Last week, the Department of Human Services proposed a new TANF sanctions policy ‘ one part of its comprehensive redesign of the TANF system. While most elements of the TANF redesign focus on creating better access to individualized services that address recipients’ unique needs, the sanctions are the “stick” element of the program, creating strict financial consequences for families when they do not participate in the program’s requirements. DCFPI is optimistic about the TANF redesign and its ability to better help residents move toward stability, but we believe that the sanctions policy should be carefully considered — and potentially revised — to ensure that it is designed in a way that helps more than it hurts.
Under the new TANF program, all participants will undergo an in-depth assessment of needs, skills, and barriers, and create an Individual Responsibility Plan (IRP) that dictates what activities must be completed in order to remain in good standing with the program. These activities may include program cornerstones such as job training programs and educational components, but might also include time for addressing barriers, caring for children, or other agreed-upon activities.
The new sanction policy will penalize TANF families for failing to comply with their IRPs. The sanctions will have three steps, and become increasingly punitive with each successive step:
- Level one — the head of household is removed from the benefit amount. Under this sanction, a family of three would instead receive the benefit amount for a family of two. This sanction is applied after one month of noncompliance.
- Level two — the family receives a full-family sanction for one month. Under this sanction, the family receives no cash benefit for one month, and may not participate in TANF activities during that period. This sanction is applied if a participant is noncompliant again at any time within 90 days of the level one sanction.
- Level three — the family receives a full-family sanction for six months. Under this sanction, the family receives no cash benefits for six months, and may not participate in TANF activities during that period. This sanction is applied if a participant is noncompliant for a second time within twelve months of the level two sanction.
This proposed policy represents a major shift from the prior sanctions policy, which did not include a full-family sanction, and allowed a family to have their benefits reinstated as soon as they came back into compliance. According to DHS, one aim of the new policy is to discourage a “revolving door” approach, in which families come in and out of compliance regularly. However, the consequences of creating a mandatory sanction period could be severe, especially for the families who rely on their TANF benefit to be able to afford basic necessities. Further, a minimum sanction time (one month for levels one and two, six months for level three) may be counterproductive in DHS’ stated goal of helping families move swiftly toward self-sufficiency by connecting them to appropriate services. Many other states, including Maryland, allow families to reengage in services — and receive reinstated benefits — as soon as the family is ready, with no minimum sanction period.
The sanctions policy is currently undergoing its 30 day public comment period, and will have to be approved by Council before implementation. The sanctions policy is available here. DCFPI will be making comments and will share those suggestions with District Dime readers in the coming weeks.
