Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

JULY 1999 

OEI-09-98-00290 

TEMPORARY ASSISTANCE 

FOR NEEDY FAMILIES 

Improving the Effectiveness and Efficiency 

of Client Sanctions 
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 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 report’s publication, ACF had not

TANF — Improving Sanction Effectiveness 1 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. Longterm 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. 

TANF — Improving Sanction Effectiveness 2 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. 

TANF — Improving Sanction Effectiveness 3 OEI-09-98-00290 
TABLE OF CONTENTS 

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

TANF — Improving Sanction Effectiveness 4 OEI-09-98-00290 
INTRODUCTION 

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

AFDC’s 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. 

TANF — Improving Sanction Effectiveness 5 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 family’s 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 WorkOriented Strategies in Five States, June, 1998, pages 48-53. 

3 The General Accounting Office, Welfare Reform: States’ Early Experiences with Benefit Termination, 

May 1997. 

TANF — Improving Sanction Effectiveness 6 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 adult’s 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 

Loss of entire grant (full-family sanction) (37) 

Loss of part of the grant (partial sanction) (14) * Lifetime sanction 

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. 

TANF — Improving Sanction Effectiveness 7 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 

TANF — Improving Sanction Effectiveness 8 OEI-09-98-00290 
closure and sanction information. At the time of this report’s 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. 

6

The 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. 

TANF — Improving Sanction Effectiveness 9 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, 

September 19987 

TANF families, 

January 19998 

State 

Percent of 

national 

recipient 

population 

Total Percent change Total TANF caseload 

since August 

1996 

per office 

(limited to the offices 

we visited) 

Total caseload per 

caseworker 

(limited to the 

offices we visited) 

9 

Maximum 

sanction 

amount10 

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. 

TANF — Improving Sanction Effectiveness 10 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. 

TANF — Improving Sanction Effectiveness 11 OEI-09-98-00290 
FINDINGS 

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 one’s 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. 

TANF — Improving Sanction Effectiveness 12 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 

office’s 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. 

TANF — Improving Sanction Effectiveness 13 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 client’s 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 wouldn’t 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 

TANF — Improving Sanction Effectiveness 14 OEI-09-98-00290 
indignant, as indicated by one who said, “They (County) need to educate the workers 

about the regulations. They (caseworkers) don’t 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 client’s 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. 

TANF — Improving Sanction Effectiveness 15 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 inhouse 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 State’s work participation rules. 

Their caseworker had no knowledge of the couple’s 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 client’s 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). 

TANF — Improving Sanction Effectiveness 16 OEI-09-98-00290 
SUMMARY 

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. 

. 

TANF — Improving Sanction Effectiveness 17 OEI-09-98-00290