,. 
Department of Health and Human Servces 
OFFICE OF 
INSPECTOR GENERAL 
FUNCTIONAL IMPAIRMENTS 
OF AFDC CLIENTS 
.. SERVICe,.. 
Richard P. Kusserow 
INSPECTOR GENERA 
1- 90-0 
OEI-0-
cl3a  EXECUTIVE  SUMMAR Y 
PUROSE 
The purpose of this inspection is to determine whether and how States with Job 
Opportunty and Basic Skis (JOBS) experience are systematically identifng and 
dealig with the functional impairments of Aid to Familes with Dependent Children
(AFC) 
clients. 
BACKGROUN 
The Aid to Fames with Dependent Children when enacted in 1935, had as its initial 
widowed mothers to stay at home with their children. Its phiosophy 
intent to allow 
shifted with the Family Support Act of 1988 into assisting needy chidren and parents 
in movig from welfare dependency to self-sufficiency. 
To promote the philosophy of self-suffciency, the Famiy Support Act requires that 
States develop a JOBS program, an education, traiing and employment program 
intended to help AFDC clients avoid long-term dependence. 
A 1988 study for the Assistant Secretary for Planning and Evaluation (ASPE) on 
functional impairents in the AFC population determined that nearly one in four 
AFC 
women on  under the age of 45 reported themselves as functionally impaired in 
contrast to one in eleven non-AFDC women. 
A study completed recently for ASPE by Child Trends, Inc. evaluated AFDC mothers 
as potential employees. It found that most of these women have a 
liited education 
score below average on verbal and math skills tests, and have had little work 
experience, are long-term welfare recipients and report health problems, alcohol abuse 
and depression. 
METIODOLOY 
This inspection was conducted in three phases: 1) telephone intervews with managers 
of the State welfare offces and with JOBS program directors in the 25 States which 
have had a JOBS program in place for at least one year; 2) site visits and telephone 
discussions with program managers and clients in eight local programs which have 
especially effective practices in helping the functionally impaired; and 3) an analysis 
and comparison of the States' AFDC and JOBS assessment forms.  The term fuctional impairment is defied for the purpose of this inspection as any 
chronic physical or mental barer which may prevent an individual from leavig
welfare and becomig self-sufcient. These impairments affect an individual's abilty 
to succeed in the JOBS program and become employed. Respondents were given this
broad defition of a fuctional impairent prior to the intervews. 
FIINGS 
Resnd 
Cli; 
Ide A Varity Of Impair Amng AFDC  Learning 
Diabil An  Mos Freq Menne 
Substnce Abuse Are  Th 
Respondents identif a varety of impairments among AFDC clients such as learning 
disabilties; substance abuse; low back pai; emotional, hearig, visual and dental 
problems; domestic violence and obesity. These impairents often contribute to low 
self esteem, frequently mentioned by respondents as a major problem, and serve as 
barrers to self-suffciency. 
Ide  Partpatin  Impair
Jobs Program  InceaSes Chances Of Havg Funtinal 
A comparson of JOBS and AFC eligibilty assessment forms shows that the JOBS 
forms ask more questions which might reveal functional impairments. The JOBS 
program directors are more confdent than AFC program directors that their initial 
assessment process does in some way identify functional impairents. Whle AFDC 
respondents think that impairments might be identifed during the AFDC eligibilty 
assessment, most stress that this assessment basically consists of a 
fiancial evaluation. 
Participation in various JOBS activities provides fuher opportunities for identifyng 
the functionally impaired. 
Ide 
Proble Ex In Dealig Wll  Funnal Impairts 
Whle referral does occur, it is not formal and there is little follow-up. Both AFDC 
and JOBS directors state that afer an impairment is identified the client is referred to 
appropriate servces, which in most cases consists solely of givig the client a 
telephone number or making a phone call. 
Additional obstacles which prevent clients from getting the servces they 
need include 
lack of avaiable publicly fuded servces, lack of transportation and lack of 
coordination among the various assistance programs. 
Funnal Impair 
State Do Not Coll Agegate Data On  AFDC 
Popultin  In  Th 
States do not collect systematic data on these impairments. When an impairment is 
identifed, it is generally recorded, on the client's individual case record, but it is not  usually collected on an aggegate level in anyone central place on either a local or 
State level. 
Some Loal Prams Are Escill Help  Funnall Impaired 
To  Th 
Special programs at the local level (all contracted through JOBS) were identifed 
which employ a variety of ways to facilitate self-suffciency in the functionally impaired. 
accommodate clients with functional impairments and to assist 
All are structured to 
them in achieving self-suffciency. 
RECOMMATIONS 
States should develop mechanisms to assure appropriate identifcation, referral 
and follow-up of clients with functional impairments. These mechanisms could 
include: 
in-depth assessments with questions and features specifcally targeted 

functional impairments

AFC 
training  and JOBS workers to identify functional impairments

and

improved links with local programs which serve the functionally 
impaied, particularly with regard to follow-up. 
The Admiistration for Chidren and Familes should assist States and local 
governments by publicizing effective practices for identifyg, referrng and 
servng the functionally impaired. 
The Administration for Children and Families should conduct research on the 
extent and nature of impairents and interventions. As suggested in ASPE' 
comments to the draft report, this research could include coordination with 
research units whose primary focus is disability. 
COMM 
Comments to the draf report were received from the Administration for Children and 
Famies (ACF) and the Assistant Secretary for Planning and Evaluation (ASPE) and 
appear in Appendix A. We have considered these comments and made changes 
where appropriate. 
In response to the first recommendation, the ACF expresses interest in workig with 
States to address the problem. While they cite fiscal constraints on States as a 
wi 
possible liting factor, they nevertheless  encourage States to look for 
impairments to a participant's successful transition to self-suffciency. They 
acknowledge that existing JOBS regulations wi be helpful in this regard.  Both ACF and ASPE expressed concern that the defiition for functional impairment 
response to these concerns, we 
used in this report is too broad and unclear.  In 
amended the report to clari the meanng of functional impairment. Prior to our 
study the nature and extent of this problem was largely unknown. Our goal was to 
preliary 
make a  identifcation of the various tyes of impairents in order to assist 
researchers and program administrators in comig to grps with functional impairents 
AFC 
of the  , we thought it important not to restrict our 
population. Therefore
defiition to any specifc conditions. Clearly, much more research is needed to define 
the problem and develop remedies.  ................................................ 
. . . . . . . . . .. .  ..  ..  ..  ..  ....  
. ..  ..  ..  ..  ..  ...   ...   ....    ....    ....    .....     .....     ......      .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       .......       ......      .....     .....     .....     .....     .....     ....    ....    ...   ...   ...   ..  ..  . 
TABLE OF CONTENTS 
EXCU SUMY 
INODUCfON 
FIINGS 
. . . . . . . . . . . . . . . . . . . 4
A Variety of Impairents  . . . . . 4
JOBS Identifcation of Functional Impairments  . . . . . . . . . . . . . . . . . . . . . . . . 4
Problems in Dealig with Functional Impaients . . . . . . . . . . . . . . . . . . . . . . 6
Data Collection . . . . . . . . . . . . . 7
Helpful Local Programs . . . . . . 8
RECOMMATIONS
COMM 
.APENDIX A . . . . . . 
. . . . . . . . . A- .. 
INTRODUCTION
PUROSE
The purpose of this inspection is to determine whether and how States with Job
Opportunity and Basic Skils (JOBS) experience are systematically identifyng and
dealig with the functional impairents of Aid to Famies with Dependent Children 
(AFDC) clients. 
BACKGROUN
AFDC
The Aid to Familes with Dependent Chidren has as its purpose, as indicated in Title 
IV of the Social Security Act (Part A, Section 401) "  encouraging the care of 
dependent chidren in their own homes.. by enabling each State to furnish fiancial 
assistance and rehabiltation and other servces to needy dependent children and the 
II The AFDC program is admistered 
parents or relatives with whom they are living. 
by States, but funded jointly by the Federal and State governments.
A family unit becomes eligible for AFDC when a dependent child, under 
18 years of 
age, is deprived of parental support for various reasons: a parent's death, a parent' 
mental or physical incapacity, a parent's absence from the home and, in 29 States, the 
parent s loss of employment. Although eligibilty may be based on any of the above 
factors, the father s absence from the home is the priary and major reason for 
program eligibilty. Therefore, even if a client may have a functional impairent, that 
impairment may not be noticed because eligibilty is based on the father 
s absence 
from the home.
When enacted in 1935, the program s intial intent was to allow widowed mothers to 
stay at home with their children, its philosophy shifted with the Family Support Act of 
ais 
1988. It now  to assist needy children and parents in moving from welfare 
dependency to self-suffciency. 
JOBS
To promote the phiosophy of self-suffciency, the Family Support Act requires that 
States develop a JOBS program, an education, training and employment program 
AFC 
intended to help  clients avoid long-term dependence. States must enroll seven 
percent of the eligible population by 1991, rising to 20 percent by 1995. Clients are 
assessed to determine their 
trainig needs and to develop an employabilty plan.
Whe all States have now implemented JOBS, some programs have been in operation 
longer than others.  The exposure of the AFDC population to JOBS, however, remais lited. As 
AFC 
indicated above, JOBS is only reaching a small portion of  clients. Nineteen 
States did not begin their JOBS program until the last possible date, October 1, 1990 
and not all have implemented it Statewide. Preliinary data for the second quarter of 
Fiscal Year  2 mion adult AFC 
1991 indicates that out of approximately 4. 
recipients, 510 000 (12 percent) are in JOBS activities at anyone point in time. This 
number is expected to increase as the program expands. State budget constraints are 
causing States to use only a par of available Federal matching funds. 
Stu
Prr 
Plang 
A 1988 study for the Assistant Secretary for  and Evaluation (ASPE) on 
fuctional impaients in the AFC population determined that nearly one in four 
AFC 
women on  under the age of 45 reported themselves as functionally impaired. 
AFC 
In contrast, only one in eleven non- women reported having a functional 
impairment. The data was derived from self-reported information on the client' 
abilty to function. 
A study completed recently for ASPE by Child Trends, Inc. evaluated AFDC mothers
as potential employees. It found that most of these women have a limited education
score below average on verbal and math skis tests, and have had litte work
experience. Also, one-half of the mothers are long-term welfare recipients. Some also
report health problems, alcohol abuse and depression. Whe this study targeted
barrers to employment, it did not specifcally look at functional impairents.
Other than these two studies, limited literature exists regarding functional impairments
in AFC. Also, little is known about what, if any, State procedures are used to
identif fuctional impairents of AFDC clients.
METIODOLOY
This inspection was conducted in three phases. Intially, the study team conducted
telephone intervews with managers of the State welfare offces (AFC respondents)
and with JOBS program directors (JOBS respondents) in the 25 States which have had
a JOBS program in place for at least one year. A total of 49 telephone intervews
were completed (one welfare manager could not be contacted).
Durig these intervews, the team asked JOBS program directors questions about
clients in their caseloads who have functional impairments, how they assess these
clients, whether and how they identified the functional impairents of these clients
and, once identifed, how the referral process works. Similarly, the team asked State
welfare managers to indicate whether and how they identifed functionally impaired
clients other than through JOBS and, once identifed, how the clients are referred.
Additionally, both tyes of respondents also provided their perceptions of the
characteristics and problems of this population. The term fuctional impairment is defied for the purpose of this inspection as any 
chronic physical or mental barrer which may prevent an individual from leaving 
welfare and becoming self-suffcient. These impairments affect an 
individual's abilty 
to succeed in the JOBS program and become employed. Respondents were 
given this
broad defiition of a functional impairent prior to the intervews. 
In the second phase, the study team collected and reviewed JOBS assessment forms 
AFC 
from 24 of the 25 States and  assessment forms from 14 of the 17 States in 
which the welfare manager thought the eligibilty assessment could 
identif functional 
impairents. The team utiled a worksheet listing features and questions on these 
forms, such as whether the individual had a barrer to employment, which were likely 
to identify functional impairents. It then checked each assessment form against this 
worksheet to determine how many of the features and questions it possessed. 
Lastly, the team chose four special programs at the local level for site visits and four 
for telephone intervews with the program managers. These eight were chosen from 
24 programs cited by State respondents as having some effective practices in helping 
the functionaly impaired. The four programs intervewed by phone were in 
Pennsylvania, Kansas, Nebraska and Iowa. The four visited were in New Jersey, 
Michigan and New Hampshire. They were chosen because they might exemplify some 
best practices for identifyg and/or servg AFC clients with functional impairments 
and because they appeared to demonstrate a variety of different program practices 
and phiosophies. The team held face-to-face discussions at each site with case 
managers or program staff to gain greater insight into the operations of the programs. 
Seventeen program clients, selected either by the program manager or the visiting 
team, provided their views of the program to the team. 
lited 
Since  literature and data exist on functional impairents in the AFDC 
population, this study was exploratory in nature. It surveyed program offcials to 
determine basically what is known about functional impairments and to identify the 
issues pertaing to this problem.  , "
FINDINGS

Impir 
Var 
Respond Ide A  Of  Amng AFDC Clits; Learning 
Freq Menne 
Diabil An Substae Abuse  Most 
Are  Th 
AFC 
All  and JOBS program directors agree that learnng disabilties, substance 
abuse, physical problems such as low back pain, and emotional problems, such as 
AFC 
depression, exist in the  population. These emotional problems are not routine 
but are severe enough to interfere with functionig. Other impairents include: 
hearing and visual problems, dental problems, domestic violence and obesity. 
Respondents based their opinions priariy on their own experience and observations 
in the field, and to a lesser extent on formal testing. 
These impairents often contribute to low self esteem, frequently mentioned by 
respondents as a major problem, and serve as barriers to self-suffciency. Many clients 
have multiple impairents and come from dysfunctional famies. 
AFC 
Many  clients do not have a high school diploma or equivalent, which many 
respondents feel is due in large par to the widespread existence of learng 
disabilties. Many clients were not successful in school and simply dropped out, never 
being identifed as learng disabled and, therefore, never received special education. 
Most were not even aware of their problem. One AFDC respondent reflects the 
views of several when he says  Fif-one percent of AFC clients do not have a high 
school degree and probably most of them have a learning disabilty." Another agrees 
that "there is a sense that a lot of literacy clients are learing disabled." Respondents 
described a learnng disabilty not as a major neurological condition, but as an 
impairment that makes learng difcult, such as dyslexia. 
AFC 
The  and JOBS directors also consider substance abuse to be prevalent in the 
AFDC population. They believe this impairment can be easily masked and only 
discovered if the client happens to be under the infuence of the substance whie in 
contact with program workers. 
Partin 
JIOdBS ePr am  Inceases Chnces Of Havig Funnal Impairts
Initial JOBS assessments are more likely to identify impairments than AFDC 
eligibility assessments. 
AFC 
A comparison of JOBS and  eligibilty assessment forms shows that the JOBS 
forms ask more questions which might reveal functional impairents. Al the JOBS 
employabilty, as opposed to only 36 percent of 
forms specifcally ask about barrers to 
AFDC eligibilty forms. Fift-five percent of JOBS forms, in contrast to 14 percent of 
AFC forms, focus on substance abuse problems. Also, 45 percent of JOBS forms 
target emotional health problems, while very few (13 percent) AFDC forms do.  Finally, JOBS forms are twce as likely as AFDC forms to have a worker observation
section that instructs workers to record observations about client functioning and 
behavior. 
The review of JOBS assessment forms also shows that approximately one-third call for 
testing which might reveal functional impairments. Th-six 
percent have skis 
testing and reading/teracy testing, and 27 percent test math skils. In those same 25 
States, no testing of any kid is conducted as part of the AFC eligibilty assessment. 
JOBS ASSESSMENT FORMS TARGET FUNCTIONAL IMPAIRMENTS 
MORE THA AFDC FORMS
100
Legend 
% OF AF FOMS WI THIS FETURE 
II % OF JO FOMS WI THIS FE11RE 
QUBEEASMAEI RP 1L\  OBATI  TENG
SUBSAN
The JOBS program directors are more confident than AFC directors that their initial 
assessment process does in some way identify functional impairments. Whe AFDC 
respondents think that impairments might be identifed durig the AFC eligibility
assessment, most stress that this assessment basically consists of a financial evaluation
lited 
mostly to questions about finances and family situation. On the other hand
most JOBS respondents report that their assessment has more detailed questions
about the clients' background and barrers to employment. One AFDC respondent 
suggests that "If more people could at least get through the JOBS assessment, that 
would be the most effcient, cost-cutting way to identify impaients because the  , "  , " , "
assessors for JOBS are case managers. JOBS assessments should become a 
requirement." 
Both AFDC and JOBS respondents generally agree that if an impairment is identifed 
in an intial assessment, it usually occurs as a result of questions asked during the 
intervews, worker observation, and testing. 
The JOBS assessors tend, on the whole, to be more qualified educationally and 
AFC 
experientially than their  counterparts. In all but one of the 25 States, at least 
75 percent of JOBS assessors have college degrees, whereas in only four of those 
States can the same be said for AFDC assessors. In 64 percent of the States, more 
than half the JOBS assessors have prior case management experience; in none of the 
States do more than hal of the AFC workers have prior case management 
experience. Also, the AFC directors report that because their staff have very large 
case loads, they may not have suffcient time to note subtle client impairments. One 
respondent reflects a prevailng view when she says  You can t identif and do volume 
servce at the same time. 
Partcipation in JOBS program activities provides further opportnities to identify 
the functionally impaired. 
Six-eight percent of JOBS program directors report that participation in later JOBS 
activities, such as traing or workshops, is likely to reveal a client s functional 
impairments because it demonstrates the client
s abilty to function in a structured 
setting. One JOBS respondent reflects the view of many when he states  It is very 
hard to identif subtle impairments if the person doesn t disclose it. They may show 
up down the road but the initial assessment isn t enough time to do it." Another states 
that  When the client begins participation in an actual component, they have to come 
every day to a program and you see problems with attendance, behavior and 
consistency in terms of performance. 
In contrast to the JOBS experience, only several AFDC respondents report that 
impairents may be picked up durig additional contact with the client, such as 
ongoing case management; they stress that this is often informal and by chance. 
Ide 
Prble Ex In Dealig Wih  Funtinal Impain 
While refe"als do occur, they are often informal with little 
follow-up. 
The AFDC and JOBS program directors report that after an impairment is identified
the client is referred to servces such as substance abuse treatment, medical and 
mental health servces, social servces and vocational rehabiltation. In most cases 
referral consists solely of givig the client a telephone number or makg a phone call. 
Limited follow-up also hinders the referral process. As one AFDC respondent states 
Follow-up is important. Otherwse the client wi be back on the rolls." Many  respondents blame large case loads and insuffcient staffng and resources for this lack 
of follow-up.
AFC 
Both  and JOBS respondents mention particularly that if clients have chronic 
disabilties that would make them eligible for SSI, they would definitely be referred. 
However, many of these disabilties are not severe enough for them to 
qualify for SSI. 
AFC 
One  respondent reports that her State "is in serious budget trouble, so we have 
to look very hard for people who could be put on SSI so the Feds, not the State, pay 
for them. 
A number of additional obstacles prevent clients from getting the servces they need.
Six-four percent of respondents cite a lack of available publicly funded servces, as 
exemplied by the long waiting lists at many substance abuse treatment centers. Fift 
two percent mention lack of transportation. Lack of coordination among the various 
assistance programs is also mentioned. 
The functionally impaired face other obstacles to self-suffciency. 
A majority of AFDC and JOBS program directors believe the functionally impaired 
face other barrers to self-suffciency. Almost all mention that these clients have a 
diffcult time fiding and retaining work that pays enough to get off the AFDC rolls. 
Over hal the respondents state that there are not enough programs, servces or 
training opportunities specifcally suited to the functionally impaired. Some other 
obstacles include transportation problems and housing difficulties. 
Full-time JOBS participation may be difcult for the functionally impaied. In order 
for States to meet the requirements for JOBS Federal funding, the JOBS participation 
rate in each State must average 20 hours per week for each participant. However 
several respondents mention that this rate may be diffcult to reach due to this 
population s impairents. Because a functionally impaired client might not initially be 
able to tolerate 20 hours of classroom instruction, other recipients' participation rates 
wi have to be proportionately higher in order for a State to reach the required 
participation rate. 
Impair 
State Do Not CoHect Agegate Data On Funtinal  AFDC 
In  Th 
Popultin 
Alost  AFC 
all JOBS and  respondents state that when a functional impairment is 
identified, it is generally recorded, usually on the client's individual case record. 
Employabilty plans, referral forms, test results and assessment forms were mentioned 
as other places where impairments might be indicated. However, while such 
inormation may be maintained in an individual case record, it is not usually collected 
on an aggegate level in anyone central place on either a local or State 
level. Several 
respondents point out the fact that the collection of such data is not a program 
requirement.  Whe awareness of the problem exists, it is not usually quantified. When JOBS and 
AFDC respondents were asked to specif the number of individuals identified as 
impaients 
having fuctional  over the past year, most could not give an exact figure. 
Those who did offered only estimates, rangig widely from two to eighty percent. 
Es 
Hel 
Some Loal Pram Are  Funnall Impaired 
To  Th 
Special programs at the local level employ a variety of ways to facilitate self
suffciency. 
AFC 
Both JOBS and  respondents mention several local programs with effective 
practices for helping the functionally impaired. Of these, the study team chose eight 
for onsite visits or telephone intervews (a forthcoming case study report wi profie 
the eight programs in greater detail). All eight accommodate clients with fuctional 
impaients and to assist them in achieving self-suffciency. These programs include: 
traing 
general equivalency degree (GED)  classes with special activities for the 
learng impaired; intensive, in-depth client assessments; programs specifically for 
long-term welfare recipients, the majority of whom are functionally impaired; and 
intensive, multi-focus group workshops. These programs were later found to be 
contracted through JOBS. 
The managers and instructors in all eight programs, say that at least half their clients 
have a functional impairment, with many havig multiple impairments. With the 
opportnity to be thoroughly evaluated and with intensive participation in program 
activities, clients are reportedly more liely to have impairments identifed, thus 
allowig appropriate treatment and referrals to be made.  , "
These local programs share several characteritics which contrbute to their 
apparent success.
maxe 
The eight local programs exhbit common qualities and practices which  their
effectiveness, as listed below. 
HAVE STRTEGIES 
RECONIZE THE  TO MINIMIZE IMPACT 
SIGNIACANCE AND  OF FUNCTIONA 
PREVALNCE OF  IMPAIRMENTS  STRESS SELF-ESTEEM 
FUNCTIONAL IMP  RMENTS  AND SKILL BUILDING 
lH EI LO 
PROGRAS I 
EMPHASIZE  HAVE A
CUENT  UTIUZE  DEDICATED
FOLLOW- INTENSIV  STAFF
CASE
MANAGEMENT
Additionally, most program managers and instructors attribute their success to dealing 
with all the needs of the individual - emotional, physical, fiancial and personal. They 
also stress the importance of teachig clients to rely upon themselves, despite any 
impairments they may have; as one respondent states  We teach them to advocate for 
themselves. 
Clients of the visited programs offer strong support.
Al client respondents from the four programs visited give these programs positive 
ratings. Clients feel that they benefit from the individual attention they receive and 
are confdent their participation will help them achieve self-sufciency. They mention 
that they are being given practical skills for enterig the workplace and, just as 
importantly, are building their self-esteem. With career discovery programs, they are 
able to explore the diferent employment options available to them.  , "  , "
Particularly in the GED classes, an effort is made to tailor education and training to 
the needs of clients with impairments. Many of these clients were not successful in 
regular school settings because their impairments, such as learning disabilties, were 
not recogned and therefore not accommodated. One client currently studyig for 
her GED asserts  Ths is a second opportunity for me. I'm not going to let it go. 
Some program graduates are no longer dependent on welfare. 
Except for one, all of the eight programs have clients who have already graduated. 
Some are currently attending college and others have steady employment. Several of 
the programs will only place clients with jobs that pay enough to keep them off of 
welfare; in most cases, these jobs pay above the minimum wage. In one program, a 
former client is now an instructor in that program; in another, a former client attained 
her Master s degree in Social Work and is now a case manager. 
The success of the individual parent also has wider implications for her/his chidren. 
Several program staff mention that when a parent is no longer dependent on welfare 
her/his children are also more likely to avoid such dependency when they become 
adults. One program manager states  Some kids thik being on AFDC is a way of 
life ; several others mention that successful participation in their programs is one way 
to "break the cycle" of future welfare generations.  RECOMMENDA TIONS
States should develop mechanisms to assure appropriate identification, referral 
and follow-up of clients with functional impairents. These mechanisms could 
include: 
in-depth assessments with questions and features specifcally targeted to
functional impairents
trainng AFC and JOBS workers to  impairents
identif functional 
and
improved lin with local programs which serve the functionally
impaired, particularly with regard to follow-up.
The Administration for Children and Familes should assist States and local 
governents by publicizig  identifg, referring and 
effective practices for 
servg 
the fuctionaly impaired.
The Administration for Children and Famies should conduct research on the 
extent and nature of impairments and interventions. As suggested in ASPE' 
comments to the draft report, this research could include coordination with 
research units whose primary focus is disabilty. 
COMM
Comments to the draft report were received from the Admistration for Children and 
Familes (ACF) and the Assistant Secretar for Plannig and Evaluation (ASPE) and 
appear in Appendix A. We have considered these comments and made changes 
where appropriate. 
In response to the fist recommendation, the ACF expresses interest in working with 
States to address the problem. While they cite fiscal constraints on States as a 
wi 
possible limiting factor, they nevertheless  encourage States to look for 
impairents to a participant s successful transition to self-suffciency. They 
acknowledge that existing JOBS regulations wil be helpful in this regard. 
Both ACF and ASPE expressed concern that the definition for functional impairent 
used in this report is too broad and unclear. In response to these concerns, we 
amended the report to clari the meaning of functional impairment. Prior to our 
study the nature and extent of this problem was largely unknown. Our goal was to 
make a preliinary identifcation of the various tyes of impairments in order to assist 
researchers and program administrators in coming to grps with functional impairments 
AFC 
of the  population. Therefore, we thought it important not to restrict our 
defition to any specifc conditions. Clearly, much more research is needed to defie 
the problem and develop remedies.  APPENDIX A 
COMMENT TO mE DRA REPORT  . .. ~~~
-= 
FEB-26-92 WED 14: 59  r-. -=
DEPARTMENTIiAn\'t&. HUMAN SERVICES 
CiFFICE OF i
SPE
ADMINISTRATION FOR CHWILDRE.N  AN 
Office of the Assistant Secretary, Suite 600 
1992 FEB I 3  i 9: q a  370 L'Enfant Promenade, S.
C. 2047 
Washington, D.
Febt"uary 13, 1992 PDIG 
DATE:  DIG-AS 
Richard P. Kusserow pcG-
TO: 
B. Barnart 
Inspector General  . ies 
Jo Ane  OGC/IG . 
FROM: 
Assistant Secretary  EX SEC 
DATE SENT 
for Children and Fam
SUBJCT: Draft for IlFuncti01\  :t pairment 
't 
c01Dent on your study of the 
Thank you for the opportunity  believe that 
clients. We 
functional impairments affecting AFDC 
it is a well written report. 
However, the report uses a definition for functional impairment
that we believe is broad and amiguous: "  (A) ny physical or 
individual from leaving 
mental barrier which may prevent an 
If the discussion were
welfare and becominq  the 
self-sufficient. 
more focused, it would better serve to address the needs of
participants and ACF. Distinctions should be drawn between those 
e., the need for eye 
conditions which. can be readily treated, i.
ents and those 
qlasses 
, dental treatments, and other physical all 
emotional and self-esteem problems which might only be alplroegvriaamtesd.  
e long term through counseling and job readiness 
over  from physical and 
These barriers should in turn be distinguished 
mental conditions which would cause exemptions for illness or 
30(b) (2) and  he report should 
incapacity at 4S CFR 250. (3). 
also acknowledqe that increasing AFDC caseloads affects a State
agency' s ability to serve the functionally impaired. 
The repcrt is correct that regulations allow for the combining
t."1e hours of those individuals scheduled to
and averaging of 
However, the last sentence of 
participate in JOBS activities. 
l implies that a particular 
the 4th paragraph on page 7 sti 
classroom instruction for a rate 
participant will have to be in 
inimum participatio 
mfoinri imnudm ivpiedruioadl  pofa rttiicmiep.a Tnheret sis n.o  Fuctionally impaired participants 
lengt of 
time appropriate to them, as long
could attend for the 
as the participation of other recipients allowed the state to 
standard. 
achieve the participation  ,.  .;. ,:;
,.,. : -:.'
 '" .
r. .
P. IUserow 
Page 2 - Richard 
OlG, in these reports and

Finally, we would like to encQurage the 
people first" language

in any subsequent report"sP,e otop lues fei r"st." lanfgiuarct;e.  means t hat the

wherever appropriate.  So, ter example,

person rather than the disability comes 
not "mentally re arded boy" but "boy with mental r,e tbaurtd "atuisoens" 
a

confined to a wheel chair 
or, not "crip,p leetdc" .o r "
Wheel chair"  In c:eneral the focus should be on the 
individual, not the particular limtation.
 iiit
Recommenda 
Commen-ts on 
RECOMMND1\T!ON NO. 
no. 1 is practical in

We do not believe that recommendation 
all States given the pressures aresssoocuiarcteeds .w Hiotwhe vienrc,r ewahseende
 ver

caseloads and declinin9 fiscal 
c look for these

appropriate, we will encourage States 

impairments to a participant's successful transition to

self-sufficiency . 
fer
prcqr. 
The JOBS final regulations specify the require'rmheen ts tat.e IV-A 
JOBS 
participant assessment in the  each 
assessment. of 
aqency must conduct an initial 
(1) educational, child 
participant's employability based enn eeds: (2) the 
care and other supportive services 
and prio 
participant' s proficiencies , skillS deficiencies, 
work experience: and (3) a review of the family 
circumstances, which may include the needs of any child of

the participant. 
This assessment would serve to identify manyr eogfu ltahtei
ons give

report. The 
conditions referred to in the 
wide latitude to the states to choose methods to assess

participants and recogni%B that methods will vary based on

resources, and program philosopiehis

caseload size, program 
to qive state IV-A aqen 
We believe Congress intended 
broad flexibility in developing assessment strateqi

pCOMMENDATION NO 2 
The OFA Division of JOBS program already has a "best

practices" responsibility which encompasses th,e  iqnactlhuedriinngg  tohfe


infornation on the total recipient populati

UnfortunatelY, without more rigorouS
functionally impaired. 
determine' which practices airthe 
evaluation, it is difficult to 
individuals 
most effective in reducing dependency among 

functional impairments.
 .. 
P.. Kusserow 
paqe 3 - Richard 
bariers or 
We aqree that when participants suffer
aiJ:ent 
1:p. which are wi1:in the capacity of the worker to 
observe, every effort should be )lde to seek the resources
to secure professional evaluation and t:e services to
However, this function must be
overcome these obstacles.  s major cnqoing
JOBS worker 
performed in the context of the 
responsibiliti 
Csouocrcdeisnsa toifo nJO wBitSh.  oWteh ecro nsecruv itchea tp wroorvkiedresr ss hiso uclrdi tbiec aplr etpoaa rrteehd e
assistance
to take full advantage of the network of services
available. 
However, it is difficult to provid 
non-reimurable services are in short 
where appropriate 
must. pay for the services, there willth bee  
supply.. If states  fuding and 
considerations regarding the allocation of 
potential efficacy of the treat1ent to achieve meaningful
participation in 
JOBS.. 
NO.. 3 
8ECOMHNDATION 
ACF will qive consideration to conducting research on 
and appropriat  interventions.. We had 
functional impairment 
iqation would shed more light en
at the OIG inves 
htophed is area. However, because of its bread defintietdio. n of 
, its usefulness was 11m! 
functicnal impairments  ..  =- ,/
' =
.... ..
-:. ~~~
Washington, D.C. 20201

1992
FE 20 

DDN 
TO:	 Richard P. Kussero 
Inspector General 
FROM:  Assistant Secretary for  OGCIIG
Planning and Evaluation  EXSE
l1DaU"  e . 
o:tG Draft Reports: .Fun
SUBEJCT:  Comment" on  and "Fuctional Impair!ents of AFDC 
of AFDC Clients" 
00401 
02.-
Clients: Case studies"  report  for 
the 
We appreciat  opportunity to review the draft 
states are 
dealing with functionally impairanedd  
your study of bow 
JOBS. This study provides the Departent 
AFDC clients under  akq 
special
states with insights about what types of impairments are found in

This informtion

popula'tio 
tehef AFfDC oporpUltatison  antd eoxam plies dof eloncalt pirogframys  
 and help this  states to
will be useful as the Departent continues to help 
Followint; are our comments on the

fine-tune their JOBS programs. 
draft. 
l8 are defined 
concerned about how 18 functional lmpaiDIents 
We are 
While functional impairments are the keystoTnhee 
oinf  tbheosteh  rreepoprot rts, the definition is somewhat unclear. 
impairment (such as low back pain) 
een having an  needs 'to 
distinction bet  i1Ipaired :by low Dack pain 
and beinq functionally 
. The fuctional impairments of most concern here are 
sb.  1;E:ned.  JOBS proqram and 
succeed in the 
those tehmatp aloffyeecdt.  Tabhiel idtiyff etroe nce ):etween chonic versubse laiecvute , 
. become  The studies, ' we 
needs to  be raised.  clearly 
i1Ipairments also  chronic  this is not 
i1pairments but 
are. referrinq to 
tated anywhere. 
the 
disabilities are a I1aj or iInpairment according to 
Learning  these 
reports. However, we wonder if  impairments had wbeereen,  
and, if they 
s school years  these impairments 
diagnosed during theses pwoemceina l 
education? Had  . special 
what was the role boef fore? Did these women receive -
been identified 
cation?  clients themselves know that they were 
Did the 
learning disabled?

that 
predominate, but what they consistht eosf 
Eism otional i1Ipairments also  . here 
unclear. The point needs to be made  serious 
are not routine emotional concerns, but 
irment 
imp  functioning. In 
which could interfere with  impairments 
emotional impairment 
interpret the emotional  everyday
the current text one might  tha  rt of 
r.. 11a r-a 7P 
reported to be relatively minor oR.. o  o:;.J r..... 
1. e. 
."'''c 
\.I  C:\l  :2"."J I:1J....1 '
':":1\. 
11-' A I  ~~~ _&.- -- --- , (
r: 
XUsserCW 
P. 
Page  2 - Richard 
eligiebinlriotyll  wihner ethien  
references aAre F)l ds t: SSI 
Several tiJes,  recipient to 
states 
encourageo if J5pa5i1r.e dR eade ar apt to wonder whY most of
disabled porti  ahcud be pointed thouatt 
benefits. It 
these clients don't get 551 
clients probably have disabiliti 
that most of these AFDC 
a,e not. severe enough for t.'lem to qualify fer SS:I. 
for, (1) the  develop 
5tates to 
The 
recommendations call  ) for ACF to assist
serve 
mechanism to provide in-depth assessment 
effective practices to identifY, refer, ando n the 
states in  conduct reearch 
(3) for ACF to  There 
int:rnts 
impaired clients, and  AFDC populati
in 
naarteur em aand  pehxytseincta lo fa nimpdairm enmts  ental/emotional aasessmet  stndard
used. 
Does OIG have any preferrreedco morm enda.tio 
tmehaastu rceasn  tboe  recommend: The st.udy.  Sftiartests  ttow oi nclud physical, 
could be strengtened by calling for 
and learning disabilities in their assessments
mentall emotional,  disabilities are 
'roo often, persons with 
and ide.TltificaticnsiO  only those with physical disabilities. 
include 
thought to  any overall guidance
is  ere 
ird  recommendation, 
Regardinq the  , such as coordination with research units
at ACF should follow
is disability?
t: 
whose primary  that ACFi  Jitrogtesthe.r  weintths 
OIG should include a reco_endati treatment of AFDC recip Such 
ADAM to  hea1.th 
mental 
with alcochoordoinatle, d iadgnosrisg abuse or  regard to 
particnar1.y productive in 
coordination could be  in the effective 
have been major advancemEatsr ly identificati 
depression. There  recent years.  depressio 
treatment of depressiopn airnti cipants with t..,atable 
ability to benefit 
and treatment of JOBS 
imact on their 
likely to have a significant self-Sufficient. 
from JOBS services and become 
of JOB5 program 
supportin'1 an evaluatcioonl lected for this
ASPE and ACF are jointlY 
strategies.  baseline data to be 
bAmeo nmge atshue rements of depfreussrie  r ianmfoonr'm1 tpio tenatbioault  
study will  This data will proide 
participants. 
impairments in this populati
the extent of emotional  report, 
few specific questions about the 
Finally, we have 
Clients: Case studies 
"Functional ImpairJents of AFDC 
teeth" on page 5 need to be
impairments.
The references to "Bad or no 
further described as to why they are 
" as indicati
"too much perfmne
The reference on page 7 to 
of a substance abuse problem needs to be explained.  ..:  . '
. , -- . ,;,"' .. -
'Rsser 
Page 3 - Richard P. 
as to how
eds an explana
paqe 12 ne
The description on  program are incorpo 
the AFDC client population Panrdo gthaem JO.B pSr evalence figues of V 
program, 
rated into the HOST/HR  en fer this 
tmpairments are 9i 
broad cateqories of  AFC clieni:s. 
but it is unclear whether they are all 
report, please 
have any specixic questions about this 
Ix you 
contact Jane Baird, 245-2409. 
Martin H. Gerr