formal Mediation APPENDIX TOC Appendices A-G Final APPENDICES A-F (1).pdf Other States Appendix (Marked Up + Highights).pdf OR – Complaint Form (1).pdf Filing Customer Service or Privacy Complaints or a Report of Discrimination Voice: 1-800-368-1019 Customer Service\/Privacy Complaint or Report of Discrimination Blank Page Appendix G – Division 21.pdf Appendix G – Division 21. Clean.pdf Blank Page Name: Home Address 1: Home Address 2: Home Phone: E-mail Address: State Agency: Claim Against – Name: Claim Against – Title: Claim Against – Address 1: Claim Against – Address 2: Claim Against – Phone: Location(s) and Date(s): Complaint Continuing?: Off Description 2: Filed complain with gov?: Off hired attorney?: Off court action?: Off Form Completed by:: Off Signature: Date of completion: Date: Intake #: Date of WalkIn if Applicable: Matter #, if Applicable: Your Name: Preferred Title eg Dr Ms Mx: Your Date of Birth: Your Address: Your City: Your State: Your Zip: Your Cell Phone: Your Other Phone: Your Occupation: Your Email: Your Race\/Ethnicity: Your Primary Language: Married: Off Domestic partner: Off Single: Off Other: Off Family Status Other: Your Emergency Contact: Person\/Entity Name: Company if any: Person\/Entity Address: Person\/Entity City: Person\/Entity State: Person\/Entity Zip: Person\/Entity Phone: Second Contact: 2nd Contact Address: 2nd Contact City: 2nd Contact State: 2nd Contact Zip: 2nd Contact Phone: Date of most recent incident of discrimination: Borough where incident occurred: Have you filed any complaint about this incident in any other place: Off EEOC: Off NY State Division of Human Rights: Off HUD: Off HPD: Off NYCHA: Off Court: Off Other_2: Off Describe other: the Commission before: Off Housing Complete Section A and D: Off Public Accommodation store restaurant taxi dentist office etc: Off Employment Complete Section C and D: Off Discriminatory Harassment Complete Section D: Off Biasbased Profiling by Law Enforcement Complete Section D: Off List when and the result of your inquiry 1: List when and the result of your inquiry 2: List when and the result of your inquiry 3: List when and the result of your inquiry 4: Coop: Off Commercial: Off Rental: Off Shelter: Off SRO: Off Owneroccupied: Off Condo: Off Approx Number of Units: Race: Off Gender: Off ReligionCreed: Off Age: Off Victim of Domestic Violence Sexual Violence or Stalking: Off Color: Off Gender Identity: Off Occupation_2: Off Military Service: Off Presence of Children: Off National Origin: Off Lawful Source of Income: Off DisabilityFailure to Accommodate: Off Marital Status: Off Sexual Orientation: Off AlienageCitizenship Status: Off Race_2: Off Age_2: Off ReligionCreed_2: Off National Origin_2: Off Sexual Orientation_2: Off Color_2: Off Gender_2: Off Gender Identity_2: Off Marital Status_2: Off AlienageCitizenship Status_2: Off DisabilityFailure to Accommodate_2: Off Military Service_2: Off More than 4: Off More than 15: Off Are you in a union: Off Which union: Salary History: Off Gender Identity_3: Off Marital Status_3: Off ReligionCreed_3: Off Caregiver Status: Off Race_3: Off Gender_3: Off Pregnancy: Off Age_3: Off Color_3: Off Sexual Orientation_3: Off Credit History: Off National Origin_3: Off Unemployment Status: Off Status as Victim of Domestic Violence Sexual Violence or Stalking: Off AlienageCitizenship Status_3: Off DisabilityFailure to Accommodate_3: Off ArrestConviction Record: Off Military Service_3: Off Briefly describe what happened: Date of Intake or WalkIn: Intake Number: Staff Member: Statute of Limitations Deadline LEB: Statute of Limitations Deadline EEOC: CRB: Off Community Org: Off Social Media: Off Newspaper: Off Advertisement Please specify if possible: Off Social Services: Off Commissioner: Off Legal Services Org: Off Email_2: Off City Agency: On CCHR Website: Off Press: Off FlyerBrochure: Off Internet: Off 311: Off TV: Off Taxi TV: Off Elected Official: Off Private Lawyer: Off Radio: Off Other Complainant: Off Advertisement (Please specify if possible): Details: a Limited English Proficient: Off Primary Language of Complainant: In which language was intake conducted: LEB staff: Off Phone_3: Off Volunteer: Off Paid Interpreter: Off 4 Were referrals made: Off Where: 5 Was a complaint filed: Off Approved by: sfn00143[0]: page1[0]: signatureSub[0]: zipCode[0]: sendToSub[0]: EmailSubmitButton1[0]: ”

“[image: Map Description automatically generated] 2021-2022 CalWORKs Trailer Bill Analysis AB 135, Chapter 85, Statutes of 2021 & AB 153, Chapter 86, Statutes of 2021 Contact Person: Kevin Aslanian [email protected] 916-712-0071 Coalition of California Welfare Rights Organizations July 2021 ASSEMBLY BILL No. 135 Introduced by Committee on Budget (Assembly Members Ting (Chair), Arambula, Bennett, Bloom, Carrillo, Chiu, Cooper, Frazier, Friedman, Cristina Garcia, Jones-Sawyer, Lee, McCarty, Medina, Mullin, Nazarian, O’Donnell, Ramos, Reyes, Luz Rivas, Blanca Rubio, Stone, and Wood) legislative counsel’s digest AB 135, as amended, Committee on Budget. Budget Act of 2021. Human services omnibus. Please note that the language in blue is new language. Table of Contents Title Page Section 18 Pandemic Emergency $640 Payments 3 Section 22. Housing and Homelessness Program additional funding 4 Section 23. Development of a global telephonic signature for social services programs. 6 Section 24. Photo ID for CalWORKs 7 Section 27. CalWORKs Overpayment Classified as Non-Fraudulent 8 Section 28- Prohibits counties from collecting stale nonfraudulent overpayment 11 Section 29. Transfers $450 million from the General Fund to the Safety Net Reserve Fund. 12 Section 30- Oral signature 13 Section 32. Potentially a six (6) months continuation of CalWORKs for parents whose children removed from the home by 14 Section 33. County option to aid families who are about to be homeless not an entitlement 16 Section 36. CalWORKs Pregnant mom reform of 2021 18 Section 37. CalWORKs 5.3% grant increase 21 Section 39. Increasing earned income disregards for CalWORKs applicants 22 Section 41. Automatic 12-month extension without the need to file an application 23 Section 42. CalOAR and CalWORKs 2.0 25 Section 44. Training of County staff relative to trauma-informed, anti-racist, anti-stigma, and implicit bias-aware culture. 27 Section 45. Exemption of income and resource of payments to CalWORKs beneficiaries for participation in an advisory group 29 Section 46. SSI Grant Increase 29 Section 49. Planning an IHSS Provider Back Up System 30 Section 60- Enhanced Services to Asylees and Vulnerable Noncitizens 33 Section 61. Increase in the county single allocation. 33 Section 77. Simplified application for elderly CalFresh applicants 34 Section 78. Telephone Signature for public social services in California. 35 Section 79 SS Transitional Benefit Program Extension 36 Section 80. Revising the CalFresh county block grant also known as the county single allocation 38 Section 81 Implement CalFresh Waivers with complying with the California Administrative Procedures Act 38 Section 82 Extension of CalFresh Applicant Choice of Interview Method. 39 Section 83 Expand CalFresh program outreach and retention and improve dual enrollment between the CalFresh and Medi-Cal programs 40 Section 84- Extends the deadline to establish and implement a statewide Restaurant Meals Program to September 1, 2021. 41 Section 85 CalFresh Overissuances 43 Section 87 CalFresh benefits for food insecure noncitizens living in California. 44 Section 91 CalFresh Outreach Grantee. 46 Section 56. California Guaranteed Income Pilot Program 49 Section 59. Funding for refugee program 51 Section 18 Pandemic Emergency $640 Payments Authorizes a flat, one-time $640 payment from the Pandemic Emergency Assistance Fund to each CalWORKs assistance unit. Requires the department to submit a written report to the Legislature relating to the payments by November 1, 2021. RECIPIENT IMPACT STATEMENT: This is the most equitable way of issuing the Pandemic Emergency benefits to the more than 300,000 CalWORKs families who care for 525,000 babies and children enduring deep poverty. Effective Date- Done SEC. 18. Chapter 4.8 (commencing with Section 8154) is added to Division 8 of the Welfare and Institutions Code, to read: CHAPTER 4.8. Pandemic Emergency Assistance 8154. (a) The State Department of Social Services shall use the funds allotted to the state from the Pandemic Emergency Assistance Fund pursuant to the American Rescue Plan Act of 2021 (Public Law 117-2), and appropriated by the Legislature for this purpose in the Budget Act of 2021, to make a flat rate one-time payment to each CalWORKs assistance unit, as defined in Section 11450.16, that is an active assistance unit on the date of eligibility, as determined by the Statewide Automated Welfare System. The amount of the one-time payment shall be based on the funds available and the most recent caseload data, as determined by the department. The department, based on data from the Statewide Automated Welfare System, shall establish the date of eligibility. (b) The department shall develop guidance on tracking and reporting procedures, and the form and manner of the payments to be made pursuant to subdivision (a). (c) The payments described in subdivision (a) shall be treated as nonrecurrent short-term benefits, as defined in Section 260.31(b)(1) of Title 45 of the Code of Federal Regulations and in the Instructions for Completion of State TANF Financial Report Form ACF-196R, published on July 31, 2014. (d) The department shall submit a written report to the Legislature, in accordance with Section 9795 of the Government Code, no later than November 1, 2021, that shall include, but not be limited to, information on the following: (1) The number of one-time payments made. (2) The dollar amount of the one-time payment. (3) Aggregate data on the form and manner of payments made and how many payments were made in each form. (4) Details on the timeframe within which payments were issued and if any administrative issues arose in that implementation. (e) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the State Department of Social Services may implement, interpret, or make specific this section by means of all-county letters or similar written instructions, which shall be exempt from submission to or review by the Office of Administrative Law. These all-county letters or similar instructions shall have the same force and effect as regulations. (f) This chapter shall remain in effect only until January 1, 2025, and as of that date is repealed. Section 22. Housing and Homelessness Program additional funding Authorizes the use of funds to provide CalWORKs housing support to provide housing support to CalWORKs recipients who are at risk of homelessness and for whom housing instability would be a barrier to self-sufficiency or child well-being. Expands the definition of an eligible individual for the Home Safe Program to include individuals who are in the intake process to adult protective services, or individuals who may be served through a tribal social services agency who appears to be eligible for adult protective services. Modifies the definition of homeless and expands the definition of eligible family to include an individual or family that is at risk of homelessness or in a living situation that cannot accommodate the child or multiple children in the home for the Bringing Families Home Program. Waives the requirement for a grantee to match funds between July 1, 2021, and June 30, 2024. RECIPIENT IMPACT STATEMENT: This is not an entitlement. This is an inefficient method of addressing homelessness in California. The only real program that addesses CalWORK Child & Family Homelessness of the Homeless Assistance Program that is an entitlement. Effective Date- This section is effective immediately. SEC. 22. Section 10618.8 is added to the Welfare and Institutions Code, to read: 10618.8. (a) Utilizing no more than ten million five hundred thousand dollars ($10,500,000) of the one-time funds appropriated in the Budget Act of 2021 for the purposes of the CalWORKs Housing Support Program (Article 3.3 (commencing with Section 11330.5) of Chapter 2 of Part 3), the Home Safe Program (Chapter 14 (commencing with Section 15770) of Part 3), the Bringing Families Home Program (Article 6 (commencing with Section 16523) of Chapter 5 of Part 4), and the Housing and Disability Advocacy Program (Chapter 17 (commencing with Section 18999) of Part 6), the department may contract with one or more vendors for the purpose of establishing a system to collect data and track outcomes, and may, in consultation with the Legislature, the County Welfare Directors Association of California, advocates for clients, and housing and homelessness stakeholders, contract with one or more independent evaluation and research agencies to evaluate the impacts of each of these programs, which may include, but are not limited to all of the following: (1) Outcomes for recipients, including achievement of housing stability. (2) Demographic information about recipients. (3) The likelihood of future homelessness and housing instability among recipients. (4) Program costs and benefits. (b) Program evaluation efforts described in subdivision (a) shall compliment evaluation efforts specified in subdivision (g) of Section 15771. (c) Utilizing no more than ten million five hundred thousand dollars ($10,500,000) of the one-time funds appropriated in the Budget Act of 2021 for the purposes of the CalWORKs Housing Support Program (Article 3.3 (commencing with Section 11330.5) of Chapter 2 of Part 3), the Home Safe Program (Chapter 14 (commencing with Section 15770) of Part 3), the Bringing Families Home Program (Article 6 (commencing with Section 16523) of Chapter 5 of Part 4), and the Housing and Disability Advocacy Program (Chapter 17 (commencing with Section 18999) of Part 6), the department may, in consultation with the Legislature, County Welfare Directors Association of California, advocates for clients, and housing and homelessness stakeholders, contract with one or more entities to provide technical assistance for each of these programs, which may include, but is not limited to all of the following: (1) Implementing and administering programs that incorporate evidence-based and emerging promising practices in homeless assistance and homelessness prevention that support the advancement of racial equity. (2) Scaling housing navigation and location services. (3) Coordination and integration between the social services department, homelessness system of care, and health systems. (4) Streamlining administrative efficiencies. (5) Data collection and reporting, outcomes monitoring, and continuous quality improvement. (d) The department shall report annually to the Legislature on contracts and expenditures made, data collected, and evaluations performed pursuant to this section, by February 1 of each year. (e) For purposes of implementing this section, contracts entered into or amended shall be exempt from all of the following: (1) Chapter 6 (commencing with Section 14825) of Part 5.5 of Division 3 of Title 2 of the Government Code. (2) The personal services contracting requirements of Article 4 (commencing with Section 19130) of Chapter 5 of Part 2 of Division 5 of Title 2 of the Government Code. (3) Part 2 (commencing with Section 10100) of Division 2 of the Public Contract Code and the State Contracting Manual. (4) Notwithstanding Section 11546 of the Government Code, from review or approval of any division of the Department of Technology, upon approval from the Department of Finance. (5) From the review or approval of any division of the Department of General Services. Section 23. Development of a global telephonic signature for social services programs. Authorizes the development of a global telephonic signature solution to enhance the ability for county human services customers and staff to complete transactions by telephone. RECIPIENT IMPACT STATEMENT: It is time that the CalWORKs program is brought into the 21st century. Effective Date- This section is effective when there is funding for it. Stay tune. SEC. 23. Section 10823.6 is added to the Welfare and Institutions 10823.6. (a) It is the intent of the Legislature that health and human services programs shall leverage telephonic signature technology to enhance the ability for county human services customers and staff to complete transactions by telephone through the creation of a global telephonic signature solution for use by county human services departments, to the extent permitted by program policy. (b) The California Statewide Automated Welfare System (CalSAWS) consortium shall be authorized to develop, deploy, and maintain a simple, standalone telephonic signature solution according to the following requirements: (1) The telephonic signature solution shall allow for storage and retrieval of recorded telephonic signatures in compliance with program policy. (2) This telephonic signature solution shall be available until equivalent functionality has been integrated into the following case manage ment systems: (A) CalSAWS. (B) Case Management Information and Payroll System (CMIPS). (C) California Automated Response and Engagement System (CWS-CARES). (c) This section shall only be implemented to the extent funding is appropriated for these purposes. (d) This section shall be rendered inoperative upon integration of the telephonic signature solution into all statewide systems included in paragraph (2) of subdivision (b) and is repealed as of January 1 of the calendar year following the date of the inoperability. Section 24. Photo ID for CalWORKs Authorizes a CalWORKs applicant or recipient to provide proof of identity via video conferencing or any other electronic means that allows for a visual interaction between the applicant or recipient and county eligibility staff instead of coming into the office to show I.D. RECIPIENT IMPACT STATEMENT: Only CalWORKs requires a photo ID. CalFresh does not require a photo ID. It is comparable to voter photo I.D. requirement which is designed to prevent people of color and the poor from voting. This needless photo I.D. requirement is also designed to discourage families and children in deep poverty from becoming eligible for CalWORKs. Effective Date- This section is effective July 1, 2021. SEC. 24. Section 10831 of the Welfare and Institutions Code is amended to read: 10831. (a) The department shall implement and maintain nonbiometric identity verification methods in the CalWORKs program. The methods approved by the department as of July 1, 2018, satisfy this requirement. (b)This section shall become operative on July 1, 2020. (b) Notwithstanding subdivision (a), commencing July 1, 2021, for purposes of identity verification, a CalWORKs applicant or recipient may provide proof of identity via videoconferencing or any other electronic means that allows for a visual interaction between the applicant or recipient and county eligibility staff. Verification conducted in this manner shall satisfy any in person identification requirement. Section 27- CalWORKs Overpayment Classified as non-fraudulent A nonfraudulent CalWORKs overpayment established on or after August 1, 2021 for the benefit months of April 2020 to the end of the COVID 19-Pandemic proclamation of a state of emergency or June 30, 2022, whichever date is sooner, be classified as an administrative error. RECIPIENT IMPACT STATEMENT: This is great, but nonfraudulent is not objectively defined. The implementing rule should define what constitutes nonfraudulent clearly. Effective Date- This section is effective whenever it is automated. SEC. 27. Section 11004 is added to the Welfare and Institutions Code, to read: 11004. The provisions of this code relative to public social services for which state grants-in-aid are made to the counties shall be administered fairly to the end that all persons who are eligible and apply for those public social services shall receive the assistance to which they are entitled promptly, with due consideration for the needs of applicants and the safeguarding of public funds. (a) Any applicant for, or recipient or payee of, those public social services shall be informed as to the provisions of eligibility and the responsibility to report facts material to a correct determination of eligibility and grant. (b) Any applicant for, or recipient or payee of, those public social services shall be responsible for reporting accurately and completely within the applicant’s, recipient’s, or payee’s competence those facts required pursuant to subdivision (a) and to promptly report any changes in those facts. (c) Current and future grants payable to an assistance unit may be reduced because of prior overpayments. In cases in which the overpayment was caused by agency error, grant payments shall be reduced by 5 percent of the maximum aid payment of the assistance unit. Grant payments to be adjusted because of prior overpayments because of any other reason shall be reduced by 10 percent of the maximum aid payments for the assistance unit. A recipient may have an overpayment adjustment in excess of the amounts allowable under this section if the recipient requests it. (d) A determination of ineligibility shall not be made retrospectively so as to result in an assessment of an overpayment when there is a failure on the part of an applicant or recipient to perform an act constituting a condition of eligibility, if the failure is caused by an error made by a state agency or a county welfare department, and if the amount of the grant received by the applicant or recipient would not have been different had the act been performed. (e) Prior to effectuating any reduction of current grants to recover past overpayments, the recipient shall be advised of the proposed reduction and of the recipient’s entitlement to a hearing on the propriety of the reduction. (f) If the department determines after a hearing that an overpayment has occurred, the county providing the public social services shall seek to recover the overpayment in accordance with subdivision (c), including any amount paid while the hearing process was pending. That adjustment shall be permitted concurrently with any suit for restitution, and recovery of overpayment by adjustment shall reduce by the amount of such recovery the extent of liability for restitution. (g) (1) (A) If the individual responsible for an overpayment is no longer receiving aid under Chapter 2 (commencing with Section 11200), recovery of overpayments received under that chapter shall not be attempted when the outstanding overpayments are less than two hundred fifty dollars ($250). When an overpayment collection is attempted, reasonable cost-effective efforts at collection shall be implemented. Reasonable efforts shall include notification of the amount of the overpayment and that repayment is required. The department shall define reasonable cost-effective collection methods. In cases involving fraud, every effort shall be made to collect the overpayments regardless of the amount. (B) The department may establish a threshold higher than two hundred fifty dollars ($250) if it determines that a higher threshold is more cost effective, but the department shall not set a lower threshold than that amount. (2) Notwithstanding subdivision (c), a county shall discharge an overpayment if the county determines that the overpayment has been caused by a major systemic error or negligence, as those terms are defined by the department. (3) (A) Except in cases involving overpayments due to fraud, a county shall only establish an overpayment if the overpayment occurred within 24 months prior to the date that the county discovered the overpayment. (B) A county shall not collect any portion of a nonfraudulent overpayment that occurred more than 24 months prior to the date the county discovered an overpayment. (h) If the individual responsible for the overpayment to the assistance unit becomes a member of another assistance unit, recovery of overpayments shall be made against the individual or the individual’s present assistance unit, or both. (i) (1) If an overpayment has been made to an assistance unit that is no longer receiving public social services, recovery shall be made by appropriate action under state law. (2) This paragraph shall be operative when the Statewide Automated Welfare System (SAWS) can automate its provisions. Except in cases involving overpayments due to fraud or an investigation into suspected fraud, if the individual responsible for the overpayment has not received aid under Chapter 2 (commencing with Section 11200) for 36 consecutive months or longer, the county shall deem an overpayment uncollectible and discharge, in accordance with existing discharge procedures, an overpayment received under that chapter. (j) A civil or criminal action shall not be commenced against any person based on alleged unlawful application for or receipt of public social services if the case record, or any consumer credit report used in the civil or criminal case of that person for the purpose of determining that the overpayment, has not been made available to that person or has been destroyed after the expiration of the three-year retention period pursuant to Section 10851. (k) (1) When an underpayment or denial of public social services occurs and, as a result, the applicant or recipient does not receive the amount to which the applicant or recipient is entitled, the county shall provide public social services equal to the full amount of the underpayment unless prohibited by federal law. In cases that have both an underpayment and an overpayment, the underpayment shall be offset against the overpayment prior to correcting any remaining underpayment. (2) Any corrective payments made pursuant to this subdivision shall be disregarded in determining the income of the family and shall be disregarded in determining the resources of the family in the month the corrective payment is made and in the following month. (l) This subdivision is applicable only to applicants, recipients, and payees under Chapter 2 (commencing with Section 11200) of Part 3 of Division 9. Any suits to recover overpayments described in subdivision (f) shall be brought on behalf of the county by the county counsel unless the board of supervisors delegates that duty to the district attorney by ordinance or resolution. (m) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement and administer this section through all-county letters or similar instruction that shall have the same force and effect as regulations until regulations are adopted. (n) The department shall adopt emergency regulations implementing this section no later than January 1, 2023. The department may readopt any emergency regulation authorized by this section that is the same as, or substantially equivalent to, any emergency regulation previously adopted pursuant to this section. The initial adoption of regulations pursuant to this section and one readoption of emergency regulations shall be deemed to be an emergency and necessary for the immediate preservation of the public peace, health, safety, or general welfare. Initial emergency regulations and one readoption of emergency regulations authorized by this section shall be exempt from review by the Office of Administrative Law. The initial emergency regulations and the one readoption of emergency regulations authorized by this section shall be submitted to the Office of Administrative Law for filing with the Secretary of State, and each shall remain in effect for no more than 180 days, by which time final regulations shall be adopted. (o) This section shall become operative on July 1, 2022, or on the date the department notifies the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement this section, whichever date is later, except as otherwise specified in paragraph (2) of subdivision (i). Section 28- Prohibits counties from collecting stale nonfraudulent overpayment Prohibits counties from collecting any portion of a nonfraudulent overpayment that occurred more than 24 months prior to the date the county discovered the overpayment. RECIPIENT IMPACT STATEMENT: This is great, but nonfraudulent is not objectively defined. The implementing rule should define what constitutes nonfraudulent clearly. Effective Date- This section is effective August 1, 2021. SEC. 28. Section 11004.1 of the Welfare and Institutions Code is amended to read: 11004.1. (a) In addition to Section 11004, this section shall apply to the CalWORKs program. (b) The amount of any CalWORKs grant overpayment shall be the difference between the grant amount the assistance unit actually received and the grant amount the assistance unit would have received under the semiannual reporting, prospective budgeting system if no a county error had not occurred and if the recipient had timely, completely, and accurately reported reported, as required under Sections 11265.1 and 11265.3. No An overpayment shall not be established based on any differences between the amount of income the county prospectively determined for the recipient for the semiannual reporting period and the income the recipient actually received during that period, provided the recipient’s report was complete and accurate. (c) No A CalWORKs grant underpayment shall not be established based on any differences between the amount of income the county prospectively determined for the recipient for the semiannual reporting period and the income the recipient actually received during that period. (d) (1) This section shall become operative on April 1, 2013. A county shall implement the semiannual reporting requirements in accordance with the act that added this section no later than October 1, 2013. (2) Upon implementation described in paragraph (1), each county shall provide a certificate to the director certifying that semiannual report ing has been implemented in the county. (3) Upon filing the certificate described in paragraph (2), a county shall comply with the semiannual reporting provisions of this section. (e) (1) Commencing August 1, 2021, a nonfraudulent CalWORKs overpayment that is established for a current CalWORKs case on or after that date, shall be classified as an administrative error if any overpaid benefit month or months occurred during the period between April 2020 and the end of the Governor’s proclamation of a state of emergency related to the COVID-19 pandemic, or June 30, 2022, whichever date is sooner. (2) If an overpayment is classified as an administrative error pursuant to paragraph (1), and the overpayment also includes overpaid months before or after the period specified in paragraph (1), the entire overpayment shall be classified as an administrative error. (3) An overpayment classified as an administrative error pursuant to this subdivision shall not be reclassified after the state of emergency related to the COVID-19 pandemic ends, but shall remain an administrative error. Section 29. Transfers $450 million from the General Fund to the Safety Net Reserve Fund. This is a Safety Net Reserve account established with CalWORKs and Medi-Cal subaccount funds. Authorizing statute(s): W&IC section 17601.20. Funds previously deposited into the Mental Health Subaccount are deposited in the CalWORKs MOE Subaccount. Counties are required to pay an increased share of CalWORKs assistance costs up to the amount of funds available in the CalWORKs MOE Subaccount. RECIPIENT IMPACT STATEMENT: This is great, however the budget used over $1 billion of CalWORKs funds as a contribution to the general fund. The $1billion should be placed in 17601.20 account. Effective Date- This section is effective immediately. SEC. 29. Section 11011.2 is added to the Welfare and Institutions Code, to read: 11011.2. For the 2021 22 fiscal year, upon order of the Director of Finance, the Controller shall transfer four hundred fifty million dollars ($450,000,000) from the General Fund to the Safety Net Reserve Fund. Section 30- Oral signature Gives individuals the option to complete an application or recertification interview and provide the required client signature orally if the county is not able to accept telephone signature and the beneficiary cannot come into the office. RECIPIENT IMPACT STATEMENT: This is does not hurt anybody, but it is not environmentally friendly .Why should a CalWORKs applicant or beneficiary leave a large carbon print when it can be electronically in the 21st century? 21st century technological innovations should be utilized not only to combat climate change but reduce CalWORKs applicants and beneficiaries the need to drive to the welfare department when the activity can be accomplished done electronically. Effective Date- This section is effective July 1, 2022. SEC. 30. Section 11054 of the Welfare and Institutions Code is amended to read: 11054. Each 11054. (a) (1) Each applicant shall be required before approval of assistance or services to file an affirmation setting forth his the applicant’s belief that he the applicant meets the specific conditions of eligibility. Such statements shall be on forms prescribed by the department and, in the case of applicants for aid to families with dependent children, shall contain a written declaration that the affirmation is made under penalty of perjury. Any person signing a statement containing such declaration, who willfully and knowingly with intent to deceive states as true any material matter which he that the person knows to be false, is subject to the penalty prescribed for perjury in the Penal Code. Whenever (2) Whenever the applicant himself is incapable of completing the required affirmation, and no affirmation required pursuant to paragraph (1), and a guardian or conservator of his the applicant’s estate has not been appointed, the affirmation may be completed on his the applicant’s behalf by a relative or close personal friend or a representative of a public agency who has all necessary knowledge regarding the applicant’s circumstances and is willing to affirm thereto. A copy of the affirmation shall be furnished to the applicant or other person completing it at the time it is filed. Such The other person completing an affirmation who willfully and knowingly with intent to deceive states as true any material matter which he that the person knows to be false is subject to the penalty prescribed for perjury in the Penal Code. A (3) A county department may also require like statements to be completed prior to before approving restoration of aid as provided by Section 11051, and may require new statements at any time for purposes of continuing assistance. (b) On and after July 1, 2021, an applicant may complete the affirmation described in subdivision (a) by means of an oral attestation in lieu of a written declaration if the applicant is unable to provide a physical signature or the county human services agency is unable to accept an electronic signature. Except for benefits issued pursuant to subparagraph (A) of paragraph (2) of subdivision (f) of Section 11450, the applicant shall submit a physical signature within 30 working days following an oral attestation for benefits to continue. (c) Subdivision (b) shall remain operative until the California Statewide Automated Welfare System consortium has implemented an integrated telephonic signature solution. Upon implementation of a telephonic signature solution, the affirmation described in subdivision (a) may be satisfied by use of a telephonic signature. Section 32. Potentially a six (6) months continuation of CalWORKs for parents whose children removed from the home by CPS. Allows CalWORKs families who have children in foster care to receive monthly cash assistance for up to six months while reunification efforts are ongoing. RECIPIENT IMPACT STATEMENT: Some parents may benefit from this provision. Most reunification plans are 18 months, and the idea is to make sure the parent is able to reunify and keep the house for the kids when they come back. Limiting the grants to parents only will reduce the probability of a successful reunification and the break-up of the family, which is anti-family. Effective Date- This section is effective July 1,2022 SEC. 32. Section 11203 is added to the Welfare and Institutions Code, to read: 11203. (a) During those times as the federal government provides funds for the care of a needy relative with whom a needy child or needy children are living, aid to the child or children for any month includes aid to meet the needs of that relative, if money payments are made with respect to the child or children for that month, and if the relative is not receiving aid under Chapter 3 (commencing with Section 12000) or 5.1 (commencing with Section 13000) of this part or Part A of Title XVI of the Social Security Act for that month. Needy relatives under this chapter include only natural or adoptive parents, the spouse of a natural or adoptive parent, and other needy caretaker relatives. (b) The parent or parents shall be considered living with the needy child or needy children for a period of up to six months, or for a time period as determined by the department, of the needy child’s or children’s absence from the family assistance unit, and the parent or parents shall be eligible for aid as specified in subdivision (a) of Section 11450 and childcare services under Article 15.5 (commencing with Section 8350) of Chapter 2 of Part 6 of Division 1 of Title 1 of the Education Code, as that article read on May 1, 2021, as well as services under this chapter, including services funded under Sections 15204.2 and 15204.8, and the special needs benefit specified in clause (i) of subparagraph (A) of paragraph (3) of subdivision (f) of Section 11450, if all of the following conditions are met: (1) The child has been removed from the parent or parents and placed in out-of-home care. (2) When the child was removed from the parent or parents, the family was receiving aid under this section. (3) The county has determined that the provision of aid as specified in subdivision (a) of Section 11450 or the provision of childcare services under Article 15.5 (commencing with Section 8350) of Chapter 2 of Part 6 of Division 1 of Title 1 of the Education Code, as that article read on May 1, 2021, or the provision of services under this chapter, including services funded under Sections 15204.2 and 15204.8, and the special needs benefit specified in clause (i) of subparagraph (A) of paragraph (3) of subdivision (f) of Section 11450, is necessary for reunification (c) The department shall revise its state Temporary Assistance for Needy Families plan to incorporate the provisions of subdivision (b) and to incorporate the good cause exception provisions the department deems necessary as authorized by Section 608(a)(10)(B) of Title 42 of the United States Code. (d) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement and administer this section through all-county letters or similar instruction that shall have the same force and effect as regulations until regulations are adopted. (e) This section shall become operative on July 1, 2022. Prior to this date, the department shall issue comprehensive policy, fiscal, and claiming instructions to the counties. The department shall notify the Legislature when the Statewide Automated Welfare System has automated this section. Section 33. County option to provide assistance to families who are about to be homeless not an entitlement Authorizes the use of funds to provide CalWORKs housing supports used to provide housing supports to CalWORKs recipients who are at risk of homelessness and for whom housing instability would be a barrier to self- sufficiency or child well-being. RECIPIENT IMPACT STATEMENT: A liberal application of this provision would be beneficial to many families. Effective Date- This section is effective immediately. SEC. 33. Section 11330.5 of the Welfare and Institutions Code is amended to read: 11330.5. (a) The department shall award funds in accordance with subdivision (e) to counties for the purpose of providing CalWORKs housing supports to CalWORKs recipients who are experiencing homelessness or at risk of homelessness, including recipients who have not yet received an eviction notice, and for whom housing instability that would be a barrier to self-sufficiency or child well-being. (b) Notwithstanding subdivision (a), this section does not create an entitlement to housing supports, which are intended to be a service to CalWORKs families and not a form of assistance, to be provided to families at the discretion of the county. (c) It is the intent of the Legislature that housing supports provided pursuant to this article utilize evidence-based models, including those established in the federal Department of Housing and Urban Development’s Homeless Prevention and Rapid Re-Housing Program. Supports provided may include, but shall not be limited to, all of the following: (1) Financial assistance, including rental assistance, security deposits, utility payments, moving cost assistance, and motel and hotel vouchers. (2) Housing stabilization and relocation, including outreach and engagement, landlord recruitment, case management, housing search and placement, legal services, and credit repair. (d) The asset limit threshold specified in subdivision (f) of Section 11450 shall not be used to determine a family’s eligibility for receipt of housing supports provided pursuant to this article. (e) Funds appropriated for purposes of this article shall be awarded to participating counties by the State Department of Social Services according to criteria developed by the department in consultation with the County Welfare Directors Association and Housing California. (f) The department, in consultation with the County Welfare Directors Association and Housing California and other stakeholders, shall develop each of the following: (1) The criteria by which counties may be awarded funds to provide housing supports to eligible CalWORKs recipients pursuant to this article. (2) The proportion of funding to be expended on reasonable and appropriate administrative activities to minimize overhead and maximize services. (3) Tracking and reporting procedures. (g) The department, in consultation with appropriate legislative staff and the County Welfare Directors Association, shall determine, in a manner that reflects the legislative intent for the use of these funds and that is most beneficial to the overall CalWORKs program, whether housing supports provided with this funding are considered to be assistance or nonassistance payments. (h) Counties may continue to provide housing supports under this section to a recipient who is discontinued because he or she the recipient no longer meets the income eligibility requirements of Section 11450.12. (i) (1) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement and administer the changes made to this section by the act that added this subdivision by means of all-county letters or similar instructions from the department that shall have the same force and effect as regulations until regulations are adopted. (2) The department shall adopt regulations implementing the changes specified in paragraph (1) no later than July 1, 2024. Section 36. Pregnant mom reform of 2021 This section increases the supplemental aid payment made to pregnantCalWORKs recipients from $47 a month to $100 a month. This payment discontinues at the end of the following month after the end of the pregnancy is reported to the county. This section empowers a pregnant parent to attest that she is pregnant and be entitled to pregnancy benefits without medical verification. The parent would have to provide medical verification of pregnancy within 30 days unless the baby is already born. This section becomes operative when the Department of Social Services certifies that the California Statewide Automated Welfare System can perform the necessary automation. RECIPIENT IMPACT STATEMENT: This is a major improvement in the CalWORKs program. The $47 special need has been in law since 1984 but pregnant women were forced to wait until their second trimester before they were eligible for CalWORKs benefits. Effective Date- This section is effective May 1, 2022 or whenever CDSS tells the Legislature that CalSAWS has been programmed to implement this section. ADVOCATE CONCERN: We do not believe that automation is necessary to issue pregnancy benefits from the date of application and accept a 30-day attestation of pregnancy. SEC. 36. Section 11450 of the Welfare and Institutions Code, as added by Section 2 of Chapter 152 of the Statutes of 2020, is amended to read: 11450. (a) (1) (A) \u2002 Aid shall be paid for each needy family, which shall include all eligible brothers and sisters of each eligible applicant or recipient child and the parents of the children, but shall not include unborn children, or recipients of aid under Chapter 3 (commencing with Section 12000), qualified for aid under this chapter. In determining the amount of aid paid, and notwithstanding the minimum basic standards of adequate care specified in Section 11452, the family’s income, exclusive of any amounts considered exempt as income or paid pursuant to subdivision (e) or Section 11453.1, determined for the prospective semiannual period pursuant to Sections 11265.1, 11265.2, and 11265.3, and then calculated pursuant to Section 11451.5, shall be deducted from the sum specified in the following table, as adjusted for cost-of-living increases pursuant to Section 11453 and paragraph (2). In no case shall the amount of aid paid for each month exceed the sum specified in the following table, as adjusted for cost-of-living increases pursuant to Section 11453 and paragraph (2), plus any special needs, as specified in subdivisions (c), (e), and (f): Number of \u2009eligible needy persons in the same home Maximum aid 1 …………………… $ \u2009326 2 …………………… \u2009535 3 …………………… \u2009663 4 …………………… \u2009788 5 …………………… \u2009899 6 …………………… 1,010 7 …………………… 1,109 8 …………………… 1,209 9 …………………… 1,306 10 or more …………………… 1,403 (B) If, when, and during those times that the United States government increases or decreases its contributions in assistance of needy children in this state above or below the amount paid on July 1, 1972, the amounts specified in the above table shall be increased or decreased by an amount equal to that increase or decrease by the United States government, provided that no increase or decrease shall be subject to subsequent adjustment pursuant to Section 11453. (2) The sums specified in paragraph (1) shall not be adjusted for cost of living for the 1990 91, 1991 92, 1992 93, 1993 94, 1994 95, 1995 96, 1996 97, and 1997 98 fiscal years, and through October 31, 1998, nor shall that amount be included in the base for calculating any cost-of-living increases for any fiscal year thereafter. Elimination of the cost-of-living adjustment pursuant to this paragraph shall satisfy the requirements of former Section 11453.05, and no further reduction shall be made pursuant to that section. (b) (1) If (A) Until the date that paragraph (2) is effective, if the family does not include a needy child qualified for aid under this chapter, aid shall be paid to a pregnant child who is 18 years of age or younger at any time after verification of pregnancy, in the amount that would otherwise be paid to one person, as specified in subdivision (a), if the pregnant child and the child, if born, would have qualified for aid under this chapter. Verification of pregnancy shall be required as a condition of eligibility for aid under this subdivision. paragraph. (2) (B) Notwithstanding paragraph (1), subparagraph (A), and until the date that paragraph (2) is effective, if the family does not include a needy child qualified for aid under this chapter, aid shall be paid to a pregnant person for the month in which the birth is anticipated and for the six-month period immediately prior to the month in which the birth is anticipated, in the amount that would otherwise be paid to one person, as specified in subdivision (a), if the pregnant person and child, if born, would have qualified for aid under this chapter. Verification of pregnancy is required as a condition of eligibility for aid under this subdivision. paragraph. (3)Paragraph (1) (C) Subparagraph (A) shall apply only when the Cal-Learn Program is operative. (2) (A) Notwithstanding paragraph (1), if the family does not include a needy child qualified for aid under this chapter, aid shall be paid to a pregnant person as of the date of the application for aid, in the amount that would otherwise be paid to one person, as specified in subdivision(a), if the pregnant person or the child, if born, would have qualified for aid under this chapter. Verification of pregnancy shall be required as a condition of eligibility for aid under this paragraph. (B) A pregnant person may provide verification of pregnancy as required in subparagraph (A) by means of a sworn statement or, if necessary, a verbal attestation. Medical verification of pregnancy shall be submitted within 30 working days following submission of the sworn statement or verbal attestation for benefits to continue. If the applicant fails to submit medical verification of pregnancy within 30 working days, the county human services agency shall continue aid when the applicant presents evidence of good-faith efforts to comply with this requirement. (C) (i) A person who receives aid pursuant to this paragraph shall report to the county, orally or in writing, within 30 days following the end of their pregnancy. (ii) Aid for persons under this paragraph shall discontinue at the end of the month following the month in which the person reports the end of their pregnancy to the county human services agency. (iii) Prior to discontinuing aid for a person under this paragraph due to the end of their pregnancy, the county human services agency shall provide information about, and referral to, mental health services, including, but not limited to, services provided by the county human services agency, when appropriate. (D) This paragraph shall take effect on July 1, 2022, or on the date that the department notifies the Legislature that the California Statewide Automated Welfare System can perform the necessary automation to implement this paragraph, whichever date is later. (c) (1) The amount of forty-seven dollars ($47) per month shall be paid to a pregnant person qualified for aid under subdivision (a) or (b) to meet the special needs resulting from pregnancy if the pregnant person and child, if born, would have qualified for aid under this chapter. County welfare departments shall refer all recipients of aid under this subdivision to a local provider of the California Special Supplemental Nutrition Program for Women, Infants, and Children. If that payment to a pregnant person qualified for aid under subdivision (a) is considered income under federal law in the first five months of pregnancy, payments under this subdivision do not apply to a person eligible under subdivision (a), except for the month in which birth is anticipated and for the three-month period immediately prior to the month in which delivery is anticipated, if the pregnant person and child, if born, would have qualified for aid under this chapter. (2) Beginning May 1, 2022, or on the date that the department notifies the Legislature that the California Statewide Automated Welfare System can perform the necessary automation to implement this paragraph, the special needs payment described in paragraph (1) shall be one hundred dollars ($100) per month. (3) Beginning July 1, 2022, or on the date that the department notifies the Legislature that the California Statewide Automated Welfare System can perform the necessary automation to implement this paragraph, the special needs payment described in this subdivision shall discontinue at the end of the month following the month in which a person reports the end of their pregnancy to the county human services agency. Section 37. CalWORKs 5.3% grant increase. . This section increases the maximum aid payments by 5.3 percent, beginning October 1, 2021. RECIPIENT IMPACT STATEMENT: This is a great improvement of the CalWORKs program. The average CalWORKs grant for a family is three (3) would still be less than 50% of the federal poverty level. The CalWORKs grants should be equal to 100% of the federal poverty level. It should be noted that only 33% of the CalWORKs families receive aid for all person in the family. Over 65% receive aid for one or more less persons due to WtW sanctions, parent(s) being timed out or excluded from the assistance unit. Effective Date- October 1, 2021. SEC. 37. Section 11450.025 of the Welfare and Institutions Code is amended to read: 11450.025. (a) (1) Notwithstanding any other law, effective on March 1, 2014, the maximum aid payments in effect on July 1, 2012, as specified in subdivision (b) of Section 11450.02, shall be increased by 5 percent. (2) Effective April 1, 2015, the maximum aid payments in effect on July 1, 2014, as specified in paragraph (1), shall be increased by 5 percent. (3) Effective October 1, 2016, the maximum aid payments in effect on July 1, 2016, as specified in paragraph (2), shall be increased by 1.43 percent. (4) (A) Effective January 1, 2017, households eligible for aid under this chapter shall receive an increased aid payment consistent with the repeal of former Section 11450.04, as it read on January 1, 2016, known as the maximum family grant rule. (B) In recognition of the increased cost of aid payments resulting from that repeal, moneys deposited into the Child Poverty and Family Supplemental Support Subaccount shall be allocated to counties pursuant to Section 17601.50 as follows: (i) One hundred seven million forty-seven thousand dollars ($107,047,000) for January 1, 2017, to June 30, 2017, inclusive. (ii) Two hundred twenty-three million four hundred fifty-four thousand dollars ($223,454,000) for the 2017 18 fiscal year and for every fiscal year thereafter. (5) Effective October 1, 2021, the maximum aid payments in effect on July 1, 2021, as specified in paragraph (3), shall be increased by 5.3 percent. Section 39. Increasing earned income disregards for CalWORKs applicants This section increases the amount of earned income that is disregarded for families applying to the program from $90 to $450. Also states the Legislature’s intent to eventually reach alignment between applicants and recipients of the amount of earned income that is disregarded. RECIPIENT IMPACT STATEMENT: This is a great improvement of the CalWORKs program. Since 1998, the standard deduction for applicants to qualify for CalWORKs has been set to $90. There are still two (2) different earned income disregards for applicants and recipients. This section goes half-way to equalizing, but there is still work to be done to achieve total equalization or simplification. Effective Date- July 1, 2022 SEC. 39. Section 11450.12 is added to the Welfare and Institutions Code, to read: 11450.12. (a) (1) An applicant family shall not be eligible for aid under this chapter unless the family’s income, exclusive of the first four hundred fifty dollars ($450) of earned income for each employed person, is less than the minimum basic standard of adequate care, as specified in Section 11452. (2) If there are subsequent changes to the income exemption as specified in subdivision (c) of Section 11451.5, the earned income exemption amount specified in this section shall be changed by an equal amount. (b) A recipient family shall not be eligible for further aid under this chapter if reasonably anticipated income, less exempt income, determined for the semiannual period pursuant to Sections 11265.1, 11265.2, and 11265.3, and exclusive of amounts exempt under Section 11451.5, equals or exceeds the maximum aid payment specified in Section 11450. (c) This section shall become operative on July 1, 2022. SEC. 40. It is the intent of the Legislature that full alignment eventually be achieved between applicants and recipients in the CalWORKs program in the amount of earned income that is disregarded for eligibility determination. Section 41. Automatic 12-month extension without the need to file an application This section would automate a one-time process that allows former CalWORKs recipients excluded due to the formerly applicable 48-month time limit, but who have fewer than 60 countable months of time on aid in CalWORKs, to be added to an existing assistance unit if all information needed to complete an eligibility determination is in the case record and all other eligibility requirements have been met. RECIPIENT IMPACT STATEMENT: This would simplify the extension of the 12 months both for the beneficiaries and the county workers. Effective Date- May 1, 2022 or whenever CalSAWS automation is done, whichever is later. SEC. 41. Section 11454 of the Welfare and Institutions Code, as added by Section 61 of Chapter 11 of the Statutes of 2020, is amended to read: 11454. (a) A parent or caretaker relative shall not be eligible for aid under this chapter when the parent or caretaker relative has received aid under this chapter or from any state under the Temporary Assistance for Needy Families program (Part A (commencing with Section 401) of Title IV of the federal Social Security Act (42 U.S.C. Sec. 601 et seq.)) for a cumulative total of 60 months. (b) (1) Except as otherwise specified in subdivision (c), Section 11454.5, or other law, all months of aid received under this chapter from January 1, 1998, to the operative date of this section, inclusive, shall be applied to the 60-month time limit described in subdivision (a). (2) All months of aid received from January 1, 1998, to the operative date of this section, inclusive, in any state pursuant to the Temporary Assistance for Needy Families program (Part A (commencing with Section 401) of Title IV of the federal Social Security Act (42 U.S.C. Sec. 601 et seq.)), shall be applied to the 60-month time limit described in subdivision (a). (c) Subdivision (a) and paragraph (1) of subdivision (b) shall not be applicable when all parents or caretaker relatives of the aided child who are living in the home of the child meet any of the following requirements: (1) They are 60 years of age or older. (2) They meet one of the conditions specified in paragraph (4) or (5) of subdivision (b) of Section 11320.3. (3) They are not included in the assistance unit. (4) They are receiving benefits under Section 12200 or 12300, State Disability Insurance benefits or Workers’ Compensation Temporary Disability Insurance, if the disability significantly impairs the recipient’s ability to be regularly employed or participate in welfare-to-work activities. (5) They are incapable of maintaining employment or participating in welfare-to-work activities, as determined by the county, based on the assessment of the individual and the individual has a history of participation and full cooperation in welfare-to-work activities. (d) (1) Notwithstanding any other statute, regulation, or other state requirement, the department shall automate a one-time process that allows former CalWORKs recipients excluded from an existing assistance unit due to the formerly applicable 48-month time limit, but who have fewer than 60 countable months of time on aid in CalWORKs, to be added to the existing assistance unit if all information needed to complete an eligibility determination is in the case record and all other eligibility requirements have been met. (2) (A) Notwithstanding any other statute, regulation, or other state requirement, the county shall not require a former CalWORKs recipient excluded from an existing assistance unit due to the formerly applicable 48-month time limit to complete and submit CalWORKs forms CW 8, CW 8A, CW 2.1NA, or CW 2.1Q in order to add the former recipient to the existing assistance unit pursuant to paragraph (1). (B) A CalWORKs recipient added to an existing assistance unit pursuant to paragraph (1) shall complete and submit to the county Cal WORKs forms CW 2.1NA and CW 2.1Q pertaining to child support within 60 days of being added to the assistance unit, or by the next scheduled semiannual report or annual redetermination, whichever is earlier. (3) This subdivision shall only remain operative for 120 days from the date of the operation of this section pursuant to subdivision (e). (d) (e) This section shall become operative on May 1, 2022, or when the department notifies the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement this section, whichever date is later. Section 42. CalOAR and CalWORKs 2.0 -Requires the Department of Social Services to convene and facilitate a CalWORKs Outcomes and Accountability Review (Cal-OAR) steering committee to make recommendations on how to implement Cal-OAR and CalWORKs 2.0 principles and practices statewide. RECIPIENT IMPACT STATEMENT: CalWORKs 2.0 or CalOAR is not going to produce much equity or program improvements. Counties that have implemented CalWORKs 2.0 still have high sanction rates. It is hoped that the data produced by CalOAR can identify equity concerns that can be addressed by CDSS the single state agency for the CalFresh and CalWORKs programs. Effective Date- Immediately SEC. 42. Section 11523.4 is added to the Welfare and Institutions Code, to read: 11523.4. (a) The Legislature finds and declares all of the following: (1) The Legislature has taken numerous steps in recent years to improve the CalWORKs program for the families who rely on it. These changes have moved California towards a more modern and compassionate approach to alleviating family poverty, and are grounded in awareness of the social determinants of health, adverse childhood experiences, and the neurotoxicity and trauma of intergenerational poverty. (2) County human services departments have led a redesign of the welfare-to-work program, known as CalWORKs 2.0, over the past five years. CalWORKs 2.0 is based on input gathered from program participants, employment services staff, and other stakeholders, as well as recent behavioral science research. The redesigned approach to welfare-to-work engagement focuses on mutual engagement between county staff and clients, that helps families set and achieve personalized goals directly relevant to their lives. This approach requires more individualized case management, tailored to families’ and individuals’ needs and strengths. (3) The Legislature adopted a new CalWORKs Outcome and Accountability Review (Cal-OAR) system in 2017. Cal-OAR establishes a locally focused, data-driven program management system that facilitates continuous improvement of county CalWORKs programs by collecting, analyzing, and disseminating outcomes and best practices. Cal-OAR has the potential to transform the CalWORKs program from one which focuses on work participation as the primary measure of success to one which measures a wide variety of real-life, participant-centered outcomes. (4) The COVID-19 pandemic and the disproportionate health and economic impacts of the pandemic on low-income persons, exacerbated within communities of color, make it even more clear how urgent and necessary implementation of CalWORKs 2.0 and Cal-OAR principles are in helping impoverished families and people of color, who are disproportionately represented in the program. (5) Cal-OAR implementation efforts were delayed due to the COVID-19 pandemic, and the state is now entering a phase that will allow reengagement in employment services activities as well as a renewed focus on the CalWORKs 2.0 and Cal-OAR structures. (b) It is the intent of the Legislature that all of the following are accomplished: (1) To restart robust conversations around CalWORKs 2.0 and Cal-OAR and set an implementation timeline, including consideration of recommendations made in February 2020 by a legislatively mandated Cal-OAR workgroup. This effort should include development of training and resources for county CalWORKs staff in order to implement the necessary culture change within CalWORKs. (2) To assist counties in developing and implementing training and resources for county CalWORKs staff, to reflect the racial, ethnic and cultural diversity of our families and communities in California and to promote equity and inclusion in CalWORKs policy and practice. Understanding and building on the steps counties have already taken in this regard is important to further building on that work statewide. (3) To further the implementation of CalWORKs 2.0 and Cal-OAR statewide, it is the intent of the Legislature that the following steps will occur: (A) Funding for intensive case management. (B) Development of resources and training to assist counties in implementing program changes. (C) Development of trauma-informed, anti-racist, and anti-stigma training for CalWORKs staff geared towards child and family well- being. (c) It is the intent of the Legislature to consider approaches to the state’s management of the federal work participation rate to diminish its negating effects on the intentional culture and program shift for the CalWORKs program. SEC. 43. Section 11523.5 is added to the Welfare and Institutions Code, to read: 11523.5. (a) The State Department of Social Services shall convene and facilitate a Cal-OAR implementation steering committee (steering committee) no later than November 1, 2021. The steering committee shall make recommendations to the Legislature on how to implement Cal-OAR and CalWORKs 2.0 principles and practices statewide, and prioritize recommendations made by the Cal-OAR stakeholder group, by April 1, 2022. As part of the recommendations required pursuant to this subdivision, the steering committee shall provide its recommendations, including any recommendations for statutory amendments, and the reasons for these recommendations. (b) The Cal-OAR implementation steering committee shall consist of representatives from the following organizations and stakeholders: (1) The State Department of Social Services. (2) The County Welfare Directors Association and its member county human services agencies. (3) The exclusive representative of county CalWORKs staff. (4) The Western Center on Law and Poverty. (5) Parent Voices. (6) Legislative staff. (c) The steering committee may consult with other individuals, organizations, and entities as deemed appropriate for the purposes of implementing CalWORKs 2.0 and Cal-OAR. Section 44. Training of County staff relative to trauma-informed, anti-racist, anti-stigma, and implicit bias-aware culture. Requires a statewide CalWORKs training effort acknowledging and addressing the intentional shift to a trauma-informed, anti-racist, anti-stigma, and implicit bias-aware culture and climate in the program, geared towards positive outcomes for child and family health and well-being. Requires the Department of Social Services to enter into one or more contracts to develop this training no later than July 1, 2022 and to share a plan developed with stakeholders with the Legislature by December 1, 2022. RECIPIENT IMPACT STATEMENT: This sounds good and we hope it will improve sometimes the horrible treatment that CalWORKs and CalFresh beneficiaries endure from their welfare workers. What needs to be changed is the culture of public social services system. This will not hurt anybody and it could end up being a positive development depending on the implementation. Effective Date- Subject to appropriations and no later than July 1, 2022. SEC. 44. Section 11523.6 is added to the Welfare and Institutions Code, to read: 11523.6. (a) Subject to an appropriation of funds for this purpose in the annual Budget Act, the State Department of Social Services shall contract for the development of training for county CalWORKs staff. The department shall enter into one or more contracts to develop this training no later than July 1, 2022. (b) The department shall consult with the County Welfare Directors Association of California, the exclusive representatives of county eligibility workers, client advocates, and other stakeholders, as deemed appropriate, in the development of this training. In developing the training, the department shall consider and draw upon, as appropriate, training and other materials already developed or in use by county human services agencies. (c) The training required pursuant to subdivision (a) shall focus on all of the following: (1) Resources to assist counties in implementing CalWORKs 2.0 and Cal-OAR and embedding these approaches into the program. (2) Incorporating and building upon principles from CalWORKs 2.0, and relevant data from the Cal-OAR efforts, taking into account work counties have already accomplished in both areas of training focus. (3) Acknowledging and addressing the intentional shift to a trauma-informed, anti-racist, anti-stigma, and implicit bias-aware culture and climate in the program, geared towards positive outcomes for child and family health and well-being. (4) The impact of implicit bias, explicit bias, and systemic bias on public benefit programs and the effect this can have on individuals seeking eligibility for and services through public benefit programs. (5) Actionable steps individuals can take to recognize and address their own implicit biases. (d) The department shall work with the stakeholders listed in subdivision (b) to develop a plan for disseminating and delivering the training required pursuant to subdivision (a). This plan shall be shared with the Legislature no later than December 1, 2022. The plan shall include all of the following: (1) The types and classifications of county staff who are to be trained and in what order the training of those staff should be prioritized. (2) The entity or entities responsible for providing the training to counties, including consideration of providing direct training as well as train-the-trainer modes of training. (3) The cost of providing the developed training to all identified staff in paragraph (1) in all counties. (4) The proposed timeline for rolling out and implementing training in all counties. (e) (1) Notwithstanding any other law, contracts established pursuant to this section shall be exempt from the personal services contracting requirements of Article 4 (commencing with Section 19130) of Chapter 5 of Part 2 of Division 5 of Title 2 of the Government Code, from the Public Contract Code and the State Contracting Manual, and shall not be subject to the approval of the Department of General Services, including provisions pursuant to Chapter 6 (commencing with Section 14825) of Part 5.5. of Division 3 of the Title 2 of the Government Code. (2) Notwithstanding Section 11546 of the Government Code, contracts established pursuant to this section are exempt from review or approval of any division of the Department of Technology, upon approval from the Department of Finance. Section 45. Exemption of income and resource of payments to CalWORKs beneficiaries for participation in an advisory group This section would exempt any payments issued to CalWORKs beneficiaries for participating in CDSS advisory workgroups. RECIPIENT IMPACT STATEMENT: This would encourage CalWORKs beneficiaries to participate in civic affairs and compensate them for their unvaluable program knowledge to have a more Effective Date- Immediately SEC. 45. Section 11523.7 is added to the Welfare and Institutions Code, to read: 11523.7. Payments, as determined by the State Department of Social Services, made to individuals serving either as individual participants or as a participant on an advisory group created by the State Department of Social Services, or the California Health and Human Services Agency, or through a user testing exercise through a contractor, for the purposes of this article shall not be taken into account as income or resources for purposes of determining the eligibility of that individual, or any other individual, for benefits or assistance, or the amount or extent of benefits or assistance, under any state or local program. Section 46. SSI Grant Increase Directs SSP grants for both individuals and couples to be increased by a percentage that can be accomplished with $29.3 million, beginning January 1, 2022. Requires notification to the Legislature of the final percentage increase effected by the appropriation in the 2021 Budget Act. This section is expected to provide a $36 grant increase for SSI beneficiaries of California. RECIPIENT IMPACT STATEMENT: This is a major achievement for SSI beneficiaries. Effective Date- January 1, 2022 SEC. 46. Section 12201.06 of the Welfare and Institutions Code is amended to read: 12201.06. (a) Commencing January 1, 2017, the amount of aid paid pursuant to this article, in effect on December 31, 2016, less the federal benefit portion received under Part A of Title XVI of the federal Social Security Act, shall be increased by 2.76 percent. (b) (1) Commencing January 1, 2022, the amount of aid paid pursuant to this article, in effect on December 31, 2021, less the federal benefit portion received under Part A of Title XVI of the federal Social Security Act, shall be increased by a percent increase, as determined by the State Department of Social Services and the Department of Finance that can be accomplished with two hundred ninety-one million two hundred and eighty-seven thousand dollars ($291,287,000). (2) The State Department of Social Services and the Department of Finance shall provide a notice to the Assembly and Senate Health and Human Services budget subcommittees, Assembly and Senate Human Services policy committees, and the Legislative Analyst’s Office of the final percent increase effectuated by the appropriation included in the Budget Act of 2021 for the purposes of implementing paragraph (1) 30 days prior to notifying the federal Social Security Administration to operationalize the grant increase in this subdivision. (3) Subject to an appropriation in the Budget Act of 2023, an additional grant increase shall commence January 1, 2024, subject to the same calculations, notifications, and implementation as described in paragraphs (1) and (2). Section 49. Planning an IHSS Provider Back Up System This section requires the Department of Social Services, in consultation with stakeholders, to create and provide to the Legislature, the framework for a permanent provider backup system. RECIPIENT IMPACT STATEMENT: This is a major need for IHSS beneficiaries. Back-up providers is a great idea to protect IHSS beneficiaries from ending up in nursing homes. Effective Date- Immediately SEC. 49. Section 12300.5 is added to the Welfare and Institutions Code, immediately following Section 12300.41, to read: 12300.5. The department, in consultation with stakeholders, shall create, and provide to the Legislature, the framework for a permanent provider backup system. The permanent backup provider system shall not be implemented, and state or federal funds appropriated in the 2021 22 fiscal year or any other fiscal year shall not be used, until statutes are enacted to define the parameters of this service, including, but not limited to, the criteria and circumstances when those services may be approved for a recipient who is authorized to receive in-home supportive services pursuant to this article or Sections 14132.95, 14132.952, or 14132.956, as administered by the department, or waiver personal care services pursuant to Section 14132.97, as administered by the State Department of Health Care Services, or any combination of these services. Section 60- Enhanced Services to Asylees and Vulnerable Noncitizens Establishes the Enhanced Services for Asylees and Vulnerable Noncitizens program to provide for persons granted asylum or who are eligible to receive refugee cash assistance and services as victims of crime. RECIPIENT IMPACT STATEMENT: This is a major achievement for SSI beneficiaries. Effective Date- Whenever there is an appropriation for this purpose. SEC. 60. Chapter 5.9 (commencing with Section 13650) is added to Part 3 of Division 9 of the Welfare and Institutions Code, to read: CHAPTER 5.9. Enhanced Services for Asylees and Vulnerable Noncitizens 13650. (a) The Legislature finds and declares all of the following: (1) Vulnerable noncitizens, asylees, and refugees are important to the fabric of our society. (2) Regardless of their legal distinctions, noncitizens face many of the same challenges integrating into the state and are often living in the same communities. (3) Refugees, asylees, and other noncitizens are granted different services due to the legal distinction of when they were identified, with refugees often being identified in the country of origin and asylees in the country of arrival. (4) Between 2017 and 2019, the number of applicants granted asylum increased from 26,199 applicants to 46,508 applicants, representing a 56-percent increase. In 2019 alone, California was the settlement state for 34 percent of all new asylees, which was the highest rate of all states. (5) Research indicates that while individuals granted asylum in this state are given eligibility to a wide range of benefits, most asylees do not get these benefits due to the lack of case management services and assistance in navigating the social safety net and health care systems. (6) The state-funded Trafficking and Crime Victim Assistance Program (TCVAP) provides critical benefits and services to noncitizen victims of human trafficking, domestic violence, and other serious crimes. TCVAP benefits and services mirror those that are available to refugees after initial resettlement. These vulnerable noncitizens would benefit from initial case management services. (7) Studies show that with proper case management support, noncitizens are better able to secure the benefits for which they are eligible, and find employment and bring immense contributions to the economy. (b) The Enhanced Services for Asylees and Vulnerable Noncitizens (ESAVN) is hereby established to provide resettlement services for persons who are currently residing in California and who are granted asylum by the United States Attorney General or the United States Secretary of Homeland Security pursuant to Section 1158 of Title 8 of the United States Code or who are eligible for assistance and services under Section 13283. (c) For purposes of this chapter, a vulnerable noncitizen is defined as any individual who would be eligible for services under Section 13283. (d) Grants or contracts awarded pursuant to this section shall be executed only with nonprofit organizations that meet the requirements set forth in paragraph (3) or (5) of subsection (c) of Section 501 of the Internal Revenue Code and have at least three years of experience with both of the following: (1) Providing case management services, as defined in subdivision (b) of Section 13651. (2) Providing culturally and linguistically appropriate services. (e) The department shall require qualified nonprofit organizations awarded contracts or grants pursuant to this section to report, monitor, or audit the services provided, as determined by the department. (f) Funds allocated for these services may also be used to conduct a formal evaluation of the services provided by a qualified entity, as determined by the department. 13651. (a) The program shall provide culturally appropriate and responsive case management services for asylees and vulnerable noncitizens for up to 90 days within the first year following the grant of asylum or after having been deemed eligible for services under Section 13283. (b) Case management services under the program shall include assistance in identifying and applying for all benefits to which the person is legally entitled, including cultural orientation and integration programs, support in accessing and navigating the public benefits and health care systems, community connection and relationship building, English language instruction, and employment training, job placement assistance, and professional recredentialing and licensing application assistance. (c) The department shall, in collaboration with service providers, determine outcome metrics to define program success. 13652. Notwithstanding any other law: (a) Contracts or grants awarded pursuant to this chapter shall be exempt from the personal services contracting requirements of Article 4 (commencing with Section 19130) of Chapter 5 of Part 2 of Division 5 of Title 2 of the Government Code. (b) Contracts or grants awarded pursuant to this chapter shall be exempt from the Public Contract Code and the State Contracting Manual, and shall not be subject to the approval of the Department of General Services. (c) The client information and records of legal services provided pursuant to this chapter shall be subject to the requirements of Section 10850 and shall be exempt from inspection under the California Public Records Act (Chapter 3.5 (commencing with Section 6250) of Division 7 of Title 1 of the Government Code). (d) The state shall be immune from any liability resulting from the implementation of this chapter. (e) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement, interpret, or make specific this chapter without taking regulatory action. 13653. The Legislature finds and declares that this chapter is a state law that may provide assistance and services for undocumented persons within the meaning of subsection (d) of Section 1621 of Title 8 of the United States Code. 13654. This chapter shall be implemented only to the extent that funds are appropriated for this purpose in the annual Budget Act. Section 61. Increase in the county single allocation. This section would incrementally increase the number of hours for intensive case management, as specified, and states the Legislature’s intent to increase to 10 hours, as of July 1, 2024, contingent on the 2023 Budget Act. RECIPIENT IMPACT STATEMENT: This is a major achievement for SSI beneficiaries. Effective Date- January 1, 2022 SEC. 61. Section 15204.35 of the Welfare and Institutions Code is amended to read: 15204.35. (a) The State Department of Social Services shall work with representatives of county human services agencies and the County Welfare Directors Association of California to develop recommendations for revising the methodology used for development of the CalWORKs single allocation annual budget. As part of the process of developing these recommendations, the department shall consult with legislative staff, advocates, and organizations that represent county workers. (b) (1) Recommendations for initial changes to the methodology for development of the CalWORKs single allocation for the 2018 19 fiscal year shall be made to the Legislature by January 10, 2018. (2) Recommendations for additional changes to the methodology for the 2019 20 and subsequent fiscal years shall be made to the Legislature by October 1, 2018. (c) The State Department of Social Services shall work with representatives of county human services agencies and the County Welfare Directors Association of California for purposes of continuing to develop the casework metrics used for the budgeting of funding for employment services in the CalWORKs single allocation and to develop the budgeting methodology for welfare-to-work direct services during the 2019 20 fiscal year. As part of the process of developing this budgeting methodology, the department shall consult with legislative staff, advocates, and organizations that represent county workers. (d) The number of hours per case per month of case work time budgeted for intensive cases as defined pursuant to the budget methodology changes for the employment services component of the CalWORKs single allocation developed pursuant to this section shall be incrementally increased for each of the 2021 22 and 2022 23 fiscal years. Subject to an appropriation in the Budget Act of 2023, as of July 1, 2023, the number of hours per case per month of case work time budgeted for intensive cases shall again be incrementally increased, and in the 2024 25 fiscal year, effective July 1, 2024, it shall be 10 hours. Section 77. Simplified application for elderly CalFresh applicants This section would require CDSS to develop a simplified application process and form for elderly applicants of CalFresh. RECIPIENT IMPACT STATEMENT: This will help the elderly, but it would make more sense to have a simplified all California given the low CalFresh participation rate of California. Effective Date- July 1, 2023 SEC. 77. Section 18900.3 is added to the Welfare and Institutions Code, to read: 18900.3. Subject to an appropriation in the annual Budget Act for these purposes, in order to increase client access and retention within CalFresh, on or before July 1, 2023, the department shall develop a CalFresh user-centered simplified paper application that minimizes the burdens of the overall enrollment process for households that include older adults 60 years of age or older, or the age otherwise applicable under federal law, and people with disabilities who are eligible to be enrolled in the Elderly Simplified Application Project, a demonstration project operated by the United States Department of Agriculture. To the extent that the Elderly Simplified Application Project is no longer operational, the department shall maintain the simplified paper application for older adults and people with disabilities. Section 78. Telephone Signature for public social services in California. This section provides that counties who accept a telephone signature for Medi-Cal today will have to accept telephone signatures for State public social services programs by January 1, 202323 for former C-IV and Los Angeles County, and by January 1, 2024 for former CalWIN counties. Question WTelephone signatures similar to those currently being used for Medi-Cal should be used in all other programs where it is not prohibited by federal law RECIPIENT IMPACT STATEMENT: This is a major achievement for SSI beneficiaries. Effective Date- January 1, 2022 SEC. 78. Section 18900.4 is added to the Welfare and Institutions Code, to read: 18900.4. (a) (1) To the extent permitted under federal law, an individual shall have the option to complete an application or recertification interview and provide the required client signature by telephone. (2) To fulfill the requirements of paragraph (1), counties may implement any method of electronic signature, including telephonic signature, in compliance with state and federal program requirements, that is supported by county business practices and available technology. (3) Counties currently using the Consortium IV (C-IV) or LEADER Replacement System (LRS) of the Statewide Automated Welfare System (SAWS) shall comply with this subdivision beginning on or before January 1, 2023, and counties currently using the CalWORKs Information Network (CalWIN) system of SAWS shall comply with this section beginning on or before January 1, 2024. (b) (1) The department, in consultation with counties, representatives of the statewide automated welfare system consortia, recognized exclusive representatives of eligibility workers, and advocates for CalFresh participants shall develop recommendations to implement a fully telephone-based service model statewide, including, but not limited to, the ability to complete the application, semi-annual report and recertification processes by telephone in all counties. The recommendations shall assess implementation of a telephone-based service model statewide in addition to, not in place of, existing options to complete the application, semi-annual report, and recertification for CalFresh in person, by mail, or online. (2) The recommendations shall be provided to the Legislature during the 2022 23 budget hearings. (3) The fully telephone-based service model assessed pursuant to subdivision (b) shall, to the extent permitted under federal law, satisfy both of the following criteria: (A) Use simple, user-friendly language and instructions for CalFresh applicants, participants, eligibility workers, and application assisters. (B) Provide service and assistance to applicants and participants in a manner that is accessible to individuals with disabilities and those who have limited English proficiency as required by applicable state and federal laws. Section 79 SSI Transitional Benefit Program Extension Extends the time for required documentation and information to be provided to restore discontinued benefits for the Transitional Benefit Program to 90 days and maintains eligibility for all beneficiaries for 2 years by pausing discontinuances. RECIPIENT IMPACT STATEMENT: This will help many SSI beneficiaries. Effective Date- Immediately or when automation is done, whichever is later. SEC. 79. Section 18900.7 of the Welfare and Institutions Code is amended to read: 18900.7. (a) There is hereby created the SSI\/SSP Cash-In Transitional Nutrition Benefit (TNB) Program. (b) The department shall use state funds appropriated for this program to provide transitional nutrition benefits to former CalFresh households that were eligible for and receiving CalFresh benefits as of June 1, 2019, or the alternate implementation date described in subdivision (b) of Section 18900.5, but became ineligible for CalFresh benefits when a previously excluded individual receiving Supplemental Security Income\/State Supplementary Payment Program benefits provided in Chapter 3 (commencing with Section 12000) of Part 3 was added to the household pursuant to paragraph (2) of subdivision (c) of Section 18900.5. (c) (1) The amount of TNB provided to each household shall be based on a TNB table developed by the department. (2) The benefit table described in paragraph (1) shall be issued annually and be based on all of the following: (A) The projected number of households described in subdivision (b). (B) Household size as determined when the previously excluded individual was added to the household pursuant to paragraph (2) of subdivision (c) of Section 18900.5. (C) The number of previously excluded individuals added to the household pursuant to paragraph (2) of subdivision (c) of Section 18900.5. (D) The total funding appropriated for purposes of this section in the annual Budget Act. (d) TNB provided pursuant to this section shall be delivered through the electronic benefits transfer system created pursuant to Section 10072, and, to the extent permitted by federal law, shall not be considered income for any means-tested program. (e) A household that is eligible for TNB shall be initially certified for one 12-month period and may be recertified for additional six-month 12-month periods through a recertification process developed by the department, following consultation with counties and stakeholders, if the household continues to meet all of the following criteria: (1) The household includes at least one individual added to the household pursuant to paragraph (2) of subdivision (c) of Section 18900.5. (2) This individual continues to receive Supplemental Security Income\/State Supplementary Payment Program benefits provided in Chapter 3 (commencing with Section 12000) of Part 3. (3) This individual remains ineligible for CalFresh benefits. (f) The department shall develop client notices for the TNB program, as appropriate. (g) (1) If a household is discontinued for failure to provide the documentation or information required to determine continuing eligibility for TNB, the benefits shall be restored, without proration, back to the original date of discontinuance of TNB, if all documentation and information required to determine continuing eligibility is provided to the county within 30 90 days of the date of discontinuance from TNB. If the household is discontinued for any other reason and reapplies for benefits, the transitional benefit provisions outlined in this section shall not apply. (2) The department, in consultation with representatives of county human services agencies and the County Welfare Directors Association of California, shall develop and implement a process that maintains eligibility for all beneficiaries of benefits provided under this section for two years by pausing the discontinuances described in paragraph (1) and marking all recertifications as complete. The pause shall take effect as soon as possible after the effective date of the act that added this paragraph, and shall continue for two years from the commencement of the pause, or until the department notifies the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement subdivision (e), whichever date is later. (h) Households that are eligible for and receive TNB under this section shall not at any point be eligible for supplemental nutrition benefits, as created in Section 18900.6, regardless of a change in household circumstances. Section 80. Revising the CalFresh county block grant also known as the county single allocation This section would allow counties and the state to make modifications of the county CalFresh administrative block grant. RECIPIENT IMPACT STATEMENT: . Under the block grant system, counties get a bunch of money and then decide how much to use for welfare fraud, how much for actual case carrying workers and how much for whatever else they want to use the money for. That is why some county services to applicants and beneficiaries vary from county to county. All of these decisions are made behind closed doors without advocate input. Block grants have always been opposed by progressives. This block grant approach is just like states’ rights in that the money is given to the counties and the counties decide what to do with the money and not in concert with the beneficiaries of the program. Effective Date- Immediately. SEC. 80. Section 18900.8 of the Welfare and Institutions Code is amended to read: 18900.8. The State Department of Social Services shall work with representatives of county human services agencies and the County Welfare Directors Association of California to update the budgeting methodology used to determine the annual funding for county administration of the CalFresh Program program beginning with the 2021 22 2022 23 fiscal year. As part of the process of updating the budgeting methodology, the ongoing workload and costs to counties of expanding the CalFresh program to recipients of Supplemental Security Income and State Supplementary Payment Program benefits shall be examined examined, and legislative staff, advocates, and organizations that represent county workers shall be consulted. Section 81 Implement CalFresh Waivers with complying with the California Administrative Procedures Act This section would authorize CDSS to run the CalFresh program waiver provisions without complying with the California Administrative Procedures Act. Waivers are generally granted for 2 years and then extended for another 2 years and another 2 years. Thus, under this law California can be operating many portions of the CalFresh program without ever doing any regulations. This more and more autocracy. RECIPIENT IMPACT STATEMENT: This will circumvent the California Administrative Procedures Act and making the California CalFresh program more autocratic and dark Effective Date- Immediately. SEC. 81. Section 18900.9 is added to the Welfare and Institutions Code, to read: 18900.9. Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may do both of the following: (a) Implement all waivers approved by the United States Secretary of Agriculture for a period of less than 24 months through all-county letters or similar instructions. (b) Implement all waivers approved by the United States Secretary of Agriculture for a period of 24 months or longer through all-county letters or similar instructions until regulations are adopted, which shall occur no later than 24 months after implementation occurs. Section 82 Extension of CalFresh Applicant Choice of Interview Method. Existing law requires each county welfare department, to the extent permitted by federal law, to exempt a household from complying with face-to-face interview requirements for the purpose of determining eligibility for CalFresh at initial application and recertification. Existing law, on or before July 1, 2021, requires each county welfare department to implement various scheduling techniques for purposes of scheduling and rescheduling at initial application and recertification. This section would extend the date for each county welfare department to implement the above-described scheduling techniques to January 1, 2022. RECIPIENT IMPACT STATEMENT: This delay would the implementation of this section that would benefit CalFresh applicants and beneficiaries. Effective Date- January 1, 2022 SEC. 82. Section 18901.10 of the Welfare and Institutions Code is amended to read: 18901.10. To the extent permitted by federal law, and subject to the limitation in subdivision (d), each county welfare department shall, if appropriate, exempt a household from complying with face-to-face interview requirements for purposes of determining eligibility at initial application and recertification, according to the following: (a) The county welfare department shall screen each household’s need for exemption status at application and recertification. (b) A person eligible for an exemption under this section may request a face-to-face interview to establish initial eligibility or to comply with recertification requirements. (c) (1) No later than July 1, 2021, January 1, 2022, for purposes of interview scheduling and rescheduling at initial application and recertification, county welfare departments shall implement one or more of the following interview scheduling techniques in addition to providing written notice, to the extent they are not currently in use: time-block, telephonic contact in conjunction with, or prior to, the provision of written communication about the need to schedule an interview, and same-day interviews. (2) The department, in consultation with the counties and client advocates, may authorize additional scheduling techniques to fulfill the requirement described in paragraph (1). (d) This section does not limit a county’s ability to require an applicant or recipient to make a personal appearance at a county welfare department office if the applicant or recipient no longer qualifies for an exemption or for other good cause. Section 83 Expand CalFresh program outreach and retention and improve dual enrollment between the CalFresh and Medi-Cal programs Extends the date that requires counties to complete efforts to expand CalFresh program outreach and retention from January 1, 2022 to January 1, 2023. RECIPIENT IMPACT STATEMENT: This is another delay of helping food insecure Californians. Effective Date- January 1, 2023 SEC. 83. Section 18918.1 of the Welfare and Institutions Code is amended to read: 18918.1. (a) In an effort to expand CalFresh program outreach and retention and improve dual enrollment between the CalFresh and Medi-Cal programs, county welfare departments shall, no later than January 1, 2022, do 2023, complete all of the following: (1) Ensure that Medi-Cal applicants applying in-person, online, or by telephone, and who also may be eligible for CalFresh, are screened and given the opportunity to apply at the same time they are applying for Medi-Cal or submitting information for the renewal process. (2) Ensure the same staff that receive Medi-Cal and CalFresh applications pursuant to paragraph (1) during the Medi-Cal application, renewal, or application and renewal processes conduct the eligibility determination functions needed to determine eligibility or ineligibility to CalFresh. (3) Designate one or more county liaisons to establish CalFresh application referral and communication procedures on outreach activities between counties and community-based organizations facilitating Medi-Cal enrollment. (b) Upon certification to the Legislature that the California Statewide Automated Welfare System (CalSAWS) can perform the necessary automation to implement this section, counties shall provide prepopulated CalFresh applications to Medi-Cal beneficiaries who are apparently CalFresh eligible and not dually enrolled during the Medi-Cal renewal process. Section 84- Extends the deadline to establish and implement a statewide Restaurant Meals Program to September 1, 2021. Existing federal law authorizes eligible counties to participate in the Restaurant Meals Program (RMP), which allows eligible recipients to purchase meals at qualified restaurants. Existing law also requires the department, to the extent permitted by federal law and in consultation with various stakeholders, to establish and implement a statewide RMP on or before September 1, 2020. This section would extend the deadline to establish and implement a statewide RMP to on or before September 1, 2021. RECIPIENT IMPACT STATEMENT: This is another delay of helping food insecure Californians. Effective Date- September 1, 2021 SEC. 84. Section 18919 of the Welfare and Institutions Code is amended to read: 18919. (a) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department shall issue an annual all-county letter providing guidance that lists which counties or regions are eligible to participate in the Restaurant Meals Program (RMP) because they meet the requirements established in Section 4014 of the federal Agricultural Act of 2014 (Public Law 113-79). The department’s all-county letter shall include instructions for how a county may choose to administer the RMP in that county or appeal a noneligible determination by the department. (b) The department shall design the electronic benefits transfer (EBT) system established pursuant to Chapter 3 (commencing with Section 10065) of Part 1 to, automatically and upon issuance of an EBT card, allow all CalFresh recipients who are eligible for the RMP to utilize their benefits in all restaurants that have been approved to participate in the RMP. (c) Except for direct farm purchasing programs or if otherwise not required at a certified farmer’s market, a restaurant shall not operate as a vendor in the program unless the restaurant permits customers to make in-store purchases, maintains a current public health license, and complies with all federal, state, and local health and safety laws, regulations, and ordinances. For the purpose of this section, in-store purchase means any purchase that is not delivered to the purchaser. (d) To the extent permitted by federal law, a county, in administering its RMP program, shall not be precluded from determining the number, type, and location of restaurants the county chooses to include as vendors to align with county administrative capacity or other factors, including, but not limited to, location of participating restaurants and recipient demand. (e) (1) To the extent permitted by federal law, the department, in consultation with various stakeholders, including, but not limited to, county human services agencies and advocates for CalFresh recipients, shall establish a statewide RMP. (2) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department shall implement this subdivision by means of all-county letters or similar instructions from the director on or before September 1, 2020. 2021. (f) To prevent hunger among college students who are homeless, elderly, or disabled, and to facilitate compliance with Section 66025.93 of the Education Code, the department may enter into a statewide memorandum of understanding with the Chancellor of the California State University, the Chancellor of the California Community Colleges, or both. Any qualifying food facility located on a campus of the California State University or a campus of the California Community Colleges may participate in the CalFresh RMP through this statewide memorandum of understanding. (g) For purposes of this section, unless it is specifically excluded from participation in the RMP by federal law or guidance, a restaurant includes, but is not necessarily limited to, an on-campus qualifying food facility, as defined in Section 66025.93 of the Education Code, an eat-in establishment, a grocery store delicatessen, and a takeaway-only restaurant. Section 85 CalFresh Overissuances This section limits the period in which a county may establish a claim to recover an overissuance of CalFresh benefits due to inadvertent household error or administrative error to the 24 months before the discovery of the overissuance by the county. RECIPIENT IMPACT STATEMENT: This is a positive change and it limits the hardship that California’s food insecure have to endure caused by the county CalFresh worker mistakes. Effective Date- July 1, 2022 or whenever automation has been done, whichever is later. SEC. 85. Section 18927.1 is added to the Welfare and Institutions Code, to read: 18927.1. (a) A county shall establish a claim to recover an overissuance of CalFresh benefits due to inadvertent household error, as defined by subdivision (b) of Section 273.18 of Title 7 of the Code of Federal Regulations, or administrative error for which 24 months or fewer have elapsed between the month the overissuance occurred and the month the county welfare department determined the overissuance occurred. A county shall not establish a claim to recover an overissuance due to inadvertent household error or administrative error for which more than 24 months have elapsed between the month the overissuance occurred and the month the county welfare department determined the overissuance occurred. (b) A claim established pursuant to this section shall equal the total amount of overissuance during the 24 months immediately preceding the date the overissuance due to the inadvertent household error or administrative error was discovered. A county shall not collect any portion of an overissuance that occurred more than 24 months before the date the county discovered the overissuance. (c) This section shall become operative on July 1, 2022, or upon the department’s notification to the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement this section, whichever date is later. (d) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement and administer this section through all-county letters or similar instructions, which shall have the same force and effect as regulations, until regulations are adopted. (e) The department shall adopt emergency regulations implementing this section no later than January 1, 2023. The department may readopt any emergency regulation authorized by this section that is the same as, or substantially equivalent to, any emergency regulation previously adopted pursuant to this section. The initial adoption of regulations pursuant to this section and one readoption of emergency regulations shall be deemed to be an emergency and necessary for the immediate preservation of the public peace, health, safety, or general welfare. Initial emergency regulations and one readoption of emergency regulations authorized by this section shall be exempt from review by the Office of Administrative Law. The initial emergency regulations and the one readoption of emergency regulations authorized by this section shall be submitted to the Office of Administrative Law for filing with the Secretary of State, and each shall remain in effect for no more than 180 days, by which time final regulations shall be adopted. Section 87 CalFresh benefits for food insecure noncitizens living in California. This section would require the department to use state funds appropriated for CFAP to provide nutritional benefits to households that are ineligible for CalFresh benefits solely due to their immigration status. RECIPIENT IMPACT STATEMENT: This is a major advance in combating food insecurity in California. All humans should be able to breath and eat. Effective Date: Whenever the department notifies the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement this section. SEC. 87. Section 18930 is added to the Welfare and Institutions Code, to read: 18930. (a) There is hereby created the California Food Assistance Program (CFAP). (b) CFAP shall utilize existing CalFresh and electronic benefits transfer system infrastructure to the extent permissible by federal law. (c) The State Department of Social Services shall use state funds appropriated for CFAP to provide nutrition benefits to households that are ineligible for CalFresh benefits solely due to their immigration status. In accordance with Section 1621(d) of Title 8 of the United States Code, this chapter provides benefits for undocumented persons. (1) Subject to an appropriation in the Budget Act of 2023, the Legislature intends to begin a targeted, age-based implementation of the expansion of CFAP regardless of immigration status. (2) Except as provided in paragraphs (3), (4), and (5) and Section 18930.5, noncitizens of the United States shall be eligible for the program established pursuant to subdivision (a) if the person’s immigration status meets the eligibility criteria of the federal Supplemental Nutrition Assistance Program in effect on August 21, 1996, but the person is not eligible for federal Supplemental Nutrition Assistance Program benefits solely due to the person’s immigration status under Public Law 104-193 and any subsequent amendments thereto. (3) Noncitizens of the United States shall be eligible for the program established pursuant to subdivision (a) if the person is a battered immigrant spouse or child or the parent or child of the battered immigrant, as described in Section 1641(c) of Title 8 of the United States Code, as amended by Section 5571 of Public Law 105-33, or if the person is a Cuban or Haitian entrant as described in Section 501(e) of the federal Refugee Education Assistance Act of 1980 (Public Law 96-422). (4) An applicant who is otherwise eligible for the program but who entered the United States on or after August 22, 1996, shall be eligible for aid under this chapter if the applicant is sponsored and one of the following apply: (A) The sponsor has died. (B) The sponsor is disabled, as defined in subparagraph (A) of paragraph (3) of subdivision (b) of Section 11320.3. (C) The applicant, after entry into the United States, is a victim of abuse by the sponsor or the spouse of the sponsor if the spouse is living with the sponsor. (5) An applicant who is otherwise eligible for the program but who entered the United States on or after August 22, 1996, who does not meet one of the conditions of paragraph (4), shall be eligible for aid under this chapter beginning on October 1, 1999. (6) The applicant shall be required to provide verification that one of the conditions of subparagraph (A), (B), or (C) of paragraph (4) has been met. (7) For purposes of subparagraph (C) of paragraph (4), abuse shall be defined in the same manner as provided in Section 11495.1 and Section 11495.12. A sworn statement of abuse by a victim, or the representative of the victim if the victim is not able to competently swear, shall be sufficient to establish abuse if one or more additional items of evidence of abuse are also provided. Additional evidence may include, but is not limited to, the following: (A) Police, government agency, or court records or files. (B) Documentation from a domestic violence program, legal, clinical, medical, or other professional from whom the applicant or recipient has sought assistance in dealing with abuse. (C) A statement from any other individual with knowledge of the circumstances that provided the basis for the claim. (D) Physical evidence of abuse. (8) If the victim cannot provide additional evidence of abuse, then the sworn statement shall be sufficient if the county makes a determination documented in writing in the case file that the applicant is credible. (d) (1) The amount of nutrition benefits provided to each CFAP household shall be identical to the amount that would otherwise be provided to a household eligible for CalFresh benefits. (2) The benefit amount for a CFAP recipient who is an excluded member of a CalFresh household shall be limited to the amount that the recipient would have received as their share of a CalFresh household benefit, had they not been excluded due to their immigration status. (3) To the extent permissible under federal law, the delivery of CFAP nutrition benefits shall be identical to the delivery of CalFresh benefits to eligible CalFresh households. (e) (1) To the extent allowed by federal law, the income, resources, and deductible expenses of those persons described in subdivision (c) shall be excluded when calculating CalFresh benefits under Chapter 10 (commencing with Section 18900). (2) No household shall receive more CalFresh benefits under this section than it would if no household member was rendered ineligible pursuant to Title IV of Public Law 104-193 and any subsequent amendments thereto. (f) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the State Department of Social Services may implement and administer this section through all-county letters or similar instructions without taking regulatory action until final regulations are adopted, but no later than 18 months after the date upon which this subdivision becomes operative. (g) This section shall become operative on the date that the department notifies the Legislature that the Statewide Automated Welfare System can perform the necessary automation to implement this section. Section 91 CalFresh Outreach Grantee. This section would require CalFresh outreach grantee to annually submit activity reports. RECIPIENT IMPACT STATEMENT: N\/A Effective Date- Immediately. SEC. 91. Section 18999.6 of the Welfare and Institutions Code is amended to read: 18999.6. (a) A grantee shall report at least annually to the department on its funding of advocacy and outreach programs in the prior year and its use of state funding provided under this chapter, including including, to the extent that data is available, all of the following: (1) The number of clients served in each of the targeted populations described in subdivision (b) of Section 18999.2 and any other populations the grantee chose to target. (2) The demographics of the clients served, including race or ethnicity, age, and gender. (3) The number of applications for benefits, and type of benefits, filed with the assistance of the grantee. (4) The number of applications approved initially, the number approved after reconsideration, the number approved after appeal, and the number not approved, including the average processing time from receipt of the application to the initial issuance of benefits. submission of applications while in the Housing and Disability Income Advocacy Program to final determination. (5) For applications that were denied, the reason or reasons for denial. (6) The number of clients who received subsidized housing during the period that their applications were pending and a their enrollment in the Housing and Disability Advocacy Program. (7) A description of how that housing impacted the clients and the rates of completed applications or approval. (7) (8) The number of clients who received subsidized housing who maintained that housing during the disability benefits application period. (8) (9) The percentage of individuals clients approved for disability benefits who retain permanent housing 6, 12, and 24 6 and 12 months after the issuance of initial benefits. approval of disability benefits. (9)The amount and percentage of reimbursements recovered for individuals approved for benefits. (10) The number of individuals eligible to be served by this program but who have not yet received services. (11) Any additional data requirements established by the department after consultation with the County Welfare Directors Association of California, tribes, and advocates for clients. (b) The department shall annually inform the Legislature of the implementation progress of the program and make related data available on its internet website. Beginning in 2020, the department shall also submit an annual report, by February 1, to the Legislature, in compliance with Section 9795 of the Government Code, regarding the implementation of the program, including the information reported by participating grantees pursuant to this section. Amended IN Senate July 11, 2021 Amended IN Assembly February 18, 2021 CALIFORNIA LEGISLATURE\u2014 2021 2022 REGULAR SESSION Assembly Bill No. 153 Introduced by Committee on Budget (Assembly Members Ting (Chair), Arambula, Bennett, Bloom, Carrillo, Chiu, Cooper, Frazier, Friedman, Cristina Garcia, Jones-Sawyer, Lee, McCarty, Medina, Mullin, Nazarian, O’Donnell, Ramos, Reyes, Luz Rivas, Blanca Rubio, Stone, and Wood) January 08, 2021 An act relating to the Budget Act of 2021. An act to amend Sections 7908, 7910, and 7912 of, and to repeal and add Sections 7911 and 7911.1 of, the Family Code, to amend Sections 1502, 1562.01, and 50807 of, and to add Chapter 11.8 (commencing with Section 50811) and Chapter 11.9 (commencing with Section 50820) to Part 2 of Division 31 of, the Health and Safety Code, and to amend Sections 319, 319.3, 358.1, 361.2, 361.21, 366, 366.1, 366.3, 366.31, 636, 706.5, 706.6, 727.1, 727.2, 4096, 4096.5, 4648, 11402, 11403.3, 11461.3, 11461.36, 11462.01, 11463, 11465, 16010.7, 16121, 16501, 16501.1, 16521.6, 16521.8, and 16530 of, to add Sections 361.22, 727.12, 4096.55, 4096.6, 11402.005, 16001.1, 16010.9, and 18257.5 to, to add Chapter 6 (commencing with Section 16550) and Chapter 7 (commencing with Section 16585) to Part 4 of Division 9 of, and to add and repeal Chapter 16 (commencing with Section 18997) of Part 6 of Division 9 of, the Welfare and Institutions Code, relating to public social services, and making an appropriation therefor, to take effect immediately, bill related to the budget. LEGISLATIVE COUNSEL’S DIGEST AB 153, as amended, Committee on Budget. Budget Act of 2021. Public social services. Section 56. California Guaranteed Income Pilot Program This is a pilot guaranteed income program with priority being given to aged out foster care children and foster care children who are pregnant. The payments under this program will be exempt as income or resources for any public social services program. RECIPIENT IMPACT STATEMENT: N\/A Effective Date- Subject to Appropriation. SEC. 56. Chapter 16 (commencing with Section 18997) is added to Part 6 of Division 9 of the Welfare and Institutions Code, to read: CHAPTER 16. California Guaranteed Income Pilot Program. 18997. (a) Subject to an appropriation for this purpose in the annual Budget Act, the State Department of Social Services shall administer the California Guaranteed Income Pilot Program to provide grants to eligible entities for the purpose of administering pilot programs and projects that provide a guaranteed income to participants. The department shall prioritize funding for pilot programs and projects that serve California residents who age out of the extended foster care program at or after 21 years of age or who are pregnant individuals. The department, in consultation with relevant stakeholders, shall determine the methodology for, and manner of, distributing grants awarded pursuant to this chapter. In determining the methodology and manner of distributing grants, the department shall ensure that grant funds are awarded in an equitable manner to eligible entities in both rural and urban counties and in proportion to the number of individuals anticipated to be served by an eligible entity’s pilot program or project. (b) In order to receive grant funds pursuant to this chapter, an eligible entity shall do both of the following: (1) Present commitments of additional funding for pilot programs and projects to be funded with a grant received pursuant to this chapter from a nongovernmental source equal to or greater than 50 percent of the amount of funding to be provided to the pilot program or project from a grant received pursuant to this chapter. (2) Agree to assist the department in obtaining, or to pursue, to the extent necessary, all available exemptions or waivers to ensure that guaranteed income payments made under those pilots and projects are not considered income or resources for the recipient of the guaranteed income payments or any member of their household in any means-tested federal, state, or local public benefit programs. (c) (1) Notwithstanding any other law, guaranteed income payments received by an individual from a pilot program or project funded pursuant to this chapter shall not be considered income or resources for purposes of determining the individual’s, or any member of their household’s, eligibility for benefits or assistance, or the amount or extent of benefits or assistance, under any state or local benefit or assistance program. (2) The department shall, in consultation with stakeholders, and after consultation with the Legislature, identify federal benefit and assistance programs that require an exemption or waiver in order for a guaranteed income payment funded with a grant provided under this chapter to be excluded from consideration as income or resources for purposes of the federal program. Notwithstanding any other law, a state department or agency that administers a program identified by the department shall, if possible, approve an exemption or waiver, or provide any other authority deemed necessary by the department, to exclude guaranteed income payments from consideration as income or resources for purposes of the federal program, or, if the state department or agency does not have that authority, seek a federal waiver or exemption. The state’s failure to be granted a federal exemption or waiver, as described in this paragraph, shall not affect the department’s ability to administer the California Guaranteed Income Pilot Program, and the department may consider alternatives to prevent adverse consequences for participants, in consultation with the Legislature and stakeholders. (d) Notwithstanding any other law, for the purposes of determining eligibility to receive benefits, or the amount or extent of medical assistance, under the Medi-Cal program, a guaranteed income payment funded with a grant provided under this chapter shall not be considered income or resources for a period of 12 months from receipt. This subdivision shall only be implemented by the State Department of Health Care Services to the extent consistent with federal law and any waivers received for the implementation of this subdivision, and federal financial participation for the Medi-Cal program is available and not otherwise jeopardized. (e) (1) The department shall review and evaluate the pilot programs and projects funded pursuant to this chapter to determine, at a minimum, the economic impact of the programs and projects and their impact on the outcomes of individuals who receive guaranteed income payments funded with a grant provided under this chapter. The department shall consult with stakeholders and legislative staff on the details of, and data components to include in, the evaluation, as well as any other topics to be addressed by the review and evaluation, in advance of any decision to contract for this evaluation. Notwithstanding any other law, the department may accept and, subject to an appropriation for this purpose, expend funds from nongovernmental sources for the review and evaluation. (2) (A) The department shall submit a report to the Legislature regarding the review and evaluation conducted pursuant to paragraph (1) and shall post a copy of the report on its internet website. (B) The report described in subparagraph (A) shall be submitted in compliance with Section 9795 of the Government Code. (f) Upon allocation of funding to eligible entities, as described in this section, the department shall report to the Legislature, and post publicly on its internet website, information about the grants funded, including which specific eligible entities received grants, the expected number of foster youth receiving guaranteed income payments funded with a grant provided under this chapter, characteristics about, and the number of, other populations receiving guaranteed income payments funded with a grant provided under this chapter, and the length of time each guaranteed income pilot program or project will be administered. (g) For the purposes of this section, eligible entity means either of the following: (1) A city, county, or city and county. (2) A nonprofit organization that is exempt from federal income taxation under Section 501(c)(3) or 501(c)(5) of the Internal Revenue Code of 1986, as amended, and that provides a letter of support for its pilot or project from any county or city and county in which the organization will operate its pilot or project. 18997.1. Notwithstanding any other law: (a) Contracts or grants awarded pursuant to this chapter shall be exempt from the personal services contracting requirements of Article 4 (commencing with Section 19130) of Chapter 5 of Part 2 of Division 5 of Title 2 of the Government Code. (b) Contracts or grants awarded pursuant to this chapter shall be exempt from the Public Contract Code and the State Contracting Manual, and shall not be subject to the approval of the Department of General Services. (c) Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement, interpret, or make specific this chapter without taking any regulatory action. Section 59. Funding for refugee program This section would provide $5 million for the refugee services program created under W&IC 13265. RECIPIENT IMPACT STATEMENT: This may help refugee children. Effective Date- Immediately until 6-30-24. 18997.2. This chapter shall become inoperative on July 1, 2026, and, as of January 1, 2027, is repealed. SEC. 59. (a) For the 2021 22 fiscal year, the sum of five million dollars ($5,000,000) is hereby appropriated from the General Fund to the State Department of Social Services to administer the California Newcomer Education and Well-Being Program, established pursuant to Section 13265 of the Welfare and Institutions Code, by allocating funding to school districts with a significant number of eligible refugee pupils to improve their well-being, English language proficiency, and academic performance. This funding shall be available for encumbrance and expenditure until June 30, 2024. (b) For purposes of making the computations required by Section 8 of Article XVI of the California Constitution, the funds appropriated in subdivision (a) shall be deemed to be General Fund revenues appropriated for school districts, as defined in subdivision (c) of Section 41202 of the Education Code, for the 2020 21 fiscal year, and included within the total allocations to school districts and community college districts from General Fund proceeds of taxes appropriated pursuant to Article XIII B, as defined in subdivision (e) of Section 41202 of the Education Code, for the 2020 21 fiscal year. Questions? Contact Person: Kevin Aslanian Telephone 916-712-0071 Email [email protected] July 2021 2 Analysis of AB 135 and 153 of the Human Services 20221-2022 California State Budget Trailer bill – ”