National Council on Disability 

An Independent agency working with the President and Congress to increase the inclusion, independence, and 

empowerment of all Americans with Disabilities. 

 

TANF AND DISABILITY — IMPORTANCE OF SUPPORTS FOR 

FAMILIES WITH DISABILITIES IN WELFARE REFORM 

Position Paper 

National Council on Disability 

1331 F Street, NW, Suite 850 

Washington, DC 20004 

202-272-2004 Voice 

202-272-2074 TTY 

202-2720-2022 Fax 

Lex Frieden, Chairperson 

March 14, 2003 

Introduction 

The Temporary Assistance for Needy Families (TANF) block grant, first created in 1996 to 

replace Aid to Families with Dependent Children (AFDC), was slated for reauthorization in 

2002. Rather than undertaking the full reauthorization, Congress passed a short extension, which 

has since been extended to the end of June 2003. It is likely to be reauthorized by Congress in the 

next few months. As part of the reauthorization process, there have been many proposals to 

strengthen protections for parents and children with disabilities participating in TANF-funded 

programs. It is important that the law establish policies that reflect both the intention and desire 

of people with disabilities to work, and the reality that certain individuals may still have severe 

work limitations requiring long-term assistance. 

While the TANF program is not specifically directed towards individuals with disabilities, 

research data indicate far-reaching effects of this program on people with disabilities. According 

to the General Accounting Office (GAO), a substantially higher proportion of TANF recipients 

reported having physical or mental impairments than did adults in the non-TANF population. In 

addition, many TANF families include a child with a disability. The work requirements and 

lifetime limits to benefits, which are key elements of welfare reform, pose special challenges for 

state and local TANF agencies in addressing the unique needs of families with a disability who 

are TANF beneficiaries. 

People with disabilities often face multiple barriers to work. In addition to the barriers faced by 

most low income Americans as they attempt to work, such as inadequate transportation and 

limited opportunities to improve education and skills, people with disabilities must meet the 

specific challenges of their physical or mental impairment or health condition – often requiring 

assistive technology, access to accessible transportation, sign language interpreters, or personal 

care assistance, work place supports etc. in order to participate in programs designed to assist 
them in finding work. When appropriate assessments of individual needs for reasonable 

accommodations are provided, people with disabilities are afforded equal opportunity for full 

participation, independent living, and economic stability. 

Also facing extraordinary challenges are parents of children with disabilities, who are frequently 

unable to find or to afford a child care setting able or willing to handle the special needs of their 

children. These parents are often called upon to miss work to provide for these special needs, 

putting them at risk of incurring TANF sanctions. They are more likely than others to experience 

significant hardships when forced to leave the TANF program due to time limits. 

While these additional challenges faced by people with disabilities may seem to paint a bleak 

picture, in fact, TANF creates a great opportunity to creatively design programs that can give 

parents with disabilities, and parents of children with disabilities, the training and support they 

need to secure and maintain employment. Some states and communities are already 

collaboratively working to help people with disabilities prepare for and sustain employment. 

Greater national emphasis on systemic collaboration and review of policies and legislation 

among federal, state, and local entities that bring consumers with disabilities to the table and 

begin dialogue and actions would serve to remove barriers and create real opportunities for 

people with disabilities to transition from welfare to work. 

 

There have been many proposals to address the unique circumstances facing families on TANF 

who experience a disability (of the parent or the child or another family member). The most 

common of these proposals would require states to provide more comprehensive assessments of 

barriers to employment, including disabilities; provide states with greater flexibility in

determining what counts as a work activity; bar states from sanctioning a family for noncompliance with a program rule if the TANF recipient or a family member has a barrier which 

prevents compliance and has not been provided with help in addressing that barrier; and provide 

funds for state-level advisory panels to consider ways in which a state can improve its TANF 

policies and procedures to better assist families who have barriers, including disabilities. 

“Every American should have the opportunity to participate fully in society and engage in 

productive work. Unfortunately, millions of Americans with disabilities are locked out of the 

workplace because they are denied the tools and access necessary for success.” President George 

W. Bush, New Freedom Initiative at p. 18, (Feb. 2001), 

www.whitehouse.gov/news/freedominitiative/freedominitiative.html. For many people with 

disabilities, TANF, if appropriately designed, could provide the tools and access needed to 

unlock doors to opportunity, productivity, and economic self-sufficiency. This paper 

summarizes research about people with disabilities and TANF and some of the proposals being 

offered for consideration to improve how TANF-funded programs address the needs of families 

with a member with a disability. This paper concludes with the following recommendations from

the National Council on Disability (NCD) for TANF reauthorization: 

 Increase TANF and childcare funding; 

 Ensure that parents with disabilities are screened, in a timely manner, with appropriate 

diagnostic tools; 

2
 Prohibit states from sanctioning families until the state has taken steps to identify barriers, 

provided the family with assistance in meeting the rules; and modified rules, if necessary to 

address the parent’s or child’s disability so that the family can comply with TANF 

requirements; 

 Provide states with flexibility in how they define countable work activities, including 

rehabilitation and participation in other activities that will help the parent to become workready, and how they determine the length of time a particular individual or family will need 

the specific services or treatment; 

 Provide states with additional resources to train case workers and other staff who serve 

TANF recipients about issues unique to disabilities, including how to provide timely and 

effective screening, and how to identify programs, resources, and opportunities for 

collaborative community initiatives to achieve systemic improvements in services for people 

with disabilities;

 Create advisory panels at the state level to assist states in addressing the needs and barriers of 

people with disabilities; 

 Facilitate access to continued Medicaid or other health coverage when recipients move from

welfare to work; 

 Assist states to better coordinate and provide services needed by children with disabilities 

and their families to address the multiple challenges facing parents and children with 

disabilities;

 Ensure that TANF programs and services comply with the Americans with Disabilities Act 

and Section 504 of the Rehabilitation Act. 

 

 Family Members with Disabilities and TANF – What We Know From the Research

Parents with disabilities. 

 Case #1 

3

 “DD is a 42 year-old woman with two children who has been trying to find appropriate work for 

the past five years. She has been receiving TANF ... She suffers from phlebitis, which causes 

severe pain without warning; her leg will become swelled and force her to rest, and on some 

days she cannot get out of bed at all. Extensive standing, walking, or other physical activity 

exacerbates the problem. She worked as a clerk for the Liquor Control Board for six months ..., 

but she was forced to quit because the job involved lifting boxes, and she was physically unable 

to perform the job’s requirements. ... In 2001 she took the civil service exam as a clerk/typist, 

and she passed, but most recently she was #577 on the waiting list. Should her name come up, 

she will likely be further hindered by her lack of a General Equivalency Degree. DD is not 

considered exempt from TANF work requirements by DPW, and so she has had to look for work, 

and attend job readiness programs, rather than focus on a program which would enable her to 

earn her G.E.D. and improve her chances ... If she does find an appropriate job, she will need a 

boss who will grant her accommodations on days when she is unable to come to work. DD 

emphasizes that she is ready and willing to support her children, but after five years on TANF, 

despite her steady efforts to find work, she still does not have an education, the networking skills, 

or the medical support that would enable her to leave the welfare rolls. ...DPW referred her to a 

program in which she could obtain job training while also obtaining her GED, but on the second 

day of the program, her phlebitis acted up and she could not get out of bed. ... she cannot re-
enroll until she provides satisfactory proof ... but she cannot see a doctor [in time to keep the 

slot.] Eventually she may be able to re-enroll, but her sixty months on TANF will have long 

since run out. It is possible, though far from certain, that she could have obtained a full-time job 

by now, with the potential for raises and promotions, if she had been placed in a high-quality 

GED program at the outset of her time on TANF, if she had regular medical coverage and a 

steady relationship with a doctor who could provide ongoing treatment for phlebitis ... and if she 

had been placed in a good job training and placement program which helped line up interviews 

for appropriate clerical positions. Instead, DD encountered frustration, denials and 

inappropriate job offers.” Community Legal Services, Philadelphia, PA, Case Histories of 

Disabilities in TANF Families in Pennsylvania. 

Case #2 

“I am 28 years old and I have two children, ages five and seven. I have suffered from epilepsy 

ever since I was five, and I have unpredictable seizures that make it difficult to work. Although I 

can usually control the epilepsy with medication, when I am under a lot of stress I am more 

likely to experience seizures ... The father of my children was abusive to me, but in the summer 

of 1999 I escaped from the situation with the help of ... a domestic violence program. After 

leaving, I had a difficult time finding employment that would allow me to support my family ... I 

received TANF for a few months, but then my income from working in a laundromat was high 

enough that I was no longer eligible. Unfortunately, the laundromat manager had to let me go 

because I was having a lot of seizures, some of them at work ...that caused me to miss work. I 

turned to the state for help again ... I reapplied and thought I had completed the process. Around 

that time, I was also in intensive care for six days due to severe seizures. For that reason I 

missed an ... appointment. When I got home from the hospital, I was greeted with a letter saying 

that since I hadn’t shown up at the meeting I was not eligible for that month because I had not 

completed the application process. ... no TANF, no food stamps, and no help with childcare or 

other support services. I called my caseworker to explain that I had been hospitalized. ... For 

some reason, she questioned whether I had an appropriate referral to be hospitalized ... Even 

though my caseworker knew about my history of domestic violence and health problems, I was 

never told about good cause for exemptions.” Statement of a Maine mother from collection of

Maine Equal Justice Partners. 

There is now a substantial body of research that documents the nature and extent of physical and 

mental impairments of parents participating in TANF programs.1

 In a national study of TANF 

recipients, the General Accounting Office (GAO) found that 44 percent of TANF recipients had 

at least one physical or mental health impairment, three times higher than the rate of such 

impairments among adults not receiving TANF benefits.2

 In 1999, 38 percent of TANF 

 1

 For a more detailed discussion, see Eileen P. Sweeney, Recent Studies Indicate that Many Parents Who are 

Current or Former Welfare Recipients Have Disabilities or Other Medical Conditions, Center on Budget and Policy 

Priorities, February 2000, http://www.cbpp.org/2-29-00wel.htm. For a discussion of the most recent studies as well

as the prevalence of other barriers to work in the TANF population, see Heidi Goldberg, Improving TANF Program

Outcomes for Families with Barriers to Employment, Center on Budget and Policy Priorities, January 2002, 

http://www.cbpp.org/1-22-02tanf3.htm. 

4

2

 U. S. General Accounting Office, Welfare Reform: More Coordinated Federal Effort Could Help States and

Localities Move TANF Recipients with Impairments Toward Employment, GAO-02-37, October 2001, available at 

www.gao.gov. 
recipients reported an impairment severe enough that the individual was unable or needed help to 

perform one or more activities, such as walking up a flight of stairs or keeping track of money 

and bills.3

 In a second report, in July 2002, GAO found that recipients with impairments are half 

as likely to exit TANF as recipients without impairments. And, people with impairments are less 

likely than people without impairments to be employed after leaving TANF. Some who no 

longer receive TANF receive Supplemental Security Income benefits (SSI) while others do not.4

In 2002, the U.S. Department of Health and Human Services (HHS) Office of the Inspector 

General confirmed that high numbers of people with disabilities receive TANF.5

The Manpower Demonstration Research Corporation (MDRC), in another study measuring 

barriers among recipients in four large urban counties, found that nearly one-third of the nonworking recipients studied reported having fair or poor health. Companion ethnographic 

interviews conducted by MDRC indicated that health problems were likely to be under-reported 

and under-rated in the survey and that the survey data did not accurately reflect the depth of 

severity of the problems that the mothers and children faced.6

 

 

There is a high incidence of mental impairments among parents who receive TANF. Based on its 

National Survey of American Families, the Urban Institute has reported that almost half of

parents receiving TANF either said that they were in poor general health or scored low on a 

standard mental health scale. One-third either said that their health limits their ability to work or 

scored as having very poor mental health.7

 Approximately one-quarter of those who have left 

welfare and are not working also have mental health impairments.8

 Two studies, in Michigan and 

Utah, did in-depth diagnostic questioning of TANF recipients. The Michigan study focused on a 

sample of all TANF recipients in one urban county while the Utah study looked at those who had 

received welfare for at least three years. In Michigan, one-quarter experienced major or clinical 

depression, one-seventh had post-traumatic stress disorder, and about seven percent had general 

anxiety disorder. The results in Utah were similar: two-fifths had major or clinical depression, 

about one-seventh had post-traumatic stress disorder, and about seven percent had general 

anxiety disorder.9

 

 3

 Id. 4

 U.S. General Accounting Office, Welfare Reform: Outcomes for TANF Recipients with Impairments, GAO-02-

884, July 2002, available at http://www.gao.gov. 5 HHS Office of the Inspector General, State Strategies for Working with Hard-to-Employ Recipients, OEI-02-00-

00630, July 2002, http://oig.hhs.gov/oei/reports/oei-02-00-00630.pdf . 6

 Denise Polit, Andrew London, and John Martinez, The Health of Poor Urban Women: Findings from the Project

on Devolution and Urban Change, Manpower Demonstration Research Corporation, May 2001, 

http://www.mdrc.org/Reports2001/UC-HealthReport/UC-HealthRpt-Overview-2001.htm. The study was conducted 

in four large urban counties: Cuyahoga County, Ohio; Los Angeles, California; Miami-Dade, Florida; and

Philadelphia, Pennsylvania. 7

 Sheila Zedlewski, Work Activity and Obstacles to Work Among TANF Recipients, Urban Institute, Series B, No. 

B-2, September 1999, http://www.urban.org. 8

 Pamela J. Loprest, Sheila R. Zedlewski, Current and Former Welfare Recipients: How Do They Differ? Urban 

Institute, Discussion Paper 99-02, 1999, http://www.urban.org.

5

9

 Sandra Danziger, Mary Corcoran, Sheldon Danziger, et al., Barriers to the Employment of Welfare Recipients, 

University of Michigan Poverty Research and Training Center, February 2000, 

http://www.fordschool.umich.edu/poverty/wesappam.pdf; Amanda Smith Barusch, Mary Jane Taylor, et al., 

Understanding Families with Multiple Barriers to Self Sufficiency: Final Report, University of Utah Social Research 

Institute, February 1999, http://www.socwk.utah.edu/pdf/sri-final1.pdf. See also, Why Some Women Fail to Achieve 
Three states — Kansas, Washington, and Utah — undertook significant efforts to determine the 

extent of learning disabilities among current TANF recipients. The three studies found that 

somewhere between one-fifth and one-third of recipients have learning disabilities. The 

Washington study suggested that up to one-half may have learning disabilities.10 There also are 

significant numbers of parents who have physical disabilities. While less has been written about 

the nature and extent of recipients’ physical impairments, it appears that about one-fifth of 

current TANF recipients have physical impairments that limit their ability to work. According to 

a 1999 report by the University of Utah Social Research Institute, among recipients who were 

not working, about one-third had physical problems. The Utah study suggests that the figure may 

be even higher among longer-term recipients.11

Children with disabilities. 

Case #3 

“I have four children, three of whom have special needs ... my son, who is eight, has attention 

deficit hyperactivity disorder and has been diagnosed with oppositional defiant disorder ... my 

son, who is nine, is being studied for depression. My daughter, who is now six, has spina bifida, 

which is a serious problem that has required her to be catheterized several times a day ever 

since she was six months old. ... The worst part of my story is that when my daughter was from 

about six months until three, I put her in day care so I could work. The day care would not 

perform the catheterization because of legal concerns. I was scared that if I did not work that I 

would be sanctioned and our family would go without needed food or some other necessity. So I 

worked and my daughter did not get catheterized that day. Her health was put at risk so I could 

meet unreasonable obligations in order to get my TANF check to take care of my family ... .” 

Statement of a Maine mother from collection of Maine Equal Justice Partners. 

Research shows significant numbers of children with disabilities live in poverty and many are in 

TANF families. The number of poor children with disabilities has increased dramatically over 

 

Economic Security: Low Job Skills and Mental Health Problems are Key Barriers, Research Forum on Children, 

Families and the New Federalism, August 2001, http://www.researchforum.org, summarizing the findings of

Danziger, et al.; Surjeet K. Ahluwalia, Sharon M. McGroder, Martha Zaslow, Elizabeth Hair, Symptoms of

Depression Among Welfare Recipients: A Concern for Two Generations, Child Trends, December 2001, a 

discussion of the problems facing both adults and children with mental impairments in TANF, see Elisa Rosman, 

Jan McCarthy, and Maria Woolverton, Focusing on Families in Welfare Reform Reauthorization: Adults with

Mental Health Needs and Children with Special Needs, National Technical Assistance Center for Children’s Mental 

Health, Georgetown University Child Development Center, October 2001. This series of nine short issue briefs is 

available at http://gucdc.georgetown.edu. 10 Martin Gerry, Candace Shively, The Kansas Learning Disabilities Initiative, National Technical Assistance 

Center for Welfare Reform, University of Kansas, and Kansas Department of Social and Rehabilitative Services, 

January 1999; Learning Disabilities: A Report by the State of Washington Department of Social and Health

Services, Economic Services Administration, Work First Division, September 1998; Barusch, Taylor, et al., 

Understanding Families with Multiple Barriers to Self Sufficiency: Final Report.

6

11 Barusch, Taylor, et al., at 44-45, Table 14. “When asked if their health interfered with specific activities, 38.4

percent answered that their health interfered a lot with vigorous activities, 12.0 percent reported that their health

interfered a lot with moderate activities, 27.5 percent reported a lot of difficulty climbing several flights of stairs, 

and 26.9 percent reported a lot of difficulty walking more than one mile.” 
the past two decades — from 3.94 million in 1983 to 4.99 million in 1996.12 Using data from the 

National Survey of America’s Families, Child Trends reports that children in families receiving 

welfare are more likely to have a physical, learning or mental health condition that limits their 

activity (20 percent of the children) than children whose families have left welfare (14 percent of 

the children). Additionally, children of current and former recipients are more likely than other 

poor children to have such conditions.13 In July 2002, the General Accounting Office reported 

that 15 percent of TANF families include a child with an impairment.14 The MDRC study found 

that one-fourth of non-employed mothers receiving TANF had a child with an illness or 

disability that limited the mothers’ ability to work or attend school.15 The Michigan study of 

TANF recipients in one urban county found that 22 percent of respondents had a child with a 

health, learning or emotional problem.16 In a study of California families receiving welfare, a 

1996 study found that “the presence of chronically ill and disabled children has a significant 

negative impact on mothers’ labor force participation, even after controlling for differences in 

women’s human capital characteristics, household configuration, and other income.” The 

presence of a child with a disability or chronic health problem was associated with a 36 to 90 

percent reduction in the odds that the mother worked, depending on the number of children with 

disabilities in the family.17

Families with a member with a disability - multiple barriers. 

Case #4 

“I suffer from anxiety, panic and social phobia disorder. I have four children and the youngest 

two need to use a respiratory machine every four to eight hours. This makes child care very hard 

to find and also very expensive. In the past, I tried to attend a Job Club ... but I was too sick and 

overwhelmed to go and I couldn’t do it. ... About six months ago, I got a doctor’s note that said 

that I couldn’t work at that time due to my problems. My caseworker told me that “the sate is not 

going to go for this,” and that I would have to work.” Statement of a Maine mother from 

collection of Maine Equal Justice Partners. 

Case #5 

“My name is Sandra. I am a 27 year old mother of three boys ages 12, 8 and 1. My children and 

I live with my mother, two of my mother’s grandchildren, and my adult brother, Billy, who is 

severely mentally retarded. I went to live with my mother when I left an abusive situation a year 

and a half ago. I have had many problems that keep me from working full-time, especially taking 

care of my disabled family members. Two of my children have medical problems that I must deal 

 12 Glenn T. Fujiura, Kiyoshi Yamaki, Trends in Demography of Childhood Poverty and Disability, published in 

Exceptional Children, Vol. 66, No.2, 187, 190-192, Winter 2000. This study looked at annual data sets – 1983

through 1994 – from the National Health Interview Survey, for children ages three to 21. 13 Kathryn Tout, Juliet Scarpa, Martha J. Zaslow, Children of Current and Former Welfare Recipients: Similarly at 

Risk, Child Trends, March 2002, http://www.childtrends.org/PDF/leaversRB302.pdf. 14 U.S. General Accounting Office, Welfare Reform: Outcomes for TANF Recipients with Impairments, GAO-02-

884, July 2002, available at http://www.gao.gov. 15 Polit, London, and Martinez, May 2001. 16 Sandra Danziger, et al., February 2000. 

7

17 Meyers, Lukemeyer, Smeeding, Work, Welfare, and the Burden of Disability: Caring for Special Needs of

Children in Poor Families, Center for Policy Research, Syracuse University, April 1996, http://wwwcpr.maxwell.syr.edu/incomsec/incomlst.htm.
with. Shawn, my eight year old, has Attention Deficit and Hyperactivity Disorder. I must make 

sure that he takes his medication. I take him to therapy each week. Mark, my baby, was 

hospitalized for several weeks when he was born with a severe respiratory infection and 

seizures. He is still sickly and has many doctors appointments. My brother cannot take care of 

himself. My mother is in poor health herself, suffering from high blood pressure, anxiety and 

other health problems. She needs my help to take care of Billy. I cook food for him, help feed 

him, change his clothes, and help him with bathing and other personal care. My mother is often 

too tired and sick to do these things and Billy cannot do them for himself. ... I have worked for 

most of my adult life at various jobs ... I have had learning disabilities throughout my life, which 

have made it hard to keep a job. Also, I miss so much work to take care of my family that I get 

into trouble for attendance. I have participated in job training programs offered by the Welfare 

Department, which have been useful for me. But I could not go to school regularly because of my 

family responsibilities. I wish I could work steady and support my family. But these problems 

often cause me to miss work, and I don’t see that changing in the future.” 18 

It is common for families with a parent with a disability or a child with a disability to have other 

barriers as well.19 These barriers include having more than one health condition, more than one 

person with disabilities in the family, and the range of barriers faced by other low-income

parents as they attempt to work, such as lack of child care, inadequate or non-existent 

transportation, and limited education and skills. In its July 2002 report, the General Accounting 

Office found that eight percent of TANF families include both a parent with impairments and a 

child with impairments.20

A study prepared by the University of Kentucky Institute on Women and Substance Abuse for 

the Kentucky Cabinet for Families and Children found that the majority of TANF clients have at 

least one significant barrier to becoming self-sufficient.21 Two-thirds (67 percent) of the 

Targeted Assessment Project clients had significant mental health problems alone or in 

combination with domestic violence, substance abuse, and/or learning problems. Mental health 

problems were a factor in all cases assessed with three problems. Of those assessed with only 

one issue, most had a serious mental health problem, such as major depression, agoraphobia, 

bipolar disorder, anxiety disorder, post-traumatic stress disorder, or psychotic disorders. Of those 

assessed with a mental health problem, 73 percent said that they were not receiving services to 

address the problem, and 44 percent said they had never received services. 

As the number of barriers a parent faces increases, the chances that the parent will be working 

decrease. It also is very likely that the existence of some impairments, such as clinical

depression, low intelligence, and learning disabilities, exacerbate a parent’s inability to address 

 18 Sharon Dietrich, Community Legal Services, Philadelphia, PA, Many Welfare Recipients Could Not Meet TANF 

Proposals for 40 Hours of Work, page 15. 19 For a more detailed discussion, see Heidi Goldberg, Improving TANF Outcomes for Families with Barriers to

Employment, page 7; and Eileen Sweeney, Recent Studies Indicate that Many Parents Who are Current or Former

Welfare Recipients Have Disabilities or Other Medical Conditions, pages 18-21. 20 U.S. General Accounting Office, cited above. 

8

21 The Targeted Assessment Project and TANF Reauthorization: Preliminary Client Data, July 1, 2000 – December 

31, 2001, prepared by University of Kentucky Institute on Women and Substance Abuse and Center on Drug and 

Alcohol Research for the Kentucky Cabinet for Families and Children, May 23, 2002
other barriers and to comply with program rules. In its Temporary Assistance for Needy Families 

(TANF) Program: Second Annual Report to Congress, the Department of Health and Human 

Services stated that, “[a]lthough there have been dramatic gains in work for many TANF 

families, too many families with multiple barriers to success are at risk of being left behind.”22 

The Urban Institute has found that “[p]erhaps the strongest predictor of not participating in work 

activity is the presence of multiple obstacles.”23 A Michigan study similarly found that the more 

barriers a woman has, the less likely it is that she is working. The authors predicted that women 

with four to six barriers had only a 41.4 percent probability of working at least 20 hours per 

week and women with seven or more barriers had only a 5.6 percent probability of working at 

least 20 hours per week.24 As a result, it is important not only to have identified the barriers a 

parent or family faces but then to work to reduce the number of barriers to increase the 

likelihood that the parent can both secure and retain employment. 

Consequences for Families with Disabilities in TANF 

Some of the studies also have looked at the outcomes for TANF families in which there is a 

member with a disability. They found the following: 

 

Families are often inappropriately sanctioned.

Case #6 

“I brought my son to Children’s Hospital and Dr. Rudd discovered my son has CP [cerebral 

palsy]. While my son was in the hospital, I got sanctioned because I wasn’t going to school for 

the mandatory 20 hours a week. They told me to get a doctor’s note and I did, but they haven’t 

taken my sanctions off. They need to have a different program for parents whose children are 

disabled.” 25 Minnesota parent 

Case #7 

“I suffer from multiple mental illnesses. I have two children who live at home with me, my son, 

who is 17, and my daughter who is 10. I am getting treatment and eventually hope to get to the 

point where I can work, but my doctor believes it will take a while. In the summer 1998, ASPIRE 

verified that I could not work because of my disabilities. In October, 1998, even though nothing 

had changed, ASPIRE had me sign a family contract that required me to work 25 hours per week 

through “Build, Develop and Learn” (BDL) . I signed it because I thought I had to and I was 

told that my family would be sanctioned if I didn’t sign it. Apparently the goal of this contract 

was to move me into a “full time job”. In the spring of 1999, I was sanctioned for not going to a 

meeting with my BDL worker. I appealed and had a hearing over the phone. My counselor wrote 

a letter ... she explained how my disabilities affect me,... and that I needed more help with my 

disabilities before I could think about getting a job. The doctor said that making me participate 

would be counter-productive to my treatment. I’m not sure how, but we lost the hearing. Luckily, 

 22 Temporary Assistance for Needy Families (TANF) Program: Second Annual Report to Congress, U.S.

Department of Health and Human Services, August 1999, at 140. 23 Pamela J. Loprest, Sheila R. Zedlewski, Current and Former Welfare Recipients: How Do They Differ? Urban 

Institute, Discussion Paper 99-17, November 1999, http://www.urban.org/ 24 Danziger, Corcoran, et al., at 23. 

9

25 Faces of Change, Alliance for Children and Families, http://www.alliance1.org/Home/Home.asp. 
I found help at Maine Equal Justice Partners. We appealed ... and DHS’s attorney agreed with 

us that I could not work and DHS dropped the sanction. ... I hope no one with mental illness has 

to go through what I did.” Statement of Maine mother, collection of Maine Equal Justice 

Partners. 

Most states impose severe sanctions on families receiving welfare when a parent fails to comply 

with TANF work requirements. More than two-thirds of the states impose full-family sanctions, 

stopping aid to children as well as parents when a parent fails to meet a program requirement. 

Nearly half of these states impose the full-family sanction the first time a parent fails to meet the 

requirement. Various research studies have analyzed the extent to which parents who have been 

sanctioned were unable to understand what was required of them to comply with state rules and 

did not understand the consequences for failing to comply — in other words, rather than willfully 

ignoring program rules, the parent’s barriers impeded her ability to comply with the rules.26 This 

may have happened because the requirements or activities were inappropriate for the parent, the 

parent never understood the program rules, the parent failed to receive the information in 

essential accessible format and other alternative means of communication, or the parent did not 

receive other support she needed to be able to comply. In many cases, the states do not identify 

the barriers or develop appropriate activities and services for people with barriers. Then, when 

the family fails to meet program requirements, a sanction is imposed. 

Studies suggest that high numbers of families with a member with a disability are being 

sanctioned. For example: 

 MDRC found that, “[w]elfare recipients with multiple health problems and with certain 

health problems (notably, physical abuse, risk of depression, having a chronically ill or 

disabled child) were more likely than other recipients to have been sanctioned in the prior 

year.” And, among those who had left welfare, “[w]elfare leavers with multiple health 

problems were more likely than other women who had left welfare to say that they had 

been terminated by the welfare agency rather than that they left of their own accord.”27

 

 Studies in Utah and Delaware suggest that parents who have learning disabilities or who 

have low intelligence find it difficult to understand and comply with the program’s 

rules.28

 One-third of the families who were sanctioned in Utah, thereby losing their family’s 

entire cash benefit, cited an individual health condition as the reason for their failure to 

participate; one-fifth cited mental problems.29

 26 See, for example, studies in Delaware and Iowa: David J. Fein, Wang S. Lee, Carrying and Using the Stick: 

Financial Sanctions in Delaware: a Better Chance Program, Abt Associates, Inc., May 1999, 

http://www.abtassoc.com/reports/ES-Sanfin3.pdf; and Lucia Nixon, Jacqueline Kauff, Jan L. Losby, Second

Assignments to Iowa’s Limited Benefit Plan, Mathematica Policy Research, August 1999, at 19, 23, 

http://www.mathematica-mpr.com/PDFs/secondlbp.pdf. 27 Polit, London and Martinez, 2001. 28 Barusch, Taylor, et al., at 51; Fein, Lee, at 13, 22. 

10

29 Michelle K. Derr, The Impact of Grant Sanctioning on Utah’s Families, University of Utah, October 1998. 
 In Iowa, one-fifth of parents who were placed in the state’s limited benefit plan a second 

time – the plan in which families that have not complied with program rules receive a 

reduced benefit (akin to a sanction) – said that their disability/health contributed to their 

being returned to the sanction status, while almost three out of ten cited their lack of

understanding of program rules.30

Families who leave TANF due to sanctions are less likely than others who leave TANF to be 

working, and if they are working, they are likely to be earning less than others who have left 

TANF.31 A recent study in three cities — Boston, Chicago, and San Antonio — also found that 

children in sanctioned families are more likely to have behavior problems and emotional 

problems than children in other families on welfare or who never received welfare.32 

A medical study issued in 2002 provides additional information about young children in 

sanctioned families. The study looked at the impact of sanctions on the health of infants and 

toddlers. It was conducted in six cities from August 1998 through December 2000: Baltimore, 

Boston, Little Rock, Los Angeles, Minneapolis, and Washington, DC. The researchers found that 

households with children aged 36 months or younger whose welfare benefits had been 

terminated or reduced by sanctions had odds of being food insecure 1.5 times as great as 

comparable households whose benefits were not decreased. In addition, young children in 

families whose welfare benefits had been terminated or reduced by sanctions had 1.3 times the 

odds of having been hospitalized since birth.33

 

Families with a family member with disabilities often are not working after leaving TANF.

Case #8 

“My name is Eve. I live in Philadelphia. I have received welfare since about 1997. I have three 

children, my son Woodley, who is now grown up and away in Job Corps; my 28-year-old son, 

Naquaine; and my son, Andrew, who died as an infant. I am the sole caregiver for Naquaine, 

 30 Nixon, Kauff, and Losby, August 1999, cited in footnote 26. Chronic health conditions identified as contributing 

to being placed in the program included drug addiction, manic depression, and chronic asthma. 31 Heidi Goldberg, A Compliance-Oriented Approach to Sanctions in State and County TANF Programs, Center on

Budget and Policy Priorities, March 2001, http://www.cbpp.org/3-28-01tanf.pdf. 32 P. Lindsay Chase-Lansdale, Rebekah Levine Coley, Brenda J. Lohman, Laura D. Pittman, Welfare Reform: What

About the Children? Welfare, Children and Families: A Three-City Study, Policy Brief 02-1, Johns Hopkins 

University, 2002, http://www.jhu.edu/~welfare/19382_Welfare_jan02.pdf. “We need to attend much more carefully 

to the plight of families experiencing welfare sanctions. Sanctioned families have a number of characteristics that

serve as markers of concern for the healthy development of children and youth. As such, state and federal

governments should explore options for identifying and reaching out to the most disadvantaged and high-risk

families involved in the welfare system. Possible policy options include assistance to bring families into compliance 

with rules before they are sanctioned, closer monitoring of sanctioned families, and the provision of additional 

supports, such as mental health services, academic enrichment, after-school programs, and other family support

services.” Id. 

11

33 Children’s Sentinel Nutrition Assessment Program, The Impact of Welfare Sanctions on the Health of Infants and

Toddlers, July 2002, Arch Pediatr Adolesc Med, Vol. 156, 678-683,

http://dcc2.bumc.bu.edu/csnappublic/welfaresanctions.htm. In the article, the authors conclude that, “Child health

professionals should be concerned that increasingly stringent requirements proposed for the 2002 welfare reform

law reauthorization may further jeopardize the health of some of America’s most vulnerable children as the 

economic cycle, sanctions, and time limits simultaneously decrease families’ resources.” 
who suffers from autism. Naquaine needs 24 hour a day care. I have been the only one to provide 

it since my husband left a long time ago. Because I need to take care of Naquaine, I simply 

cannot work 40 hours a week, every week. ... Things are always coming up with Naquaine that

make me drop everything to take care of him. If his bus is late, I need to wait with him. If he acts 

up in school, the teachers call me and expect me to come immediately. The after-school program 

has been a great help. But the welfare office cut off my childcare subsidy, and the program is 

getting ready to put him out, because I cannot pay. I am so worried about losing my care for 

him. When you are a single parent, it is very hard to both work and take care of your children. 

When I came on welfare, I tried to do it by working the 11:00 pm to 7:00 am shift, when my 

children were sleeping, so I could take care of them during the day. I left Naquaine and my baby 

Andrew with my older son when I went to work, because I didn’t have anyone else to care for 

them. My baby died one night while I was at work; he just stopped breathing. They say it was 

Sudden Infant Death. I feel like if I had been there Andrew would not have died. People on 

welfare have no problem working if their children are safe. I want to work. I’ve worked all my 

life. But it always ends up that I get fired because of missing work. Everything may be going well 

on the job, then something comes up, and I lose it.” 34 

Many parents with disabilities who have left TANF do not work; some have lost jobs they held 

when they left TANF. 

For example: 

 In a Colorado study, 35 percent of the former TANF recipients surveyed were not 

working at the time of the survey. Almost one-third said that personal health problems or 

other personal problems prevented them from working.35 That study concluded: “We 

need to attend much more carefully to the plight of families experiencing welfare 

sanctions. Sanctioned families have a number of characteristics that serve as markers of

concern for the healthy development of children and youth. As such, state and federal 

governments should explore options for identifying and reaching out to the most 

disadvantaged and high-risk families involved in the welfare system. Possible policy 

options include assistance to bring families into compliance with rules before they are 

sanctioned, closer monitoring of sanctioned families, and the provision of additional 

supports, such as mental health services, academic enrichment, after-school programs, 

and other family support services.” 

 In a Mississippi survey of people who left TANF early in 1998, three to eight months 

later 53 percent had not worked since leaving TANF and 65 percent were not working at 

the time of the survey. Of the latter group, 27 percent reported they were physically or 

mentally ill.36 In the article about this study, the authors conclude that, “Child health 

 34 Sharon Dietrich, Community Legal Services, Philadelphia, PA, Many Welfare Recipients Could Not Meet TANF 

Proposals for 40 Hours of Work. 35 Evaluation of the Colorado Works Program: First Annual Report, Berkeley Planning Associates, November 

1999, at 29, Figure 2-4.

12

36 Jesse D. Beeler, Bill M. Brister, Sharon Chambry, et al., Tracking of TANF Clients, First Report of a

Longitudinal Study: Mississippi’s Temporary Assistance for Needy Families Program, Center for Applied Research, 

Millsaps College, revised January 1999, at 12, Table 8.
professionals should be concerned that increasingly stringent requirements proposed for 

the 2002 welfare reform law reauthorization may further jeopardize the health of some of 

America’s most vulnerable children as the economic cycle, sanctions, and time limits 

simultaneously decrease families’ resources.” 

 A study by the Hudson Institute and Mathematica Policy Research of Milwaukee families 

who were involved in the conversion of the Wisconsin welfare plan from AFDC to 

Wisconsin Works (W-2), found that among those who reported a personal disability or 

health problem or the disability or health problem of a family member, 23 percent were 

not employed, were not in a W-2 work training placement and did not receive either SSI 

or a kinship care payment.37

Anecdotal evidence suggests that, to avoid the ultimate loss of benefits, some TANF recipients 

with disabilities were shifted off TANF and onto the SSI roles before they could take advantage 

of the TANF supports and services that might have led to employment. 

Parents with a child with disabilities face more barriers to work. 

Case #9 

“My name is Theresa. I am a 33 year old ...mother of three children ages 13, 10 and 8. I 

currently receive TANF for myself and my three children, and I am likely to reach my five-year 

lifetime limit for TANF in March, 2003. My 10-year-old Chae suffers from Attention Deficit 

Hyperactivity Disorder and major depression. His needs prevent me from working in a full-time 

job. I participated in several job training programs offered by my welfare caseworker ... I did 

not have a good experience at these programs, but I really wanted to find a way to get the 

education and training that I needed to find a job that would support my family. In June, 2000, I 

decided to close my TANF case and join the Army. I thought the Army would provide me with 

training and job advancement that I did not get through the welfare department. While I was in 

the Army my children were cared for by my relatives. But several months after I enlisted, Chae 

was diagnosed with ADHD and major depression. He was even hospitalized for some time due to 

his depression. Because of his illness and hospitalization, I was forced to get a leave of absence 

and later an Honorable Discharge from the Army in order to take care of him. I returned to 

Philadelphia and re-opened my TANF case. I currently meet my work requirements ... by doing 

20 hours per week of community service, as well as an independent job search. I am afraid of 

working too much. Because of what happened when I was in the Army and not around for Chae. 

I am very scared that he can be hospitalized again if I don’t spend enough time taking care of 

him. I very much want to find a job that will enable me to get off welfare and support my family. 

But I am also very concerned about my children’s health and well being. I feel that I am in a 

“lose-lose” situation.”38 

 37 Rebecca Swartz, Jacqueline Kauff, Lucia Nixon, Tom Fraker, Jay Hein, Susan Mitchell, W-2: Converting to

Wisconsin Works: Where Did Families Go When AFDC Ended in Milwaukee? Hudson Institute and Mathematica 

Policy Research, 1999, at 37-38, Table 6-4, http://www.mathematica-mpr.com/PDFs/w2report.pdf. 

13

38 Sharon Dietrich, Community Legal Services, Philadelphia, PA, Many Welfare Recipients Could Not Meet TANF

Proposals for 40 Hours of Work, p.21. 
In addition, research indicates that parents with children with disabilities are less likely to leave 

TANF, and when they do leave welfare for work, they are less likely to have the flexibility on 

their jobs to meet their children’s needs. For example: 

 The presence of a child with disabilities in a family has been found to dramatically 

reduce the chances that the parent will be working. A 1996 Syracuse University study of 

California families receiving welfare found that “the presence of chronically ill and 

disabled children has a significant negative impact on mothers’ labor force participation, 

even after controlling for differences in women’s human capital characteristics, 

household configuration, and other income.” The presence of a child with a disability or 

chronic health problem was associated with a 36 to 90 percent reduction in the odds that 

the mother worked, depending on the number of children with disabilities in the family.39

 In a study of women in urban and rural Michigan who receive TANF cash assistance and 

who have children with disabilities, families identified three systemic barriers to selfsufficiency for their families: poorly trained welfare caseworkers who do not understand 

the complexities of raising a child with disabilities, limited public transportation 

(nonexistent in rural areas and unreliable, inaccessible, or limited in range in urban areas) 

and inadequate child care.40 

 

State Responses to the Research 

The results of these studies suggest that states need to design their programs better to identify 

and assist parents with disabilities and parents of children with disabilities. Two key features of 

the 1996 law make these improvements possible: the flexibility states have to design their 

programs to assist families to move to self sufficiency and the availability of federal TANF 

funds. The decline in cash assistance caseloads — freeing up TANF funds to provide work 

supports and to assist families with barriers — provided some states with the opportunity to look 

more closely at how best to meet the needs of this population.41

Some states have been moving in this direction. Some of the steps states have taken include: 

 Reducing inappropriate sanctions. Tennessee has established a sanction review 

procedure that determines whether the state followed its policies and also provides the 

family with a second chance to come into compliance. In 2001, Maine adopted a presanction review procedure as well. Vermont, Iowa, and Utah have procedures that help to 

 39 Marcia K. Meyers, Anna Lukemeyer, Timothy Smeeding, Work, Welfare, and the Burden of Disability, Caring

for Special needs of Children in Poor Families, Center for Policy Research, Syracuse University, April 1996, 

http://aspe.hhs.gov/daltcp/reports/wrkwlfes.htm. 40 Barbara W. LeRoy, Donna M. Johnson, Sharonlyn Harrison, Open Road or Blind Alley? Welfare Reform, 

Mothers and Children with Disabilities, Skillman Center for Children, Wayne State University, Occasional Paper 

Series 2000, No. 4, November 2000, http://www.skillmancenter.culma.wayne.edu

14

41 For information on TANF spending, see U.S. Department of Health and Human Services, Temporary Assistance 

for Needy Families (TANF) Fifth Annual Report to Congress, February 2003, Tables 2:8 through 2:15, 

http:www.acf.hhs.gov/programs/ofa/indexar.htm, and Zoe Neuberger, TANF Spending in Federal Fiscal Year 2001,

Center on Budget and Policy Priorities, March 2002, http://www.cbpp.org/3-21-02tanf.htm. 
better identify families with disabilities who need greater supports or modifications of

rules in order to come into compliance with program rules. 

 Tailoring services to the individual needs of families with a member with disabilities so 

that the parent can move towards employment.42 Tennessee has established the “Family 

Services Counseling” (FSC) program designed to help parents address barriers. The 100-

plus masters-level social workers across the state who staff the FSC program have the 

authority to modify program rules so that a family can comply; secure treatment, 

education and training; and otherwise take steps to help parents and children with barriers 

such as mental health, learning disabilities, domestic violence and substance abuse. 

Pennsylvania has created the “Maximizing Participation Project” (MPP) for people with 

barriers who cannot meet the current work requirement and are approaching their five 

year time limit. MPP provides comprehensive assessments and intensive case 

management to help parents address barriers. There is no minimum work requirement in 

MPP. Currently, 1700 parents with disabilities voluntarily participate in MPP.43 Vermont 

has designed a collaborative effort between its TANF agency and the vocational 

rehabilitation agency, creating 11 new counselor positions in the VR agency, to work 

with TANF families with disabilities.

44 Kentucky’s 32 Targeted Assessment Specialists, 

employed by the University of Kentucky under a contract with the state’s TANF agency, 

are on-site at public assistance and child protective services offices in 18 communities to 

conduct assessments, pre-treatment, and follow-up services focused on mental health, 

domestic violence, substance abuse and learning problems.45

 Adjusting requirements when a parent’s full attention needs to be devoted to the health 

and welfare of a child with a disability. Illinois recently modified its rules to provide for a 

“family care” barrier, stopping the TANF time clock for a parent who provides full-time 

care required by a child under age 18 or a spouse due to their medical condition. 

California has a rule similar to the Illinois rule, providing that if a person’s care-taking 

responsibilities for a child or other family member who is ill or incapacitated 

significantly impairs the ability of the person to be regularly employed or to participate in 

welfare-to-work activities, the person will be exempt from the work rules and the months 

will not count toward the person’s time clock. 

Helpful guides for state and county administrators on how to identify and serve families with a 

member with a disability have been published, often with funding from HHS.46 In addition, in 

 42 For greater detail about these and other state programs, see Heidi Goldberg, Recent TANF Proposals Would 

Hinder Successful State Efforts to Help Families Overcome Barriers to Employment and Find Better Paying Jobs, 

Center on Budget and Policy Priorities, April 2002, http://www.cbpp.org/5-9-02tanf.pdf . 43 Jonathan M. Stein, Brendan Lynch, The Administration’s Proposed Increases in TANF Work Requirements are

Unfair to Pennsylvania TANF Recipients with Disabilities, Community Legal Services, April 2002. 44 Johnette T. Hartnett, Vermont’s Response to Welfare Reform for People with Disabilities: An Evaluation of

Vermont’s Vocational Rehabilitation (VR) and PATH Partnership, University of Vermont, Fall 2002. 45 See study referred to in footnote 22.

15

46 See Gretchen Kirby, Jacquelyn Anderson, Addressing Substance Abuse Problems Among TANF Recipients: A 

Guide for Program Administrators, Mathematica Policy Research, July 2000, http://www.mathematicampr.com/PDFs/addresssubstance.pdf; Michelle Derr, Heather Hill, LaDonna Pavetti, Addressing Mental Health

Problems Among TANF Recipients: A Guide for Program Administrators, Mathematica Policy Research, July 2000, 
2001, the Office for Civil Rights at HHS issued guidance to states and counties on the 

applicability of Section 504 of the Rehabilitation Act of 1973 and the Americans with 

Disabilities Act in TANF-funded programs.47 This technical assistance has helped state 

administrators to focus on ways to assist parents with disabilities as well as parents with a child 

with a disability. 

The HHS Inspector General’s report provides some information about the types of actions states 

are taking to identify families with barriers to work and then concludes that “states are still 

facing challenges”: “States report facing several challenges in addressing recipients with barriers 

to employment. At least 13 states report they do not have the capacity to serve all recipients with 

some of the barriers we addressed. Forty-one states do not have any specific strategies to help 

recipients who face multiple barriers. Only nine states report using pilot programs to implement 

new approaches for any of these populations. Additionally, few states have information about the 

barriers faced by recipients who have been sanctioned or have strong evidence about the 

effectiveness of their strategies to help recipients with the barriers we addressed in this 

inspection.”48

Solid TANF methods of administration can make all the difference for people with disabilities as 

they struggle to support and nurture their families and live independently. However, experience 

to date suggests that while TANF’s potential is being realized for some families with a disability, 

the state’s TANF rules can also unravel a family if the parent’s disability is not identified and 

services and supports are not provided. The following examples from Colorado set out starkly 

the differing consequences. These examples are taken from a report by the Governor of 

Colorado’s Task Force on TANF implementation that focused on several barriers, including 

mental health issues, chronic health problems, physical disabilities, learning disabilities, 

language barriers, and multiple barriers.49 The examples were included in testimony before the 

House Human Resources Subcommittee of the Ways and Means Committee on April 11, 2002.50

 

http://www.mathematica-mpr.com/PDFs/addressmental.pdf. See also, Rebecca Brown, Evelyn Ganzglass, Serving 

Welfare Recipients with Learning Disabilities in a Work First Environment, National Governors Association Center

for Best Practices, 1999, http://www.nga.org; Amy Brown, Beyond Work First: How to Help Hard-to-Employ 

Individuals Get Jobs and Succeed in the Workforce, Manpower Demonstration Research Corporation, 2001, 

http://www.mdrc.org/Reports2001/HardtoServe/MDRCHow-ToHardtoEmploy.pdf; M.Robin Dion, Michelle K. 

Derr, Jacquelyn Anderson, LaDonna Pavetti, Reaching All Job Seekers: Employment Programs for Hard-to-Employ 

Populations, Mathematica Policy Research, October 1999, http://www.mathematica-mpr.com/PDFs/hdemploy.pdf. 47 Office for Civil Rights, U.S. Department of Health and Human Services, Prohibition Against Discrimination on

the Basis of Disability in the Administration of TANF (Temporary Assistance for Needy Families), January 2001, 

http://www.hhs.gov/ocr/prohibition.html; see also Eileen P. Sweeney, HHS Guidance Explains How Federal Laws

Barring Discrimination Against People with Disabilities Apply in State and County TANF Programs, Center on

Budget and Policy Priorities, February 2001, http://www.cbpp.org/2-26-01wel.htm. In his reply to the HHS 

Inspector General’s report, cited at footnotes 5 and 45, at page 23, HHS Assistant Secretary for Children and 

Families Wade Horn indicated that there has been broad dissemination of the OCR guidance on TANF and 

disabilities. 48 HHS Office of the Inspector General, cited at footnote 5, above, page iii. The report focused on eight barriers: 

substance abuse, domestic violence, mental health issues, chronic health problems, physical disabilities, learning

disabilities, language barriers, and multiple barriers. 49 Both clients= stories are printed in Moving Forward with Welfare Reform, The Governor=s Task Force on

Welfare Reform Report, Colorado, September 12, 2000. 

16

50 Paul Marchand, Co-chair of Consortium for Citizens with Disabilities TANF Task Force, testimony before 
Case #10 

“Client A was tested and had an IQ of 67. She was sent to Vocational Rehab and then instructed 

to seek work. She received childcare for two occasions and then was sanctioned in Colorado 

Works. Her family became homeless in November 1998 and the children were placed in foster 

care in December 1998.” 

Case #11 

“Client B has an IQ of 67 and is a victim of domestic violence. There is suspicion of brain 

damage as a result of abuse. She cannot communicate well, she is conscientious but has few 

skills. She has an anxiety disorder which cannot be treated because of her heart problem. She 

sees a physician weekly to manage blood thinning medications. She had surgery for a valve 

replacement one year ago. She was assigned to a community college program which reported 

that she would be doing fine but then the next day she couldn’t remember what she had learned. 

It takes the parent approximately one month to learn a bus route. The county required that she 

find a job in six months. Later that expectation was lowered to ten hours of time within her 

supported living program.@

“The description of the steps the state took to help Client B provides a sense of the types of steps 

that states will need to take in order to help some parents with disabilities to maximize their 

potential. Unfortunately, no steps — not even ongoing child care for her children — were taken 

to assist Client A, with the tragic consequence that she was sanctioned, lost her home, and then 

lost custody of her children.” 

Proposals to Improve Outcomes for Families with Disabilities in TANF 

It is clear that disability is a significant issue within the TANF program and that the unique needs 

of individuals with disabilities must be addressed if the system is to achieve the goal of securing 

employment and economic independence for TANF recipients who live with a disability. A 

number of improvements needed in the TANF law have been proposed by organizations 

representing people with disabilities to assist states to best meet the needs of families with 

disabilities. 51 The National Council on Disability makes the following recommendations to 

strengthen the ability of the states to support families with disabilities in their welfare system. 

1. Increased TANF and Child Care Funding. Last year, the Congressional Budget Office 

estimated that the costs to states of meeting new work requirements and increased participation 

 

Human Resources Subcommittee, Ways and Means Committee, April 11, 2002. 

http://www.aucd.org/legislative_affairs/testimony_tanf.htm. In the testimony, Mr. Marchand stated: “It should not

be acceptable to the Congress that even one parent with disabilities or one parent caring for a child with disabilities 

faces these types of consequences in TANF. Unfortunately, the research suggests that problems like this are all to 

frequently occurring across the country, at great personal expense to parents and children.” 

17

51 For a more detailed discussion, see two documents prepared by the TANF Task Force of the Consortium for 

Citizens with Disabilities, Principles Guiding the Reauthorization of TANF, and TANF Reauthorization Policy 

Priorities, both of which are included in the testimony of Paul Marchand, The Arc, on behalf of the Consortium

before the Human Resources Subcommittee of the Ways and Means Committee, April 11, 2002. The Policy 

Priorities also are available on the CCD website, http://www.c-c-d.org/tanfreautho.htm. 
rate targets would be up to $11 billion over five years (roughly $6 billion in work program costs 

and $5 billion in increased child care costs for work program participants). The Center for Law 

and Social Policy estimates that the five-year costs of implementing proposed increased work 

and participation rate requirements are in the range of $15.1 billion above what states would 

otherwise spend under current law.52 Without the funding needed to meet the new requirements, 

states will have to cut effective programs now funded with TANF in order to comply. In other 

words, there already is significant evidence that states need more than they currently receive 

annually in order to simply maintain the programs they currently have in place. 

The Congressional Budget Office estimated that :an additional $4.55 billion in child care 

funding over the next five years is needed to ensure that the mandatory federal child care 

funding stream, state funds used to match these federal funds, and the TANF funds 

devoted to child care keep pace with inflation. CBO’s $4.55 billion figure may understate 

the cost of maintaining current services because the estimate assumes that states will be

able to maintain their current levels of using TANF for childcare. This is unlikely to 

occur. In 2002, states spent $1.6 billion more than their annual TANF allotments, by 

drawing on unspent TANF funds carried over from prior years.53 These “carry-over” 

funds have been exhausted or nearly exhausted in most states. To bring spending in line 

with their annual TANF block grant allotment, many states will have to cut TANF

funding for various programs, including child care programs, in the next few years. The 

funding shortage will hit hardest families who have children with disabilities who may 

require more expensive specialized care.54

Not surprisingly, the types of services and supports that families with a member with a 

disability need in order to succeed are often intensive, individualized, long-term, and 

more costly than the services that families without barriers need. If no additional funds 

are added to the basic TANF block grant, as inflation further erodes the value of the 

TANF block grant, it will become increasingly difficult for states to pay for the services

and supports that people with disabilities need in order to be able to move successfully

from welfare to work. Additional funding for both the TANF block grant and the child 

care program will be necessary to enable these programs to meet federal requirements 

and programmatic needs for families with disabilities. 

2. Screening and Assessment. The reauthorization must include provisions to ensure that parents 

with barriers, including disabilities and other health conditions, are screened in a timely manner 

with appropriate diagnostic tools to determine if a more comprehensive assessment is needed. 

Comprehensive assessments must be provided by qualified professionals to identify barriers to 

employment and to suggest to state or county staff the steps needed to assist the family. As part 

 52 Steve Savner, Julie Strawn, Mark Greenberg, TANF Reauthorization: Opportunities to Reduce Poverty by

Improving Employment Outcomes, April 2002, http://www.clasp.org. 53 Zoe Neuberger, Annual TANF Expenditures Remain $2 Billion Above Block Grant, Center on Budget Policy and

Priority, October 30, 2002

18

54 CBO’s $4.55 billion figure may understate the cost of maintaining current services because the estimate assumes 

that states will be able to maintain their current levels of using TANF for childcare. This is unlikely to occur. In

2002, states spent $1.6 billion more than their annual TANF allotments, by drawing on unspent TANF funds carried 

over from prior years. These “carry-over” funds have been exhausted or nearly exhausted in most states. To bring

spending in line with their annual TANF block grant allotment, many states will have to cut TANF funding for 

various programs, including childcare programs, in the next few years. 
of the screening and assessment process, states should also consider documentation from other 

systems of the existence of a disability in a family. The changes to TANF must also ensure that 

screening and assessments are voluntary on the part of TANF beneficiaries and that TANF 

beneficiaries with disabilities are not subjected to a sanction or closure for failing to participate 

in a screening or assessment. Screening and assessment results must be maintained in accordance 

with professional standards of confidentiality. 

3. Sanctions. The federal legislation should prohibit a state from sanctioning a family until the 

state has: 1) taken steps to identify barriers, including disabilities; 2) provided the family with 

assistance in meeting the rules; and, 3) modified rules, if necessary to address the parent’s or 

child’s disability, so that the family can comply. The federal legislation should require states to 

have pre-sanction review procedures to reduce the chance of arbitrary and inappropriate 

sanctions being applied against a family with a family member with a disability. Based on the 

research on people with barriers and sanctions, it is reasonable to expect that greater numbers of 

parents with disabilities and other barriers will be sanctioned rather than helped under proposals 

for the new TANF program if they are not provided these protections.

4. State Flexibility. As pointed out in an earlier section of this paper, a key feature of the 1996 

law that has made it possible for states to improve the way they support individuals with 

disabilities has been the flexibility states have to design their programs. The federal legislation 

should build on the 1996 statute by providing states with flexibility in how they define countable 

work activities, including rehabilitation and participation in other activities that will help the 

parent to become work-ready and how they determine the length of time that a particular 

individual or family will need the specific services or treatment. States must be given greater 

flexibility in how they will determine who will be exempt from the time limit and for how long. 

TANF Families with disabilities must be provided with the services and supports needed to assist 

them to be able to successfully move into an independent work setting. States need the flexibility 

to design the individualized plans that parents with disabilities and children with disabilities 

need. For example, 

 While 30 hours of activity each week is required by current law for families with children 

age six or older, states currently have the flexibility to require 40 hours of participation 

from families, but most have not chosen to do so universally. Instead of focusing on 

keeping participants busy for precisely 40 hours per week while they are on welfare, 

states have been able to place a greater emphasis on structuring work programs that 

provide the types of activities needed to move participants with and without disabilities

into paid employment and off of welfare (regardless of the precise number of hours these 

activities add up to each week). 

 Some parents with young children with disabilities are helped by the provision in the 

current statute that allows states to get full credit when a parent with a child under the age 

of six (regardless of disability) is working for 20 hours because they are able to meet their 

child’s needs while being involved in a countable work activity part-time, for 20 hours. 

The flexibility states have to provide this modest protection must be retained. 55

 

19

55 For a detailed discussion of why the 40 hour proposal is not feasible and will be impossible for many parents to 
 Important information is available on the issue of state flexibility from the Vermont 

experience, which has created “hybrid” TANF/VR counselors in the VR agency. The 

agency’s experience with non-TANF closures may be instructive. Forty-eight percent of 

VR’s non-TANF successful closures to employment were people whose primary 

disability was mental illness, mental retardation, learning disability, or substance abuse. 

“The average length of time from applying for services to becoming employed for these 

individuals has been: mental illness, 15 months; mental retardation, 14 months; learning 

disability, 17 months; and substance abuse, 10 months.”56 Without the flexibility to adapt 

work requirements and participation rates to the needs of the individuals, states would be 

forced to provide services to recipients which are less individualized and less appropriate 

to their needs, forcing recipients into a “one size fits all” approach that will be harmful to 

parents with disabilities and children with disabilities in TANF families. 

The federal legislation should also allow states with waivers to continue under their waiver rules 

after reauthorization. A number of states were granted waivers to the welfare requirements under 

the old AFDC rules and were allowed to continue to operate under the same waiver, even when 

the rule differed from the new TANF rules. Often these rules allow states to provide more 

appropriate activities for parents than are permitted under standard federal TANF rules and, in 

some cases, to extend time limits for some parents with disabilities based on individual 

circumstances. It is important to note that NCD does not endorse a practice that exempts an 

individual from work requirements in lieu of providing the appropriate accommodations for the 

disability. However, extensions may be justified and especially important for families with care 

giving requirements that make it impossible for them to participate in required activities.57 

5. Training. The federal legislation should provide states with additional resources to train 

caseworkers and other staff who serve TANF recipients about issues unique to disabilities, 

including timely and effective screening, and the design of programs responsive to the needs of 

people with barriers of disability, identification and utilization of resources available in the 

community, and opportunities to develop collaborative relationships with other state and local 

public and private agencies, including grants to states and counties interested in supporting 

initiatives to achieve systemic improvements in addressing the needs of persons with diagnosed 

and undiagnosed disabilities. Caseworkers and other staff should also receive training in the 

unique needs of, and issues that have implications for, people with disabilities from diverse 

cultures. According to Fujiura, “If you have a disability in America, and you are from a diverse 

racial/ethnic group, odds are that you and your family live in poverty and that you will be poorer 

than others of your class and color.” http://www.mswitzer.org/sem99/papers/fujiura.html. 

 

meet, see Sharon Dietrich, Many Welfare Recipients Could Not Meet TANF Proposals for 40 Hours of Work, 

Community Legal Services, April 2002, http://www.clsphila.org/Tanf_reauthorization.htm. The appendix to the 

paper provides examples of families in Pennsylvania who are working or trying to work and whose family

circumstances would make it impossible to meet 40 hours as they cannot meet the current 30 hour requirement. In

the majority of the examples, the parent is caring for children with disabilities or other family members with

disabilities. 56 Johnette T. Hartnett, cited above at footnote, page 7. 

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57 Ruth Bourquin, Persons with Disabilities and TANF: A Promising Massachusetts Model, Massachusetts Law 

Reform Institute, March 2002. 
6. Advisory Panels. The federal legislation should create advisory panels at the state level to 

assist the state in determining steps it should take to improve how it addresses the needs of 

people with barriers, including people with disabilities, in their TANF programs. 

 7. Health Care. The federal legislation should facilitate access to continued Medicaid or other 

health insurance coverage when recipients move from welfare to work. For any family, health 

coverage is essential. For a parent with a disability, continuing health care coverage when 

working may be the key support that allows the parent to work while addressing her medical 

needs. Transitional Medicaid Assistance (TMA) has helped to meet this need. For a parent with a 

disability, because TMA is time-limited, it will not fill the gap over time if the parent’s job does

not provide insurance — which is often the case for many low-wage jobs. However, it does help 

to ease the transition and, in states that have expanded Medicaid coverage to more parents at 

incomes higher than the very low TANF levels, the parent may be able to move into the 

expanded Medicaid coverage program after TMA. Because the Medicaid eligibility rules for 

children are more generous and the children can also enroll in the State Children’s Health 

Insurance Program if they are over-income for Medicaid, TMA is most important for parents 

who typically have to meet more stringent income eligibility rules than children.58 Studies in 

other income programs, such as SSI, have shown that fear of loss of health coverage is one 

reason that recipients with disabilities may be reluctant to work.

59 While there are no parallel 

studies in TANF, it would seem likely that similar concerns exist for parents with disabilities in 

TANF. The Transitional Medicaid Assistance program reauthorization period must parallel the 

reauthorization period for the rest of TANF. 

 

8. Service Coordination. Because multiple services are available at the state and local level for 

adults and children with disabilities, the federal legislation should assist states to better 

coordinate and provide services needed by children with disabilities and their families, including 

coordination among state agencies to address the multiple challenges facing parents and their 

children with disabilities.

60

9. ADA and Section 504 Compliance. The federal legislation should be consistent with federal 

civil rights protections for individuals with disabilities under the Americans with Disabilities Act 

(ADA) and Section 504 of the Rehabilitation Act, enabling states to easily comply with all three 

Acts. These recommendations would help states and counties meet their legal obligations to 

implement the long-standing national policy set forth in Section 504 of the Rehabilitation Act 

and the ADA to ensure that people with disabilities have equal and meaningful access to their 

TANF-funded programs, including the ability to benefit from state programs that assist families 

in transitioning from welfare to self-sufficiency. 

 

 58 For information on state actions to expand Medicaid for parents, see Matthew Broaddus, Shannon Blaney, Annie 

Dude, Jocelyn Guyer, Leighton Ku, Jaia Peterson, Expanding Family Coverage: States’ Medicaid Eligibility 

Policies for Working Families in the Year 2000, Center on Budget and Policy Priorities, February 2002, 

http://www.cbpp.org/1-2-02health.pdf. 59 See, for example, The Environment of Disability Policy Income: Programs, People, History and Context, 

National Academy of Social Insurance, 1996, page 104. 

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60 See Rosman et al, Issue Brief 3, page 4. 
Conclusion 

There is now a very strong record that indicates that significant numbers of parents with 

disabilities and parents with children with disabilities are in the TANF program. The record also 

indicates that many of these families have been sanctioned and have not received the services 

and supports they need to succeed. Some of the states, using the flexibility that Congress gave 

them in 1996 and the TANF funds freed up due to falling cash assistance caseloads, have taken 

very practical steps to assist these families. The federal legislation should include provisions to 

ensure that people with disabilities receive the appropriate supports and services to enable them

to transition to work successfully. 

_____________________________________________________________________________________________

The National Council on Disability wishes to acknowledge the contributions of Eileen Sweeney, 

Cary LaCheen, and Celane McWhorter to this paper. 

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