What is the best way to move families from welfare to work? The District is preparing a new policy that would terminate cash assistance to families when parents do not comply with work requirements in the Temporary Assistance for Needy Families (TANF) program. The new policy stems from legislation adopted in 2010.
DCFPI disagrees with this strict “full-family sanction” approach, and we recently submitted comments on these proposed rules along with Bread for the City, the Legal Aid Society, and the Washington Legal Clinic for the Homeless.* The comments are intended to make sure that DC’s sanctions policy includes protections for TANF families, which include one of three children in the city.
Why do we oppose full-family sanctions? Research shows that cutting off parents and their children from cash assistance doesn’t lead to increased program participation and help get parents to work. Instead, full-family sanctions tend to fall on families with serious personal problems that make compliance difficult, such as parents with depression. In the end, cutting off parents and their children from critical resources makes it even harder for families to move toward a self-sustaining future.
Despite these objections, the DC Council passed legislation in 2010 requiring the Department of Human Services (DHS) to add new penalties for parents out of compliance with TANF work rules, and DHS submitted a proposed new policy this August. The District has long had a policy to reduce benefits, but not eliminate them, for non-compliance. To its credit, DHS is also rolling out major reforms to improve TANF services focused on education and training. The agency’s director has made it clear that he hopes the improvements will mean that full-family sanctions will be used rarely.
That said, sanctions will be imposed in some cases, which makes it important that the new rules are designed to minimize the possible harm to families with children. Here are some highlights from our comments.
Don’t impose full-family sanctions until new TANF employment services are in place: Many families don’t participate in TANF work activities because they don’t lead to sustainable employment. A pilot program this year showed parents will participate when meaningful work preparation services are offered. Families should not be subject to full family sanctions until they have been offered services under the re-designed TANF employment program.
Create clear interim “warning” steps before families are entirely cut off: Under the proposed policy, a family that falls out of compliance would see a partial cut in benefits — as they do under current rules — and then would have benefits entirely eliminated 90 days later. We propose an interim step — cutting benefits in half — to serve as a wake-up call that DC is serious about families complying with TANF.
Allow families to work with DHS to modify work preparation plans: Some families may face sanctions because they were asked to engage in services that were not appropriate for them — such as expecting someone with low literacy skills to go straight to work. DHS should allow families to point out when their “individual responsibility plan” is difficult or impossible to comply with, and work with families to create a more achievable plan.
Allow families to participate in education and training while under sanction: Families could face elimination of cash benefits for six months, and the proposed policy also would cut these families off from any education or training program they had been participating in. We believe families under sanction should be allowed to continue participating in services that ultimately will help them succeed, even in periods when their cash has been cut off.
The full set of comments can be found here.
* Professor Lisa Martin of the Catholic University School of Law also signed on to these comments.
