Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
TEMPORARY ASSISTANCE 
FOR NEEDY FAMILIES 
Improving Client Sanction Notices 
JUNE GIBBS BROWN 
Inspector General 
OCTOBER 1999 
OEI-09-98-00292  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 evaluate sanction notices sent to clients of the Temporary Assistance for Needy 
Families (TANF) program. 
BACKGROUND 
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 
(PRWORA, P.L. 104-193) significantly overhauled the Federal welfare system.  The 
previous Aid to Families with Dependent Children (AFDC) entitlement program 
guaranteed Federal benefits to all eligible participants.  The PRWORA replaced AFDC 
with TANF, a block grant program with strict participation requirements and a 5-year cap 
on Federal cash aid.  Under TANF, States are granted the authority and flexibility to 
design programs that move clients from welfare to self-sustaining employment, but must 
meet rigorous performance measures. 
States use financial sanctions  monetary penalties applied to clients cash aid  to 
enforce participation with certain Federal and State provisions of TANF.  All States must 
sanction clients who fail to participate in work activities or child support enforcement. 
Individual States may, at their discretion, sanction clients who do not cooperate with other 
requirements.  Minimum amounts and durations of sanctions are prescribed by Federal 
law, but States determine maximum penalty levels. 
Sanctioned clients may attempt to cure a sanction informally by complying with program 
requirements or establishing good cause for not participating.  Alternatively, they may 
formally request an appeal to determine if the sanction was appropriate.  Depending on the 
timing of the cure or appeal, clients can sometimes resolve a sanction dispute before their 
benefits are reduced or terminated. 
State and county TANF offices send sanction notices to notify clients of sanction 
decisions.  Little guidance is provided to States on developing sanction notices, and our 
preinspection research revealed that these notices vary widely in quality and content. 
Thus, we determined that an evaluation of sanction notices was warranted. 
We purposefully selected eight States in which to visit at least one urban and one rural 
office.  In total, we visited 26 TANF offices, where we held caseworker focus groups, 
director interviews, and limited case-file reviews of recently sanctioned cases with 
individual caseworkers.  At 19 of the offices, we conducted client focus groups and also 
1 
TANFImproving Client Sanction Notices  OEI-09-98-00292  interviewed at least one advocacy group in each State.  In addition, we collected sanction 
policies and notices from each State.  Lastly, we reviewed 47 notices issued by the offices 
that we visited, evaluating each for completeness and clarity. 
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. 
FINDINGS 
Comprehensive and understandable notices can improve the sanction process. A 
sanction notice with complete information in a clear format can improve client 
understanding and help alleviate frustration for both clients and caseworkers. 
Sanction notices are deficient in some respects.  Although most notices adequately 
explain some sanction details, many lack instructions on how to cure sanctions and do not 
reference local legal aid.  A few notices contain incorrect information which can mislead 
clients and create extra work for caseworkers.  Confusing wording on notices impedes 
client understanding, an effect heightened by language barriers. 
RECOMMENDATION 
We recommend that the Administration for Children and Families encourage States to 
issue comprehensive and understandable sanction notices with information on (1) the 
amount, duration, and cause of the sanction, (2) names and phone numbers of specific 
contacts in the TANF office or service provider who will have more information about the 
sanction, (3) how to cure the sanction, (4) client appeal, fair hearing, and, if applicable, 
conciliation rights, and (5) referral(s) for local legal assistance. 
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 notices.  It will provide States with 
2 
TANFImproving Client Sanction Notices  OEI-09-98-00292  examples of understandable and comprehensive sanction notices and facilitate networking 
among States interested in improving State sanction notices. 
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: 
Educating Clients about Sanctions (OEI-09-98-00291), describes how States 
communicate to clients the changes in sanction policies and procedures. 
3 
TANFImproving Client Sanction Notices  OEI-09-98-00292  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

Curing and appealing sanctions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Sanction notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Comprehensive and understandable notices  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Incomplete notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Incorrect notices  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Confusing notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  9

RECOMMENDATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11

APPENDICES 
A:  Comprehensive and understandable notice  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

B:  Detailed secondary notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  14

C:  Incorrect and confusing notice  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4 
TANFImproving Client Sanction Notices  OEI-09-98-00292  I N T R O D U C T I O N  
PURPOSE 
To evaluate sanction notices sent to clients of the Temporary Assistance for Needy 
Families (TANF) program. 
BACKGROUND 
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 
(PRWORA, P.L. 104-193) significantly overhauled the Federal welfare system.  The 
previous Aid to Families with Dependent Children (AFDC) entitlement program 
guaranteed Federal benefits to all eligible participants.  The PRWORA replaced AFDC 
with TANF, a block grant program with strict participation requirements and a 5-year cap 
on Federal cash aid.  Under TANF, States are granted the authority and flexibility to 
design programs that move clients1 from welfare to self-sustaining employment, but must 
meet rigorous performance measures. 
Client Sanctions Under TANF 
Financial sanctions  monetary penalties applied to clients cash aid  enforce 
cooperation with certain TANF program requirements.2  Federal TANF law directs States 
to sanction clients for failure to participate in work activities and noncooperation with 
child support enforcement efforts.  States also may sanction clients who fail to follow 
other guidelines, such as child immunization and school attendance requirements, or who 
fail to attend required meetings or other program activities (e.g., training sessions). 
States may develop unique sanction policies within parameters set by TANF.  They are 
required, at minimum, to apply a pro rata benefit reduction for each month a client 
receives aid and is not in compliance.  States are free, however, to determine maximum 
sanction amounts and durations, including full-family sanctions and lifetime exclusion from 
the program.  Some use tiered sanctions, with progressively stiffer penalties for each 
instance of noncompliance. 
1For the purposes of this report, a TANF client is the head or heads of a family receiving cash aid. 
2Clients exempted from program requirements for good cause reasons, such as unavailability of child 
care and danger of domestic violence, are not subject to sanctions. 
5 
TANFImproving Client Sanction Notices  OEI-09-98-00292  Curing and Appealing Sanctions 
Informal conciliation processes in some States allow clients and TANF offices to resolve 
any disputes involving a sanction.  Clients who receive notices may attempt to cure the 
sanction by complying with program requirements or establishing good cause.  If done 
promptly, clients benefits remain intact.  If not, clients may have full benefits restored 
only after the minimum sanction duration has expired.3 
If conciliation is unsuccessful or unavailable, clients in all States have the right to appeal a 
sanction.  Clients who submit an appeal within State time frames can opt to continue their 
full benefits or accept the reduced benefit level while the appeal is decided.  Clients who 
continue full benefits and lose the appeal must return overpayments to the TANF agency. 
Conversely, the TANF agency must pay back benefits to clients who win the appeal and 
had their benefits reduced. 
Sanction Notices 
To notify clients of sanction decisions, TANF offices issue one or more written sanction 
notices.4  Offices also have the responsibility to inform clients of conciliation processes (if 
applicable), their appeal rights, and their right to legal counsel.  A notice of intent often 
is sent to clients when the initial noncompliance occurs, warning that a sanction is 
imminent if not cured or appealed.  Offices issue a second notice when the actual benefit 
reduction takes place. 
The TANF legislation provides little guidance to States on the development of sanction 
notices, and our preinspection research indicated a wide range in their quality and content. 
Thus, we determined that an evaluation of sanction notices was warranted. 
METHODOLOGY 
We purposefully selected an eight-State sample to capture diversity in: 
<  percent reduction in TANF recipient population,5 
<  State policies on TANF client sanctions, 
<  percent of national TANF recipient population, and 
<  geographic location. 
3The specific processes and time frames for curing sanctions differ by State. 
4States may elect to notify clients by other means, such as phone calls, in addition to sanction notices. 
5Caseload reduction rates were used as a proxy for sanction rates, as reliable client sanction data for all 
50 States did not exist when we selected the sample. 
6 
TANFImproving Client Sanction Notices  OEI-09-98-00292  We visited at least one urban and one rural office in the following States:  California, 
Florida, Idaho, Michigan, Minnesota, New York, Ohio, and Texas.  In total, we visited 26 
local TANF offices. 
We gathered data from diverse sources to obtain a balanced picture of sanctions.  At each 
of the TANF offices that we visited, we held focus groups with caseworkers, interviewed 
the director, and performed limited case-file reviews of recently sanctioned cases with 
individual caseworkers.  In 19 of the sites, we conducted focus groups with clients and 
also spoke with at least one client advocacy group in each State.  In addition, we collected 
sanction policies and publications.  Lastly, we reviewed 47 notices issued by the offices 
that we visited, evaluating each for completeness and clarity.6 
The methods 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 thorough 
information on 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. 
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: 
Educating Clients about Sanctions (OEI-09-98-00291), describes how States 
communicate to clients the changes in sanction policies and procedures. 
6The office was our unit of analysis rather than the notice, as some offices send multiple notices. For 
these offices, we aggregated information contained on all notices for our evaluation. 
7 
TANFImproving Client Sanction Notices  OEI-09-98-00292  F I N D I N G S  
Comprehensive and understandable notices can improve the 
sanction process 
A sanction notice with complete information in a clear format can improve client 
understanding and help alleviate frustration for both clients and caseworkers.  We spoke 
with several clients who had received sanction notices and were unsure of whom to 
contact to discuss their situations.  In addition, caseworkers noted that they spend an 
inordinate amount of time with sanctioned clients, explaining the reasons for the sanctions 
and the actions required to achieve compliance. 
Notices must contain some crucial information for clients to understand both their 
sanctions and their rights.  Comprehensive sanction notices provide: 
<  the amount, duration, and cause of the sanction, 
<  the name and number of the clients caseworker, 
<  instructions on how to cure the sanction, 
<  an explanation of the clients appeal rights, and 
<  referrals for free legal assistance. 
The information can be presented in a variety of effective formats, but the best notices 
clearly explain each of the key elements above with straightforward wording.  These 
notices highlight their seriousness in multiple languages and emphasize the important 
sections with large, bold type.  Examples of such notices appear in appendices A and B.7 
Most sanction notices lack some key elements 
Clients must know how to cure a sanction in order to have full benefits reinstated, but only 
one-third of the sanction notices explicitly provide this information.  For example, one 
countys sanction notice reads, . . . you must show that you are willing to comply with 
employment program requirements to meet eligibility requirements, but does not specify 
the exact actions a client must take to demonstrate a willingness to comply.  Only a few 
of the sanction notices fully explain the steps required to cure a sanction.  In order to end 
the sanction you must do the following . . .  reads one notice, allowing the caseworker to 
fill in details for individual clients. 
7The notices in appendices A and B are from the same office. The first is sent at the initial instance of 
noncompliance, the second when the actual benefit reduction takes place. 
8 
TANFImproving Client Sanction Notices  OEI-09-98-00292  Clients have the right to representation in sanction disputes, but more than one quarter of 
the notices give incomplete or no information on contacting local legal services.  Instead 
of directly referencing a local legal organization, some sanction notices state, If you want 
to know more about how a fair hearing process works or to find out if free legal help is 
available, contact your local [TANF] Agency.  Clients likely would be reluctant to 
contact the agency imposing the sanction to seek help with an appeal. 
Notices more consistently outline other sanction details.  More than three-quarters 
effectively relate the amount of the sanction, the reason(s) for the sanction, the name and 
number of the caseworker whom the client should contact, and the appeal rights of the 
client.  Almost two-thirds provide complete information on the length of the clients 
sanction.  Those that do not usually give a start date for the sanction, but do not specify its 
minimum duration. 
Notices with incorrect information complicate the sanction 
process 
A few notices contain incorrect information that can create extra work for caseworkers 
and cause anxiety for clients.  For example, the notice in appendix C clearly states, You 
will not be eligible for Medicaid after 08/31/98.  According to the issuing States policy, 
however, TANF clients cannot be removed from Medicaid for nonparticipation in TANF 
programs or noncooperation with child support enforcement efforts.  Thus, caseworkers 
must manually fill in the correct details on the last page of the notice and cross out the 
incorrect information.  If left uncorrected, clients will be misinformed of the status of their 
medical benefits. 
Sanction notices are sometimes difficult to understand 
Confusing wording can complicate sanction details.  For instance, the notice on the next 
page is unclear on the amount of the sanction.8  The notice first informs the client, at point 
A, that her household will be receiving a $188 TANF grant.  Then, at point B, the notice 
states the clients benefit will be reduced from $188 to $110 because of noncompliance. 
The comments section (point C) further clouds the message by adding that the benefits 
will be reduced by $78.  The notice in appendix C provides another example of confusing 
language. 
8The comments section in this notice originally appeared on two separate pages. The template for the 
second, which mentions the clients appeal rights and gives a contact for free legal services, is identical to page 3 
of the notice presented in appendix C 
9 
TANFImproving Client Sanction Notices  OEI-09-98-00292  Example of Confusing Sanction Notice 
A 
B 
C 
Several TANF offices send notices in only a few languages despite the diversity of their 
clients.  In one area, the TANF office issues notices only in English although one-third of 
its clients speak only Spanish, according to the local advocacy group.  I get six to eight 
clients a week who get notices from [the TANF office] that they dont understand, 
reported another advocacy representative. 
10 
TANFImproving Client Sanction Notices  OEI-09-98-00292  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 issue understandable and 
comprehensive sanction notices with information on: 
<<  the amount of the sanction,

<<  the duration of the sanction,

<<  the cause of the sanction,

<<  names and phone numbers of specific contacts in the TANF

office or service provider who will have more information about 
the sanction, 
<<  how to cure the sanction, 
<<  client appeal, fair hearing, and, if applicable, conciliation rights, 
and 
<<  referral(s) for local legal assistance. 
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 notices.  It will provide States with 
examples of understandable and comprehensive sanction notices and facilitate networking 
among States interested in improving State sanction notices. 
11 
TANFImproving Client Sanction Notices  OEI-09-98-00292  APPENDIX A 
Notice that Contains Clear Information in Multiple Languages

Highlights 
importance in 
seven languages 
Includes specific 
sanction amounts 
Gives reason for 
the sanction 
Clearly tells how 
to lift sanction 
and whom to 
contact 
12 
TANFImproving Client Sanction Notices  OEI-09-98-00292  Clearly explains 
appeal and 
conciliation 
rights 
Gives number 
for legal aid 
13 
TANFImproving Client Sanction Notices  OEI-09-98-00292  APPENDIX B 
Detailed Notice of Benefit Reduction

(Follows Notice in Appendix A)

Shows benefit 
recalculation 
14 
TANFImproving Client Sanction Notices  OEI-09-98-00292  APPENDIX C 
Notice that Contains Incorrect and Confusing Information

Incorrectly states 
that Medicaid is 
sanctioned 
Vague 
information 
Confusing 
information 
15 
TANFImproving Client Sanction Notices  OEI-09-98-00292  No correction of 
prior statement 
of Medicaid 
sanction 
16 
TANFImproving Client Sanction Notices  OEI-09-98-00292  17 
TANFImproving Client Sanction Notices  OEI-09-98-00292