ORR State Letter

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  \# **07-08**                                   **Date: April 4, 2007**
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| **TO:**       | STATE REFUGEE COORDINATORS                           |
|               |                                                      |
|               | WILSON-FISH PROGRAMS                                 |
|               |                                                      |
|               | NATIONAL VOLUNTARY AGENCIES                          |
|               |                                                      |
|               | OTHER INTERESTED PARTIES                             |
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| **FROM:**     | Martha E. Newton                                     |
|               |                                                      |
|               | Director\                                            |
|               | Office of Refugee Resettlement                       |
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| **SUBJECT:**  | ORR Recommendations and Proposed Reporting           |
|               | Requirements and Guidelines for Economic             |
|               | Self-Sufficiency                                     |
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The purpose of this State Letter is to review ORR proposals and
recommendations that came out of ORR's Economic Self-Sufficiency Work
Group, and to solicit feedback on these proposals so that ORR can
formalize clarifications or revisions to current reporting requirements
related to refugee economic self-sufficiency. These recommendations were
initially presented at the ORR Annual Consultation held in January 2007.

**[Work Group Background and Goals]{.underline}**

In 2006, ORR established an Economic Self-Sufficiency Work Group
comprised of ORR staff, State coordinators, Wilson-Fish programs, local
and national Voluntary Agencies, Mutual Assistance Associations, an
employment Technical Assistance provider, and the Department of State.

The Work Group revisits the work of a 1994 Work Group on Economic
Self-Sufficiency, which allowed ORR to develop specific performance
measures that have served as basis for reporting outcomes for
State-Administered and Wilson-Fish programs since 1996.

The Work Group was established so that ORR could:

-   Review goals and performance measures related to refugee economic
    self-sufficiency

-   Clarify performance measures and select new or revised measures

-   Where possible, recommend policy and programmatic solutions to
    establish greater consistency and accuracy in reporting across
    State-Administered, Wilson-Fish, and Voluntary Agency Matching Grant
    programs.

-   Strengthen overall ORR policies and operations related to refugee
    economic self-sufficiency

The Work Group was not designed to reach consensus on any of the issues
before it; ORR intended that individual group members would provide ORR
with information that would help inform our policies and procedures.

ORR instructed Work Group members to consider "economic
self-sufficiency" to be defined as "earning a total family income at a
level that enables a family unit to support itself without receipt of a
cash assistance grant." This definition is taken directly from the ORR
regulations at 45 CFR 400.2. Though ORR recognizes that true refugee
self-sufficiency depends on a number of factors other than family income
(including language acquisition, cultural integration, etc), it was
determined that these issues of broader integration were more
appropriate for ORR's Integration Work Group. Economic Self-Sufficiency
Work Group members were instructed to focus mainly on the financial and
employment-related aspects of integration and self-sufficiency as
mandated to ORR in the Refugee Act of 1980.

The Work Group members include:

-   ORR Staff

    -   Pam Green-Smith, Ken Tota, Josh Trent, Ron Munia, Carl
        Rubenstein, Moushumi Beltangady, Laura Garcia, Sowsan Deifallah,
        Jim Perlmutter, and Tim Forbes

-   Representatives from

    -   Department of State (Bureau of Population, Refugees, and
        Migration (PRM)) (*ex officio*)

    -   State-Administered Programs (Maryland, New York, and Texas)

    -   Wilson-Fish Programs (Alaska and Massachusetts)

    -   Local and National Voluntary Agencies (U.S. Conference of
        Catholic Bishops, Church World Service, Ethiopian Community
        Development Council, Hebrew Immigrant Aid Society, International
        Rescue Committee, Lutheran Immigration and Refugee Service)

    -   Mutual Assistance Association (Ethiopian Community Development
        Council)

    -   Employment Program Technical Assistance Provider (RefugeeWorks)

**[Work Group Activities]{.underline}**

Work Group members convened in October 2006 to discuss the definition of
economic self-sufficiency as in Federal Regulations, review and discuss
current performance measures and reporting guidelines, consider "ideal"
performance indicators for measuring refugee economic self-sufficiency,
talk about which performance measures should be established, and discuss
reporting issues related to the selected measures.

Subsequent to the meeting, the group members engaged in continued
discussion (via an interactive Wiki web space and a series of conference
calls) on the selection of performance measures, as well as discussion
of issues related to reporting on several of the measures, the
definition of caseload, reporting timeframes, which job should be
reported if one client enters multiple jobs within the reporting period,
and how to address the self-sufficiency outcomes of TANF (non-Refugee
Cash Assistance (RCA)) clients.

**[ORR Recommendations on Performance Measures]{.underline}**

On the basis of suggestions from various members of the work group and
our own independent analysis, ORR recommends a number of new and revised
performance measures, as well as changes in reporting timeframes. Seven
performance measures are proposed here as what we consider to be the
best (and most feasibly measurable) indicators of economic
self-sufficiency.

*[Performance Measures \# 1 -- 5]{.underline} are meant to be reported
on by all State-Administered and Wilson-Fish programs for all (enrolled
5-year eligible) clients. Measure 1 is to be reported on for Matching
Grant Program clients as well.*

**Measure 1: Refugees Entering Employment**

-   Grantees report on the *number* of refugees entering into
    unsubsidized employment, either full- or part-time, during the
    reporting period.

-   This proposed measure is the same as the current measure related to
    entered employment, with the clarification that the measure refers
    to the number of refugees who enter employment at any time within
    the reporting period, regardless of how many jobs they enter during
    the reporting period.

**Measure 2: Average Hourly Wage of Refugees Entering Full-time
Employment**

-   Grantees report on the average hourly wage of refugees entering
    full-time employment during a given reporting period.

-   For refugees entering multiple jobs during the reporting period,
    grantees report on only the job with highest wage at placement for
    each individual refugee.

-   As with Measure 1, this indicator is linked to the number of
    eligible refugees rather than the number of jobs held by those
    refugees.

**Measure 3: Refugees Offered Health Benefits through Full-Time
Employment**

-   Grantees report on the number of refugees offered health benefits
    through any full-time job placement during the reporting period.

-   For refugees entering multiple jobs during the reporting period,
    grantees report on the number of refugees holding any full-time job
    offering a refugee health benefits. The selected job need not be the
    same job reported for the hourly wage measure. In addition, there is
    no requirement that the refugee take advantage of the offered
    benefits.

-   As with Measures 1 and 2, this indicator is linked to the number of
    eligible refugees rather than the number of jobs held by those
    refugees.

**Measure 4: Cash Assistance Terminations Due to Earnings from
Employment**

-   Grantees report on the number of refugees whose cash assistance is
    terminated due to earned income in an amount that exceeds the income
    standard for the case based on family size, thereby rendering the
    case ineligible for cash assistance. For those clients enrolled in
    TANF rather than ORR-funded cash assistance programs, the cash
    assistance termination determinations would be based on whether the
    earned income is in an amount "predicted to exceed" the State's TANF
    payment income standard.

-   This proposed measure is the same as the current measure related to
    cash assistance terminations, with the clarification that the
    measure refers to the number of refugees whose cash assistance is
    terminated based on the program's eligibility policies, regardless
    of how many jobs they enter during the reporting period.

-   While this measure is retained, ORR proposes dropping the current
    measure related to cash assistance reductions.

**Measure 5: Refugees Employed at 90 Days**

-   Grantees report on the number of refugees who are employed on the
    90th day after their initial employment placement during the
    reporting period (whether in the initial job or a different job).

-   This proposed measure is the same as the current measure related to
    90 day employment, with the clarification that the measure refers to
    the number of refugees who are employed 90 days after initial
    employment in any job, regardless of how many jobs they enter during
    the reporting period.

*[Performance Measures #6 -- 7]{.underline} are to be reported on by
State-Administered and Wilson-Fish programs for clients receiving RCA,
and by Matching Grant programs. Each of these measures is a three-part
measure. These measures are conceived as "snapshot" or "point-in-time"
measures and are meant to assess the performance of eligible refugees in
the months after arrival. ORR is still considering how exactly
point-in-time data will be determined.*

**Measure 6: Economic Self-Sufficiency at 120 days (Snapshot)**

-   Three part measure:

a)  Grantees report on the number of cases that are self-sufficient
    (earning a total family income that enables a family unit to support
    itself without receipt of a cash assistance grant) 120 days after
    date of eligibility.

b)  Grantees report on the average hourly wage of refugees in current
    job.

c)  Grantees report on the number of refugees offered health benefits
    through their current job.

**Measure 7: Economic Self-Sufficiency at 180 or 240 days (Snapshot)**

-   Three part measure:

    a.  Grantees report on the number of cases that are self-sufficient
        (earning a total family income that enables a family unit to
        support itself without receipt of a cash assistance grant) 180
        or 240 days after date of eligibility.

    b.  Grantees report on the average hourly wage of refugees in
        current job.

    c.  Grantees report on the number of refugees offered health
        benefits through their current job.

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-   Whether the measure will be reported at 180 or 240 days is still
    under discussion.

Measures 6 and 7 are new for State-Administered and Wilson-Fish
programs.

**[Additional Proposals and Outstanding Issues]{.underline}**

1)  *Proposal:* Definition of Caseload

-   ORR proposes defining employment services caseload (used in Measures
    1-5) as "the total number of refugees receiving employment services
    during the reporting period, excluding only those individuals
    exempted from employment services according to the state\'s policies
    and procedures."

-   ORR proposes defining the self-sufficiency caseload (Measures 6-7)
    as composed of "family units" as defined in the ORR Regulations at
    45 CFR 400.2, "an individual adult, married individuals without
    children, or parents, or custodial relatives, with minor children
    who are not eligible for TANF, who live in the same household." All
    cases that received ORR assistance during the reporting period are
    included in the measure.

2)  *Proposal:* Adjust reporting timeframes to achieve consistency
    across programs

-   ORR proposes the institution of trimester reporting on the Federal
    Fiscal Year for State-Administered, Wilson-Fish, and Matching Grant
    programs.

-   This would allow for more consistency in measurement across
    programs, and allow for better assessment of the refugee program as
    a whole. Also, trimester reporting syncs up with the current 8-month
    RCA eligibility time frame, and reflects the current reporting
    scheme for the Matching Grant program.

3)  *Proposal:* Reporting on refugee TANF recipients

-   ORR proposes that economic self-sufficiency data on Measures 6 and 7
    (self-sufficiency snapshot) be collected and reported on for all
    recipients of ORR-funded cash assistance, including RCA,
    Wilson-Fish, or Matching Grant program assistance.

-   Data on TANF recipients' receipt of cash assistance terminations
    (Measure 4) will continue to be collected for those individuals who
    access ORR-funded employment services.

4)  *Outstanding issue:* How to measure Economic Self-Sufficiency for
    Measures #6 -- 7

-   Measures \# 6 -- 7 state that economic self-sufficiency should be
    defined as earning a total family income that enables a family unit
    to support itself without receipt of a cash assistance grant.[^1]
    ORR is still trying to determine what standard this should be
    measured against. Several possible options are under consideration:

    -   Family income is measured against a state's maximum TANF income
        standards for the family size. If a family unit earns more than
        the maximum income, it will be considered self-sufficient. It is
        important to note that many States have very low maximum TANF
        income standards, often far less than the Federal Poverty Line
        and frequently a very poor indicator of a family's ability to
        support itself.

    -   Family income is measured against the income standards of the
        ORR program in which the family is enrolled (this is
        particularly relevant to the Wilson-Fish program). If a family
        unit earns more than the maximum income, it will be considered
        self-sufficient.

    -   Family income is measured against the Federal Poverty Line.
        While this is higher than the maximum TANF eligibility income in
        most States, it is not adjusted by locality. Applying this
        standard to refugees regardless of location might not give a
        clear indication of each individual refugee's self-sufficiency.

    -   Family income is measured against some local standard (such as
        the Consumer Price Index, which is available by Metropolitan
        Statistical Area). This might give a clearer picture of whether
        a family is able to afford some basic "basket of goods" in its
        community.

    -   Each grantee determines the standard for "supporting oneself
        without receipt of a cash assistance grant" based on an analysis
        of whether the case is earning enough to meet basic living needs
        as identified in a self-sufficiency budget or some agreed-upon
        set of expenses (perhaps detailed in the State Plan or other
        planning document and approved by ORR).

-   ORR feels that the chosen standard should be clearly defined and
    applied so as to ensure maximum clarity in the reporting and
    interpretation of grantee data.

5)  *Outstanding issue: Harmonization with Department of State, Bureau
    of Population, Refugees, and Migration*

-   The proposed measures and timelines do not apply to the Department
    of State's Reception and Placement program.

-   ORR and PRM will assess the possibility of aligning certain
    definitions and reporting timeframes.

6)  *Outstanding Issue: Structure of Matching Grant Program*

-   To be consistent with other ORR programs, the Matching Grant Program
    is considering moving to a Fiscal Year program rather than a
    Calendar Year program.

-   As discussed under Measure 7, economic self-sufficiency could be
    measured at 180 days (the length of MG program eligibility) or 240
    days (the length of RCA eligibility) after eligibility. Work Group
    members suggested that ORR might consider the possibility of moving
    MG from a 6 month (180 days) to an 8 month (240 days) program in
    order to improve synchronization between ORR programs.

**[Next Steps]{.underline}**

ORR solicits feedback and comments on the proposals, recommendations,
and outstanding issues listed above. Please provide your comments (in
the same order and format as the State Letter) to Moushumi Beltangady
(<moushumi.beltangady@acf.hhs.gov>) by **April 25, 2007**.

Following the receipt of feedback, ORR will consult with members of the
Work Group to reach final decisions about measures, reporting
timeframes, and other policy and programmatic issues. It is anticipated
that another State Letter or policy document will be released this
summer detailing ORR's final decisions and procedures.

Please contact Pamela Green-Smith (<pamela.greensmith@acf.hhs.gov>) or
Moushumi Beltangady (<moushumi.beltangady@acf.hhs.gov>, 202-260-2613)
with any questions or concerns.

[^1]: A cash assistance grant should only include the financial
    assistance provided to refugees whose earnings fall below the
    programs' respective income eligibility standard. Other financial
    assistance provided to the refugee in the form of a bonus, incentive
    or disregard based on the refugees' achievement of a successful
    employment outcome as indicated in the approved State Plan or
    Wilson-Fish Agency application should not be considered as cash
    assistance for the purposes of measuring cash assistance
    terminations (measure 4) and economic self --sufficiency (measure 6
    and 7).