Department of Health and Human Servces 

OFFICE OF 

INSPECTOR GENERAL 

FUNCTIONAL IMPAIRMENTS 

OF AFDC CLIENTS 

.. SERVICe,.. 

,. 

1-

cl3a 

Richard P. Kusserow 

INSPECTOR GENERA 

OEI-0-90-0 
EXECUTIVE SUMMAR Y 

PUROSE 

The purpose of this inspection is to determine whether and how States with Job 

Opportunty and Basic Skis (JOBS) experience are systematically identifng and 

dealig with the functional impairments of Aid to Familes with Dependent Children

(AFC) clients. 

BACKGROUN 

The Aid to Fames with Dependent Children when enacted in 1935, had as its initial 

intent to allow widowed mothers to stay at home with their children. Its phiosophy 

shifted with the Family Support Act of 1988 into assisting needy chidren and parents 

in movig from welfare dependency to self-sufficiency. 

To promote the philosophy of self-suffciency, the Famiy Support Act requires that 

States develop a JOBS program, an education, traiing and employment program 

intended to help AFDC clients avoid long-term dependence. 

A 1988 study for the Assistant Secretary for Planning and Evaluation (ASPE) on 

functional impairents in the AFC population determined that nearly one in four 

women on AFC under the age of 45 reported themselves as functionally impaired in 

contrast to one in eleven non-AFDC women. 

A study completed recently for ASPE by Child Trends, Inc. evaluated AFDC mothers 

as potential employees. It found that most of these women have a liited education 

score below average on verbal and math skills tests, and have had little work 

experience, are long-term welfare recipients and report health problems, alcohol abuse 

and depression. 

METIODOLOY 

This inspection was conducted in three phases: 1) telephone intervews with managers 

of the State welfare offces and with JOBS program directors in the 25 States which 

have had a JOBS program in place for at least one year; 2) site visits and telephone 

discussions with program managers and clients in eight local programs which have 

especially effective practices in helping the functionally impaired; and 3) an analysis 

and comparison of the States' AFDC and JOBS assessment forms. 
The term fuctional impairment is defied for the purpose of this inspection as any 

chronic physical or mental barer which may prevent an individual from leavig welfare and becomig self-sufcient. These impairments affect an individual's abilty 

to succeed in the JOBS program and become employed. Respondents were given this broad defition of a fuctional impairent prior to the intervews. 

FIINGS 

Resnd Ide A Varity Of Impair Amng AFDC Cli; Learning Diabil An Substnce Abuse Are Th Mos Freq Menne 

Respondents identif a varety of impairments among AFDC clients such as learning 

disabilties; substance abuse; low back pai; emotional, hearig, visual and dental 

problems; domestic violence and obesity. These impairents often contribute to low 

self esteem, frequently mentioned by respondents as a major problem, and serve as 

barrers to self-suffciency. 

Jobs Program Partpatin InceaSes Chances Of Havg Funtinal Impair Ide 

A comparson of JOBS and AFC eligibilty assessment forms shows that the JOBS 

forms ask more questions which might reveal functional impairments. The JOBS 

program directors are more confdent than AFC program directors that their initial 

assessment process does in some way identify functional impairents. Whle AFDC 

respondents think that impairments might be identifed during the AFDC eligibilty 

assessment, most stress that this assessment basically consists of a fiancial evaluation. 

Participation in various JOBS activities provides fuher opportunities for identifyng 

the functionally impaired. 

Proble Ex In Dealig Wll Ide Funnal Impairts 

Whle referral does occur, it is not formal and there is little follow-up. Both AFDC 

and JOBS directors state that afer an impairment is identified the client is referred to 

appropriate servces, which in most cases consists solely of givig the client a 

telephone number or making a phone call. 

Additional obstacles which prevent clients from getting the servces they need include 

lack of avaiable publicly fuded servces, lack of transportation and lack of 

coordination among the various assistance programs. 

State Do Not Coll Agegate Data On Funnal Impair In Th AFDC Popultin 

States do not collect systematic data on these impairments. When an impairment is 

identifed, it is generally recorded, on the client's individual case record, but it is not 
usually collected on an aggegate level in anyone central place on either a local or 

State level. 

Some Loal Prams Are Escill Help To Th Funnall Impaired 

Special programs at the local level (all contracted through JOBS) were identifed 

which employ a variety of ways to facilitate self-suffciency in the functionally impaired. 

All are structured to accommodate clients with functional impairments and to assist 

them in achieving self-suffciency. 

RECOMMATIONS 

States should develop mechanisms to assure appropriate identifcation, referral 

and follow-up of clients with functional impairments. These mechanisms could 

include: 

in-depth assessments with questions and features specifcally targeted 


functional impairments


training AFC and JOBS workers to identify functional impairments


and


improved links with local programs which serve the functionally 

impaied, particularly with regard to follow-up. 

The Admiistration for Chidren and Familes should assist States and local 

governments by publicizing effective practices for identifyg, referrng and 

servng the functionally impaired. 

The Administration for Children and Families should conduct research on the 

extent and nature of impairents and interventions. As suggested in ASPE' 

comments to the draft report, this research could include coordination with 

research units whose primary focus is disability. 

COMM 

Comments to the draf report were received from the Administration for Children and 

Famies (ACF) and the Assistant Secretary for Planning and Evaluation (ASPE) and 

appear in Appendix A. We have considered these comments and made changes 

where appropriate. 

In response to the first recommendation, the ACF expresses interest in workig with 

States to address the problem. While they cite fiscal constraints on States as a 

possible liting factor, they nevertheless wi encourage States to look for 

impairments to a participant's successful transition to self-suffciency. They 

acknowledge that existing JOBS regulations wi be helpful in this regard. 
Both ACF and ASPE expressed concern that the defiition for functional impairment 

used in this report is too broad and unclear. In response to these concerns, we 

amended the report to clari the meanng of functional impairment. Prior to our 

study the nature and extent of this problem was largely unknown. Our goal was to 

make a preliary identifcation of the various tyes of impairents in order to assist 

researchers and program administrators in comig to grps with functional impairents 

of the AFC population. Therefore, we thought it important not to restrict our 

defiition to any specifc conditions. Clearly, much more research is needed to define 

the problem and develop remedies. 
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................................................ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .. 

TABLE OF CONTENTS 

EXCU SUMY 

INODUCfON €

FIINGS . . . . . . . . . . . . . . . . . . . 4€

A Variety of Impairents . . . . . 4€

JOBS Identifcation of Functional Impairments . . . . . . . . . . . . . . . . . . . . . . . . 4€

Problems in Dealig with Functional Impaients€

Data Collection€

Helpful Local Programs€

RECOMMATIONS€

COMM €

.APENDIX A . . . . . . €

. . . . . . . . . . . . . . . . . . . . . . 6€

. . . . . . . . . . . . . 7€

. . . . . . 8€

. . . . . . . . . A-
.. 

INTRODUCTION€

PUROSE€

The purpose of this inspection is to determine whether and how States with Job€

Opportunity and Basic Skils (JOBS) experience are systematically identifyng and€ dealig with the functional impairents of Aid to Famies with Dependent Children 

(AFDC) clients. 

BACKGROUN€

AFDC€

The Aid to Familes with Dependent Chidren has as its purpose, as indicated in Title 

IV of the Social Security Act (Part A, Section 401) " encouraging the care of 

dependent chidren in their own homes.. by enabling each State to furnish fiancial 

assistance and rehabiltation and other servces to needy dependent children and the 

parents or relatives with whom they are living. II The AFDC program is admistered 

by States, but funded jointly by the Federal and State governments.€

A family unit becomes eligible for AFDC when a dependent child, under 18 years of 

age, is deprived of parental support for various reasons: a parent's death , a parent' 

mental or physical incapacity, a parent's absence from the home and, in 29 States, the 

parent s loss of employment. Although eligibilty may be based on any of the above 

factors, the father s absence from the home is the priary and major reason for 

program eligibilty. Therefore, even if a client may have a functional impairent, that 

impairment may not be noticed because eligibilty is based on the father s absence 

from the home.€

When enacted in 1935, the program s intial intent was to allow widowed mothers to 

stay at home with their children, its philosophy shifted with the Family Support Act of 

1988. It now ais to assist needy children and parents in moving from welfare 

dependency to self-suffciency. 

JOBS€

To promote the phiosophy of self-suffciency, the Family Support Act requires that 

States develop a JOBS program, an education, training and employment program 

intended to help AFC clients avoid long-term dependence. States must enroll seven 

percent of the eligible population by 1991, rising to 20 percent by 1995. Clients are 

assessed to determine their trainig needs and to develop an employabilty plan. Whe all States have now implemented JOBS, some programs have been in operation 

longer than others. 
The exposure of the AFDC population to JOBS, however, remais lited. As 

indicated above, JOBS is only reaching a small portion of AFC clients. Nineteen 

States did not begin their JOBS program until the last possible date, October 1, 1990 

and not all have implemented it Statewide. Preliinary data for the second quarter of 

Fiscal Year 1991 indicates that out of approximately 4. 2 mion adult AFC 

recipients, 510 000 (12 percent) are in JOBS activities at anyone point in time. This 

number is expected to increase as the program expands. State budget constraints are 

causing States to use only a par of available Federal matching funds. 

Prr Stu€

A 1988 study for the Assistant Secretary for Plang and Evaluation (ASPE) on 

fuctional impaients in the AFC population determined that nearly one in four 

women on AFC under the age of 45 reported themselves as functionally impaired. 

In contrast, only one in eleven non-AFC women reported having a functional 

impairment. The data was derived from self-reported information on the client' 

abilty to function. 

A study completed recently for ASPE by Child Trends, Inc. evaluated AFDC mothers€

as potential employees. It found that most of these women have a limited education€

score below average on verbal and math skis tests, and have had litte work€

experience. Also, one-half of the mothers are long-term welfare recipients. Some also€

report health problems, alcohol abuse and depression. Whe this study targeted€

barrers to employment, it did not specifcally look at functional impairents.€

Other than these two studies, limited literature exists regarding functional impairments€

in AFC. Also, little is known about what, if any, State procedures are used to€

identif fuctional impairents of AFDC clients.€

METIODOLOY€

This inspection was conducted in three phases. Intially, the study team conducted€

telephone intervews with managers of the State welfare offces (AFC respondents)€

and with JOBS program directors (JOBS respondents) in the 25 States which have had€

a JOBS program in place for at least one year. A total of 49 telephone intervews€

were completed (one welfare manager could not be contacted).€

Durig these intervews, the team asked JOBS program directors questions about€

clients in their caseloads who have functional impairments, how they assess these€

clients, whether and how they identified the functional impairents of these clients€

and, once identifed, how the referral process works. Similarly, the team asked State€

welfare managers to indicate whether and how they identifed functionally impaired€

clients other than through JOBS and, once identifed, how the clients are referred.€

Additionally, both tyes of respondents also provided their perceptions of the€

characteristics and problems of this population.€
The term fuctional impairment is defied for the purpose of this inspection as any 

chronic physical or mental barrer which may prevent an individual from leaving 

welfare and becoming self-suffcient. These impairments affect an individual's abilty 

to succeed in the JOBS program and become employed. Respondents were given this broad defiition of a functional impairent prior to the intervews. 

In the second phase, the study team collected and reviewed JOBS assessment forms 

from 24 of the 25 States and AFC assessment forms from 14 of the 17 States in 

which the welfare manager thought the eligibilty assessment could identif functional 

impairents. The team utiled a worksheet listing features and questions on these 

forms, such as whether the individual had a barrer to employment, which were likely 

to identify functional impairents. It then checked each assessment form against this 

worksheet to determine how many of the features and questions it possessed. 

Lastly, the team chose four special programs at the local level for site visits and four 

for telephone intervews with the program managers. These eight were chosen from 

24 programs cited by State respondents as having some effective practices in helping 

the functionaly impaired. The four programs intervewed by phone were in 

Pennsylvania, Kansas, Nebraska and Iowa. The four visited were in New Jersey, 

Michigan and New Hampshire. They were chosen because they might exemplify some 

best practices for identifyg and/or servg AFC clients with functional impairments 

and because they appeared to demonstrate a variety of different program practices 

and phiosophies. The team held face-to-face discussions at each site with case 

managers or program staff to gain greater insight into the operations of the programs. 

Seventeen program clients, selected either by the program manager or the visiting 

team, provided their views of the program to the team. 

Since lited literature and data exist on functional impairents in the AFDC 

population, this study was exploratory in nature. It surveyed program offcials to 

determine basically what is known about functional impairments and to identify the 

issues pertaing to this problem. 
, 

FINDINGS


Respond Ide A Var Of Impir Amng AFDC Clits; Learning 

Diabil An Substae Abuse Are Th Most Freq Menne 

All AFC and JOBS program directors agree that learnng disabilties, substance 

abuse, physical problems such as low back pain, and emotional problems, such as 

depression, exist in the AFC population. These emotional problems are not routine 

but are severe enough to interfere with functionig. Other impairents include: 

hearing and visual problems, dental problems, domestic violence and obesity. 

Respondents based their opinions priariy on their own experience and observations 

in the field, and to a lesser extent on formal testing. 

These impairents often contribute to low self esteem, frequently mentioned by 

respondents as a major problem, and serve as barriers to self-suffciency. Many clients 

have multiple impairents and come from dysfunctional famies. 

Many AFC clients do not have a high school diploma or equivalent, which many 

respondents feel is due in large par to the widespread existence of learng 

disabilties. Many clients were not successful in school and simply dropped out, never 

being identifed as learng disabled and, therefore, never received special education. 

Most were not even aware of their problem. One AFDC respondent reflects the 

views of several when he says Fif-one percent of AFC clients do not have a high 

school degree and probably most of them have a learning disabilty." Another agrees 

that "there is a sense that a lot of literacy clients are learing disabled." Respondents 

described a learnng disabilty not as a major neurological condition, but as an 

impairment that makes learng difcult, such as dyslexia. 

The AFC and JOBS directors also consider substance abuse to be prevalent in the 

AFDC population. They believe this impairment can be easily masked and only 

discovered if the client happens to be under the infuence of the substance whie in 

contact with program workers. 

JOBS Pram Partin Inceases Chnces Of Havig Funnal Impairts Ide 

Initial JOBS assessments are more likely to identify impairments than AFDC 

eligibility assessments. 

A comparison of JOBS and AFC eligibilty assessment forms shows that the JOBS 

forms ask more questions which might reveal functional impairents. Al the JOBS 

forms specifcally ask about barrers to employabilty, as opposed to only 36 percent of 

AFDC eligibilty forms. Fift-five percent of JOBS forms, in contrast to 14 percent of 

AFC forms, focus on substance abuse problems. Also, 45 percent of JOBS forms 

target emotional health problems, while very few (13 percent) AFDC forms do. 
Finally, JOBS forms are twce as likely as AFDC forms to have a worker observation€

section that instructs workers to record observations about client functioning and 

behavior. 

The review of JOBS assessment forms also shows that approximately one-third call for 

testing which might reveal functional impairments. Th-six percent have skis 

testing and reading/teracy testing, and 27 percent test math skils. In those same 25 

States, no testing of any kid is conducted as part of the AFC eligibilty assessment. 

JOBS ASSESSMENT FORMS TARGET FUNCTIONAL IMPAIRMENTS 

MORE THA AFDC FORMS€

100€

QUESAI€ BAER 1\ EMPL SUBSAN€

Legend 

% OF AF FOMS WI THIS FETURE 

II % OF JO FOMS WI THIS FE11RE 

OBATI TENG€

The JOBS program directors are more confident than AFC directors that their initial 

assessment process does in some way identify functional impairments. Whe AFDC 

respondents think that impairments might be identifed durig the AFC eligibility€

assessment, most stress that this assessment basically consists of a financial evaluation€ lited mostly to questions about finances and family situation. On the other hand€

most JOBS respondents report that their assessment has more detailed questions€

about the clients' background and barrers to employment. One AFDC respondent 

suggests that "If more people could at least get through the JOBS assessment, that would be the most effcient, cost-cutting way to identify impaients because the 
, 

, , 

assessors for JOBS are case managers. JOBS assessments should become a 

requirement." 

Both AFDC and JOBS respondents generally agree that if an impairment is identifed 

in an intial assessment, it usually occurs as a result of questions asked during the 

intervews, worker observation, and testing. 

The JOBS assessors tend, on the whole, to be more qualified educationally and 

experientially than their AFC counterparts. In all but one of the 25 States, at least 

75 percent of JOBS assessors have college degrees, whereas in only four of those 

States can the same be said for AFDC assessors. In 64 percent of the States, more 

than half the JOBS assessors have prior case management experience; in none of the 

States do more than hal of the AFC workers have prior case management 

experience. Also, the AFC directors report that because their staff have very large 

case loads, they may not have suffcient time to note subtle client impairments. One 

respondent reflects a prevailng view when she says You can t identif and do volume 

servce at the same time. 

Partcipation in JOBS program activities provides further opportnities to identify 

the functionally impaired. 

Six-eight percent of JOBS program directors report that participation in later JOBS 

activities, such as traing or workshops, is likely to reveal a client s functional 

impairments because it demonstrates the client s abilty to function in a structured 

setting. One JOBS respondent reflects the view of many when he states It is very 

hard to identif subtle impairments if the person doesn t disclose it. They may show 

up down the road but the initial assessment isn t enough time to do it." Another states 

that When the client begins participation in an actual component, they have to come 

every day to a program and you see problems with attendance, behavior and 

consistency in terms of performance. 

In contrast to the JOBS experience, only several AFDC respondents report that 

impairents may be picked up durig additional contact with the client, such as 

ongoing case management; they stress that this is often informal and by chance. 

Prble Ex In Dealig Wih Ide Funtinal Impain 

While refe"als do occur, they are often informal with little follow-up. 

The AFDC and JOBS program directors report that after an impairment is identified€

the client is referred to servces such as substance abuse treatment, medical and 

mental health servces, social servces and vocational rehabiltation. In most cases 

referral consists solely of givig the client a telephone number or makg a phone call. 

Limited follow-up also hinders the referral process. As one AFDC respondent states 

Follow-up is important. Otherwse the client wi be back on the rolls." Many 
respondents blame large case loads and insuffcient staffng and resources for this lack 

of follow-up.€

Both AFC and JOBS respondents mention particularly that if clients have chronic 

disabilties that would make them eligible for SSI, they would definitely be referred. 

However, many of these disabilties are not severe enough for them to qualify for SSI. 

One AFC respondent reports that her State "is in serious budget trouble, so we have 

to look very hard for people who could be put on SSI so the Feds, not the State, pay 

for them. 

A number of additional obstacles prevent clients from getting the servces they need.

Six-four percent of respondents cite a lack of available publicly funded servces, as 

exemplied by the long waiting lists at many substance abuse treatment centers. Fifttwo percent mention lack of transportation. Lack of coordination among the various 

assistance programs is also mentioned. 

The functionally impaired face other obstacles to self-suffciency. 

A majority of AFDC and JOBS program directors believe the functionally impaired 

face other barrers to self-suffciency. Almost all mention that these clients have a 

diffcult time fiding and retaining work that pays enough to get off the AFDC rolls. 

Over hal the respondents state that there are not enough programs, servces or 

training opportunities specifcally suited to the functionally impaired. Some other 

obstacles include transportation problems and housing difficulties. 

Full-time JOBS participation may be difcult for the functionally impaied. In order 

for States to meet the requirements for JOBS Federal funding, the JOBS participation 

rate in each State must average 20 hours per week for each participant. However 

several respondents mention that this rate may be diffcult to reach due to this 

population s impairents. Because a functionally impaired client might not initially be 

able to tolerate 20 hours of classroom instruction, other recipients' participation rates 

wi have to be proportionately higher in order for a State to reach the required 

participation rate. 

State Do Not CoHect Agegate Data On Funtinal Impair In Th AFDC 

Popultin 

Alost all JOBS and AFC respondents state that when a functional impairment is 

identified, it is generally recorded, usually on the client's individual case record. 

Employabilty plans, referral forms, test results and assessment forms were mentioned 

as other places where impairments might be indicated. However, while such 

inormation may be maintained in an individual case record, it is not usually collected 

on an aggegate level in anyone central place on either a local or State level. Several 

respondents point out the fact that the collection of such data is not a program 

requirement. 
Whe awareness of the problem exists, it is not usually quantified. When JOBS and 

AFDC respondents were asked to specif the number of individuals identified as 

having fuctional impaients over the past year, most could not give an exact figure. 

Those who did offered only estimates, rangig widely from two to eighty percent. 

Some Loal Pram Are Es Hel To Th Funnall Impaired 

Special programs at the local level employ a variety of ways to facilitate selfsuffciency. 

Both JOBS and AFC respondents mention several local programs with effective 

practices for helping the functionally impaired. Of these, the study team chose eight 

for onsite visits or telephone intervews (a forthcoming case study report wi profie 

the eight programs in greater detail). All eight accommodate clients with fuctional 

impaients and to assist them in achieving self-suffciency. These programs include: 

general equivalency degree (GED) traing classes with special activities for the 

learng impaired; intensive, in-depth client assessments; programs specifically for 

long-term welfare recipients, the majority of whom are functionally impaired; and 

intensive, multi-focus group workshops. These programs were later found to be 

contracted through JOBS. 

The managers and instructors in all eight programs, say that at least half their clients 

have a functional impairment, with many havig multiple impairments. With the 

opportnity to be thoroughly evaluated and with intensive participation in program 

activities, clients are reportedly more liely to have impairments identifed, thus 

allowig appropriate treatment and referrals to be made. 
, 

These local programs share several characteritics which contrbute to their 

apparent success.€

The eight local programs exhbit common qualities and practices which 

effectiveness, as listed below. 

maxe their€

HAVE STRTEGIES 

RECONIZE THE TO MINIMIZE IMPACT 

SIGNIACANCE AND OF FUNCTIONA 

PREVALNCE OF IMPAIRMENTS STRESS SELF-ESTEEM 

FUNCTIONAL IMP RMENTS AND SKILL BUILDING 

lH EI LO PROGRAS I 

EMPHASIZE HAVE A€

CUENT UTIUZE DEDICATED€

FOLLOW- INTENSIV STAFF€

CASE€

MANAGEMENT€

Additionally, most program managers and instructors attribute their success to dealing 

with all the needs of the individual - emotional, physical, fiancial and personal. They 

also stress the importance of teachig clients to rely upon themselves, despite any 

impairments they may have; as one respondent states We teach them to advocate for 

themselves. 

Clients of the visited programs offer strong support.€

Al client respondents from the four programs visited give these programs positive 

ratings. Clients feel that they benefit from the individual attention they receive and 

are confdent their participation will help them achieve self-sufciency. They mention 

that they are being given practical skills for enterig the workplace and, just as 

importantly, are building their self-esteem. With career discovery programs, they are 

able to explore the diferent employment options available to them. 
, 

, 

Particularly in the GED classes, an effort is made to tailor education and training to 

the needs of clients with impairments. Many of these clients were not successful in 

regular school settings because their impairments, such as learning disabilties, were 

not recogned and therefore not accommodated. One client currently studyig for 

her GED asserts Ths is a second opportunity for me. I'm not going to let it go. 

Some program graduates are no longer dependent on welfare. 

Except for one, all of the eight programs have clients who have already graduated. 

Some are currently attending college and others have steady employment. Several of 

the programs will only place clients with jobs that pay enough to keep them off of 

welfare; in most cases, these jobs pay above the minimum wage. In one program, a 

former client is now an instructor in that program; in another, a former client attained 

her Master s degree in Social Work and is now a case manager. 

The success of the individual parent also has wider implications for her/his chidren. 

Several program staff mention that when a parent is no longer dependent on welfare 

her/his children are also more likely to avoid such dependency when they become 

adults. One program manager states Some kids thik being on AFDC is a way of 

life ; several others mention that successful participation in their programs is one way 

to "break the cycle" of future welfare generations. 
RECOMMENDA TIONS€

States should develop mechanisms to assure appropriate identification, referral 

and follow-up of clients with functional impairents. These mechanisms could 

include: 

in-depth assessments with questions and features specifcally targeted to€

functional impairents€

trainng AFC and JOBS workers to identif functional impairents€

and€

improved lin with local programs which serve the functionally€

impaired, particularly with regard to follow-up.€

The Administration for Children and Familes should assist States and local 

governents by publicizig effective practices for identifg, referring and 

servg the fuctionaly impaired.€

The Administration for Children and Famies should conduct research on the 

extent and nature of impairments and interventions. As suggested in ASPE' 

comments to the draft report, this research could include coordination with 

research units whose primary focus is disabilty. 

COMM€

Comments to the draft report were received from the Admistration for Children and 

Familes (ACF) and the Assistant Secretar for Plannig and Evaluation (ASPE) and 

appear in Appendix A. We have considered these comments and made changes 

where appropriate. 

In response to the fist recommendation, the ACF expresses interest in working with 

States to address the problem. While they cite fiscal constraints on States as a 

possible limiting factor, they nevertheless wi encourage States to look for 

impairents to a participant s successful transition to self-suffciency. They 

acknowledge that existing JOBS regulations wil be helpful in this regard. 

Both ACF and ASPE expressed concern that the definition for functional impairent 

used in this report is too broad and unclear. In response to these concerns, we 

amended the report to clari the meaning of functional impairment. Prior to our 

study the nature and extent of this problem was largely unknown. Our goal was to 

make a preliinary identifcation of the various tyes of impairments in order to assist 

researchers and program administrators in coming to grps with functional impairments 

of the AFC population. Therefore, we thought it important not to restrict our 

defition to any specifc conditions. Clearly, much more research is needed to defie 

the problem and develop remedies. 
APPENDIX A 

COMMENT TO mE DRA REPORT 
. .. 

r-. -= FEB-26-92 WED 14: 59 

DEPARTMENTIiAn\'t&. HUMAN SERVICES 

CiFFICE OF i€SPE

ADMINISTRATION FOR CHILDREN AN €

Office of the Assistant Secretary, Suite 600 1992 FEB I 3 i 9: q a 370 L'Enfant Promenade, S.W. 

Washington, D.C. 2047 

PDIG 

DATE: Febt"uary 13, 1992 DIG-AS 

TO: Richard P. Kusserow pcGInspector General 

OGC/IG . 

FROM: Jo Ane B. Barnart EX SEC Assistant Secretary 

for Children and Fam . ies DATE SENT 

SUBJCT: Draft for IlFuncti01\ :t pairment 

Thank you for the opportunity 't c01Dent on your study of the 

functional impairments affecting AFDC clients. We believe that 

it is a well written report. 

However, the report uses a definition for functional impairment that we believe is broad and amiguous: " (A) ny physical or 

mental barrier which may prevent an individual from leaving 

If the discussion were welfare and becominq self-sufficient. the 

more focused, it would better serve to address the needs of participants and ACF. Distinctions should be drawn between those 

conditions which. can be readily treated, i. e., the need for eye-€

qlasses , dental treatments, and other physical all ents and those 

emotional and self-esteem problems which might only be alleviated 

over e long term through counseling and job readiness programs. 

These barriers should in turn be distinguished from physical and 

mental conditions which would cause exemptions for illness or 

incapacity at 4S CFR 250. 30(b) (2) and (3). he report should 

also acknowledqe that increasing AFDC caseloads affects a State

agency' s ability to serve the functionally impaired. 

The repcrt is correct that regulations allow for the combining€

and averaging of t."1e hours of those individuals scheduled to€

participate in JOBS activities. However, the last sentence of 

the 4th paragraph on page 7 sti l implies that a particular 

participant will have to be in classroom instruction for a rate 

minimum period of time. There is no inimum participatio 

for individual participants. Fuctionally impaired participants 

could attend for the lengt of time appropriate to them, as long€

as the participation of other recipients allowed the state to 

achieve the participation standard. 
, 

,. .. :;,., ..

r. .€

Page 2 - Richard P. IUserow 

Finally, we would like to encQurage the OlG, in these reports and


in any subsequent reports, to use "people first" language
 that the


wherever appropriate. "People first." languac;e means €

person rather than the disability comes firt. So, ter example,


not "mentally re arded boy" but "boy with mental retardation"


or, not "crippled" or "confined to a wheel chair , but "uses a


Wheel chair" , etc. In c:eneral the focus should be on the 

individual, not the particular limtation.


Commen-ts on Recommenda iiit€

RECOMMND1\T!ON NO. 

We do not believe that recommendation no. 1 is practical in


all States given the pressures associated with increased


caseloads and declinin9 fiscal resources. However, whenever


c look for these
 appropriate, we will encourage States 


impairments to a participant's successful transition to
 self-sufficiency . fer€

The JOBS final regulations specify the requirement 

participant assessment in the JOBS prcqr. 'rhe stat.e IV-A 

aqency must conduct an initial assessment. of each 

participant's employability based en (1) educational, child 

care and other supportive services needs: (2) the 

participant' s proficiencies , skillS deficiencies, and prio 

work experience: and (3) a review of the family 

circumstances, which may include the needs of any child of


the participant. 

This assessment would serve to identify many of the


conditions referred to in the report. The regulations give


wide latitude to the states to choose methods to assess


participants and recogni%B that methods will vary based on


caseload size, program resources, and program philosophi


We believe Congress intended to qive state IV-A aqen ies€

broad flexibility in developing assessment strateqi


pCOMMENDATION NO 2 

The OFA Division of JOBS program already has a "best
 practices " responsibility which encompasses the qathering of
 , including the


infornation on the total recipient populati
 functionally impaired. UnfortunatelY, without more rigorouS determine' which practices are 

evaluation, it is difficult to individuals ith€

most effective in reducing dependency among 


functional impairments.

.. 

paqe 3 - Richard P.. Kusserow 

bariers or 

We aqree that when participants suffer

1:p.aiJ:ent which are wi1:in the capacity of the worker to 

observe, every effort should be )lde to seek the resources€

to secure professional evaluation and t:e services to€

overcome these obstacles. However, this function must be€

performed in the context of the JOBS worker s major cnqoing€

responsibiliti 

Coordination with other service providers is critical to the

success of JOBS. We concu that workers should be prepared are 

to take full advantage of the network of servicesassistance available. However, it is difficult to provid 

where appropriate non-reimurable services are in short 

supply.. If states must. pay for the services, there will be 

considerations regarding the allocation of fuding and the 

potential efficacy of the treat1ent to achieve meaningful participation in JOBS.. 

8ECOMHNDATION NO.. 3 

ACF will qive consideration to conducting research on 

functional impairment and appropriat interventions.. We had 

at the OIG inves iqation would shed more light en€ hoped this area. However, because of its bread definition of 

functicnal impairments , its usefulness was 11m! ted. 
:. .. ,/

Washington, D.C. 20201


1992 FE 20 


DDN 

TO:	 Richard P. Kussero 

Inspector General 

OGCIIG FROM: Assistant Secretary for EXSE Planning and Evaluation 

l1DaU" e . 

Comment" on o:tG Draft Reports: .Fun SUBEJCT: 

of AFDC Clients" and "Fuctional Impair!ents of AFDC 

02.- 00401 Clients: Case studies" 

We appreciat the opportunity to review the draft report for 

your study of bow states are dealing with functionally impaired 

AFDC clients under JOBS. This study provides the Departent and 

states with insights about what types of impairments are found in
 akq special the AFDC popUlation and examples of local programs 


efforts to identify and help this popula'tio This informtion


will be useful as the Departent continues to help states to€

comments on the


fine-tune their JOBS programs. Followint; are our €

draft. l8 are defined 

We are concerned about how 18 functional lmpaiDIents 

in these report While functional impairments are the keystone of both reports, the definition is somewhat unclear. The 

distinction bet een having an impairment (such as low back pain) 

and beinq functionally i1Ipaired :by low Dack pain needs 'to 

sb. 1;E:ned. . The fuctional impairments of most concern here are 

those that affect ability to succeed in the JOBS proqram and 

. become employed. The difference ):etween chonic versus acut 

i1Ipairments also needs to be raised. The studies, ' we believe, 

are. referrinq to chronic i1pairments but this is not clearly 

tated anywhere. 

Learning disabilities are a I1aj or iInpairment according to the 

reports. However, we wonder if these impairments had been 

diagnosed during these women s school years and, if they were, 

what was the role of special education? Had these impairments 

been identified before? Did these women receive -. special 

cation? Did the clients themselves know that they were 

learning disabled?


Emotional i1Ipairments also predominate, but what they consist of is unclear. The point needs to be made . here that thes 

imp irment are not routine emotional concerns, but serious 

which could interfere with functioning. In 

emotional impairment 

the current text one might tha ar-a 7P rt of everyday interpret the emotional impairments 

reported to be relatively minor oR.. o r.. 11 o:;.J r..... 

1. e. 

."'''c 

\.I C:\l :2"" 1..1' .JI:J.. 

11-' A I ':":1\. 
_&., (

r: 

P. XUsserCW Page 2 - Richard 

Several tiJes, references are )lds t: SSI 

eligibility wherein 

states encourage iJpaired AF recipient to enroll in the 

disabled porti of 551. Reade ar apt to wonder whY most of

benefits. It that ahcud be pointed out 

these clients don't get 551 

that most of these AFDC clients probably have disabiliti 

a,e not. severe enough for t.'lem to qualify fer SS:I. 

The recommendations call ) for ACF to assist€ for, (1) the 5tates to develop 

mechanism to provide in-depth assessment serve 

states in effective practices to identifY, refer, and 

There impaired clients, and in AFDC populati (3) for ACF to conduct reearch on the 

nature and extent of impairments stndard are ma physical and mental/emotional aasessmet int:rnts 

that can be used. Does OIG have any preferred or 

measures to recommend: The st.udy. first two recommenda.tio 

could be strengtened by calling for States to includ physical, 

mentall emotional, and learning disabilities in their assessments 'roo often, persons with disabilities are 

and ide.TltificaticnsiO 

thought to include only those with physical disabilities. is ere 

ird recommendation, 

any overall guidance€

Regardinq the €

at ACF should follow, such as coordination with research units€

is disability?€ whose primary 

that ACF t: together with ents OIG should include a reco_endati ADAM to treatment of AFDC recip€ coordinate diagnosis

with alcohol, drg abuse or mental hea1.th iJirts. Such 

coordination could be particnar1.y productive in regard to 

depression. There have been major advancemts in the effective 

treatment of depression in recent years. Early identificati 

and treatment of JOBS participants with t..,atable depressio 

imact on their ability to benefit 

likely to have a significant self-Sufficient. 

from JOBS services and become 

collected for this ASPE and ACF are jointlY supportin'1 an evaluation of JOB5 program 

strategies. Among the baseline data to be amon'1 potential 

study will be measurements of depressi about 

participants. This data will proide furer informti 

the extent of emotional impairments in this populati€

Finally, we have few specific questions about the report, 

Clients: Case studies 

"Functional ImpairJents of AFDC 

The references to "Bad or no impairments. teeth" on page 5 need to be€

further described as to why they are €

The reference on page 7 to 

"too much perfmne" as indicati€

of a substance abuse problem needs to be explained. €
. 

, .: . ,,;.. 

Page 3 - Richard P. €'Rsser 

as to how€

The description on paqe 12 needs an explana€ program are incorpothe AFDC client population and the JOBS 

rated into the HOST/HR Progam. prevalence figues of V 

broad cateqories of tmpairments are 9i en fer this program, 

AFC clieni:s. 

but it is unclear whether they are all €

Ix you have any specixic questions about this report, please 

contact Jane Baird, 245-2409. 

Martin H. Gerr