TANF and SSI: Opportunities Exist to Help People with Impairments Become More Self-Sufficient
Published: 2004-09-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The nation's social welfare system has been transformed into a system emphasizing work and personal responsibility, primarily through the creation of the Temporary Assistance for Needy Families (TANF) block grant. The Supplemental Security Income (SSI) program has expanded policies to help recipients improve self-sufficiency. Given that SSA data indicate an overlap in the populations served by TANF and SSI, and the changes in both programs, this report examines (1) the extent that TANF recipients with impairments are encouraged to apply for SSI and what is known about how SSI caseload growth has been affected by such TANF cases, (2) the extent that work requirements are imposed on TANF recipients applying for SSI, and the range of services provided to such recipients, and (3) the extent that interactions exist between the SSI and TANF programs to assist individuals capable of working to obtain employment.
section_title: What GAO Found
paragraphs: In our nationwide survey of county TANF offices, we found that nearly all offices reported that they refer recipients with impairments to SSI, but the level of encouragement to apply for SSI varies. While almost all of the county TANF offices stated that they advise such recipients with impairments to apply for SSI, 74 percent also follow up to ensure the application process is complete, and 61 percent assist recipients in completing the application. Because TANF offices are referring individuals with impairments to SSI, these referrals will have some effect on the SSI caseload. However, due to data limitations, the magnitude of the effect these referrals have on SSI caseload growth is uncertain. While SSA can identify whether SSI recipients have income from other sources, it cannot easily determine whether this income comes from TANF or some other assistance based on need. In addition, past research has not found conclusive evidence regarding the impact that TANF referrals have on SSI caseload growth. Estimates from our survey found that although some TANF offices impose work requirements on individuals with impairments, about 86 percent of all offices reported that they either sometimes or always exempt adult TANF recipients awaiting SSI determinations from the work requirements. One key reason for not imposing work requirements on these recipients is the existence of state and county TANF policies and practices that allow such exemptions. Nevertheless, county TANF offices, for the most part, are willing to offer noncash services, such as transportation and job training, to adult recipients with impairments who have applied for SSI. However, many recipients do not use these services. This low utilization may be related to exempting individuals from the work requirement, but it may also be due to the recipients' fear of jeopardizing their SSI applications. Another reason for the low utilization of services is that many services are not necessarily available; budgetary constraints have limited the services that some TANF offices are able to offer recipients with impairments. Many county TANF offices' interactions with SSA include either having a contact at SSA to discuss cases or following up with SSA regarding applications for SSI. Interactions that help individuals with impairments increase their self-sufficiency are even more limited. In all the states we visited, we found that such interactions generally existed between TANF agencies and other agencies (such as the Departments of Labor or Education). In addition, 95 percent of county TANF offices reported that their interactions with SSA could be improved. State and county TANF officials feel they have to take the lead in developing and maintaining the interaction with SSA. One SSA headquarters official stated that SSA has no formal policy regarding outreach to TANF offices but would consider a partnership provided there is some benefit for SSA. Still, about 27 percent of county TANF offices reported that they were discouraged in their attempts to establish a relationship with SSA because staff at the local SSA field office told them that they did not have the time or the interest.

section_title: Letter
paragraphs: Over the past several years, the nation’s social welfare system has been  transformed from a system emphasizing income support to one  emphasizing work and personal responsibility. Central to this  transformation was the creation of the Temporary Assistance for Needy  Families (TANF) block grant in 1996. Administered by the Department of  Health and Human Services (HHS), TANF provides states with   $16.5 billion each year. The Social Security Administration’s (SSA)  disability programs, including the Supplemental Security Income (SSI)  program, have also recently expanded policies and initiated demonstration  projects aimed at helping recipients enter the workforce and achieve self- sufficiency. SSI, which serves adults with low income and assets, paid  about $18.6 billion in benefits in 2002 to about 3.8 million working age   (18-64) recipients with blindness or other disabilities.
SSA’s disability determination process can be lengthy, extending over   2 years when all administrative appeals are included. Concerns exist  whether TANF recipients with impairments who are applying for SSI  receive employment-related services while waiting for an eligibility  determination. The disability management literature has emphasized that  the longer an individual with an impairment remains out of the workforce  the less likely the individual is to ever return to work. Providing such  services in a timely manner also has implications for TANF recipients  running up against the TANF program’s 5-year time limit because in   2000, nearly 59 percent of all working age applicants for SSI were denied  benefits.
While TANF caseloads have decreased since the program’s inception, in  1996, not all recipients leave TANF to go to work. Some recipients with  impairments severe enough to qualify them for SSI leave TANF once they  are determined eligible for SSI. SSA administrative data have shown an  overlap in the populations served by TANF and SSI: Up to 25 percent of  the SSI caseload age 18 to 64 received income assistance based on need  (including TANF) prior to becoming eligible for SSI, and this figure has  remained fairly stable over the past few years.
Given the new environment in which both programs have placed increased  emphasis on encouraging recipients to find employment, and the overlap  in both populations, this report examines (1) the extent to which TANF  recipients with impairments are encouraged to apply for SSI and what is  known about how SSI caseload growth has been affected by such TANF  cases; (2) the extent to which work requirements are imposed by TANF  agencies on their recipients who are applying for SSI, and the range of  services TANF agencies provide to such recipients with impairments; and  (3) the extent to which interactions exist between the SSI and TANF  programs to assist individuals capable of working obtain employment.
To do this work, we conducted a mail survey of a stratified random sample  of 600 county TANF offices, representative of county TANF offices  nationwide. The survey gathered data on the extent that TANF recipients  with impairments are encouraged to apply for SSI, whether work  requirements are imposed and the type of services provided during the  period of SSI eligibility determination, and the extent that interactions  exist between the SSI and TANF programs. Our survey achieved an   88 percent response rate, and we weighted the results to generalize our  findings to all county TANF offices nationwide. To determine what is  known about how SSI caseload growth has been affected by TANF  referrals for SSI, we identified and reviewed reports studying this issue  and assessed each study’s findings. We also visited five states (Arizona,  Colorado, Iowa, Oregon, and Vermont) known for providing employment- related services to TANF recipients with impairments, to gain an  understanding of the types of interactions that exist between the SSI and  TANF programs and to assess whether there are opportunities for  improving these agencies’ efforts at assisting their recipients with  impairments into employment. In each of these states, we interviewed  state and county TANF officials, and SSA field office staff, as well as SSA  headquarters officials. We conducted our work between June 2003 and  May 2004 in accordance with generally accepted government auditing  standards. See appendix I for a more detailed discussion of our methods.
subsections: section_title: Background
paragraphs: The Personal Responsibility and Work Opportunity Reconciliation Act of  1996 (PRWORA) replaced the individual entitlement to benefits under the  61-year-old Aid to Families with Dependent Children (AFDC) program  with TANF block grants to states and emphasized the transitional nature  of assistance and the importance of reducing welfare dependence through  employment. Administered by HHS, TANF provides states with   $16.5 billion each year, and in fiscal 2002, the total TANF caseload  consisted of 5 million recipients. PRWORA provides states with the  flexibility to set a wide range of TANF program rules, including the types  of programs and services available and the eligibility criteria for them.  States may choose to administer TANF directly, devolve responsibility to  the county or local TANF offices, or contract with nonprofit or for-profit  providers to administer TANF. Some states have also adopted “work first”  programs, in which recipients typically are provided orientation and  assistance in searching for a job; they may also receive some readiness  training. Only those unable to find a job after several weeks of job search  are then assessed for placement in other activities, such as remedial  education or vocational training.
While states have great flexibility to design programs that meet their own  goals and needs, they must also meet several federal requirements  designed to emphasize the importance of work and the temporary nature  of TANF aid. For example, TANF established stronger work requirements  for those receiving cash benefits than existed under AFDC. Furthermore,  to avoid financial penalties, states must ensure that a steadily rising  specified minimum percentage of adult recipients are participating in work  or work-related activities each year. To count toward the state’s minimum  participation rate, adult TANF recipients in families must participate in a  minimum number of hours of work or a work-related activity a week,  including subsidized or unsubsidized employment, work experience,  community service, job search, providing child care for other TANF  recipients, and (under certain circumstances) education and training. If  recipients refuse to participate in work activities as required, states must  impose a financial sanction on the family by reducing the benefits, or they  may opt to terminate the benefits entirely. States must also enforce a   60-month limit (or less at state option) on the length of time a family may  receive federal TANF assistance, although the law allows states to provide  assistance beyond 60 months using state funds.
The TANF caseload includes, as did AFDC, low-income individuals with  physical or mental impairments considered severe enough to make them  eligible for the federal SSI program. Administered by SSA, SSI is a means- tested income assistance program that provides essentially permanent  cash benefits for individuals with a medically determinable physical or  mental impairment that has lasted or is expected to last at least 1 year or  to result in death and prevents the individual from engaging in substantial  gainful activity. To qualify for SSI, an applicant’s impairment must be of  such severity that the person is not only unable to do previous work but is  also unable to do any other kind of substantial gainful work that exists in  the national economy. Work is generally considered substantial and  gainful if the individual’s earnings exceed a particular level established by  statute and regulations. SSA also administers the Disability Insurance  program (DI), which uses the same definition of disability, but is not  means-tested and requires an individual to have a sufficient work history.
For both DI and SSI, SSA uses the Disability Determination Service (DDS)  offices to make the initial eligibility determinations. If the individual is  not satisfied with this determination, he or she may request a  reconsideration of the decision with the same DDS. Another DDS team  will review the documentation in the case file, as well as any new  evidence, and determine whether the individual meets SSA’s definition of  disability. If the individual is not satisfied with the reconsideration, he or  she may request a hearing before an Administrative Law Judge (ALJ). The  ALJ conducts a new review and may hear testimony from the individual,  medical experts, and vocational experts. If the individual is not satisfied  with the ALJ decision, he or she may request a review by SSA’s Appeals  Council, which is the final administrative appeal within SSA. Despite  recent improvements to the process, going through the entire process,  including all administrative appeals, can average over 2 years.
In most states, SSI eligibility also entitles individuals to Medicaid benefits.  TANF recipients may apply for Medicaid benefits and are likely to qualify,  but receipt of TANF benefits does not automatically qualify a recipient for  Medicaid.
While SSA has recently expanded policies and initiated demonstration  projects aimed at helping DI and SSI beneficiaries enter or return to the  workforce and achieve or at least increase self-sufficiency, its disability  programs remain grounded in an approach that equates impairment with  inability to work. This approach exists despite medical advances and  economic and social changes that have redefined the relationship between  impairment and the ability to work. The disconnect between SSA’s  program design and the current state of science, medicine, technology,  and labor market conditions, along with similar challenges in other  programs, led GAO in 2003 to designate modernizing federal disability  programs, including DI and SSI, as a high-risk area urgently needing  attention and transformation.
The Ticket to Work and Work Incentives Improvement Act of 1999  amended the Social Security Act to create the Ticket to Work and Self- Sufficiency Program (Ticket Program). This program provides most DI and  SSI beneficiaries with a voucher, or “ticket,” which they can use to obtain  vocational rehabilitation, employment, or other return-to-work services  from an approved provider of their choice. The program, while voluntary,  is only available to beneficiaries after the lengthy eligibility determination  process. Once an individual receives the ticket, he or she is free to choose  whether or not to use it, as well as when to use it. Generally, disability  beneficiaries age 18 through 64 are eligible to receive tickets. The Ticket  Program has been implemented in phases and is to be fully implemented  in 2004.
The Social Security Advisory Board (Advisory Board) has questioned  whether Social Security’s definition of disability is appropriately aligned  with national disability policy. The definition of disability requires that  individuals with impairments be unable to work, but then once found  eligible for benefits, individuals receive positive incentives to work. Yet  the disability management literature has emphasized that the longer an  individual with an impairment remains out of the workforce the more  likely the individual is to develop a mindset of not being able to work and  the less likely the individual is to ever return to work. Having to wait for  return-to-work services until determined eligible for benefits may be  inconsistent with the desire of some individuals with impairments who  want to work but still need financial and medical assistance. The Advisory  Board, in recognizing that these inconsistencies need to be addressed, has  suggested some alternative approaches. One option they discussed in a  recent report is to develop a temporary program, which would be available  while individuals with impairments were waiting for eligibility  determinations for the current program. This temporary program might  have easier eligibility rules and different cash benefit levels but stronger  and more individualized medical and other services needed to support a  return to work.
SSA has also realized that one approach may not work for all beneficiaries,  and in recent years it has begun to develop different approaches for  providing assistance to individuals with disabilities. One example of these  efforts is the proposed Temporary Allowance Demonstration, which  would provide immediate cash and medical benefits for a specified period  to individuals who meet SSA’s definition of disability and who are highly  likely to benefit from aggressive medical care. SSA is also in the process of  developing the Early Intervention Demonstration. This demonstration  project will test alternative ways to provide employment-related services  to disability applicants. Although both of these demonstration projects  only cover the DI program, SSA also has the authority to conduct other  demonstration projects with SSI applicants and recipients.
section_title: TANF Recipients with Impairments Are Encouraged to Apply to SSI; Impact on SSI Caseload Growth Is Inconclusive
paragraphs: Estimates from our nationwide survey of county TANF offices indicated  that almost all offices reported that they refer at least some recipients with  impairments to apply for SSI. But the level of encouragement these  individuals receive from their local TANF office to apply for SSI varies,  with many offices telling the individual to apply for SSI and some offices  helping the recipient complete the application. Because TANF offices are  referring individuals to SSI, these referrals will have some effect on the SSI  caseload. However, findings regarding the impact that these SSI referrals  from TANF have on SSI caseload growth are inconclusive, due to data  limitations.
subsections: section_title: Nearly All County TANF Offices Refer Recipients with Impairments to Apply for SSI, but the Level of Encouragement Varies
paragraphs: Based on estimates from our survey, 97 percent of all counties refer at  least some of their adult TANF recipients with impairments to SSA to  apply for SSI. As table 1 shows, 33 percent of county TANF offices said  that it is their policy to refer to SSI only those adults whose impairments  are identified as limiting or preventing their ability to work. However,  another 32 percent of county TANF offices said that it is their policy to  refer all TANF recipients identified with impairments to SSI for eligibility  determinations.
TANF offices reported that they rely on several methods to identify an  individual’s impairment and assess whether the individual could work or  should be referred to SSI. Estimates from our survey indicated that all  county offices rely on the applicant to disclose his or her impairment. In  addition, 96 percent of all counties rely on caseworker observation, about  57 percent use a screening tool, and about 60 percent use an intensive  assessment.
Once recipients are identified as having impairments, TANF offices need  to decide which individuals to refer to SSI. As table 2 shows, many  counties rely on multiple forms of documentation or other information to  make this decision, rather than referring all individuals with impairments.  Specifically, 94 percent of all counties reported that they use  documentation from a recipient’s physician, and 95 percent reported that  they use self-reported information from the recipient.
While nearly all county TANF offices reported that they refer at least some  individuals with impairments to SSI, the level of encouragement such  individuals receive from their local TANF office appears to vary. About   98 percent of county TANF offices reported that they tell these recipients  to call or go to SSA to apply for SSI. About 61 percent reported that they  will also assist a recipient in completing the SSI application, and about   74 percent reported that they follow up to ensure the application process  is complete. Some of the variation in the level of encouragement may be  explained by the fact that some states are work first states. Officials we  interviewed in four states acknowledged that they try to get all TANF  recipients to work, including recipients with impairments. Therefore,  while they make referrals to SSI, officials in these work first states told us  that they try to encourage work more than the SSI application process.  However, officials in all five of the states we visited stated that if they feel  an individual has a severe impairment, they would have the individual  apply for SSI.
section_title: Findings About How SSI Caseload Growth Has Been Affected by Referred TANF Recipients with Impairments Are Inconclusive due to Data Limitations
paragraphs: Since county TANF offices refer individuals with impairments to SSI, these  referrals will have some effect on the SSI caseload. To determine the  magnitude of the effect that these TANF referrals have had on SSI  caseload growth, SSA would need to know who among their applicants are  TANF recipients. However, SSA headquarters officials told us that the  agency does not know who is referred or how people are referred because  it does not collect those data. Although the SSI application specifically  asks whether the applicant is receiving TANF, this information is  combined with other income assistance based on need in SSA’s database.  Therefore, while the working age (18-64) SSI caseload has increased   33 percent over the last decade, SSA does not have an easy way to  accurately determine the magnitude of the effect that the TANF referrals  have had on the growth of the SSI rolls.
Also, in a study funded by SSA and conducted by The Lewin Group,  researchers found little, if any, evidence that TANF had increased referrals  to SSI. Only one of the five states the researchers visited remarked of a  perceptible increase in transitions to SSI. The authors noted that the likely  reason for not finding a significant increase in referrals due to welfare  reform is the fact that referrals to SSI had already been occurring under  AFDC, and that the full impact of the welfare reform changes would not be  known until the time limit for benefit receipt had elapsed. However, to  date there have not been any studies that looked at this issue.
In addition to SSA not knowing the magnitude of the effect that TANF  referrals have had on SSI caseload growth, TANF officials we interviewed  stated that they generally do not have historical data on SSI referrals,  approvals, and denials. But officials in most states that we visited said they  are in the process of improving their data collection in this respect,  including tracking methods to determine the status of an SSI application,  which should provide them with better data in the future.
section_title: TANF Offices Differ in Their Exemptions from Work Requirements, but Utilization of Noncash Services Is Generally Low
paragraphs: TANF offices vary in whether they make work requirements mandatory for  their adult recipients with impairments awaiting SSI eligibility  determinations. Even though estimates from our survey showed that   83 percent of county TANF offices reported offering noncash services to  TANF recipients with impairments who are awaiting SSI eligibility  determinations, these services may not be available or are not fully  utilized. Reasons for this low service utilization may include exemptions  from the work requirements and an insufficient number of job training or  related services.
subsections: section_title: Work Requirements Are Not Always Mandatory for Those TANF Recipients with Impairments Awaiting SSI Eligibility Determinations
paragraphs: Estimates from our survey showed that about 86 percent of county TANF  offices have policies that always or sometimes exempt from the work  requirements adult TANF recipients with impairments who are referred to  SSI for eligibility determinations. Also, about 31 percent of county TANF  offices consider the number of times a recipient is denied and appeals an  SSI decision as a factor when deciding to exempt recipients from the work  requirements.
Our survey further found that 82 percent of counties reported exempting  recipients, in part, on the basis of the degree to which the impairment  limits the recipient’s ability to work. In addition, about 69 percent of  county TANF offices reported that the severity of the impairment was a  major factor in their decisions to exempt people with impairments who  are awaiting SSI determinations from work requirements. One TANF  official we interviewed told us that the recipients’ impairments were too  great to participate in work activities.
However, some of the state and county TANF officials we interviewed  explained that they have developed alternative practices to help recipients  with impairments participate in work activities. TANF officials from two  of the states we visited told us that they have developed a modified work  requirement for adult TANF recipients with impairments. A TANF official  from one of these states said that the modified work requirements  encourage individuals with impairments to work, but they do not expect  that these individuals will be able to work in a full-time capacity. One  county TANF official we interviewed explained that the work  requirements and services provided for their recipients with impairments  are very individualized, based on recommendations of the doctors who  meet with the recipients. However, in all of the states and counties we  visited, TANF officials said that individualized services can be costly. One  state official said that his state’s program does not have the funds to pay  for the training needed by people with learning disabilities. The official  added that when people with impairments need substantial help, there  were limits as to what could be funded in a work first state.
section_title: A Broad Range of Services Are Offered to Recipients Awaiting SSI Determinations, but Utilization Is Low
paragraphs: Even though about 51 percent of county TANF offices do not require adult  TANF recipients awaiting SSI determinations to participate in any type of  job services, education services, work experience programs, or other  employment services, 83 percent of county TANF offices reported that  they are still willing to provide work-related or support services to this  population. One state official we interviewed reported that the services  provided are the same for persons with or without impairments. Officials  in this state explained that these services include transportation, child  care, medical assistance, tuition assistance, vocational rehabilitation, and  assistance with obtaining SSI benefits.
Even though county TANF offices may be willing to offer noncash services  to their recipients, among those counties that could provide us with  information on service utilization, utilization of these services tended to be  low. While the low utilization of services may be due to exemptions from  the work requirements, service availability may also be an issue. Estimates  from our survey showed that 40 percent of county TANF offices reported  one of the reasons adult TANF recipients with impairments, who are  awaiting SSI eligibility determinations, are not participating in work  activities is that there are an insufficient number of job training or related  services available for them to use. In addition, some TANF officials that  we interviewed cited not only limited funding, but also their offices’ own  TANF policies as factors that might explain why services may not be  available to recipients with impairments. For example, a state TANF  official we interviewed said that state budget cuts have resulted in  trimming of support services made available to recipients. Another state  official explained that adult recipients with impairments who are placed in  an exempted status are allowed access to medical services but not work- related support services, such as transportation, clothing, or vehicle  repairs. The official further explained that those services are limited to  those individuals who are in work activities.
In addition, estimates from our survey showed that 50 percent of county  TANF offices reported recipients’ motivation to apply for SSI was one of  the conditions that might challenge or hinder their offices in providing  employment services. Some state and county TANF officials we  interviewed also believe that one of the main reasons why there is low  utilization of services is recipients’ fear of jeopardizing their SSI  applications. While participation in a work activity does not necessarily  preclude an individual from obtaining disability benefits from SSA,  estimates from our survey showed that 41 percent of county TANF offices  reported that their recipients with impairments, awaiting SSI eligibility  determinations, are unsure whether or not the demonstration of any work  ability would hinder or disqualify their chances for SSI eligibility. State and  county TANF officials we interviewed explained that recipients applying  for SSI or awaiting an SSI decision fear participating in work activities.  Some of the county TANF officials we interviewed explained that this  population does not want to participate in work-related services for fear of  jeopardizing their applications. These officials noted that compounding  recipients’ fears are attorneys who may be attempting to protect their  clients’ interests by sending TANF offices notices saying that any work  activity could jeopardize their clients’ SSI applications. These fears have  led to TANF workers having some difficulty in getting their recipients with  impairments to explore work options during the time they are applying for  SSI. One state TANF official we interviewed pointed out that  conversations with their recipients about work activities have generally  occurred because the recipients want to volunteer for such activities. A  county TANF official explained that there is a challenge in providing work  services to this population, as the recipients are so focused on getting on  SSI that it is difficult to get them to focus on anything else.
Yet another reason for the low use of noncash service is that some of the  county TANF officials we interviewed expressed some uncertainty as to  how to best serve their adult TANF recipients with impairments,  explaining that they are sending mixed signals when it comes to  encouraging work. One county TANF official we interviewed said that on  one hand, recipients are being told about using TANF services to obtain  employment, and then, on the other hand, recipients are being told to  apply for SSI benefits, which require an applicant to focus on his or her  inability to work. Some TANF offices also allow TANF recipients with  impairments to count applying for SSI as a work activity. Estimates from  our survey showed that about 30 percent of county TANF offices reported  that they consider the SSI application process an activity that satisfies the  work requirement. Also, another county official we interviewed stated that  if a client goes into an exempted status, the client must participate in at  least one activity a week, but not necessarily a work activity. It can be any  service the TANF office has to offer, including physical therapy or  assistance in completing the SSI application.
section_title: Some Interaction Between County TANF Offices and SSA Exists, but Opportunities Exist for Improvement
paragraphs: Some county TANF offices have developed interactions with SSA offices,  but such interactions have been of a limited nature and have focused on  the SSI application process. Estimates from our survey indicated that  some TANF offices have some form of interaction with SSA. Estimates  from our survey also showed that two frequently reported forms of  interaction between county TANF offices and SSA include having a  contact at SSA with whom to discuss cases and following up with SSA  regarding applications for SSI.
In describing his office’s interactions with SSA, one state TANF official we  interviewed said that his office, SSA, and DDS have a good working  relationship, which includes cross training between the agencies and  discussions concerning the SSI application process. However, estimates  from our survey showed about 95 percent of county TANF offices reported  that they would like to develop a relationship, or improve their  relationship, with their local SSA field office with regard to adult TANF  recipients applying for SSI. One state TANF official that we interviewed  said that his office does not have much of a relationship with SSA. He  noted that he had no contacts within SSA but would like to develop a  formal relationship with DDS so that they could make faster  determinations for the deferred TANF caseload. A county TANF official  we interviewed said that her office’s communication with SSA is largely  one-sided. This TANF official explained that even though her office sends  documentation that supports a recipient’s SSI application, SSA does not  inform them of any eligibility decisions it makes with TANF applicants. As  a result, TANF staff must rely on their recipients telling them about  decisions or on a computer system that indicates if an individual is  receiving benefits. Finally, in all of the states we visited, TANF officials  told us that they interact with SSA to assist their TANF recipients with  impairments get onto SSI. Estimates from our survey also showed that  64 percent of counties reported that their interactions were TANF officials  following up with SSA regarding a recipient’s SSI application, and   53 percent reported having a contact at SSA to discuss cases.
TANF offices identified a number of ways they would like to improve  interactions with SSA, but most of these focused on making the SSI  application process more efficient and not on working together to assist  TANF recipients with impairments toward employment and self- sufficiency. Estimates from our survey showed about 57 percent of the  county TANF offices said that they would like to receive training from SSA  regarding the SSI application process and eligibility requirements,   50 percent said they would like to have a contact at SSA with whom to  discuss cases, and 41 percent said they would like to have regular  meetings or working groups with SSA regarding interactions and other  issues related to serving low-income individuals with impairments. In  addition, one TANF official we interviewed would like interactions with  SSA to be improved and thinks they could be if he knew what DDS was  looking for in the application process, such as what it requires for  evidence. In contrast, only 6 percent of county TANF offices reported that  they would like to improve interactions with SSA specifically related to  providing SSA with information on employment-related services received  while on TANF.
Although TANF offices reported an interest in developing a close working  relationship with SSA, based on their interactions with SSA, some state  and county TANF officials believed that they had to take the lead in  developing these relationships. For example, one TANF official we  interviewed explained that he had attempted to make contact with SSA to  discuss a potential partnership and address some of the county’s issues  with the SSI application process but received no response. The county  official then wrote a letter to a top SSA regional official asking about  partnering opportunities. In response, the regional official instructed the  SSA area director, along with the local SSA and state DDS office, to meet  with county officials.
One SSA headquarters official we interviewed told us there is no SSA  policy that directs or encourages their field offices to interact with TANF  offices. The official also told us that SSA would consider such a  partnership with TANF offices but would want assurances of what the  benefits would be for SSA. In addition, the official said that the agency  does not want to start up a partnership that would overly tax its already  high workloads. The official further said that if it were to develop a  relationship with TANF offices, SSA would then have to develop a training  program and then administer it to all operations personnel. The official  noted that developing and administering such a training program would  not be a small task. SSA officials did state that if a TANF office makes a  request for training sessions, SSA would be willing to provide training on  the application process. However, about 27 percent of county TANF  offices reported that they were discouraged in their attempts to establish a  relationship with SSA because the local SSA field office told the TANF  office that SSA did not have the time or the interest.
While officials at SSA headquarters stated that they are largely unaware of  any partnerships or interactions between TANF offices and local SSA field  offices, some local SSA officials have found such relationships beneficial.  In particular, one SSA official has found his office’s relationship with the  local TANF office to be a form of outreach for SSA by helping his office  identify people who would qualify for SSI. He explained that his local SSA  office does not always have the time or staff to conduct outreach. He  further explained that TANF case managers can explain the benefits and  provide assistance to the TANF recipient applying for SSI. Thus, when a  letter comes from the DDS that initially denies the claim, the individual is  less likely to throw it away, as he or she is more aware of the process. This  could save SSA time and money as the applicant knows that he or she  must appeal within a certain amount of time, thereby reducing the need to  start over because of missed deadlines.
While 34 percent of those county TANF offices that provide services to  recipients awaiting SSI eligibility determinations reported interacting with  SSA in some manner to serve adult TANF recipients with impairments, a  much higher proportion reported receiving assistance from other agencies  or programs. For example, as table 3 shows, 91 percent of county TANF  offices reported that at least some of their recipients awaiting SSI  determinations received assistance from the state vocational rehabilitation  agencies, and 86 percent of all offices reported that at least some of their  recipients received assistance from the state or local mental health  agency. Further, in all of the states we visited, TANF offices reported  working with other agencies, such as the Department of Education and the  Department of Labor, to help TANF recipients with impairments find  work.
section_title: Conclusions
paragraphs: With the new emphasis on work and self-sufficiency taken by TANF and  SSI, and the overlap in the populations served by both programs,  opportunities exist to improve the way these two programs interact in  order to help individuals with impairments become more self-sufficient.  While some interactions between TANF offices and SSA do exist, they are  often limited to how best to assist a TANF recipient with impairments  become eligible for essentially permanent cash benefits under SSI.  Moreover, the practice by most TANF offices of exempting individuals  from work requirements while awaiting SSI eligibility determination, as  well as SSA’s policy of offering return-to-work services and incentives only  after a lengthy eligibility process, undermines both programs’ stated goals  of promoting self-sufficiency. In addition, this practice runs counter to the  disability management literature that has emphasized that the longer an  individual with an impairment remains out of the workforce the less likely  the individual is to ever return to work. In recognition of this, SSA is  planning demonstration projects that will test alternative ways to provide  benefits and employment supports to DI applicants. However, TANF  recipients with impairments, because of their low income and assets, are  more likely to apply and qualify for SSI. Moreover, TANF recipients with  impairments often receive assessments of their conditions and capacity to  work while on TANF. Since SSA cannot easily identify who among its  applicants are TANF recipients, SSA is also unable to systematically  identify the types of services that the SSI applicant may have received  through TANF or know whether the SSI applicant has been assessed as  having the capacity to work or not. Being able to identify the receipt of  TANF benefits, as well as the noncash services received through TANF,  may help SSA accomplish its mission of promoting the employment of  beneficiaries with impairments. By sharing information and establishing  better working relationships with TANF agencies, SSA could identify,  among its applicants who are or were TANF recipients, those individuals  capable of working and could then target them for employment-related  services and help them achieve self-sufficiency or at least reduce their  dependency on cash benefits. Although the disconnect in work  requirements between TANF and SSA’s disability programs and the timing  of when employment-related services are provided to SSI recipients could  be barriers to establishing a continuity of services, the earlier provision of  employment-related services, as part of a demonstration project, could  mitigate these potential barriers.
While some county TANF officials we interviewed have developed  working relationships with their local SSA office, other counties have not  or may be unaware of the possibilities for interactions with SSA and how  to go about establishing these relationships. Sharing best practices about  how TANF agencies can distinguish, among the recipients they have  referred to SSI, those individuals without the capacity to work from those  with the capacity to work and who could benefit from employment-related  services could help ensure that those individuals with work capacity be  given the assistance they need to help them obtain employment. Moreover,  sharing best practices for establishing useful interactions with SSA could  help ensure that employment-related services could continue after the  person becomes eligible for SSI.
section_title: Recommendations
paragraphs: To help individuals with impairments become more self-sufficient and to  address the gap in continuous work services between the TANF and SSI  programs, we are recommending that SSA, as part of a new demonstration  project, work with TANF offices to develop screening tools, assessments,  or other data that would identify those TANF recipients with impairments  who while potentially eligible for SSI may also be capable of working.  Once these recipients have been identified, the TANF offices and SSA  could work together to coordinate aggressive medical care and  employment-related services that would help the individual obtain  employment and achieve or at least increase self-sufficiency.
In order to facilitate and encourage a sharing of information among TANF  offices regarding the development of interactions with SSA that might  increase self-sufficiency of recipients with impairments, we are  recommending that HHS provide space on its Web site to serve as a  clearinghouse for information regarding best practices and opportunities  for TANF agencies to interact with SSA. This would allow state and county  TANF officials to share information on what they are doing, what works,  and how to go about establishing relationships with SSA. It would also  provide states and counties with access to the research of federal  agencies, state and county offices, and other researchers that they may  need in order to develop a strong functional relationship with SSA and  help TANF recipients with impairments move toward economic  independence. HHS should be able to minimize its work and expense by  using its Web site to share this information.
section_title: Agency Comments and Our Response
paragraphs: We provided a draft of this report to HHS and SSA for comment. Both  agencies generally agreed with our recommendations and indicated that  they look forward to working together to help low-income individuals with  impairments become more self-sufficient. Specifically, SSA stated that it  would be pleased to work with HHS on the planning and design of a  demonstration project. Likewise, HHS stated that it would be pleased to  have its staff work with SSA to develop a process or criteria for identifying  individuals who could benefit from employment services.
In addition, in response to the findings of our report, SSA said it would  take immediate measures to ensure that it responds to all requests from  TANF offices for training on SSA’s programs.
Also in its comments, SSA suggested that we include in our report the fact  that states may exempt up to 20 percent of their caseload from the time  limits and that many states waive work requirements for persons applying  for SSI. In both the draft we sent to SSA and the final version, we included  a footnote explaining the time limit exemptions, and in the body of the  report we discussed the issue of work requirement exemptions for persons  applying for SSI.
HHS’ comments appear in appendix II and SSA’s comments appear in  appendix III. In addition, both HHS and SSA provided technical comments,  which we have incorporated as appropriate.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution until 30 days after the date of this  letter. At that time, we will send copies to the Secretary of HHS, the  Commissioner of Social Security, appropriate congressional committees,  and other interested parties. The report is also available at no charge on   GAO’s Web site at http://www.gao.gov. If you have any questions about  this report, please contact me or Carol Dawn Petersen on (202) 512-7215.  Other staff who made key contributions are listed in appendix IV.
section_title: Appendix I: Scope and Methods
paragraphs: To determine the extent that Temporary Assistance for Needy Families  (TANF) recipients with impairments are encouraged to apply for  Supplemental Security Income (SSI), whether work requirements are  imposed, the range of services provided during the period of SSI eligibility  determination, and the extent that interactions exist between the SSI and  TANF programs, we conducted a nationally representative survey of   600 county TANF administrators from October 14, 2003, through February  20, 2004.
For the most part, TANF services are provided at the county level, so we  selected a random probability sample of counties for our survey. We  derived a nationwide listing of counties from the U.S. Bureau of the  Census’s county-level file with 2000 census data and yearly population  estimates for 2001 and 2002. We selected a total sample of 600 counties out  of 3,141 counties. To select this sample, we stratified the counties into two  groups. The first group consisted of the 100 counties in the United States  with the largest populations, using the 2002 estimates. The second group  consisted of the remaining counties in the United States. We included all  of the 100 counties with the largest populations in our sample to ensure  that areas likely to have large concentrations of TANF recipients were  represented. From the second group, consisting of all the remaining  counties, we selected a random sample of 500 counties.
After selecting the sample of counties, we used the American Public  Human Services Association’s Public Human Services Directory   (2002-2003) to determine the name and address of the TANF administrator  for each county. In states with regional TANF programs, we asked the  regional director to fill out a questionnaire for each county in the region.  We obtained responses from 527 of 600 counties, for an overall response  rate of about 88 percent. The responses are weighted to generalize our  findings to all county TANF offices nationwide. Sample weights reflect the  sample procedure, as well as adjusting for nonresponse.
Because we followed a probability procedure based on random selections,  our sample is only one of a large number of samples that we might have  drawn. Since each sample could have provided different estimates, we  express our confidence in the precision of our particular sample’s results  at a 95 percent confidence level at an interval of plus or minus  5 percentage points. This is the interval that would contain the actual  population value for 95 percent of the samples we could have drawn. In  other words, we are 95 percent confident the confidence interval will  include the true value of the study population.
In addition to the reported sampling errors, the practical difficulties of  conducting any survey may introduce other types of errors, commonly  referred to as nonsampling errors. For example, differences in how a  particular question is interpreted, the sources of information available to  respondents, or the types of people who do not respond can introduce  unwanted variability into the survey results. We included steps in both the  data collection and data analysis stages for the purpose of mitigating such  nonsampling errors.
section_title: Appendix II: Comments from the Department of Health and Human Services
section_title: Appendix III: Comments from the Social Security Administration
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, David J. Forgosh, Cady Summers,  Megan Matselboba, Christopher Moriarity, and Luann Moy made key  contributions to this report.