Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

OCTOBER 1999 

OEI-09-98-00292 

TEMPORARY ASSISTANCE 

FOR NEEDY FAMILIES 

Improving Client Sanction Notices 
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 
EXECUTIVE SUMMARY 

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 

TANF—Improving Client Sanction Notices 1 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 

TANF—Improving Client Sanction Notices 2 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. 

TANF—Improving Client Sanction Notices 3 OEI-09-98-00292 
TABLE OF CONTENTS 

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

TANF—Improving Client Sanction Notices 4 OEI-09-98-00292 
INTRODUCTION 

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. 

1

For the purposes of this report, a TANF “client” is the head or heads of a family receiving cash aid. 

2

Clients exempted from program requirements for “good cause” reasons, such as unavailability of child 

care and danger of domestic violence, are not subject to sanctions. 

TANF—Improving Client Sanction Notices 5 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. 

3

The specific processes and time frames for curing sanctions differ by State. 

4

States may elect to notify clients by other means, such as phone calls, in addition to sanction notices. 

5

Caseload 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. 

TANF—Improving Client Sanction Notices 6 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. 

6

The 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. 

TANF—Improving Client Sanction Notices 7 OEI-09-98-00292 
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. 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 client’s caseworker, 

< instructions on how to cure the sanction, 

< an explanation of the client’s 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 

county’s 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. 

7

The 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. 

TANF—Improving Client Sanction Notices 8 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 client’s 

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 State’s 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 client’s 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. 

8

The comments section in this notice originally appeared on two separate pages. The template for the 

second, which mentions the client’s appeal rights and gives a contact for free legal services, is identical to page 3 

of the notice presented in appendix C 

TANF—Improving Client Sanction Notices 9 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 don’t understand,” 

reported another advocacy representative. 

TANF—Improving Client Sanction Notices 10 OEI-09-98-00292 
<

<

<

<

<

<

<

RECOMMENDATION 

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 selfsustaining 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. 

TANF—Improving Client Sanction Notices 11 OEI-09-98-00292 
APPENDIX A 

Notice that Contains Clear Information in Multiple Languages

Highlights 

importance in 

seven languages 

Gives reason for 

the sanction 

Includes specific 

sanction amounts 

Clearly tells how 

to lift sanction 

and whom to 

contact 

TANF—Improving Client Sanction Notices 12 OEI-09-98-00292 
Clearly explains 

appeal and 

conciliation 

rights 

Gives number 

for legal aid 

TANF—Improving Client Sanction Notices 13 OEI-09-98-00292 
APPENDIX B 

Detailed Notice of Benefit Reduction

(Follows Notice in Appendix A)

Shows benefit 

recalculation 

TANF—Improving Client Sanction Notices 14 OEI-09-98-00292 
APPENDIX C 

Notice that Contains Incorrect and Confusing Information

Incorrectly states 

that Medicaid is 

sanctioned 

Vague 

information 

Confusing 

information 

TANF—Improving Client Sanction Notices 15 OEI-09-98-00292 
No correction of 

prior statement 

of Medicaid 

sanction 

TANF—Improving Client Sanction Notices 16 OEI-09-98-00292 
TANF—Improving Client Sanction Notices 17 OEI-09-98-00292