Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

OCTOBER 1999 

OEI-09-98-00291 

TEMPORARY ASSISTANCE 

FOR NEEDY FAMILIES 

Educating Clients about 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 determine how States inform clients about sanction policies under the Temporary 

Assistance for Needy Families (TANF) program. 

BACKGROUND 

In 1996, Congress significantly overhauled the Federal 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). The TANF 

program 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. 

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

cash assistance reductions ranging from $25 to lifetime ineligibility. The TANF law 

provides States flexibility to define client sanctions and penalties, as well as “good cause” 

reasons for work exemptions. The TANF law requires States to provide clients the option 

to appeal sanction decisions and to have a fair hearings system to resolve the appeal. 

However, States decide the specifics of their appeals and fair hearings policies and 

processes. 

States also can decide how to inform clients of TANF program policies and procedures. 

States can conduct orientation sessions, provide orientation packets, or instruct 

caseworkers to inform clients about TANF during screenings and interviews. 

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 in addition to meeting individually with TANF office 

directors and selected TANF caseworkers who assisted us with limited case-file reviews of 

recently sanctioned clients. We also 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 private client advocacy group. 

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 

TANF — Educating Clients about Sanctions 1 OEI-09-98-00291 
implementation in States with widely varying attributes. We also gained a thorough 

understanding of our respondents’ relationships with and attitude 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 

TANF offices explain sanctions to clients repeatedly, using diverse methods 

Some TANF offices communicate sanction information to clients at multiple times and 

with a variety of media. For example, offices conduct orientation classes, show instructive 

videos, and issue packets of information. Caseworkers frequently discuss sanctions with 

clients throughout the process. 

Orientation materials commonly lack information about the amount of the 

sanction and the definition of good cause 

More than two-thirds of TANF offices do not provide clear and complete information 

about the amount of sanctions and the definition of “good cause” exemptions from work 

requirements. 

Most States describe other vital information about sanctions completely and 

present it in a logical format 

The reasons for and durations of sanctions and client appeal rights are explained clearly in 

most written material provided to clients. About half of the TANF orientation materials 

present information in a well-labeled packet and in a logical format. 

TANF clients do not fully understand sanctions and, according to caseworkers, 

are not concerned about sanctions until they are imposed 

Clients rarely had more than a superficial understanding of sanctions. Regardless of the 

State’s sanctions policy, clients often reported that they would be “cut off” if they violated 

program rules. In addition, caseworkers told us that a sanction is not often a concern to 

clients until it is imposed. 

TANF — Educating Clients about Sanctions 2 OEI-09-98-00291 
RECOMMENDATION 

We recommend that the Administration for Children and Families encourage States to 

provide complete, correct, and understandable information to clients on: the causes of 

sanctions; the amounts of sanctions; the duration of sanctions; “good cause” reasons for 

work exemptions; and client appeal, fair hearing, and, if applicable, conciliation rights. 

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 information. As an initial step, it will 

provide States with examples of effective sanction information and facilitate networking 

among States interested in improving their sanction information. We made changes to the 

report based on the technical comments we received from the agency and clarified that we 

do not project our findings beyond the sample sites. 

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: 

Improving Client Sanction Notices (OEI-09-98-00292), reviews State 

methods for informing clients of sanction decisions via written notices. 

TANF — Educating Clients about Sanctions 3 OEI-09-98-00291 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY .................................................... 1

INTRODUCTION .......................................................... 5

Purpose ............................................................. 5

Background .......................................................... 5

Client sanctions under TANF ....................................... 5

“Good Cause” .................................................. 6

Appeals and fair hearings .......................................... 6

Informing clients ................................................. 6

Methodology ......................................................... 7

FINDINGS ................................................................ 9

Explaining sanctions to clients ............................................ 9

Vital information omitted ................................................ 9

Clients lack of understanding and concern .................................. 12

RECOMMENDATION ..................................................... 14

APPENDICES 

A: Orientation information with clear, complete, and concise information on sanctions, fair

hearings, and good cause ............................................... 15

B: Orientation information containing thorough appeal rights information ............. 19

TANF — Educating Clients about Sanctions 4 OEI-09-98-00291 
INTRODUCTION 

PURPOSE 

To determine how States inform clients about sanction policies under the Temporary 

Assistance for Needy Families (TANF) program. 

BACKGROUND 

In 1996, Congress significantly overhauled the Federal 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 

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. 

Client Sanctions under TANF 

Clients who do not follow program rules and requirements face “sanctions,” including 

cash assistance reductions ranging from $25 to lifetime ineligibility. States have increased 

authority to define sanctionable offenses and determine specific penalties. Federal TANF 

law directs States to sanction clients for not cooperating with child support enforcement 

efforts and/or not participating in work activities. 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 to attend other program 

activities (e.g., training sessions). 

The law mandates a minimum benefit reduction for some sanctions (e.g., a 25 percent cash 

assistance reduction for failure to participate in child support enforcement efforts), but 

States can set a maximum sanction, ranging from a pro rata sanction 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 the program rules and 

requirements. For example, some States incrementally decrease cash assistance to families 

each time they fail to comply, sometimes leading to the loss of the entire cash grant. 

TANF — Educating Clients about Sanctions 5 OEI-09-98-00291 
The TANF law also allows States flexibility in determining the duration of sanctions. 

States must, at a minimum, reduce the cash grant pro rata for each month the client 

receives aid and is not in compliance. States can set maximum sanction duration. Some 

States increase the duration of the sanction each time the client does not comply, which 

sometimes results in lifetime ineligibility. 

“Good Cause” 

If a TANF client refuses to participate in work activities or comply with other TANF 

program requirements, the State must sanction the client, except where “good cause” or 

other exceptions apply. The TANF law directs that States exempt from work 

requirements single custodial parents of children under the age of six who cannot obtain 

child care. States also can define “good cause” and other exceptions as they deem 

appropriate. Although State definitions vary, they commonly allow “good cause” for: lack 

of transportation, victims of domestic violence, lack of suitable employment, and illness of 

the participant. 

Appeals and Fair Hearings 

States are required to provide clients the option to appeal sanctions and must have a fair 

hearings system to resolve the appeal. State appeals and fair hearings policies and 

procedures may vary since TANF requires only that States certify that they have a fair 

hearings process in place and describe it. 

Informing Clients of Program Rules 

States decide how and when to inform clients of their sanction policy, the conciliation 

process, how to restore benefits once sanctioned, and the appeals and fair hearings 

process. States can, for example, conduct individual or group orientation sessions or 

provide all clients with packets of written materials including policy information. 

TANF — Educating Clients about Sanctions 6 OEI-09-98-00291 
METHODOLOGY 

We purposefully selected an eight-State sample based on: 

< percent reduction in TANF recipient populations,1 

< State policies on TANF client sanctions (e.g., full-family versus 

partial grant reduction), 

< percent of national TANF recipient population, and 

< geographic diversity 

Since our sample was purposeful, we do not project our findings. We visited offices in the 

following States: California, Florida, Idaho, Michigan, Minnesota, New York, Ohio, and 

Texas. In each State, we visited at least two offices — an urban and 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 to15 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 a 

single client to a group of more than 20. The clients were selected either in advance by 

the TANF office or while they were present for other business during our visit. We also 

collected and reviewed State and county policies, publications, and notices from each 

TANF office. 

In each State visited, we interviewed staff from at least one client advocacy organization. 

In total, we conducted 9 interviews with 15 advocacy groups. 

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. 

1

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 from each 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 — Educating Clients about Sanctions 7 OEI-09-98-00291 
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: 

Improving Client Sanction Notices (OEI-09-98-00292), reviews State 

methods for informing clients of sanction decisions via written notices. 

TANF — Educating Clients about Sanctions 8 OEI-09-98-00291 
FINDINGS 

TANF offices explain sanctions to clients repeatedly, using 

diverse methods 

Some TANF offices use multiple media to explain sanction policies to clients. They 

conduct thorough orientation classes, show instructive videos in the waiting rooms, host 

on-site legal representatives, and issue well-labeled handouts and pamphlets. The best 

offices have bi-lingual caseworkers, screeners, and translators to explain TANF policies 

and to answer client questions. 

Most caseworkers said they frequently discuss sanctions with clients. They tell clients 

about sanctions during the screening process, at the orientation session, during one-on-one 

interviews and appointments, when reviewing the rights and responsibilities form, and 

while setting up individual responsibility plans. A few caseworkers said they inform 

clients about sanctions only at a later time, usually when a client is not cooperating or is in 

the initial stages of the sanction process. 

More than two-thirds of TANF offices omit vital information 

about sanctions from their written client material 

In addition to providing clients with sanction information orally during interviews and

group meetings, all TANF offices provide written materials that explain most facets of the

State’s sanction policy. Vital information about the sanction policies include:

< causes for sanctions,

< amounts of sanctions2

,

< durations of sanctions,

< “good cause” reasons for work exemptions, and 

< client appeal rights.

Only 31 percent of TANF offices provide clear and complete information on all of the

above areas of vital information.

2 By ‘amounts of sanctions,’ we mean either the formula used to calculate the benefit reduction or a fixed 

monetary penalty. A 25 percent cash assistance reduction is an example of the former, and a set $75 penalty is an 

example of the latter. 

TANF — Educating Clients about Sanctions 9 OEI-09-98-00291 
Orientation materials commonly lack information about the amount of the 

sanction and the definition of good cause 

Approximately half of the TANF offices do not provide clients with complete, correct, and 

precise information on the amount of sanctions. For example, one orientation flyer read, 

“If you refuse to participate in a [job search program] without good cause, you may lose 

all or part of your public assistance benefits until you agree to cooperate or for a period up 

to six months.” That State’s sanction policy does not include a full family sanction, 

although the passage implies that it does. Although the minimum duration of the sanction 

in that State is indeed six months for the third instance of noncompliance, clients can be 

sanctioned indefinitely if they persist in not complying. The passage implies that the 

sanction lasts six months, at most. Nowhere else in the State’s orientation materials are 

sanctions explained in any more detail than the above passage. In addition, the State’s 

orientation material addressing sanctions for not cooperating with child support 

enforcement includes only the following passage, “Non-cooperation without good cause 

could result in the termination of [cash assistance] benefits.” Again, the material 

incorrectly implies that the State has a full-family sanction. 

Orientation materials frequently lack definitive information about “good cause” reasons 

for not complying with work requirements. Many State and county materials use the 

phrase “good cause” to denote the legitimate reasons for exclusion from work 

requirements, but often do not actually define the term or give concrete examples. For 

instance, one office’s material reads, “You have the right to claim good cause for not 

complying with a program benefit...,” but nowhere on the document is there a definition or 

examples of what constitutes “good cause.” 

Most States describe all other vital information about sanctions completely and 

present it in a logical format 

Client orientation materials contain clear and complete information about most sanction 

details. Approximately two-thirds of the TANF orientation materials we reviewed 

(1) include specific examples of reasons why a client may be sanctioned, (2) list the 

duration of sanctions, and (3) explain client appeal rights (see appendix A). Some States 

successfully use their rights and responsibilities document to outline program 

requirements, compulsory activities, and potential consequences (i.e., namely sanctions). 

Some TANF offices effectively present information about the reasons for and the duration 

of sanctions in the orientation packets, on the TANF application, and in individual 

responsibility plans. The most informative documents explicitly describe each of the 

reasons for which a client may be sanctioned. For example, an excerpt from one county’s 

orientation packet reads, “...[if you] refuse to agree to a welfare to work plan, or fail to 

show proof of satisfactory progress in your activity, or quit or refuse a job, then the 

TANF — Educating Clients about Sanctions 10 OEI-09-98-00291 
county can sanction you.” Materials often specify the duration of each level of sanction

(See appendix A for an example).

Most TANF offices provide clients with clear and complete information about client

appeal rights in rights and responsibilities documents, on the TANF applications, and in

booklets about TANF rules and policies. Figure 1 illustrates one of the best documents

we reviewed. In it, the terms “conciliation” and “fair hearing” are defined explicitly and

the processes and policies for both forms of dispute resolution are explained. (See

appendix B for the complete document.) The document also advises clients in seven

languages that the information contained is important. 

Figure 1 Appeal rights information excerpt 

Seven languages 

are used to 

explain the 

form’s 

importance. 

“Conciliation” 

and “fair 

Phone numbers 

for free legal aid 

are provided. 

Instructions on 

how to request a 

conciliation 

conference 

fair hearing are 

and 

TANF — Educating Clients about Sanctions 11 OEI-09-98-00291 
Orientation materials often present information in a logical format. About half of the 

orientation materials we reviewed include a separate packet that clearly distinguishes 

TANF sanction information from Medicaid or food stamps. The language is clear and the 

terminology is well-defined (see appendix A). The TANF offices often effectively 

emphasize sanction information by using large, bold fonts, printing the material on brightly 

colored paper, or repeating the information in several places throughout the orientation 

packet. 

Clients and advocates contend that TANF offices provide limited information 

about sanctions 

Clients commonly reported that they receive insufficient sanction information, and only in 

written form. Almost half said they learned about sanctions through either orientation 

packets or written documents received in the mail. Some explained that they only acquire 

information about sanctions from fliers and other clients. Few clients said that they had 

received sanction information in both written and oral forms (e.g., from caseworkers or 

TANF office staff). 

Several advocacy groups explained that clients often are not well-informed about sanction 

policies. The information provided to clients is frequently neither clear nor complete. One 

advocacy group explained, “The only thing clients know is what’s in the guidebook. The 

guidebook tells them that the grant will be reduced, but it doesn’t tell them by how much.” 

They also criticize TANF offices for failing to educate clients who do not speak English or 

who are illiterate. One advocacy group claimed, “If you can’t read at all or if you speak a 

different language, then you’re sanctioned.” 

TANF clients do not fully understand sanctions and, 

according to caseworkers, are not concerned about 

sanctions until they are imposed 

Clients rarely had more than a superficial knowledge of sanctions 

Clients in almost half of the focus groups did not completely understand the sanction 

policies imposed by their TANF offices. In eight of the nineteen focus groups, clients 

were unclear about the amounts, durations, causes, and remedies of sanctions under 

TANF. Clients said they would most likely be “cut off” if they failed to participate in the 

TANF program. This was a common response, even in States and counties in which 

TANF offices impose partial sanctions. Some clients had more incorrect information 

about sanctions. For example, they reported that “after awhile” the sanction affects 

Medicaid, while in actuality the State’s sanction policy allows only for the removal of the 

TANF — Educating Clients about Sanctions 12 OEI-09-98-00291 
adult from the TANF cash assistance. A few clients knew most or all of the details about 

client sanctions under TANF. 

Caseworkers in a quarter of the focus groups confirmed that clients often do not 

comprehend sanction information. Although caseworkers repeatedly inform clients about 

sanctions, many clients still do not understand. Some clients often act like they don’t care 

about sanctions when, in reality, they do not understand the information because of 

language barriers. 

A sanction often is not a concern to clients until it is imposed, according to 

caseworkers 

When a majority of caseworkers tell clients about sanctions, they are faced with clients 

who simply “don’t care.” While many caseworkers said that clients “don’t pay attention” 

to the sanction details, other caseworkers echoed the sentiment that, “Some clients say, 

‘Go ahead. You can’t sanction my kids.’” Clients also can become angry when they are 

first faced with the new sanction policies during orientation, according to some 

caseworkers. “Ninety percent of the clients I see to make the personal responsibility 

contract are mad. It’s a real escalated, emotional situation,” one caseworker explained. 

Clients more frequently pay attention or react once they are sanctioned. Most 

caseworkers reported that although clients will react when sanctions are imposed, their 

reactions are mixed. Some clients call immediately after the sanction has been imposed, 

while others are never heard from again. Most caseworkers agreed, however, that “the 

first sanction gets [clients’] attention.” 

TANF — Educating Clients about Sanctions 13 OEI-09-98-00291 
<

<

<

<

<

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 provide complete, correct, and 

understandable information to clients on: 

< the causes of sanctions, 

< the amounts of sanctions, 

< the duration of sanctions, 

< “good cause” reasons for work exemptions, and 

< client appeal, fair hearing, and, if applicable, conciliation rights. 

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 information. As an initial step, it will 

provide States with examples of effective sanction information and facilitate networking 

among States interested in improving their sanction information. We made changes to the 

report based on the technical comments we received from the agency and clarified that we 

do not project our findings beyond the sample sites. 

TANF — Educating Clients about Sanctions 14 OEI-09-98-00291 
APPENDIX A 

ORIENTATION INFORMATION WITH CLEAR, COMPLETE

AND CONCISE INFORMATION ON SANCTIONS, 

FAIR HEARINGS, AND GOOD CAUSE

TANF — Educating Clients about Sanctions 15 OEI-09-98-00291 
TANF — Educating Clients about Sanctions 16 OEI-09-98-00291 
TANF — Educating Clients about Sanctions 17 OEI-09-98-00291 
TANF — Educating Clients about Sanctions 18 OEI-09-98-00291 
APPENDIX B 

ORIENTATION INFORMATION CONTAINING

THOROUGH APPEAL RIGHTS INFORMATION

TANF — Educating Clients about Sanctions 19 OEI-09-98-00291 
TANF — Educating Clients about Sanctions 20 OEI-09-98-00291 
TANF — Educating Clients about Sanctions 21 OEI-09-98-00291