+------------------------------------+---------------------------------+
| Temporary Assistance for Needy     | U.S. Department of Health and   |
| Families                           | Human Services                  |
|                                    |                                 |
| **Program Instruction**            | Administration for Children and |
|                                    | Families                        |
|                                    |                                 |
|                                    | Office of Family Assistance     |
|                                    |                                 |
|                                    | Washington, DC 20447            |
+------------------------------------+---------------------------------+
| No. TANF-ACF-PI-2007-04            | Date: September 10, 2007        |
+------------------------------------+---------------------------------+

**TO:** State agencies administering the Temporary Assistance for Needy
Families Program.

**SUBJECT:** Reporting on TANF Agency NDNH Match Results.

**REFERENCES**: Section 453(j)(3) of the Social Security Act.

**PURPOSE**: The purpose of this Program Instruction is to explain how
to complete and submit the TANF Agency NDNH Match Results Report and to
specify submission deadlines.

**BACKGROUND:**

Federal law grants the Secretary of the Department of Health and Human
Services (HHS) discretion to disclose information maintained in the
National Directory of New Hires (NDNH) to State agencies operating
Temporary Assistance for Needy Families (TANF) programs. The NDNH
contains new hire, quarterly wage, and unemployment compensation
information and is maintained by the Office of Child Support Enforcement
(OCSE) within its \"Location and Collection\" system of records, No.
09-90-0074, last published at 69 Federal Register 31392, June 3, 2004.

The Office of Child Support Enforcement (OCSE) is required to report
measures of performance of the Federal Parent Locator Service (FPLS),
which includes the NDNH. As part of the TANF-NDNH matching agreement,
the Office of Family Assistance (OFA) must provide OCSE a quarterly
report of outcomes attributable to each State Agency's use of NDNH match
results.

**POLICY:**

[Matching TANF adults receiving federally-funded assistance]{.underline}

The purpose of the TANF-NDNH matching program is to provide State
agencies with information resulting from a comparison of its files on
adults receiving federally- or MOE-funded TANF assistance against data
contained in the NDNH. This information can then be used by State
agencies to verify the eligibility of adult TANF recipients and their
continuing compliance with statutory and regulatory requirements.

[Matching other individuals served by the TANF program]{.underline}

In addition to matching adults receiving federally- or MOE-funded TANF
assistance, States may also match adults who receive assistance under a
separate State program (SSP) funded with State MOE dollars ("qualified
State expenditures" as defined in section 409(a)(7)(B)(i)) and parents
who reside with a child who is a recipient of assistance (the
"SSP/child-only match"). However, NDNH match results provided to State
TANF agencies can only be used to determine eligibility for adults
receiving federally-funded TANF assistance. Therefore, States may not
use these NDNH match results to take eligibility actions (such as
benefit reduction or case closure) for adults not receiving
federally-funded TANF assistance. Although match results for those not
receiving federally-funded assistance cannot be used for eligibility
purposes, the results can be used for administrative purposes such as
correcting work participation data or modifying case closure
information.

**ACTION:**

Each State TANF agency participating in the NDNH matching process is
required to report quarterly on the four items listed in the TANF Agency
NDNH Match Results Report for their new hires (W-4) match, quarterly
wage (QW) match, and unemployment insurance (UI) match. This report
should be completed for both the TANF adult recipient match and the
SSP/child-only match, although items 2 through 4 will not be completed
for SSP/child-only match results since eligibility actions are not
allowed. As is stated in the report, outcomes should be reported in row
representing the month of the match, not the month of verification or
case action. Data will be reported 45 days after the end of each
quarter.

The TANF Agency NDNH Match Results report should represent what happened
to the adult with verified employment---specifically if the individual's
grant was reduced or if the case they were a part of was closed. As the
explanation to items 2 and 3 specifies, these items should represent the
"number of unduplicated individuals reported in item 1 \[adults with
previously unknown employment that were verified as employed\] . . .
whose TANF grant was closed \[or reduced\]." Therefore, information
reported in item 2 and 3 should represent the number of individuals with
previously unknown employment that had their benefits reduced or cases
closed, not the number of individuals in the case that were affected by
these actions.

[Overlap between NDNH and the State Directory of New Hires]{.underline}

States should report on all NDNH verified matches that reveal previously
unknown employment, not just those that are out-of-State or federal
agency matches that would not be available from the State Directory of
New Hires. If an NDNH match is conducted, the individual is verified as
employed, and the employment was previously unknown to the agency it
should be reported on item 1 of the form regardless of if the match
would also be found in the State Directory of New Hires.

[Submitting amended reports]{.underline}

We anticipate that State reports may be incomplete when submitted 45
days after the end of the quarter as the State may not have verified all
matches or have taken action on all match results. Therefore, data
reported in prior quarterly submissions can be amended by reporting the
revised information in subsequent quarterly submissions.

Consider the following example:

[Date]{.underline} [Action]{.underline}

End of July: June adult TANF adults are matched to the NDNH (15,000
adults)

Early August: Match results are returned to the State (4,000 total W-4
matches)

> September: Match results verified and sent to local offices for action
> (400 adults verified to have employment that was previously unknown to
> the agency)
>
> October: Actions are taken based on verified employment information
> (350 adults have actions taken, as others had income below disregard
> levels or benefits were not changed for other reasons)

November: Adult receives adjusted benefit/no benefit as a result of
action (350 adults)

All match results should be reported in the month of the match, not the
month of case action or when costs are avoided. In the example above,
the actions taken for the 350 adults in October (resulting in cost
avoidance in November) would be reported on the July row of the
reporting form. The State would submit their fourth quarter report (July
through September) in mid-November, although it may be incomplete at
that point as they may not have yet verified all matches or have taken
action on all verified matches. In mid-February (45 days after the end
of the next quarter) the State would send both the first quarter report
and an amended fourth quarter report containing updated information on
all results from the July match. If actions were still being taken on
the July match results after this amended report was submitted, the
State would continue to submit amended reports each quarter until all
actions resulting from the July match had been reported on a final
amended report for that quarter.

**FURTHER EXPLANATION OF REPORTING ITEMS:**

Item 1. Unduplicated Individuals Verified as Employed: The number of
unduplicated individuals with previously unknown employment that had a
NDNH match and were verified as being employed while they were a TANF
recipient in your State.

Unduplicated individuals means counting the same person no more than
once per fiscal year. If the individual was found in more than one of
the three data sources, they should be reported under the data match
that triggered the verification resulting in case action. Consider the
following example:

> A match reveals verified income that is insufficient to trigger
> benefit reduction or case closure, but in a later match the individual
> is again identified as employed but this time has income significant
> enough to result in benefit reduction or case closure.

The first verified match (revealing income but not enough for a benefit
change) should be reported under item 1 as previously unknown employment
but would not be reported on items 2, 3, or 4 on the form. The reporting
on the second match resulting in case action depends on whether the
employment is different than the employment discovered in the earlier
match and when in the year the match occurs. If the later match
identifies the same employment as the first match (although the person
may be working a different number of hours or may be paid more or less
than before), this would not meet the definition of "previously unknown
employment" and should not be reported. If the second match is for a
different employer but within the same fiscal year as the first match,
it should not be reported a second time. However, if the second match is
for a different employer and in a new fiscal year, it should be reported
in the new year under item 1 as previously unknown employment and also
under items 2, 3, and 4 if applicable.

In some cases, a State agency may verify employment resulting from an
NDNH match but take no action because earnings are below the TANF
earnings disregard for the State or county. If these matches were
disregarded and not investigated further, it may not be possible to
determine whether the employment was already known by the agency. These
verified matches should still be reported under item 1 as previously
unknown employment, although there would be nothing to report under
items 2, 3, and 4.

Item 4. Unduplicated First-Month Avoided TANF Costs: Total first-month
TANF costs avoided from items 2 and 3.

First-month avoided costs equal the difference between 1) the monthly
grant that the TANF case would have been given in the absence of
verified employment information resulting from an NDNH match, and 2) the
monthly grant the TANF case actually received after the verified
employment information was used to modify benefits. For example, suppose
an NDNH match is verified and reveals previously unknown employment. The
State recalculates the TANF benefit for the case, resulting in the case
receiving a monthly TANF grant that is \$100 less than what they would
have received in absence of the employment information found through the
NDNH. As a result of the NDNH match, the State has avoided \$100 in
costs in the month when benefits were reduced. The State would report a
\$100 first-month avoided cost in item 4 of the report. The full \$100
would be reported as avoided costs regardless of if it represents State
or federal funds.

**EFFECTIVE DATE:**

States should submit their FY 2008 first quarter report by February 14,
2008.

**SUBMISSION DATES:**

Data is to be reported 45 days after the end of each quarter. Data
reported in prior quarterly submissions can be amended in subsequent
quarterly submissions. Quarterly reports should be submitted as follows:

Quarter 1 (Oct. -- Dec.): Report by February 14

Quarter 2 (Jan. -- Mar.): Report by May 15

Quarter 3 (Apr. -- Jun.): Report by August 14

Quarter 4 (Jul. -- Sep.): Report by November 14

**SUBMITTAL PROCEDURE:**

Reports should be submitted electronically to:

> Sean Hurly, Director
>
> Division of Data Collection and Analysis
>
> Office of Family Assistance
>
> Email: <sean.hurley@acf.hhs.gov>

**ATTACHMENTS**: TANF Agency NDNH Match Results reporting form

**INQUIRIES:** Inquiries should be made to Sean Hurley, Director of the
Division of Data Collection and Analysis, Office of Family Assistance,
ACF (email: <sean.hurley@acf.hhs.gov>).

Sidonie Squier

Director

Office of Family Assistance