Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
TEMPORARY ASSISTANCE 
FOR NEEDY FAMILIES 
Educating Clients about Sanctions 
JUNE GIBBS BROWN 
Inspector General 
OCTOBER 1999 
OEI-09-98-00291  OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 
protect the integrity of the Department of Health and Human Services programs as well as the 
health and welfare of beneficiaries served by them.  This statutory mission is carried out through a 
nationwide program of audits, investigations, inspections, sanctions, and fraud alerts.  The 
Inspector General informs the Secretary of program and management problems and recommends 
legislative, regulatory, and operational approaches to correct them. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 
Inspector General.  It conducts short-term management and program evaluations (called 
inspections) that focus on issues of concern to the Department, the Congress, and the public.  The 
inspection reports provide findings and recommendations on the efficiency, vulnerability, and 
effectiveness of departmental programs. 
OEI's San Francisco regional office prepared this report under the direction of Kaye D. Kidwell, 
Regional Inspector General, and Paul A. Gottlober, Deputy Regional Inspector General.  Principal 
OEI staff included: 
REGION IX  HEADQUARTERS 
Steven Zerebecki, Lead Analyst  Linda Hall, Program Specialist 
Scott Hutchison, Program Analyst  Alan Levine, Program Specialist 
Lori Stickel, Program Analyst 
To obtain copies of this report, please call the San Francisco Regional Office at (415)437-7900. 
Reports are also available on the World Wide Web at our home page address: 
http://www.dhhs.gov/progorg/oei  E X E C U T I V E   S U M M A R Y  
PURPOSE 
To determine how States inform clients about sanction policies under the Temporary 
Assistance for Needy Families (TANF) program. 
BACKGROUND 
In 1996, Congress significantly overhauled the Federal welfare system with the passage of 
the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA, P.L. 
104-193), eliminating Aid to Families with Dependent Children (AFDC).  The TANF 
program replaced AFDC with State block grants, giving States more authority to design 
programs that move clients from welfare to self-sustaining employment.  Except where 
expressly provided under PRWORA, the Federal Government may not prescribe State 
spending on TANF. 
Clients who fail to comply with program rules and requirements face sanctions, including 
cash assistance reductions ranging from $25 to lifetime ineligibility.  The TANF law 
provides States flexibility to define client sanctions and penalties, as well as good cause 
reasons for work exemptions.  The TANF law requires States to provide clients the option 
to appeal sanction decisions and to have a fair hearings system to resolve the appeal. 
However, States decide the specifics of their appeals and fair hearings policies and 
processes. 
States also can decide how to inform clients of TANF program policies and procedures. 
States can conduct orientation sessions, provide orientation packets, or instruct 
caseworkers to inform clients about TANF during screenings and interviews. 
We purposefully selected an 8-State sample from which we visited a total of 26 TANF 
offices in both urban and rural areas.  At most sites, we conducted separate focus groups 
with TANF caseworkers and clients in addition to meeting individually with TANF office 
directors and selected TANF caseworkers who assisted us with limited case-file reviews of 
recently sanctioned clients.  We also collected and reviewed State and county policies, 
publications, and notices from each TANF office.  In each of the sample States, we 
interviewed staff from at least one private client advocacy group. 
The methods we used during this study pose some distinct advantages and disadvantages 
for the scope of our findings.  The purposeful sample allowed us to examine sanction 
1 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  implementation in States with widely varying attributes.  We also gained a thorough 
understanding of our respondents relationships with and attitude towards sanctions.  Our 
methodology precludes us, however, from commenting on the extent to which our 
findings and observations are representative nationwide.  We also cannot evaluate direct 
outcomes of sanction policies, procedures, and practices on clients and the program. 
FINDINGS 
TANF offices explain sanctions to clients repeatedly, using diverse methods 
Some TANF offices communicate sanction information to clients at multiple times and 
with a variety of media.  For example, offices conduct orientation classes, show instructive 
videos, and issue packets of information.  Caseworkers frequently discuss sanctions with 
clients throughout the process. 
Orientation materials commonly lack information about the amount of the 
sanction and the definition of good cause 
More than two-thirds of TANF offices do not provide clear and complete information 
about the amount of sanctions and the definition of good cause exemptions from work 
requirements. 
Most States describe other vital information about sanctions completely and 
present it in a logical format 
The reasons for and durations of sanctions and client appeal rights are explained clearly in 
most written material provided to clients. About half of the TANF orientation materials 
present information in a well-labeled packet and in a logical format. 
TANF clients do not fully understand sanctions and, according to caseworkers, 
are not concerned about sanctions until they are imposed 
Clients rarely had more than a superficial understanding of sanctions.  Regardless of the 
States sanctions policy, clients often reported that they would be cut off if they violated 
program rules.  In addition, caseworkers told us that a sanction is not often a concern to 
clients until it is imposed. 
2 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  RECOMMENDATION 
We recommend that the Administration for Children and Families encourage States to 
provide complete, correct, and understandable information to clients on:  the causes of 
sanctions; the amounts of sanctions; the duration of sanctions; good cause reasons for 
work exemptions; and client appeal, fair hearing, and, if applicable, conciliation rights. 
AGENCY RESPONSE 
We received comments on the draft report from the Administration for Children and 
Families.  The agency concurred with our recommendation and stated that it is committed 
to working with States to improve State sanction information.  As an initial step, it will 
provide States with examples of effective sanction information and facilitate networking 
among States interested in improving their sanction information.  We made changes to the 
report based on the technical comments we received from the agency and clarified that we 
do not project our findings beyond the sample sites. 
This is one of three OIG reports on how States administer client sanctions 
under TANF.  One companion report, Temporary Assistance for Needy 
Families:  Improving the Effectiveness and Efficiency of Client Sanctions 
(OEI-09-98-00290), provides a broad overview of State administration of 
client sanctions.  The other, Temporary Assistance for Needy Families: 
Improving Client Sanction Notices (OEI-09-98-00292), reviews State 
methods for informing clients of sanction decisions via written notices. 
3 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  T A B L E   O F   C O N T E N T S  
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

INTRODUCTION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Purpose  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Client sanctions under TANF  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Good Cause  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Appeals and fair hearings  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Informing clients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Explaining sanctions to clients  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Vital information omitted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Clients lack of understanding and concern  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

RECOMMENDATION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  14

APPENDICES 
A:	 Orientation information with clear, complete, and concise information on sanctions, fair

hearings, and good cause  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

B:  Orientation information containing thorough appeal rights information . . . . . . . . . . . . .  19

4 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  I N T R O D U C T I O N  
PURPOSE 
To determine how States inform clients about sanction policies under the Temporary 
Assistance for Needy Families (TANF) program. 
BACKGROUND 
In 1996, Congress significantly overhauled the Federal welfare system with the Personal 
Responsibility and Work Opportunity Reconciliation Act (PRWORA, P.L. 104-193), 
ending federally-funded welfare entitlements.  When President Clinton signed the bill into 
law in August 1996, Aid to Families with Dependent Children (AFDC) was replaced with 
TANF, a block grant program that gives States more authority and flexibility to design 
programs that move clients from welfare to self-sustaining employment.  Except where 
expressly provided for under PRWORA, the Federal Government may not prescribe State 
spending of TANF block grant funds. 
Client Sanctions under TANF 
Clients who do not follow program rules and requirements face sanctions, including 
cash assistance reductions ranging from $25 to lifetime ineligibility.  States have increased 
authority to define sanctionable offenses and determine specific penalties.  Federal TANF 
law directs States to sanction clients for not cooperating with child support enforcement 
efforts and/or not participating in work activities.  States also may sanction clients for 
testing positive for controlled substances, not following an Individual Responsibility 
Plan, refusing to work towards achieving a high-school diploma or the equivalent, failing 
to attend school, and/or failing to attend required meetings or to attend other program 
activities (e.g., training sessions). 
The law mandates a minimum benefit reduction for some sanctions (e.g., a 25 percent cash 
assistance reduction for failure to participate in child support enforcement efforts), but 
States can set a maximum sanction,  ranging from a pro rata sanction to a full family 
sanction that eliminates all cash assistance to the entire family.  States also may increase 
sanctions for clients who repeatedly fail to comply with the program rules and 
requirements.  For example, some States incrementally decrease cash assistance to families 
each time they fail to comply, sometimes leading to the loss of the entire cash grant. 
5 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  The TANF law also allows States flexibility in determining the duration of sanctions. 
States must, at a minimum, reduce the cash grant pro rata for each month the client 
receives aid and is not in compliance.  States can set maximum sanction duration.  Some 
States increase the duration of the sanction each time the client does not comply, which 
sometimes results in lifetime ineligibility. 
Good Cause 
If a TANF client refuses to participate in work activities or comply with other TANF 
program requirements, the State must sanction the client, except where good cause or 
other exceptions apply.  The TANF law directs that States exempt from work 
requirements single custodial parents of children under the age of six who cannot obtain 
child care.  States also can define good cause and other exceptions as they deem 
appropriate.  Although State definitions vary, they commonly allow good cause for: lack 
of transportation, victims of domestic violence, lack of suitable employment, and illness of 
the participant. 
Appeals and Fair Hearings 
States are required to provide clients the option to appeal sanctions and must have a fair 
hearings system to resolve the appeal.  State appeals and fair hearings policies and 
procedures may vary since TANF requires only that States certify that they have a fair 
hearings process in place and describe it. 
Informing Clients of Program Rules 
States decide how and when to inform clients of their sanction policy, the conciliation 
process, how to restore benefits once sanctioned, and the appeals and fair hearings 
process.  States can, for example, conduct individual or group orientation sessions or 
provide all clients with packets of written materials including policy information. 
6 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  METHODOLOGY 
We purposefully selected an eight-State sample based on: 
<  percent reduction in TANF recipient populations,1 
<  State policies on TANF client sanctions (e.g., full-family versus 
partial grant reduction), 
<  percent of national TANF recipient population, and 
<  geographic diversity 
Since our sample was purposeful, we do not project our findings.  We visited offices in the 
following States:  California, Florida, Idaho, Michigan, Minnesota, New York, Ohio, and 
Texas.  In each State, we visited at least two offices  an urban and rural office.  We 
conducted preinspection research in July and August 1998 in Maryland and Nevada prior 
to conducting our formal fieldwork which we concluded in November 1998. 
In total, we visited 26 TANF offices in 22 counties.  In each office, we conducted a focus 
group with caseworkers.  The focus groups varied in size from 2 to15 workers.  We also 
interviewed some caseworkers individually and conducted limited case-file reviews of 
recently sanctioned TANF clients.  We interviewed the director of the TANF office in 
each county and clients in 19 of the 26 offices.  The client interviews ranged in size from a 
single client to a group of more than 20.  The clients were selected either in advance by 
the TANF office or while they were present for other business during our visit.  We also 
collected and reviewed State and county policies, publications, and notices from each 
TANF office. 
In each State visited, we interviewed staff from at least one client advocacy organization. 
In total, we conducted 9 interviews with 15 advocacy groups. 
The methods we used during this study pose some distinct advantages and disadvantages 
for the scope of our findings.  The purposeful sample allowed us to examine sanction 
implementation in States with widely varying attributes.  We also gained a thorough 
understanding of our respondents relationships with and attitudes towards sanctions.  Our 
methodology precludes us, however, from commenting on the extent to which our 
findings and observations are representative nationwide.  We also cannot evaluate direct 
outcomes of sanction policies, procedures, and practices on clients and the program. 
1The primary factor for State selection was TANF recipient population reduction rates since TANF was 
implemented.  Based on the reduction rates, States were stratified into four groups, from which we chose two 
States from each group. While we would have preferred to use State sanction rates, reliable client sanction data 
for all 
50 States did not exist at the time we selected the sample. We felt that caseload reduction rates were the most 
reasonable proxy for sanction rates in selecting this purposeful sample. 
7 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  This is one of three OIG reports on how States administer client sanctions 
under TANF.  One companion report, Temporary Assistance for Needy 
Families:  Improving the Effectiveness and Efficiency of Client Sanctions 
(OEI-09-98-00290), provides a broad overview of State administration of 
client sanctions.  The other, Temporary Assistance for Needy Families: 
Improving Client Sanction Notices (OEI-09-98-00292), reviews State 
methods for informing clients of sanction decisions via written notices. 
8 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  F I N D I N G S  
TANF offices explain sanctions to clients repeatedly, using 
diverse methods 
Some TANF offices use multiple media to explain sanction policies to clients.  They 
conduct thorough orientation classes, show instructive videos in the waiting rooms, host 
on-site legal representatives, and issue well-labeled handouts and pamphlets.  The best 
offices have bi-lingual caseworkers, screeners, and translators to explain TANF policies 
and to answer client questions. 
Most caseworkers said they frequently discuss sanctions with clients.  They tell clients 
about sanctions during the screening process, at the orientation session, during one-on-one 
interviews and appointments, when reviewing the rights and responsibilities form, and 
while setting up individual responsibility plans.  A few caseworkers said they inform 
clients about sanctions only at a later time, usually when a client is not cooperating or is in 
the initial stages of the sanction process. 
More than two-thirds of TANF offices omit vital information 
about sanctions from their written client material 
In addition to providing clients with sanction information orally during interviews and

group meetings, all TANF offices provide written materials that explain most facets of the

States sanction policy.  Vital information about the sanction policies include:

<  causes for sanctions,

<  amounts of sanctions2,

<  durations of sanctions,

<  good cause reasons for work exemptions, and 

<  client appeal rights.

Only 31 percent of TANF offices provide clear and complete information on all of the

above areas of vital information.

2 By amounts of sanctions, we mean either the formula used to calculate the benefit reduction or a fixed 
monetary penalty. A 25 percent cash assistance reduction is an example of the former, and a set $75 penalty is an 
example of the latter. 
9 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  Orientation materials commonly lack information about the amount of the 
sanction and the definition of good cause 
Approximately half of the TANF offices do not provide clients with complete, correct, and 
precise information on the amount of sanctions.  For example, one orientation flyer read, 
If you refuse to participate in a [job search program] without good cause, you may lose 
all or part of your public assistance benefits until you agree to cooperate or for a period up 
to six months.  That States sanction policy does not include a full family sanction, 
although the passage implies that it does.  Although the minimum duration of the sanction 
in that State is indeed six months for the third instance of noncompliance, clients can be 
sanctioned indefinitely if they persist in not complying.  The passage implies that the 
sanction lasts six months, at most.  Nowhere else in the States orientation materials are 
sanctions explained in any more detail than the above passage.  In addition, the States 
orientation material addressing sanctions for not cooperating with child support 
enforcement includes only the following passage, Non-cooperation without good cause 
could result in the termination of [cash assistance] benefits.  Again, the material 
incorrectly implies that the State has a full-family sanction. 
Orientation materials frequently lack definitive information about good cause reasons 
for not complying with work requirements.  Many State and county materials use the 
phrase good cause to denote the legitimate reasons for exclusion from work 
requirements, but often do not actually define the term or give concrete examples.  For 
instance, one offices material reads, You have the right to claim good cause for not 
complying with a program benefit..., but nowhere on the document is there a definition or 
examples of what constitutes good cause. 
Most States describe all other vital information about sanctions completely and 
present it in a logical format 
Client orientation materials contain clear and complete information about most sanction 
details.  Approximately two-thirds of the TANF orientation materials we reviewed 
(1) include specific examples of reasons why a client may be sanctioned, (2) list the 
duration of sanctions, and (3) explain client appeal rights (see appendix A).  Some States 
successfully use their rights and responsibilities document to outline program 
requirements, compulsory activities, and potential consequences (i.e., namely sanctions). 
Some TANF offices effectively present information about the reasons for and the duration 
of sanctions in the orientation packets, on the TANF application, and in individual 
responsibility plans. The most informative documents explicitly describe each of the 
reasons for which a client may be sanctioned.  For example, an excerpt from one countys 
orientation packet reads, ...[if you] refuse to agree to a welfare to work plan, or fail to 
show proof of satisfactory progress in your activity, or quit or refuse a job, then the 
10 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  county can sanction you.  Materials often specify the duration of each level of sanction

(See appendix A for an example).

Most TANF offices provide clients with clear and complete information about client

appeal rights in rights and responsibilities documents, on the TANF applications, and in

booklets about TANF rules and policies.  Figure 1 illustrates one of the best documents

we reviewed.  In it, the terms conciliation and fair hearing are defined explicitly and

the processes and policies for both forms of dispute resolution are explained.  (See

appendix B for the complete document.)  The document also advises clients in seven

languages that the information contained is important. 

Figure 1 Appeal rights information excerpt 
Seven languages 
are used to 
explain the 
forms 
importance. 
Conciliation 
and fair 
Instructions on 
how to request a 
conciliation 
conference and 
fair hearing are 
Phone numbers 
for free legal aid 
are provided. 
11 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  Orientation materials often present information in a logical format.  About half of the 
orientation materials we reviewed include a separate packet that clearly distinguishes 
TANF sanction information from Medicaid or food stamps.  The language is clear and the 
terminology is well-defined (see appendix A).  The TANF offices often effectively 
emphasize sanction information by using large, bold fonts, printing the material on brightly 
colored paper, or repeating the information in several places throughout the orientation 
packet. 
Clients and advocates contend that TANF offices provide limited information 
about sanctions 
Clients commonly reported that they receive insufficient sanction information, and only in 
written form.  Almost half said they learned about sanctions through either orientation 
packets or written documents received in the mail.  Some explained that they only acquire 
information about sanctions from fliers and other clients.  Few clients said that they had 
received sanction information in both written and oral forms (e.g., from caseworkers or 
TANF office staff). 
Several advocacy groups explained that clients often are not well-informed about sanction 
policies.  The information provided to clients is frequently neither clear nor complete.  One 
advocacy group explained, The only thing clients know is whats in the guidebook.  The 
guidebook tells them that the grant will be reduced, but it doesnt tell them by how much. 
They also criticize TANF offices for failing to educate clients who do not speak English or 
who are illiterate.  One advocacy group claimed, If you cant read at all or if you speak a 
different language, then youre sanctioned. 
TANF clients do not fully understand sanctions and, 
according to caseworkers,  are not concerned about 
sanctions until they are imposed 
Clients rarely had more than a superficial knowledge of sanctions 
Clients in almost half of the focus groups did not completely understand the sanction 
policies imposed by their TANF offices.  In eight of the nineteen focus groups, clients 
were unclear about the amounts, durations, causes, and remedies of sanctions under 
TANF.  Clients said they would most likely be cut off if they failed to participate in the 
TANF program.  This was a common response, even in States and counties in which 
TANF offices impose partial sanctions.  Some clients had more incorrect information 
about sanctions.  For example, they reported that after awhile the sanction affects 
Medicaid, while in actuality the States sanction policy allows only for the removal of the 
12 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  adult from the TANF cash assistance.  A few clients knew most or all of the details about 
client sanctions under TANF. 
Caseworkers in a quarter of the focus groups confirmed that clients often do not 
comprehend sanction information.  Although caseworkers repeatedly inform clients about 
sanctions, many clients still do not understand.  Some clients often act like they dont care 
about sanctions when, in reality, they do not understand the information because of 
language barriers. 
A sanction often is not a concern to clients until it is imposed, according to 
caseworkers 
When a majority of caseworkers tell clients about sanctions, they are faced with clients 
who simply dont care.  While many caseworkers said that clients dont pay attention 
to the sanction details, other caseworkers echoed the sentiment that, Some clients say, 
Go ahead.  You cant sanction my kids. Clients also can become angry when they are 
first faced with the new sanction policies during orientation, according to some 
caseworkers.  Ninety percent of the clients I see to make the personal responsibility 
contract are mad.  Its a real escalated, emotional situation, one caseworker explained. 
Clients more frequently pay attention or react once they are sanctioned.  Most 
caseworkers reported that although clients will react when sanctions are imposed, their 
reactions are mixed.  Some clients call immediately after the sanction has been imposed, 
while others are never heard from again.  Most caseworkers agreed, however, that the 
first sanction gets [clients] attention. 
13 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  R E C O M M E N D A T I O N  
The Office of Inspector General recognizes that the TANF block grant program gives 
States broad authority to design programs that quickly move welfare clients to self-
sustaining employment.  There is a role for the Administration for Children and Families 
(ACF), however, in providing guidance to States. 
We recommend that ACF encourage States to provide complete, correct, and 
understandable information to clients on: 
<<  the causes of sanctions, 
<<  the amounts of sanctions, 
<<  the duration of sanctions, 
<<  good cause reasons for work exemptions, and 
<<  client appeal, fair hearing, and, if applicable, conciliation rights. 
AGENCY RESPONSE 
We received comments on the draft report from the Administration for Children and 
Families.  The agency concurred with our recommendation and stated that it is committed 
to working with States to improve State sanction information.  As an initial step, it will 
provide States with examples of effective sanction information and facilitate networking 
among States interested in improving their sanction information.  We made changes to the 
report based on the technical comments we received from the agency and clarified that we 
do not project our findings beyond the sample sites. 
14 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  APPENDIX A 
ORIENTATION INFORMATION WITH CLEAR, COMPLETE

AND CONCISE INFORMATION ON SANCTIONS, 

FAIR HEARINGS, AND GOOD CAUSE

15 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  16 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  17 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  18 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  APPENDIX B 
ORIENTATION INFORMATION CONTAINING

THOROUGH APPEAL RIGHTS INFORMATION

19 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  20 
TANF  Educating Clients about Sanctions  OEI-09-98-00291  21 
TANF  Educating Clients about Sanctions  OEI-09-98-00291