Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
TEMPORARY ASSISTANCE 
FOR NEEDY FAMILIES 
Improving the Effectiveness and Efficiency 
of Client Sanctions 
JUNE GIBBS BROWN 
Inspector General 
JULY 1999 
OEI-09-98-00290  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 describe how States administer client sanctions under the Temporary Assistance for 
Needy Families (TANF) program. 
BACKGROUND 
In 1996, Congress significantly overhauled the 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).  Temporary

Assistance for Needy Families (TANF) 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.

The TANF program grants cash assistance on a time-limited basis to needy families, but

requires States to implement more stringent work requirements than under AFDC.  The

TANF law encourages States to create programs that are two-pronged: 1) they should

move clients to work quickly and 2) they should encourage personal responsibility.  The

law gives States broad authority to set their own time limits on cash assistance and when

clients must participate in work activities. 

Clients who fail to comply with TANF program rules and requirements face sanctions,

including cash assistance reductions ranging from $25 to lifetime ineligibility.  States vary

in how they define client sanctions and penalties, including the amounts and durations of

sanctions.  As of August 1998, 37 States impose full-family sanctions, eliminating cash

assistance to the entire family.  In general, States sanction clients for a minimum amount

of time for each instance of noncompliance or until the client complies.  Five States have

policies that include lifetime exclusion from TANF. 

States can decide how and when to inform clients of sanction policies and sanction

decisions.  They use several methods to resolve client disputes of sanction decisions,

including conciliation meetings.

Reliable and comparable State statistics on TANF client sanctions currently are not

available.  The Administration for Children and Families (ACF) required all States to

report 1998 TANF caseload data under a temporary emergency reporting system. 

However, ACF has discovered inconsistencies in how States define and report case

closure and sanction information.  At the time of this reports publication, ACF had not

1 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  published 1998 data on benefit reductions and case closures resulting from sanctions and 
was working with States to standardize data reporting. 
The General Accounting Office (GAO) also is conducting a national study on client 
sanctions under TANF.  Using data obtained from selected States, GAO will report 
sanction and case closure data. 
The objective of our study is to describe how sanctions are being administered at State 
and local government levels, with special emphasis on caseworker implementation.  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.  We also met with TANF office directors and selected 
caseworkers, who assisted us with limited case-file reviews of recently sanctioned TANF 
clients.  We 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 client advocacy organization. 
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. 
FINDINGS 
Caseworkers use sanctions to motivate clients, not to punish them 
Caseworkers report that they use sanctions either to motivate clients to comply with 
TANF programs or to motivate personal responsibility in general.  Sanctions are 
consistent with State program objectives and serve as a tool to encourage clients to 
comply with program rules. 
Sanctions are more effective when they are administered on a case-by-case basis 
Sanctions are effective for some clients, such as those earning unreported income.  Long-
term clients, frequently from inter-generational welfare families, require more extensive 
services.  Encouraging compliance from this group through sanctions or other means is 
exceedingly difficult.  Some TANF offices have developed simple procedures, such as 
mandatory conciliation meetings and home visits, to prevent inappropriate client sanctions. 
2 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  Sanctions are less effective when clients face substantial barriers to compliance 
Since some TANF clients face obstacles that hinder their immediate program participation, 
sanctions are not always effective.  Client barriers include substance abuse, mental illness, 
low literacy, domestic violence, and lack of transportation and childcare.  Some TANF 
caseworkers have inadequate resources to identify their clients barriers, leaving them few 
options but to sanction noncompliant clients. 
Sanctions are administered more efficiently when the TANF office is a one-stop 
job center staffed by total case managers 
Case managers who have decision-making authority and access to extensive on-site client 
services can effectively identify and remove client barriers and use sanctions more 
efficiently.  Some TANF offices, however, fragment their client services among several 
providers, leading to strained client communications and inefficient sanctions.  In some 
TANF offices, caseworkers are unaware of the reasons and remedies for client sanctions 
imposed by social service contractors and other third parties. 
Summary 
This report is intended to provide a broad introduction to State administration of client 
sanctions under TANF.  The companion reports (referenced below) provide more detailed 
information, including recommendations to improve Federal guidance. 
This is one of three OIG reports on how States administer client sanctions 
under TANF.  One companion report, 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.  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  Improving Sanction Effectiveness  OEI-09-98-00290  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  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Sanction amounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Conciliations, appeals, and fair hearings  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Informing clients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  8

State sanction data  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

State attributes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  12

Purpose of sanctions  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Case-specific sanctions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Identifying and addressing client barriers  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Management styles and caseworker authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

SUMMARY  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  17

4 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  I N T R O D U C T I O N  
PURPOSE 
To describe how States administer client sanctions under the Temporary Assistance for 
Needy Families (TANF) Program. 
BACKGROUND 
In the summer of 1996, Congress significantly overhauled the 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 Temporary Assistance for Needy Families (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.

The TANF program grants cash assistance to needy families on a time-limited basis, but

requires States to implement more aggressive and immediate work requirements than

AFDCs Job Opportunities and Basic Skills (JOBS) program.  With few exceptions and

after State-administered skills assessments, TANF requires clients1 to participate in work

activities (e.g., subsidized or unsubsidized employment, time-limited training, or

community service).  Clients must participate in work activities after a maximum of 

2 years on cash assistance and are limited to 5 years of federally-funded cash assistance. 

States have authority to require work sooner and may extend aid beyond the 5-year limit,

provided States use no Federal funds towards the individual grant.

The TANF law includes guidance to States on work requirements and allows States to

design their own programs that encourage clients to be responsible for their families well

being.  Since Federal cash assistance to needy families is time-limited, TANF clients must

move quickly from welfare dependency to self-sufficiency.  To achieve this, States may

develop programs that encourage the formation and maintenance of two-parent families,

strengthen child-support collection from absent parents, and ensure child immunization

and school attendance.

1 For purposes of this report, a TANF client is the head or heads of the family receiving cash assistance. 
5 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290 To encourage clients to follow the new program rules and requirements, TANF allows 
States broader authority to reduce or eliminate cash assistance to noncompliant clients. By 
sanctioning clients, States can link their programs that encourage personal responsibility 
to the cash assistance that they administer. 
Client Sanctions under TANF 
The TANF law provides sanctions as one mechanism for promoting client personal 
responsibility.  Client sanctions under the new program have a dual intent.2  They 
(1) motivate clients to participate in welfare-to-work programs and (2) hold clients 
accountable for their actions.  According to the General Accounting Office (GAO), States 
that had strengthened their sanction provisions in an effort to shift accountability to clients 
had imposed the most client benefit-terminations nationally in 1996.3  The three States that 
shared this approach accounted for approximately 72 percent of all AFDC benefit 
terminations. 
Clients who do not follow TANF program rules and requirements face various penalties, 
including cash assistance reductions ranging from $25 to lifetime ineligibility.  Although 
client sanctions existed under AFDC, States now have increased authority to define 
sanctionable offenses and specific penalties.  Federal TANF law directs States to sanction 
clients for not participating in work activities and/or not cooperating with child-support 
enforcement efforts.  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 other program activities (e.g., training sessions). 
Definitions of client sanctions vary among States.  While noncompliance with some 
program requirements may result in a pro rata sanction for existing clients, it may result in 
ineligibility for new clients.  For example, failure by a client to appear for an orientation 
session is cause for a sanction in some States.  In other States, it would cause an 
administrative case closure for a client at an application stage.  Failure to provide proof 
of child immunizations could cause a sanction, a monetary penalty, or a case closure, 
depending on the eligibility status of the familys case. 
Sanctioned clients who remain on the TANF roles for more than 3 out of the previous 
12 months encumber States efforts to achieve minimum mandated participation rates. 
States face block grant reductions if they fail to ensure that a minimum percentage of their 
TANF clients are engaged in work activities. 
2 The Urban Institute, Building an Employment Focused Welfare System: Work First and Other Work-
Oriented Strategies in Five States, June, 1998, pages 48-53. 
3 The General Accounting Office, Welfare Reform: States Early Experiences with Benefit Termination, 
May 1997. 
6 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  Sanction Amounts and Duration 
While the TANF law mandates minimum benefit reductions for some sanctions (e.g., a 25 
percent cash assistance reduction for failure to participate in child-support enforcement 
efforts), States may set maximum benefit reduction levels ranging from the adults portion 
of cash assistance 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 
program rules and requirements.  For example, some States incrementally reduce cash 
assistance to families with each incidence of client noncompliance, sometimes leading to 
the loss of the entire cash grant.  As of August 1998, 37 States administer full-family 
sanctions as either the first sanction or as the maximum in a series of progressive sanctions 
(see figure 1).4  Five States impose a lifetime sanction on clients who repeatedly fail to 
comply with program rules.5 
Figure 1 
*  * 
__ 
* 
* 
* 
Maximum Amount of Sanction 
50 States plus District of Columbia 
* Lifetime sanction  Loss of entire grant (full-family sanction)  (37) 
Loss of part of the grant (partial sanction)  (14) 
4 Department of Health and Human Services, Administration for Children and Families, Office of 
Planning, Research and Evaluation, TANF Program First Annual Report to Congress, August 1998. 
5 Ibid. 
7 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  Sanction durations also have changed under TANF.  Under JOBS, Federal rules mandated

that the first client sanction continue until the client complied, the second sanction for at

least 3 months, and the third and subsequent sanctions for a minimum of 

6 months.  The TANF program requires that States, at a minimum, reduce the cash

assistance pro rata for each month a client receives assistance and is not in compliance. 

States also can set maximum sanction amounts and duration, including, as mentioned

previously, lifetime ineligibility.  Some States sanction clients indefinitely, until they

comply.

Conciliations, Appeals, and Fair Hearings 
The TANF program affords States more flexibility to design programs that resolve client 
disputes of sanction decisions.  Under JOBS, before individual benefits were interrupted, 
States were required to begin a conciliation process that (1) explained the sanction 
decision to the client and (2) attempted to resolve any client disputes of the decision.  The 
conciliation focused on moving the client into compliance before a sanction was imposed. 
Under TANF, States no longer must conciliate disputes prior to sanctioning, although 
some States have left intact the conciliation processes they had used under JOBS. 
States were required under AFDC to inform clients of their right to appeal decisions 
formally and participate in fair hearings to resolve disputes over sanctions.  States must 
still provide clients the option to appeal sanction decisions and must have a system of fair 
hearings to resolve appeals.  State appeals and fair hearings policies may vary since TANF 
requires only that States certify that they have a fair hearing process in place and describe 
it. 
Informing Clients of Program Rules and Sanction Decisions 
Under TANF, States decide how to inform clients of sanction policies, individual decisions 
to sanction, the conciliation process, how to restore benefits once sanctioned, and the 
appeals and fair hearings processes.  States can, for example, conduct individual or group 
orientation sessions, provide all clients with packets of materials including policy 
information, or choose to inform clients of decisions to sanction using letters, phone calls, 
and/or home visits.  For more information on TANF communications and client  sanction 
notices, see the companion reports entitled Client Sanctions under Temporary Assistance 
for Needy Families: Challenges in Communication, OEI-09-98-00291, and Client 
Sanctions under Temporary Assistance for Needy Families: Improving Client Sanction 
Notices, OEI-09-98-00292. 
State Sanction Data 
Reliable and comparable State statistics on TANF client sanctions currently are not 
available.  The Administration for Children and Families (ACF) required all States to 
report 1998 TANF caseload data under a temporary emergency reporting system. 
However, ACF has discovered inconsistencies in how States define and report case 
8 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  closure and sanction information.  At the time of this reports publication, ACF had not 
published 1998 data on benefit reductions and case closures resulting from sanctions and 
was working with States to standardize data reporting. 
The GAO also is conducting a national study on client sanctions under TANF.  Using data 
obtained from selected States, GAO will report sanction and case closure data. 
METHODOLOGY 
Our study focuses on State administration of client sanctions under TANF, with special 
emphasis on caseworker-level implementation.  We purposefully selected an eight-State 
sample based on: 
<  percent change in TANF recipient population,6 
<  State policies on TANF client sanctions (e.g., full-family versus 
partial grant reduction), 
<  percent of national recipient population, and 
<  geographic diversity. 
Since our sample was purposeful, we do not project any findings or observations to any 
States other than those in the sample.  We visited the following States:  California, 
Florida, Idaho, Michigan, Minnesota, New York, Ohio, and Texas.  In each State, we 
visited at least two TANF offices -- an urban office and a 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 to 15 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 
an individual to a group of more than 20.  The clients were selected either in advance by 
the TANF office or during our visit while they were present for other business.  We also 
collected and reviewed State and county policies, publications, and notices from each 
TANF office.  In each State, we interviewed staff from at least one client advocacy 
organization.  In total, we conducted 9 interviews with 15 advocacy organizations. 
6The 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 per 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. 
9 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  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. 
The following table provides an overview of selected attributes from the States we visited. 
Selected State Attributes 
Table 1 
TANF recipients,  TANF families, 
September 19987  January 19998 
Percent of  Total  Percent change Total TANF caseload  Total caseload per  Maximum 
national  since August  per office  caseworker 9  sanction 
recipient  1996  (limited to the offices  (limited to the  amount10 
State 
population  we visited)  offices we visited) 
California  24.0  1,908,534  -26  364 to 17,484  60 to 212  Pro rata11 
Florida  3.1  246,191  -54  1,200  not available  Full family 
Idaho  0.04  3,285  -85  30 to 120  40 to 120  Full family 
Michigan  3.9  308,817  -39  200  not available  25 percent 
Minnesota  1.8  141,440  -17  150 to 15,179  70  Pro rata 
New York  10.8  862,162  -25  92 to 2800  120 to 175  Pro rata 
Ohio  4.0  319,912  -42  188 to 11,654  60 to 286  Full family 
Texas  4.4  346,232  -47  88 to 481  200 to 225  $78/$125 
Total  52.0  4,136,573  -35  30 to 15,179  40 to 286 
7 Department of Health and Human Services, Administration for Children and Families, 1998. 
Recipients refers to all family members receiving cash assistance. 
8 The TANF agencies we visited provided all figures in the TANF families column. Families refers 
to the TANF case and typically includes all family members on assistance (see definition of recipients).  According 
to ACF, TANF families averaged 2.7 recipients in September 1998. 
9 Includes all types of cases: TANF, Medicaid-only, food stamps-only, or any combination of the three 
benefits. 
10 Department of Health and Human Services, Administration for Children and Families, Office of 
Planning, Research and Evaluation, TANF Program First Annual Report to Congress, August 1998. 
11 As of August 1998, all counties in California, except one, impose pro rata sanctions. We visited eight 
counties in California, including the one that imposes full-family sanctions. 
10 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  This is one of three OIG reports on how States implement client sanctions 
under TANF.  One companion report, 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.  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. 
11 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  F I N D I N G S  
Caseworkers use sanctions to motivate clients, not to 
punish them 
According to a consensus of caseworkers in more than two-thirds of the focus groups, the 
purpose of client sanctions is either to motivate compliance with TANF programs or to 
motivate personal responsibility.  Caseworkers use sanctions as a wake-up call or a 
reality check for clients.  Some mentioned that sanctions are consistent with the message 
that welfare benefits are now time-limited.  In approximately 15 percent of the focus 
groups, at least one caseworker mentioned that sanctions are used to punish clients. 
Some caseworkers reported that sanctions cause clients to feel the consequences of their 
actions.  Using this approach, caseworkers told us that sanctions can encourage client 
responsibility for ones self and family. 
Sanctions are more effective when they are administered on 
a case-by-case basis 
Sanctions are very effective for specific TANF clients, according to caseworkers.  For 
example, clients earning unreported income can be detected using sanctions.  Clients who 
already are working and have no intention of participating in job preparedness or job 
search programs are being effectively sanctioned and in some cases have had their benefit 
levels adjusted.  On the other hand, caseworkers and directors agreed that sanctions are 
least effective for the group known as lifers or frequent flyers.  These are long-term 
recipients, frequently from inter-generational welfare families.  They often face multiple 
barriers, compounded by the belief that public aid is a way of life and their inalienable 
right.  This combination makes it very difficult for caseworkers to reach these clients 
effectively, whether through sanctions or other means. 
Some States have policies and procedures designed to prevent clients who have legitimate 
barriers to participation from being sanctioned inappropriately.  To identify any hidden 
barriers, some offices mandate home visits to all sanctioned clients.  Other offices require 
contact between the caseworker and client prior to sanctioning.  Some offices require 
clients to appear for a mandatory conciliation meeting at the TANF office prior to a 
reduction in benefits.  The conciliation meeting provides clients with the opportunity to 
explain their reasons for noncompliance and possibly avoid the reduction.  For example, 
one TANF office sanctioned a client for failure to provide proof of volunteer hours 
worked.  The client avoided an interruption in benefits by providing proof of volunteer 
hours during the conciliation session. 
12 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  Sanctions are less effective when clients face substantial 
barriers to compliance 
The TANF population is so diverse that sanctions do not serve as motivators for all. 
Certain clients face barriers that prevent them from moving immediately from welfare to 
work.  In some counties, TANF staff are not prepared to recognize or assess clients 
problems.  In others, staff lack the resources to help clients overcome barriers to 
employment. 
Some clients face obstacles that hinder their immediate participation in TANF 
programs 
Some TANF clients are ill prepared to immerse themselves quickly in the world of work 
due to personal and public obstacles.  One of the biggest barriers to employment is lack of 
transportation.  In more than one-third of the sites visited, caseworkers cited 
transportation as a problem.  Lack of reliable transportation is especially acute in rural 
areas, where clients already face limited prospects for entry-level jobs.  At fewer sites, 
caseworkers said that clients face barriers such as poor English language skills, lack of 
affordable housing, attitude problems, and low self-esteem.  Clients are delayed further 
from participating in TANF programs when they face multiple barriers. 
Other barriers are more difficult for caseworkers to identify, but create insidious obstacles 
for clients.  They include substance abuse, mental illness, low-literacy, and domestic 
violence.  Identification of these barriers often rests solely with the caseworker, and failure 
to identify and address the problems may ultimately result in a sanction. 
Most sites provide child-care subsidies and referrals.  Some caseworkers cited their 
offices policy of providing referrals and subsidies for child care and would not accept 
clients claims that quality child care is unavailable as a good cause for not working.  In 
these offices, clients risk sanctions for missing a required meeting or not accepting a job 
offer due to lack of child care.  Clients and caseworkers agree that the lack of quality child 
care constitutes a legitimate barrier to work.  However, referral services for child care 
varied among the different sites.  At one site, caseworkers referred clients to a community 
nonprofit clearing house for child care providers willing to accept county subsidies.  At 
some sites, the TANF agency simply provided clients with a list of local providers.  At 
another site, caseworkers offered little guidance to clients other than to keep looking. 
Caseworkers and clients acknowledged that some clients are reluctant to or refuse to leave 
their children long enough to complete program requirements, although affordable and 
subsidized child care may exist.  Caseworkers reported that some clients mistrust child 
care providers and refuse to place their children in day care. 
13 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  TANF caseworkers have inadequate resources to identify their clients barriers 
Determining if their clients face barriers to employment is a crucial responsibility of TANF 
caseworkers.  The TANF law requires that States assess all clients required to participate 
in work activities.  Most TANF offices used formal and/or informal processes to identify 
client barriers.  The resources available to caseworkers during assessments varied among 
the offices.  For example, some offices offered on-site drug and alcohol screening and 
domestic abuse counseling, while at another office, caseworkers simply administered 
written questionnaires to clients.  We found one office that had no assessment program 
and placed clients in work experience programs after only a 3-week job search. 
Simply getting all of the clients to come into the office for an assessment has proven to be 
a challenge.  At some sites, a clients refusal or failure to appear for assessment is cause 
for sanction.  Some offices send one or two letters requesting an appearance prior to 
imposing a sanction.  Other offices require caseworkers to phone clients or make a home 
visit prior to sanctioning the family.  At one site that routinely performs home visits, 
caseworkers lauded the practice as the most effective method of discovering client 
barriers. 
Large caseloads and new job responsibilities adversely affect caseworkers ability to 
address client barriers.  Some caseworkers complained that their caseloads were too large 
to provide the individual service that TANF requires.  Individual TANF caseloads ranged 
from 5 to 212 cases.  When food stamps and Medicaid-only cases are added to the 
individual caseloads, the range ballooned to 40 to 286 cases.  In some TANF offices, the 
shift in job duties from traditional eligibility determination to more complete case 
management has intensified the TANF casework. 
Imposing sanctions is a cumbersome process, according to caseworkers in more than half 
of our focus groups.  The rigorous paperwork associated with sanctions makes them 
burdensome and time-consuming.  Other problems cited include complicated and outdated 
computer systems, new sanction rules and policies, communication problems, and more 
frequent client contact.  Some caseworkers were reluctant to sanction clients, claiming it 
required too much work.  Other caseworkers reported that they view sanctions as 
punishment for themselves because of the amount of time and effort required to sanction 
a client. 
Caseworkers in several focus groups said that they lacked training about sanctions.  At 
one TANF office, they had to spend a lot of time teaching themselves the new rules. 
Others reported  doing a very superficial job with the clients.  They are frustrated that 
they cannot provide in-depth services to clients.  The TANF handbooks also contain 
incomplete sanction policies and procedures.  Thus, caseworkers are unable to answer 
some of their clients questions about sanctions.  According to one client,  The change 
has been a big mess.  I would ask the workers questions, and the workers wouldnt know 
the answers.  Other clients acknowledged that their caseworkers are under a lot of 
pressure and overwhelmed because of the new rules.  However, some clients remained 
14 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  indignant, as indicated by one who said, They (County) need to educate the workers 
about the regulations.  They (caseworkers) dont know the programs. 
While most of the TANF directors we interviewed reported that staff had received some 
training on the new sanction policies, the amount of training varied.  Some caseworkers 
received twelve hours of training on the new policies; for others, training consisted only of 
memos regarding recent changes. 
Sanctions are administered more efficiently when the TANF 
office is a one-stop job center staffed by total case 
managers 
Extensive on-site client services and empowered case managers contribute to 
efficient client sanctions 
Local TANF agencies that operate as one-stop job centers are better suited to meet 
clients needs and therefore can sanction more efficiently.  These reorganized offices 
typically offer a wide array of services designed to address client barriers.  They send a 
clear message to clients:  Welfare is temporary, and the TANF agency is committed to 
moving clients to self-sufficiency.  Caseworkers and directors in these offices were more 
likely to report that sanctions are effective. 
Total case managers exhibited a more in-depth understanding of their clients and 
sometimes seemed more interested in moving clients to self-sufficiency.  Being responsible 
for both eligibility determination and employment services, total case managers said they 
understood the links among successful barrier identification, effective sanctions, and 
efforts to move clients to self-sufficiency.  Being involved in all aspects of a clients case 
allows caseworkers to develop a more comprehensive approach to determining the 
appropriateness of client sanctions. 
Sanctions are more effective when caseworkers have more discretion during the sanction 
process.  For example, in some offices, caseworkers have the freedom to determine 
whether a sanction is appropriate on a case-by-case basis.  However, other TANF offices 
have automated the sanction process and immediately impose sanctions when a client fails 
to comply with a requirement. 
15 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  Fragmented client services and strained communications impede caseworkers 
from imposing efficient client sanctions 
The traditional welfare office model, which emphasizes benefit eligibility with few in-
house services, does not allow caseworkers to use sanctions as effectively as one-stop job 
centers.  As a result, clients are more at risk of inappropriate sanctions, even when they 
face legitimate barriers to participation.  For example, in one traditional welfare office, 
clients were placed on a county work crew, cleaning public parks after a 3-week up-front 
job search.  No assessments or referrals to work preparation programs (e.g., GED 
classes) were offered.  A husband and wife at that office had been sanctioned for not 
completing their minimum number of hours on the work crew, despite their interests in 
other job preparation programs that qualify under the States work participation rules. 
Their caseworker had no knowledge of the couples interests or abilities. 
Offices that employ separate eligibility and employment caseworkers, sometimes miles 
away from one another, are least prepared to sanction clients efficiently.  Workers in these 
arrangements often complained of the constraints the distance between the branches, both 
literal and figurative, put on effective communication.12  Clients must complete duplicate 
forms and explain things to two caseworkers, causing stress and frustration among all 
parties.  Clients were frustrated by the repetitive and sometimes conflicting information 
they received from caseworkers.  Nobody gives us the same information, complained 
one client.  Clients often were confused about which caseworker to call to discuss a 
sanction or their situation in general. 
Efficient sanctioning also can be impeded by the introduction of third parties to the 
sanction process.  In some counties, the TANF agency opted to contract with nonprofit or 
private firms for various client services.  In general, contracted services include, but are 
not limited to:  initial assessments, job search, and job preparedness.  Some States give 
contractor staff authority to sanction TANF clients for not participating in their programs. 
When contractors initiate a client sanction, they tell State or county TANF staff when to 
adjust the clients benefits.  In some cases, caseworkers do not know the specific cause or 
remedy for their clients sanctions.  Caseworkers reported strong dissatisfaction with this 
process because they often are the first to hear from a client who receives a sanction 
notice, yet they have little information or advice to offer.  Their ability to help clients move 
into compliance is hindered when they cannot explain the cause and remedy for the 
sanction. 
Some total case managers reported, however, that they are overwhelmed by the shift in 
job duties and increased responsibilities.  They complained that their caseloads are too 
large to do all that is necessary for their clients.  Others reported that their relationships 
with clients have transformed substantially as a result of their new job responsibilities and 
not always for the better. 
12For more information on communication issues in TANF offices, see the companion report entitled 
Temporary Assistance for Needy Families: Educating Clients about Sanctions (OEI-09-98-00291). 
16 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290  S U M M A R Y  
This report was intended to provide a broad introduction to State administration of client 
sanctions under TANF.  The companion reports, Temporary Assistance for Needy 
Families:  Educating Clients about Sanctions (OEI-09-98-00291) and Temporary 
eAssistance for Needy Families:  Improving Client Sanction Notices (OEI-09-98-00292) 
provide more detailed information, including recommendations to improve Federal 
guidance. 
. 
17 
TANF  Improving Sanction Effectiveness  OEI-09-98-00290