TANF and Child Welfare Programs: Increased Data Sharing Could Improve Access to Benefits and Services
Released: 2011-10-20T00:00:00

Letter

Background

TANF Program Funding and Goals

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) significantly changed federal welfare policy for low- income families with children, from a program that entitled eligible families to monthly cash payments to a capped block grant that emphasizes employment and work supports for most adult recipients. As part of PRWORA, Congress created the TANF program, through which HHS provides states about $16.5 billion each year in block grant funds to implement the program. To receive its TANF block grant, each state must also spend at least a specified level of its own funds, which is referred to as state maintenance of effort (MOE).

TANF is a flexible funding stream that states can use to provide cash assistance and a wide range of services that further the program’s four goals, including assisting needy families so that children can be cared for in their own homes or in the homes of relatives. In 2009, states spent about 30 percent of their TANF funds on cash assistance for needy families, and the remaining funds were spent on other purposes, such as child care, employment programs, and child welfare services.

Determining Eligibility for TANF Cash Assistance and Benefit Levels

Although the specific eligibility requirements vary by state, to qualify for TANF cash assistance, families must pass both nonfinancial tests based on the demographic characteristics of the family, and financial tests based on the income and asset holdings available to the family. The TANF program gives states the flexibility to develop their own definition of an eligible family. While some states allow unrelated caregivers acting in place of a parent to apply for TANF benefits, other states limit benefits to relative caregivers and parents, according to information contained in the Urban Institute’s Welfare Rules Database.

Each state sets its own TANF benefit levels, and the amount a family receives depends in part on who is in the assistance unit. An assistance unit is a group of people living together, often related by blood or some other legal relationship. States can exclude adults from the assistance unit but still allow the children to receive some assistance. In these child- only cases, the adults in the family are excluded from the assistance unit and are not considered when calculating the benefit amount. There are four main types of family circumstances that result in child-only cases:  SSI parents. A parent is receiving Supplemental Security Income (SSI) and is receiving TANF child-only payments on behalf of their children.

Immigrant parents. A family is headed by an immigrant parent who is not eligible for TANF. These parents could include illegal immigrants, as well as certain recent legal immigrants who are ineligible for TANF. Ineligible immigrants can receive TANF for their children, provided the children are U.S. citizens.  Sanctioned or disqualified parents. The parent has not complied with TANF program requirements, such as work requirements, and has been denied benefits, but the state allows the children to continue receiving benefits. States must also disqualify adults from receiving TANF benefits for other reasons, such as if they are fleeing to avoid a felony conviction, violating a condition of probation or parole, or in certain circumstances, fraudulently receiving TANF assistance.  Nonparent caregivers. A child is living with a family headed by a nonparent caregiver, often a relative who receives cash assistance on a child’s behalf. According to HHS, nonparent caregivers may not be legally obligated to support these children, and states can provide child-only grants to any relative caring for a child, regardless of the relative’s income, provided that the relative meets the state’s TANF definition of a relative caretaker. If the nonparent caregiver chooses to have their income and resources considered in order to receive a higher level of assistance, the caregiver may be subject to work requirements and time limits.

Families receiving cash assistance with adults in the assistance unit are subject to federal time limits and work requirements. PRWORA established a 60-month time limit for families with an adult receiving aid; however, states have the option to use federal funds to extend assistance beyond the federal time limit for hardship reasons the state has defined. PRWORA also requires adults to engage in work activities after 2 years of assistance, or sooner, if the state determines the recipient is ready. TANF child-only cases are typically not subject to these requirements.

Child Welfare Program Administration and Federal Funding

Child welfare programs provide services to protect children from abuse and neglect, to help parents care for their children successfully, and to provide support to children who cannot safely live with their parents. HHS’ Children’s Bureau oversees federal funding to states for child welfare programs, and states administer these programs. The principal federal funding sources for child welfare are through Titles IV-E and IV-B of the Social Security Act, although child welfare services are also supported by nondedicated federal funding sources, including TANF. In fiscal year 2011, about $6.5 billion was available under IV-E, and about $757 million was made available to states under IV-B, according to HHS budget documents.

Child welfare agencies typically become involved in family situations after receiving reports of child abuse and neglect. Child welfare staff screen and investigate reports of child maltreatment and make recommendations about whether a child can remain safely at home. When abuse or neglect is identified, the agency may provide services designed to improve the situation and avoid removing children from their homes. If such services cannot ensure a child’s safety in their home, the agency may work with the family to determine another living arrangement for the child or petition a court to place the child in foster care.

When children are taken into foster care, the state child welfare agency becomes responsible for determining where the child should live and providing the child with support. The agency may place the foster child in the home of a relative or with unrelated foster parents. States receiving Title IV-E foster care funding must make foster care payments on behalf of eligible children whose foster care placements have been licensed or approved. Under the act, states are responsible for establishing standards for foster family homes and child care institutions that protect the safety of children. Foster parent licensing requirements vary by state and may include training, background checks, and home inspections, according to a HHS report. States must provide foster care payments on behalf of each child who meets certain requirements to cover the cost of providing food, clothing, shelter, daily supervision, and other expenses, but are given flexibility in determining the payment amount. The agency must also assess the needs of the children and arrange for needed services. States must ensure that caseworkers develop a case plan for each child receiving foster care payments to assure that services are provided, and caseworkers must visit with the children periodically. Foster care is intended to be a temporary living arrangement until children can be returned safely to their parents or placed in some other permanent living arrangement, such as guardianship or adoption by a nonparent caregiver.

HHS’ Administration on Aging

HHS’ Administration on Aging oversees a separate program that provides support to nonparent caregivers. The National Family Caregiver Support Program, established in 2000, provides grants to states to fund a range of supports that assist caregivers. In fiscal year 2010, the National Family Caregiver Support Program was allocated about $153 million. State agencies can use up to 10 percent of their funding to provide support services to grandparent caregivers or caregivers age 55 and older who are raising children of relatives. The Administration on Aging funds these activities primarily through grants to each state’s agency on aging. States must fund five types of services under this program: information to caregivers about available services; assistance to caregivers in gaining access to the services; individual counseling, organization of support groups, and caregiver training in the areas of health, nutrition, and financial literacy; respite care; and supplemental services on a limited basis.

TANF Child-Only Cases Have Increased Slightly, and the Composition of the Caseload Varies by State

The TANF child-only caseload increased slightly between fiscal years 2000 and 2008, but comprised a greater share of the overall TANF caseload because TANF cases with adults in the assistance unit decreased substantially. During this time period, the number of TANF child-only cases increased from about 772,000 cases to approximately 815,000 cases, but the number of families with adults receiving assistance decreased by about 700,000 cases from about 1.5 million to about 800,000 cases. As a result, the share of child-only cases in the overall TANF caseload increased from about 35 percent to about half (see fig. 1). We previously reported that changes states made to their welfare programs as they implemented TANF, including work requirements, time limits, sanctions, and diversion policies, contributed to a significant decline in program participation. TANF cases also declined in part because during the 1990s when the economy was stronger, incomes increased, and fewer families were eligible for TANF. Our past work and survey results indicated that one of the reasons child- only cases may not have declined as much as cases with adults in the assistance unit is because these cases are not subject to time limits in most states and recipients may receive assistance for a longer time period.

Between fiscal years 2000 and 2008, increases in two of the categories were statistically significant: children living with parents who were ineligible because they receive SSI benefits and children living with parents who were ineligible because of their immigration status. Cases in which the parents were ineligible due to immigration status almost doubled and increased from 11 percent of the TANF child-only caseload in fiscal year 2000 to 19 percent in fiscal year 2008 (see fig. 2). This increase of 8 percentage points is statistically significant and represents an increase from about 83,000 cases in fiscal year 2000 to over 155,000 cases in fiscal year 2008, with the greatest increase occurring in California. Specifically, TANF child-only cases headed by ineligible immigrants in California more than doubled, from about 46,000 to almost 93,000. This increase accounts for 64 percent of the estimated total increase in these cases nationwide.

Over this same time period, the number of cases in the “unknown caregiver” category–where the relationship between the child and caregiver is unclear–decreased significantly and it is possible that some of the increase in child-only cases with ineligible parents due to SSI receipt or immigration status resulted from better identification of previously unknown caregivers. Given available data, we were unable to determine how much of the increase was due to better reporting versus an actual increase in the number of cases.

Through our TANF survey, officials from 40 states indicated that the composition of their TANF child-only caseload, as of December 2010, was similar to the composition in 2008. The majority of families who received TANF child-only assistance included children living with parents who were ineligible for cash assistance, and about one-third included children living with nonparent caregivers. However, the composition of the TANF child-only caseload varies by state. For example, as reported through our survey, almost 60 percent of TANF child-only cases in Tennessee included children living with nonparent caregivers, compared with 31 percent in Texas. In addition, cases that are child-only because the parent receives SSI comprise 40 percent of the TANF child-only caseload in Tennessee compared with 10 percent in Texas (see fig. 3).

Some of the variation in the composition of TANF child-only cases can be attributed to differences in state demographics and state TANF policies. For example, parents who were ineligible for TANF due to their immigration status account for a greater portion of the TANF child-only caseload in states with relatively large immigrant populations, such as California and Texas. Our survey found that for the 40 states that reported data, about one-third of the TANF child-only caseload is comprised of families in which the parents are ineligible due to their immigration status compared to more than half of the caseloads in California and Texas. Another variation among states is how they determine TANF eligibility for children living with nonparent caregivers. States with less restrictive eligibility rules may have larger numbers of nonparent caregiver cases. For example, Washington, which has a relatively high percentage of nonparent cases, allows unrelated caregivers, such as a friend or neighbor, to apply for TANF child-only assistance after undergoing a home study and background check, according to information provided by state officials. Other states, such as Texas, reported that they limit eligibility for TANF child-only assistance to nonparent caregivers related to the child by blood, marriage, or adoption.

Most Nonparent Caregivers Are Women, and Some Children Have Experienced Abuse or Neglect

Nonparent caregivers in TANF child-only cases tend to be unmarried women over 50 years old (see table 1). African-Americans are overrepresented in these cases, making up 39 percent of the nonparent caregivers but representing approximately 13 percent of the general U.S. population.

Research suggests that many relative caregivers receiving cash assistance have low incomes and health problems. A study analyzing national survey data found that an estimated 55 percent of families in which a child was living in an informal arrangement with a nonparent caregiver receiving cash assistance had income levels below the federal poverty level. The same study found that an estimated 63 percent of these caregivers were unemployed, and an estimated 43 percent of them were in fair or poor health. According to our analysis of HHS’ TANF administrative data, TANF child-only families with nonparent caregivers often receive other types of public assistance. For example, over 90 percent receive Medicaid, and over 40 percent receive Supplemental Nutrition Assistance Program (SNAP) benefits (see fig. 4).

Children who live with nonparents and receive TANF child-only assistance tend to be over 10 years old, related to their nonparent caregiver, and on assistance for at least 2 years (see table 2). More than three-quarters of children are over age 5, and about half of the children are at least 11 years old. A small percentage of children in child-only cases are 18 years old or older. Almost all children are related to their nonparent caregiver, and most often the child is the caregiver’s grandchild. Like the nonparent caregivers, African-American children are overrepresented, making up 40 percent of the children in these cases but approximately 16 percent of the child population in the United States.

Some children living with nonparents who receive TANF child-only assistance live with nonparent caregivers as a result of parental abuse or neglect, but the extent to which these children have had involvement with the state’s child welfare agency is unclear because few states collect this information. In our survey, 6 states reported that between 10 percent and 73 percent of children in TANF child-only cases had been the subject of a Child Protective Services (CPS) investigation, and 6 states reported that between 0 percent and 10 percent had been in state custody. During our site visits, officials from Washington provided us with data showing that about 12 percent of their TANF child-only cases with nonparent caregivers included children who had CPS involvement. Officials from Texas provided us with data showing that one-third of their TANF child-only cases with nonparent caregivers included children who were in state custody.

Child Welfare Involvement and Funding Availability Influence Benefit Levels and Services for Children Living with Nonparents

Benefits and Services Available to Children Living with Nonparents Depend on Child Welfare Involvement and Licensing Status of Caregiver

A child’s circumstances, level of child welfare agency involvement, and licensing status of the caregiver influence whether a child is eligible for a foster care payment or a TANF child-only payment (see fig. 5). In some cases, a child may be living with a nonparent caregiver in an informal arrangement made by the parents, and other family members, and a child welfare agency may not be involved because either the child has not experienced abuse or neglect or the maltreatment was not reported to the agency. In other cases, the child welfare agency may be involved after receiving a report of child abuse or neglect; however, instead of taking legal custody of the child the agency helps the parent voluntarily place the child with a relative caregiver. When determining whether to seek custody of a child, child welfare agencies generally consider factors such as the circumstances of the maltreatment, choices made by the parent, and the availability of a relative willing to intervene. Children living with relatives in informal arrangements or voluntary placements are typically eligible for TANF child-only payments provided the relatives meet their state’s definition of a relative caregiver, according to a 2007 survey of state child welfare agencies. This survey also found that relative caregivers of children taken into state custody may be compensated as foster parents if they meet the training and home requirements to be licensed. Relative caregivers may still apply for TANF child-only payments if they cannot or choose not to meet licensing requirements.

States are not federally prohibited from providing caregivers a foster care payment and a TANF payment for the same child, but the three states we visited did not allow caregivers to receive both payments to support the same child, according to state officials. Specifically, according to HHS officials, there is no programmatic prohibition in either the IV-E program or the TANF program against a caregiver receiving a foster care payment and a TANF payment for the same child, provided eligibility for both programs exists. A state must, however, ensure that it does not use federal TANF or state MOE funds to fulfill the IV-E matching requirement.

Officials in the three states we visited reported that children may receive ongoing financial assistance from TANF and services from a state’s child welfare program, but relative caregivers were not allowed to receive ongoing financial assistance to support the same child from both programs at the same time. For example, a child may receive services from a state’s child welfare program but receive ongoing financial assistance through the TANF program because the child is living with a relative who is not a licensed foster parent.

Texas Relative Caregiver and Other Designated Caregiver Assistance Program This program assists unlicensed relative and fictive kin caregivers who are caring for children in state custody and who meet income and other standards. Fictive kin caregivers are not related to the child but have a long-standing and significant relation- ship with the child or the child’s family. The program provides a one-time $1,000 payment per sibling group to integrate the child into the home and help the caregiver purchase items such as a bed, bedding, and clothing. Caregivers may also be reimbursed for child-related expenses up to $500 per child per year while the child is in state custody. This program also provides reimbursement for child-related expenses up to $500 per year for up to 3 years (or until the child is 18, whichever comes first) to caregivers who become legally responsible for the child through Permanent Managing Conservator- ship.

Foster care and TANF payment amounts vary by state; however, the minimum monthly foster care payment exceeded the TANF child-only payment in almost all states, according to our survey results. For one child, the national average minimum monthly foster care payment is $511 while the average TANF child-only payment is $249 (see table 3). The amount of the foster care payment also depends on the child’s age and any special needs in most states, according to our survey results, and licensed foster parents may receive payments higher than the minimum foster care payment. Gaps between the TANF child-only and foster care payments increase as caregivers take care of additional children because the TANF child-only payment may decrease with each individual child while the foster care payment does not, according to information collected in the states we visited. States may provide relative caregivers additional financial assistance to supplement the TANF child-only payment. For example, Texas and Tennessee provide supplements to the TANF child- only payment under certain circumstances.

Many children in state custody live with relatives who do not receive foster care payments because they are not licensed foster parents. Unlicensed relative caregivers of children in state custody are not eligible to receive foster care payments in 32 of the 43 states responding to this question in our child welfare survey. States reported licensing between 0 and 100 percent of relatives caring for children in state custody. Specifically, 12 states reported that all relatives caring for children in state custody were licensed while in 10 states, less than 15 percent of relatives were licensed. Figure 6 shows licensure rates reported by 34 states and the District of Columbia.

States’ efforts to inform relative caregivers of their options can affect whether the caregivers become licensed. State and local offices we visited reported using a number of different practices to inform relative caregivers of their options and encourage them to become licensed. For example, in Washington, child welfare officials said relatives are informed of the licensing process in letters sent directly by the caseworker and during family meetings facilitated by the child welfare agency. In Tennessee, a kinship coordinator is located in every local child welfare office to inform relative caregivers of their options, according to child welfare staff we interviewed. Child welfare workers we interviewed in Texas said that in the past they did not emphasize the option to become licensed, but they have recently begun a concerted effort to help relatives become licensed so that they can take advantage of the state’s new subsidized guardianship program. These three states also reported making some non-safety- related changes to their licensing processes to help relatives become licensed, such as waiving physical space requirements in the home and reducing the amount of required training hours.

The ability and willingness of relatives to go through the licensing process also affects the extent to which states license relative caregivers. Some relative caregivers may not be able to meet the standards applied to prospective foster parents in their state. For example, relative caregivers or other adults living in the home may have been convicted of a drug-related offense that would preclude the caregiver from becoming licensed but would not prevent them from caring for the child as an unlicensed caregiver, according to some child welfare staff we interviewed during our site visits. In other cases, relatives may perceive the licensing process as too intrusive or burdensome, according to some child welfare staff we interviewed. During our site visits, TANF officials indicated that when relative caregivers apply for TANF child-only assistance, they are required to provide documentation verifying their relationship to the child and that the child resides with them without a parent present. Relative caregivers applying for TANF child-only assistance are not required to undergo a background check, home assessment, or have any ongoing interaction with caseworkers, according to TANF officials in the states we visited.

The following information is documented in the home screening: age of applicant(s) (must be at least 21 yrs. of age)

Although relative caregivers may be eligible for some level of ongoing financial assistance to help them raise the children in their care, research suggests that many relative caregivers in informal arrangements do not receive any cash assistance. A study analyzing national survey data found that about 20 percent of relatives caring for children in informal arrangements reported receiving cash assistance. State and local TANF staff we interviewed suggested various reasons for relatives not accessing TANF child-only benefits. For example, relative caregivers may not be aware that they are eligible for assistance or may not want to receive public assistance. In other cases, the relative caregiver may have a difficult time providing the necessary documentation to verify their relationship with the child or may not want to provide required information about the child’s parents (often the caregiver’s son or daughter) to help the state collect child support.

Examples of some of the documentation required: proof that the nonparent caregiver is related to the proof that the nonparent caregiver lives with and is Applicants must be interviewed by a caseworker. If approved, TANF recipients agree to: cooperate with child support requirements; get medical screenings and all required immuniza- Tennessee developed the Relative Caregiver Program, which provides support to children who are not in state custody and whose relative caregivers have incomes below 200 percent of the federal poverty level, according to information provided by Tennessee state officials. To be eligible, the relative caregiver must be related by blood, marriage, or adoption, be the child’s primary caregiver, and agree to an in-home assessment. Tennessee’s child welfare agency contracts with community based organizations throughout the state to operate the program. The types of assistance available through this program, which became available statewide in 2006, include information about available benefits, support groups, respite care, short-term case management, and start-up or emergency financial assistance. placements routinely maintain ongoing supervision of the children removed from their parents’ homes. Families with informal arrangements made by the parents and other family members to care for children are typically not involved with the child welfare system, but some states have developed programs to help these families.

Children living with relatives receiving TANF child-only payments may be eligible for other services through the TANF agency, but fewer services are available compared to the services child welfare agencies provide for foster children (see fig. 7). According to our survey of state TANF administrators, TANF agencies in 23 states offer child care assistance to nonparent caregivers, and 3 states offer respite care. Less than half of TANF agencies provide case management for TANF child-only cases, so in a majority of states, TANF agencies are unlikely to have ongoing contact with the caregiver after eligibility is determined.

Available federal funding influences the level of assistance states offer relative caregivers. Thirty-seven states reported in our survey that federal financing of child welfare services had some influence on the assistance made available to children in a relative’s care. Title IV-E funding, which accounts for most of the federal funding dedicated for child welfare services, is restricted to supporting foster children who live with licensed or approved foster parents. Specifically, states can only be reimbursed by the federal government for payments made to support children if, among other requirements, the children are in foster care, meet income and resource requirements, and are living with licensed or approved foster parents. In addition, changes made by the Deficit Reduction Act of 2005 clarified the amount that states can seek in federal reimbursement for IV-E administrative costs associated with foster children living with unlicensed relatives. Many states have used TANF to fund child welfare services because although TANF funding is a capped block grant, it is a more flexible funding source. For example, in Texas, 30 percent of the child welfare agency’s budget was funded with TANF dollars in state fiscal year 2010, according to state officials. However, some states may not be able to continue relying on TANF to fund child welfare services because they need to use TANF funds to address other program goals, such as promoting work. For example, Tennessee officials told us that they previously used some of their TANF grant to fund enhanced payments for relative caregivers and their Relative Caregiver Program, but that the state recently discontinued this practice due to budget constraints.

In addition to federal funding constraints, 28 states reported that the cost to the state of serving children in TANF or child welfare programs influences the supports that are made available. Officials in the three states we visited described recent budget problems that made it more difficult to fund supports for children living with relative caregivers. Tennessee’s Relative Caregiver Program was cut by 15 percent, and the state limited participation in their Families First Kinship Program to about 90 children, according to state officials. Officials in Texas told us that their state legislature recently proposed eliminating Texas’ Relative Caregiver Assistance Program, but that the program was ultimately spared after state agency officials successfully argued that, without this support, many relatives would be unable to care for the children, and the state would incur much higher costs if these children were placed with licensed foster care providers. In Washington, the state legislature authorized the TANF agency to begin means-testing child-only applicants to help address the state’s budget shortfall, according to state officials.

In addition to federal and state funding constraints, states’ child welfare reform efforts have affected the types of assistance states offer children living with relative caregivers. Specifically, 31 states reported in our child welfare survey that their state’s efforts to place maltreated children with relatives and prevent entry into foster care had some influence on the type of assistance made available. For example, Texas implemented a child welfare reform effort that involved hiring additional CPS staff and implemented family group decision-making meetings. The state also began providing more in-home services to parents and increased efforts to identify relatives when out-of-home care is necessary. These efforts resulted in significant reductions in the number of children taken into state custody, an increase in relative placements, and lower costs for the state. State officials in Tennessee reported implementing a similar child welfare reform effort, which involved hiring more CPS staff, using family group decision-making meetings, and improving efforts to identify relatives and prevent children from entering foster care.

Coordination Efforts Between TANF and Child Welfare Programs Can Affect Access to Services

Several State and Local Efforts Are Under Way to Coordinate TANF and Child Welfare Programs

Several states have initiated efforts to coordinate TANF and child welfare programs to better serve children living with relative caregivers. About two-thirds of states reported in our surveys that state TANF and child welfare staff meet periodically to work on common areas of concern, such as state budget or policy issues, and about half of state child welfare administrators reported working with their state TANF agency to make additional services available. For example, Washington’s TANF agency convened various state agencies including child welfare, in part to improve coordination and help relative caregivers access resources and services. Tennessee’s TANF and child welfare agency collaborated on a pilot project to provide an additional payment to supplement the TANF child-only payment for relative caregivers caring for children who were determined to be at risk of entering foster care. New York reported in our survey that the state’s TANF and child welfare agencies worked together to launch an informational campaign to help relative caregivers access TANF child-only and child welfare benefits and services.

States surveyed and local offices we visited reported that various efforts are also under way at the local level to coordinate services for children living with relative caregivers. These efforts include colocating TANF and child welfare services in the same building and working together on case planning. Thirty-two states reported about half of their child welfare offices are located in the same building as TANF offices. Some TANF and child welfare staff from our site visits said colocation facilitated coordination by allowing staff to more easily contact each other about cases. In addition, officials from five states—California, Colorado, Kansas, Louisiana, and North Carolina—reported having a combined team of TANF and child welfare staff who work with relative caregivers within their states. In North Carolina, combined TANF and child welfare units, which provide “one- stop” services, improved communication about families, programs, and resources with the goal of preventing children from entering foster care.

Most states cited benefits to coordination between state and local TANF and child welfare agencies (see fig. 8). States reported that coordination was most helpful in providing customer service to parents and relative caregivers, followed by improved decision-making regarding appropriate services for families and better use of TANF and child welfare staff resources. For example, Colorado commented in our survey that one benefit of coordination is maximizing available TANF resources to prevent children from entering the child welfare system if the family lacks its own resources.

To promote coordination between TANF and child welfare programs, HHS’ Administration for Children and Families (ACF) provided approximately $3.5 million per year for five years in grants to states and tribes. ACF’s Office of Financial Assistance awarded 10 grants to tribes to test the effectiveness of efforts to coordinate tribal TANF and child welfare services for tribal families at risk of child abuse or neglect. In addition, ACF’s Children’s Bureau provided grants to 2 states, a tribal organization, and 2 counties to support collaboration between TANF and child welfare programs. The purposes of the Children’s Bureau grants are to: (1) demonstrate models of effective collaboration between TANF and child welfare agencies that will improve outcomes for children and youth who are in, or are at risk of entering, the child welfare system; (2) evaluate and document the processes and outcomes of these collaborations; and (3) develop identifiable sites that state and local TANF and child welfare agencies can look to for guidance and possible replication of collaboration efforts. ACF officials told us they convene meetings so that grantees can share information about their projects, but information about the outcomes of these efforts has not been made available to other states, in part because the demonstration projects and evaluations are still under way. ACF officials told us that, although dissemination activities to date have focused on information sharing among grantees, as grantees complete their work, the agency plans to disseminate best practices and lessons learned to all states. They noted that as site visits to the grantees are completed, the agency plans to post on relevant web sites information gleaned from the grantees on promising practices.

Limited Information Sharing Can Hinder Relative Caregiver Access to Available Benefits and Services

Information sharing between TANF and child welfare programs can benefit children living with relative caregivers, but our review in states where we performed site visits suggests this does not occur consistently. When case workers are knowledgeable about other government programs and community resources, they may be better able to refer families to appropriate services. A few offices we visited reported holding regular meetings during which information is shared about the policies of each program, however, some offices did not report meeting regularly. In our site visits, some TANF and child welfare staff reported being unaware of the services offered in each others’ programs and the correct TANF eligibility rules for relative caregivers. For example, some TANF workers in Tennessee described instances in which child welfare workers had told relative caregivers that they were eligible for child care from the TANF agency, without clarifying that the caregivers must be working and meet certain income limits to qualify. In Texas and Tennessee, TANF and child welfare staff at the state and local levels were unaware of services available to relative caregivers provided by their respective state agencies on aging.

In addition to information sharing between state TANF and child welfare staff, data sharing is another way to help caregivers access benefits and services. Under Title IV-E, states that receive federal funding to develop their child welfare information systems—known as statewide automated child welfare information systems (SACWIS)—are required to the extent practicable to develop an interface with the information system used by the state’s TANF program. This interface is intended to allow the exchange of client data. According to ACF officials, 23 of the 34 state child welfare systems they formally reviewed have met this requirement, and 11 state child welfare systems have not met this requirement. ACF has not reviewed the remaining 17 state child welfare systems because either the states do not operate SACWIS systems or the systems are still being developed. Child welfare administrators from 10 of these 17 states reported in our survey that case information cannot be shared between the child welfare and TANF information systems. Similarly, less than half of state TANF administrators responding to our survey reported that their information systems share data with their state’s child welfare systems, which would allow them to identify duplicate payments or information on whether a client is receiving child welfare services (see fig. 9). Some local TANF workers we spoke to in all three states we visited said they would like to access information in their state’s child welfare information system in order to more easily confirm if a child has been removed from their parents and placed with a relative. Similarly, some local child welfare workers we interviewed said that their state’s TANF agency often has more accurate contact information than their office and that this information could help them locate relative caregivers or parents.

In addition to providing federal funding for the development of SACWIS, HHS provides guidance and technical assistance to help states develop child welfare information systems that can interact with TANF information systems, but more than half the states report obstacles to sharing information, such as privacy concerns and technical challenges. According to HHS officials, federal law should not present a barrier to the sharing of information between the TANF and child welfare agencies, although state law may, as states are permitted to determine their own confidentiality rules. Thirty state TANF administrators and 20 state child welfare administrators said that concerns about client confidentiality have prevented them from sharing information in their state. The National Association of State TANF Administrators, an affiliate of the American Public Human Services Association, suggested in a recent paper that more clarification was needed about whether federal laws prohibit states from sharing information between state TANF and child welfare agencies. HHS officials indicated they have provided states with technical assistance on the interface requirement through conferences and ongoing training. HHS also funds the National Resource Center for Child Welfare Data and Technology, which provides technical assistance to states focused on, among other things, improving case management and data collection systems to improve outcomes for children and families in the child welfare system.

Conclusions

Children often come into the care of relatives unexpectedly and under very difficult circumstances, and many of these caregivers have limited resources. TANF and child welfare programs provide financial assistance and other types of services to these families, but many relative caregivers may not know how to access benefits and services or that such assistance is available. Coordination among programs that provide financial assistance and support to these families is one way to ensure that caregivers are aware of available resources. It will be important for ACF to follow through with its plans to disseminate information gathered from its grants about effective collaboration practices so states can have models to look to for possible replication. Data sharing is another way for states to help caregivers access assistance. If caseworkers have automatic access to information about shared clients, they may be able to make better decisions about what services are needed and accelerate eligibility determination. Although some states are currently sharing data, others indicated they are not due to confidentiality and privacy concerns. HHS has issued guidance to clarify that federal rules do not prohibit data sharing, but less than half of states are moving forward with data sharing efforts.

Recommendations for Executive Action

To help states share data between TANF and child welfare information systems operating within states, we recommend that the Secretary of Health and Human Services direct ACF to clarify its guidance and provide additional technical assistance to states on data sharing opportunities. For example, the HHS-funded National Resource Center for Child Welfare Data and Technology could collect information from states that are successfully sharing data, including how they addressed concerns about client confidentiality, and disseminate that information to all states.

Agency Comments and Our Evaluation

We provided a draft of this report to the HHS for review and comment. HHS agreed with our recommendation and indicated it will provide additional guidance to states and tribes concerning the ability to share information between TANF and child welfare agencies. HHS also provided technical comments, which we incorporated as appropriate. A letter conveying HHS’s comments is reproduced in appendix V.

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If you or your staff members have any questions regarding this report, please contact me at (202) 512-7215 or brownke@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributors to this report are listed in appendix VI.

Appendix I: Scope and Methodology

To address the objectives of this study, we used a variety of methods. Specifically, we:  analyzed publicly available Temporary Assistance for Needy Families (TANF) active caseload data from the U.S. Department of Health and Human Services (HHS), including the number and types of families receiving TANF cash assistance and the characteristics of children and nonparent caregivers in TANF child-only cases;  analyzed HHS’ Adoption and Foster Care Analysis and Reporting System (AFCARS) data reported by states including the number of foster children, number of foster children living with relatives, and the number receiving federally supported foster care payments; conducted a nationwide survey of state TANF administrators and a separate nationwide survey of state child welfare administrators; visited three states and selected localities within each state and interviewed officials administering TANF and child welfare programs; interviewed officials from HHS and reviewed pertinent federal laws, regulations, and agency guidance; and interviewed researchers and others knowledgeable about TANF and child welfare programs from a range of organizations.

We conducted our work from October 2010 to October 2011 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Review of TANF and Child Welfare Data from HHS

TANF Data

Because HHS is responsible for collecting state TANF data and reporting on state TANF programs nationally, we reviewed relevant TANF data compiled by that agency. HHS collects aggregated and disaggregated case record information from states on the families receiving TANF cash assistance. States are required to collect monthly TANF data and report the data to HHS quarterly. States have the option to submit either sample data or data on their entire TANF caseload (universe) data to HHS. Using the disaggregated data, we developed national estimates of the TANF caseload, TANF child-only caseload, the types of TANF child-only cases, and characteristics of the children and head-of-household adults in TANF child-only cases with nonparent caregivers. To analyze how the TANF child-only caseload has changed over time, we analyzed HHS’s TANF data for fiscal years 2000 through 2008, the most recent data available. To identify the characteristics of TANF child-only cases with nonparent caregivers, we analyzed 2008 data, including several variables that provided information about the demographics and economic circumstances of these cases. Because the scope of our work extended to the 50 states and Washington, D.C., we excluded data for the U.S. territories from our analyses. Because many of the states report samples of cases to HHS, we weighted the estimates to reflect the sample design employed by each of these states. All national estimates produced from our analysis of the TANF data are subject to sampling errors. We express our confidence in the precision of our results as a 95 percent confidence interval. This is the interval that would contain the actual population value for 95 percent of the samples the states could have drawn.

To assess the reliability of HHS’ TANF data, we reviewed relevant HHS documentation, including guidance for states on data collection and sampling, interviewed HHS officials, conducted electronic data testing, and compared our results with related information reported by HHS and other researchers. While we interviewed HHS officials to gather information on the processes they use to ensure the completeness and accuracy of the TANF caseload data, we did not independently verify these data with states. In addition, although HHS does not perform on- site reviews of states’ TANF data, auditors in each state periodically review state TANF programs, including administrative data, to comply with the Single Audit Act of 1984. Because of these reviews, as well as the steps taken by HHS officials to ensure the completeness and accuracy of these data, we determined that they were sufficiently reliable for the purposes of this report.

Tables 4, 5, 6, 7, and 8 provide the estimates and 95 percent confidence intervals for the data we present in the body of this report.

To examine the extent to which foster children live with relatives and what payments foster children receive, we reviewed relevant national data on children in foster care from HHS’s Adoption and Foster Care Analysis and Reporting System (AFCARS). HHS uses AFCARS to capture, report, and analyze information collected by the states concerning all foster care children for whom state child welfare agencies have responsibility for placement, care, or supervision. We reviewed AFCARS data for fiscal years 2005 through 2009 and identified the number of foster children living with relatives and the number of children receiving a federally supported IV-E foster care payment. To assess the reliability of these data, we reviewed documentation about the collection and reporting of AFCARS data and conducted electronic testing of AFCARS data. We also interviewed relevant HHS officials to clarify data elements, procedures, and reasons for missing information. The AFCARS data on the placement setting of children in foster care and whether they receive a IV-E foster care payment were found to be sufficiently reliable for the purposes of this engagement.

Surveys of State TANF and Child Welfare Administrators

To help address all of our research objectives, we conducted a Web- based survey of state TANF administrators and a separate survey of state child welfare administrators in all 50 states and the District of Columbia. The survey was conducted between March 2011 and June 2011, and administrators from every state and the District of Columbia responded. The TANF survey included questions about: TANF child-only policies, the current TANF child-only caseload, financial assistance and services available to children in these cases, kinship care programs, coordination between TANF and child welfare programs, and the factors influencing the assistance available to children living with relative caregivers. The child welfare survey included questions about: the financial assistance and services available to children in foster care, the extent to which relative homes are licensed as foster parents, kinship care programs, implementation of subsidized guardianship, coordination between TANF and child welfare programs, and the factors influencing the assistance available to children living with relative caregivers.

Because this was a survey of all states and not a sample survey, there are no sampling errors. However, the practical difficulties of conducting any survey may introduce errors, commonly referred to as nonsampling errors, such as variations in how respondents interpret questions and their willingness to offer accurate responses. We took steps to minimize nonsampling errors, including reviews by experts in the content field, pretesting draft instruments, and having an independent analyst check all computer programs. Specifically, during survey development, we pretested draft instruments with TANF and child welfare administrators from four states (Maryland, Ohio, Virginia, and Washington) in February 2011. We selected the pretest states to provide variation in program administration (e.g., state-administered vs. county-administered programs) and geographic location. In the pretests, we were generally interested in the clarity, precision, and objectivity of the questions, as well as the flow and layout of the survey. For example, we wanted to ensure definitions used in the surveys were clear and known to the respondents, categories provided in closed-ended questions were complete and exclusive, and the ordering of survey sections and the questions within each section was appropriate. We revised the final survey based on pretest results. To further minimize errors, programs used to analyze the survey data and make estimations were independently verified to ensure the accuracy of this work.

While we did not fully validate specific information that states reported through our survey, we took steps to ensure that the information was of sufficient quality for the purposes of this report. For example, we reviewed the responses and identified those that required further clarification and, subsequently, conducted follow-up interviews with those respondents to ensure the information they provided was reasonable and reliable. On the basis of these checks, we believe our survey data are of sufficient quality for use in our work.

Site Visits

To gather information about how TANF and child welfare programs are implemented at the local level, we conducted site visits, between December 2010 and March 2011, to Tennessee, Texas, and Washington, and selected localities in those states. Specifically, we met with state officials in each state and visited Upper Cumberland, Rutherford, and Davidson counties in Tennessee; Travis, Williamson, and Hays counties in Texas; and King, Grays Harbor, and Thurston counties in Washington. These states were selected because they varied in TANF caseload characteristics and implementation of programs to assist relative caregivers. We worked with the states to select localities that were located in both urban and rural areas to help ensure that we captured any differences in TANF and child welfare program implementation. Within each state, we interviewed state TANF and child welfare administrators, as well as TANF and child welfare staff from two to three local offices. Through these interviews, we collected information on TANF child-only policies and caseload characteristics, the types of assistance available to children living with relative caregivers, coordination between TANF and child welfare programs, and the factors influencing the types of assistance available to support children living with relative caregivers.

Appendix II: States’ Reported Child-Only Caseloads and Reasons That Cases Are Child-Only

Appendix III: States’ Monthly TANF Child-Only and Foster Care Payment Rates

Appendix III: States’ Monthly TANF Child-Only and Foster Care Payment Rates 1 child 2 children 3 children . . .

475 1 child 2 children 3 children . . .

Appendix IV: Subsidized Guardianship and the TANF Child-Only Caseload

As part of this study, we were asked to examine how states have implemented the option, known as the Guardianship Assistance Program (GAP), and how it has affected TANF child-only caseloads. To address this question, we collected information from HHS, our survey of state child welfare administrators, and interviews with researchers who have expertise in child welfare. We also reviewed the evaluations of the guardianship waiver demonstration projects that 11 states submitted to HHS.

Status of Subsidized Guardianship

The Fostering Connections to Success and Increasing Adoptions Act of 2008 gave states the option to use federal Title IV-E funding—that was previously reserved for foster care and adoption services—to support relatives who become guardians under certain circumstances. To st receive funding, the child must be Title IV-E eligible, the caregiver mu the be a licensed or approved foster parent, and the child must live with caregiver for at least 6 months. In addition, reunification with the child’s birth parents and adoption by the relatives must be ruled out as permanency options. States that adopt the federal GAP option can be federally reimbursed for a portion of the cost of providing kinship guardianship assistance payments on behalf of eligible children. states developed subsidized guardianship programs prior to the availability of federal funding, according to previous studies. States that had subsidized guardianship programs funded with state funds could benefit from the new federal option, provided the children meet federal eligibility requirements. States that did not previously have subsidized guardianship programs have to consider whether state funding is available to cover the costs that will not be federally reimbursed.

The reimbursement rate for the guardianship payments is the rate states are reimbursed for Medicaid. States opting to provide such payments may also claim federal reimbursement for a portion of the administrative and training costs associated with operating the program. submitted Title IV-E plan amendments to adopt the option to operate a guardianship assistance program. ACF has approved 22 amendments, and amendments from the remaining 7 states are under ACF review or are being revised (see fig. 10). As of the second quarter of fiscal year 2011, 10 states submitted claims for federal reimbursement for IV-E guardianship assistance payments on behalf of 1,004 children. In addition, Illinois, which implemented one of the IV-E waiver projects, submitted claims on behalf of 2,893 children who were eligible based on their participation in the waiver demonstration.

In addition to the federal GAP option, 30 states reported in our survey that they had another subsidized guardianship program in place (see italicized states in figure). Some of these other state subsidized guardianship programs have broader eligibility rules compared with the federal program. Specifically, 7 states reported that children who were not in state custody could benefit from their state subsidized guardianship program, and 14 allowed unlicensed relative caregivers to participate.

Based on our review, we were unable to determine whether or not there is connection between the availability of guardianship and TANF child- only cases. States are just beginning to implement the GAP option, and it is too early to determine whether the availability of subsidized guardianship will have an effect on the TANF child-only caseload at this point in time. The state evaluations of the 11 IV-E subsidized guardianship waiver projects did not include any information that indicates that subsidized guardianship programs have affected TANF child-only caseloads. The state evaluations indicated that the IV-E subsidized guardianship waiver projects offered a guardianship option to children in state or tribal custody, and 6 of the 11 states required the caregivers be licensed foster parents. Most state child welfare agencies responding to a question in our survey about the relationship between subsidized guardianship and the TANF child-only caseload reported that they did not believe the number of TANF child-only cases with nonparent caregivers would be affected by the availability of subsidized guardianship in their state. Researchers we interviewed were not aware of a connection between subsidized guardianship and TANF child-only caseloads. Subsidized guardianship may not be a viable option for most children in TANF child-only cases because most of the children are not in state custody, and the relative caregivers are not licensed, according to some of the researchers we interviewed.

Appendix V: Comments from the Department of Health and Human Services

Appendix VI: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, others making key contributions to this report include: Elizabeth Morrison, Cathy Roark, John Townes, Marissa Dondoe, Allyson Goldstein, Kate van Gelder, James Bennett, Hiwotte Amare, Carl Barden, Luann Moy, Lorraine Ettaro, Beverly Ross, Alex Galuten, Leia Dickerson, Amy Frazier, Kristy Kennedy, Claudine Pauselli, and Almeta Spencer.