TANF and SSI
Opportunities Exist to Help People with Impairments Become More Self-Sufficient Gao ID: GAO-04-878 September 15, 2004The 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.
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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
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Report to the Chairman, Subcommittee on Human Resources, Committee on
Ways and Means, House of Representatives:
United States Government Accountability Office:
GAO:
September 2004:
TANF and SSI:
Opportunities Exist to Help People with Impairments Become More Self-
Sufficient:
GAO-04-878:
GAO Highlights:
Highlights of GAO-04-878, a report to the Chairman, Subcommittee on
Human Resources, Committee on Ways and Means, House of Representatives:
Why GAO Did This Study:
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.
What GAO Found:
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.
What GAO Recommends:
GAO recommends that SSA, in a new demonstration project, work with
TANF officials to identify recipients with impairments capable of
working and coordinate services to help them improve self-sufficiency.
GAO also recommends that HHS use its Web site as a clearinghouse for
information regarding opportunities for TANF agencies to work with SSA.
Both SSA and HHS generally agreed with our recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-04-878.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Cindy M. Fagnoni (202)
512-7215 fagnonic@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
TANF Recipients with Impairments Are Encouraged to Apply to SSI; Impact
on SSI Caseload Growth Is Inconclusive:
TANF Offices Differ in Their Exemptions from Work Requirements, but
Utilization of Noncash Services Is Generally Low:
Some Interaction Between County TANF Offices and SSA Exists, but
Opportunities Exist for Improvement:
Conclusions:
Recommendations:
Agency Comments and Our Response:
Appendix I: Scope and Methods:
Appendix II: Comments from the Department of Health and Human Services:
Appendix III: Comments from the Social Security Administration:
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Tables:
Table 1: County TANF Office Policies for Referring Adult Cash
Recipients to SSI:
Table 2: Information Used by County TANF Offices to Determine whether
to Refer Adult Recipients to SSI:
Table 3: Agencies or Programs That Support TANF Offices by Providing
Services to At Least Some Adult TANF Cash Recipients Awaiting SSI
Eligibility Determinations:
Abbreviations:
AFDC: Aid to Families with Dependent Children:
ALJ: Administrative Law Judge:
DDS: Disability Determination Service:
DI: Disability Insurance:
HHS: Department of Health and Human Services:
PRWORA: Personal Responsibility and Work Opportunity Reconciliation Act
of 1996:
SSA: Social Security Administration:
SSI: Supplemental Security Income:
TANF: Temporary Assistance for Needy Families:
United States Government Accountability Office:
Washington, DC 20548:
September 15, 2004:
The Honorable Wally Herger:
Chairman, Subcommittee on Human Resources:
Committee on Ways and Means:
House of Representatives:
Dear Mr. Chairman:
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.[Footnote 1]
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.[Footnote 2]
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.[Footnote 3]
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,[Footnote 4] 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.[Footnote
5] 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.
Results in Brief:
Estimates from our nationwide survey of county TANF offices indicated
that almost all offices reported that they encourage at least some TANF
recipients with impairments to apply for SSI, but the effect these TANF
referrals have had on SSI caseload growth is inconclusive. In order to
better serve individuals with impairments, nearly all TANF offices rely
on one or more methods to identify impairments. Although nearly all
county TANF offices reported that they refer recipients with
impairments to SSI, the level of encouragement that these individuals
receive to apply for SSI appears to vary. While almost all county TANF
offices stated that they advise such recipients with impairments to
apply for SSI, about 74 percent also follow up to ensure the
application process is complete, and about 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 applicants have income
from other sources, it cannot easily determine whether this income
comes from TANF or some other assistance based on need. Furthermore,
SSA does not collect any data indicating whether an applicant is
referred from another program. In addition, past research has not found
conclusive evidence regarding the impact that TANF referrals have on
SSI caseload growth.
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 with impairments
awaiting SSI eligibility determinations from the work requirement. One
key reason, cited by some county TANF officials we interviewed, for not
imposing work requirements on adult TANF recipients with impairments
awaiting SSI is the existence of state or county TANF policies and
practices that exempt recipients from the work requirements.
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,
our survey and interviews with state and county TANF officials indicate
that many recipients do not use these services. This low utilization
may be related to exempting individuals from the work requirement, but
there are other reasons. Some TANF officials we interviewed in the
states we visited said that one of the reasons recipients with
impairments do not use these services is because of the recipient's
fear of jeopardizing their SSI applications. Another reason for the low
utilization of services is that many services are not necessarily
available. Forty percent of county TANF offices noted that one of the
reasons adult TANF recipients with impairments were not participating
in work activities was an insufficient number of job training or
related services. Some state and county TANF officials we interviewed
indicated that budgetary constraints have also limited the services
that they are able to offer recipients with impairments.
Interactions between TANF offices and SSA are limited. Our survey
showed that some TANF offices have stated an interest in developing a
relationship with SSA. However, estimates from our survey showed that
53 percent of counties reported that their interactions included having
a contact with SSA, and 64 percent reported that their interactions
included following up with SSA regarding a recipient's application for
SSI. According to our survey results and interviews with TANF officials
in the states we visited, interactions that help individuals with
impairments increase their self-sufficiency are limited. In the states
we visited, we found that such interactions generally existed between
TANF agencies and other agencies (such as the Department of Labor or
Department of Education). Nevertheless, county TANF offices would like
to improve their interactions with SSA, with 95 percent of county TANF
offices reporting that their interactions could be improved. For
example, about 57 percent of counties reported that receipt of training
on the SSI application process and eligibility requirements is a useful
interaction. However, only 6 percent of counties reported that they
would like to improve interactions with SSA specifically related to
providing SSA with information on employment-related services, such as
vocational rehabilitation, that recipients received prior to applying
for SSI. Some state and county TANF officials that we interviewed also
said that they felt they had to take the lead in developing and
maintaining interactions with SSA. One SSA headquarters official
indicated that SSA has no formal policy regarding outreach to TANF
offices but would consider such a partnership provided there is some
benefit for SSA. The official also added that they will always respond
to TANF training or information requests. 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 them that they did not have the time or the interest.
In order to help individuals with impairments increase self-sufficiency
and to address the gap in continuous work services between TANF and
SSI, we are recommending that SSA, as part of a new demonstration
project, work with TANF agencies to identify those low-income
individuals with impairments who while potentially eligible for SSI may
also have the capacity to work, and coordinate services to increase the
likelihood that such individuals can obtain employment and become more
self-sufficient. In order to facilitate and encourage a sharing of
information among TANF offices to 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. HHS should be able to minimize its work and expense by using its
Web site to share this information. Both SSA and HHS 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.
Background:
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,[Footnote 6] 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,[Footnote 7] although the law allows states to provide
assistance beyond 60 months using state funds.[Footnote 8]
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[Footnote 9] 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.[Footnote 10] 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.[Footnote
11] If the individual is not satisfied with this determination, he or
she may request a reconsideration of the decision with the same
DDS.[Footnote 12] 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.[Footnote 13]
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.[Footnote 14]
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[Footnote 15] (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.[Footnote 16] 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.[Footnote 17] 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.[Footnote 18]
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.
TANF Recipients with Impairments Are Encouraged to Apply to SSI; Impact
on SSI Caseload Growth Is Inconclusive:
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.
Nearly All County TANF Offices Refer Recipients with Impairments to
Apply for SSI, but the Level of Encouragement Varies:
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.
Table 1: County TANF Office Policies for Referring Adult Cash
Recipients to SSI:
Policy: Refer all recipients with impairments;
Percent: 32%.
Policy: Refer based on criteria from SSI eligibility determination
process;
Percent: 13%.
Policy: Refer only those who are work limited;
Percent: 33%.
Policy: No policy;
Percent: 20%.
Source: Percentages are estimated from GAO survey of county TANF
offices.
Note: Respondents were also given the option of indicating that their
policy was something other than those listed above, and 2 percent of
respondents indicated other.
[End of table]
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.
Table 2: Information Used by County TANF Offices to Determine Whether
to Refer Adult Recipients to SSI:
Information: Documentation from recipient's physician;
Percent: 94%.
Information: Documentation from medical professional other than a
physician;
Percent: 80%.
Information: Evaluation by an on-site or vendor medical professional;
Percent: 31%.
Information: Evaluation of recipient's ability to work by state
vocational rehabilitation worker;
Percent: 70%.
Information: Informal evaluation by caseworker or social worker;
Percent: 85%.
Information: Documented evaluation by caseworker;
Percent: 49%.
Information: Behavior observed by caseworker;
Percent: 82%.
Information: Self-reported information from recipient;
Percent: 95%.
Source: Percentages are estimated from GAO survey of county TANF
offices.
[End of table]
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.[Footnote 19] 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.
Findings About How SSI Caseload Growth Has Been Affected by Referred
TANF Recipients with Impairments Are Inconclusive due to Data
Limitations:
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.[Footnote 20] 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.[Footnote 21]
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.[Footnote 22] 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.[Footnote 23] 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.
TANF Offices Differ in Their Exemptions from Work Requirements, but
Utilization of Noncash Services Is Generally Low:
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.
Work Requirements Are Not Always Mandatory for Those TANF Recipients
with Impairments Awaiting SSI Eligibility Determinations:
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.[Footnote 24] 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.
A Broad Range of Services Are Offered to Recipients Awaiting SSI
Determinations, but Utilization Is Low:
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.
Some Interaction Between County TANF Offices and SSA Exists, but
Opportunities Exist for Improvement:
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.
Table 3: Agencies or Programs That Support TANF Offices by Providing
Services to At Least Some Adult TANF Cash Recipients Awaiting SSI
Eligibility Determinations:
Agencies: State Vocational Rehabilitation;
Percent: 91%.
Agencies: Other U.S. Department of Education Programs;
Percent: 67%.
Agencies: Social Security Administration;
Percent: 34%.
Agencies: U.S. Department of Labor;
Percent: 69%.
Agencies: State or Local Mental Health Agency;
Percent: 86%.
Agencies: Community Programs;
Percent: 67%.
Agencies: Other;
Percent: 9%.
Agencies: None;
Percent: 1%.
Source: Percentages are estimated from GAO survey of county TANF
offices.
[End of table]
Conclusions:
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.
Recommendations:
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.
Agency Comments and Our Response:
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.
Cynthia M. Fagnoni:
Managing Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methods:
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.[Footnote 25] 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.
[End of section]
Appendix II: Comments from the Department of Health and Human Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
AUG 23 2004:
Ms. Cynthia M. Fagoni:
Managing Director,
Education, Workforce, and Income Security Issues:
United States Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Fagoni:
Enclosed are the Department's comments on your draft report entitled,
"TANF and SSI - Opportunities Exist to Help People with Impairments
Become More Self-Sufficient" (GAO-04-878). The comments represent the
tentative position of the Department and are subject to reevaluation
when the final version of this report is received.
The Department provided several technical comments directly to your
staff.
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Lewis Morris:
Chief Counsel to the Inspector General:
Enclosure:
The Office of Inspector General (OIG) is transmitting the Department's
response to this draft report in our capacity as the Department's
designated focal point and coordinator for Government Accountability
Office reports. OIG has not conducted an independent assessment of
these comments and therefore expresses no opinion on them.
COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) ON THE
GOVERNMENT ACCOUNTABILITY OFFICE'S (GAO's) DRAFT REPORT ENTITLED "TANF
AND SSI--OPPORTUNITIES EXIST TO HELP PEOPLE WITH IMPAIRMENTS BECOME
MORE SELF-SUFFICIENT" (GAO-04-878):
General Comments:
HHS appreciates the opportunity to comment on GAO's draft report. HHS
is in general agreement with GAO's conclusions and would like to see
States establishing closer relationships with Social Security
Administration (SSA) offices in order to improve services for those
potentially eligible for Supplemental Security Income (SSI). The
Temporary Assistance for Needy Families (TANF) program seeks to help
each of its clients achieve the highest degree of self-sufficiency
possible. Doing this requires properly assessing both the abilities and
limitations of disabled clients and finding, when possible, appropriate
work settings and training that can give each client the opportunity to
work. When possible, clients who have impairments should not be
exempted from work activities but helped to find accommodating settings
through which they could provide for their families. At the same time,
TANF provides important assistance in helping interested clients apply
for SSI.
It is important, however, to appreciate that TANF efforts to promote
maximum family self-sufficiency through work while helping some clients
apply for SSI are inherently in conflict. Since SSI is intended for
clients who cannot provide for themselves through work, participation
in accommodating work activities while on TANF can be used as evidence
against a client's application for SSI. Therefore, when TANF agencies
assess a client as being potentially SSI eligible, efforts at helping
such clients pursue work are frequently abandoned.
Opportunities exist for better coordination and collaboration among
TANF and SSI offices during the application process and afterwards to
help individuals with impairments pursue work training, return to work
services, and become more self-sufficient. We would be pleased to have
ACF work with SSA to develop a process or criteria for identifying
individuals who could benefit from employment services.
GAO Recommendation:
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.
HHS Comment:
While this recommendation is directed to SSA, ACF welcomes the
opportunity to work with SSA on developing model screening tools,
assessments, or other data that would be useful in matching clients to
appropriate work settings.
GAO Recommendation:
In order to facilitate and encourage information sharing 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 website to serve as a
clearinghouse for information regarding best practices and
opportunities for TANF agencies to interact concerning SSA. This would
allow State and county TANF officials to share information concerns
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 website to share this
information.
HHS Comment:
ACF's Office of Family Assistance (OFA) website already offers a
connection to OFA's Welfare Peer Technical Assistance Network. The
network provides peer technical assistance to other agencies and
solicits innovative programs and practices under a variety of headings.
OFA will explore establishment of a new category of TANF/SSI
interaction and solicit information that will be useful.
Based on SSA data which states that up to 25 percent of the SSI
caseload ages 18-64 received income assistance based on need (including
TANF), the report (see Highlights section and page 2) indicates that
there is "overlap" between the SSI and TANF populations. In fact, all
States prohibit individuals receiving SSI benefits from simultaneously
receiving TANF benefits; thus, what is being described as an "overlap"
is a subset of the SSI population who used to receive TANF benefits. It
would be helpful to clarify whether the data cited in the report were
collected at the time of application for SSI and whether they include
benefits received for other family members, as a parent may receive SSI
on his/her own behalf and TANF on behalf of his/her children.
The report (see page 12) cites a 2000 report finding little increase in
referrals to SSI from TANF in the wake of welfare reforms, but also
states, "...the full impact of the welfare reform changes would not be
known until the time limit for benefit receipt had elapsed." At this
point, recipients in all States have reached the 5-year national time
limit; however, all States are under the 20 percent limit on
extensions, so there is no reason to expect a sharp increase in
referrals to SSI.
[End of section]
Appendix III: Comments from the Social Security Administration:
SOCIAL SECURITY:
The Commissioner:
August 17, 2004:
Ms. Cynthia M. Fagnoni:
Director, Education, Workforce and Income Security Issues:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Fagnoni:
Thank you for the opportunity to review and comment on the draft report
"Temporary Assistance for Needy Families (TANF) and Supplemental
Security Income (SSI): Opportunities Exist to Help People with
Impairments Become More Self-Sufficient" (GAO-04-878).
Our response and technical comments to the draft report are enclosed.
If your staff has questions about the comments, they may contact
Candace Skurnik, Director, Audit Management and Liaison Staff, at (410)
965-4636.
Sincerely,
Signed by:
Jo Anne B. Barnhart:
Enclosure:
SOCIAL SECURITY ADMINISTRATION BALTIMORE MD 21235-0001:
COMMENTS ON THE GOVERNMENT ACCOUNTABILITY OFFICE (GAO) DRAFT REPORT,
"TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) AND SUPPLEMENTAL
SECURITY INCOME (SSI) OPPORTUNITIES EXIST TO HELP PEOPLE WITH
IMPAIRMENTS BECOME MORE SELF-SUFFICIENT" GAO-04-878:
We appreciate the opportunity to comment on the draft report. We are
concerned to discover from the report that one-fourth of the TANF
offices that responded to GAO's survey claimed to be rebuffed when they
contacted an SSA Field Office to request training on our programs. We
have two positions within the Regional Offices (RO) specifically
dedicated to responding to that type of request, Public Affairs
Specialists and Area Work Incentive Coordinators. We will ensure that
our ROs respond to such requests from TANF offices and enhance
communications on TANF nationwide. By improving our communications with
TANF offices, we may benefit by seeing some reduction in the number of
persons referred who clearly are not disabled under SSA rules.
Additionally, we currently have under development two demonstration
projects designed for Title II applicants that should provide valuable
lessons to consider in connection with development of a TANF/SSI early
intervention project.
To enhance this report, we suggest you include the fact that States can
set up waivers for any group on TANF provided they do not waive more
than 20 percent of their total recipients. Many States, such as
Illinois, waive work requirements and time limits if the person is
applying for SSI, or if the State has determined that the person is
unable to work due to medical condition, even if his SSI application
was denied.
Our response to the specific recommendation and technical comments are
below.
Recommendation 1:
As part of a new demonstration project, SSA staff should work with TANF
offices to identify recipients with impairments capable of working and
to coordinate services to help individuals improve self-sufficiency.
Comment:
We agree. As noted above, SSA has plans underway for several
demonstration projects aimed at assisting individuals with disabilities
to achieve self-sufficiency through work. Although we do not currently
have plans for a demonstration project involving TANF and SSI, we
believe that such a project could benefit both of these groups of
individuals. We will be pleased to work with HHS on the planning and
design for this proposed project.
[End of section]
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Carol Dawn Petersen, (202) 512-7215:
Michael J. Collins, (202) 512-7215:
Staff Acknowledgments:
In addition to those named above, David J. Forgosh, Cady Summers, Megan
Matselboba, Christopher Moriarity, and Luann Moy made key contributions
to this report.
FOOTNOTES
[1] SSI also provides income assistance to children with disabilities
and the aged who have low income and assets.
[2] This includes individuals who may have been denied benefits and
abandoned their claims before exhausting all appeals.
[3] A field in SSA's database does indicate whether an applicant
receives assistance based on need, but this includes TANF as well as
other forms of income assistance based on need. While this does not
give an accurate estimate of the portion of SSI recipients who were
TANF recipients, it does provide an upper bound.
[4] The surveys were mailed to either the director of the county TANF
office or the regional director, depending on the structure of the TANF
program in each state. The surveys were completed by the director or
his/her designee.
[5] Sampling errors for estimates presented in this report did not
exceed 5 percentage points. See appendix I for a more detailed
discussion of sampling errors.
[6] In addition to federal funds, states must also provide funding for
TANF. However, states are not required to spend all of their block
grant in the year the money is received; instead they can accumulate
unused funds to be used at a later time. Therefore, total TANF
expenditures in 2002, including federal, state, and accumulated funds,
totaled $28.4 billion.
[7] A state may exempt up to 20 percent of its average monthly caseload
for hardship or having been subjected to domestic violence.
[8] Estimates from our survey show that only 2 percent of counties
always, and 16 percent sometimes, move TANF recipients with impairments
awaiting SSI determinations to state only funded cash assistance.
[9] While the SSI regulations do not guarantee permanent benefit
status, only 0.4 percent of SSI disability recipients leave SSI because
of work, and only 6.8 percent are no longer eligible because of medical
improvement. Excess income or resources can also end a person's SSI
benefits.
[10] In 2004 the substantial and gainful activities level for nonblind
individuals is $810 per month, and for blind individuals is $1,350 per
month, of countable earnings. Both levels are indexed to the average
wage index.
[11] There are 54 primarily state-operated DDS offices; their staff
consists generally of a variety of positions such as disability
examiners, medical consultants, vocational specialists, and quality
assurance personnel.
[12] In September 2003, the Commissioner testified before the House
Committee on Ways and Means, saying that she intended to revise the
disability determination process. For example, she proposed eliminating
the reconsideration and the Appeals Council stages of the current
process.
[13] If the individual is not satisfied with the Appeals Council
action, the individual may appeal to a federal district court. The
individual can continue legal appeals to the U.S. Circuit Court of
Appeals and ultimately to the Supreme Court of the United States.
[14] GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.:
Jan. 1, 2003).
[15] The Social Security Advisory Board is an independent, bipartisan
board created by the Congress and appointed by the President and the
Congress to advise the President, the Congress, and the Commissioner of
Social Security on programs and matters related to SSA.
[16] In addition to the Ticket Program, SSA also offers other work
incentives to disability beneficiaries aimed at encouraging work. For
SSI recipients, these work incentives include such things as earned
income exclusions (which are intended to make work more enticing since
some earned income is excluded from countable income), a deduction for
impairment-related work expenses, and continuation of SSI, which allows
beneficiaries to work and continue receiving benefits until their
countable income exceeds the SSI limit.
[17] GAO, SSA Disability: Return-to-Work Strategies From Other Systems
May Improve Federal Programs, GAO/HEHS-96-133 (Washington, D.C.: July
11, 1996).
[18] Social Security Advisory Board, The Social Security Definition of
Disability, (Washington, D.C.: Oct. 2003).
[19] The labor market may also be a contributing factor in deciding to
refer an individual with an impairment to SSI.
[20] In order for SSA to obtain this information, special processing
runs are required. Based upon recent work, SSA determined that 95
percent of the reported income based on need was from TANF.
[21] Over the last few years, the percentage of the SSI caseload age 18
to 64 that received income assistance based on need prior to becoming
eligible for SSI has remained fairly stable at 25 percent. While this
does not give an accurate estimate of the portion of SSI recipients who
were TANF recipients, it does provide an upper bound.
[22] Cornell University and The Lewin Group, Policy Brief: Transitions
from AFDC to SSI Prior to Welfare Reform, (Ithaca, NY: Feb. 1, 2000).
[23] HHS pointed out that recipients in all states have reached the 5-
year national time limit. However, all states are under the 20 percent
limit on extensions, so there is no reason to expect a sharp increase
in referrals to SSI.
[24] A modified work policy, for example, allows TANF recipients with
impairments to work fewer hours than the federal work requirement
without being sanctioned. Modified work policies are defined by the
state and are not federally approved.
[25] The response rate for the stratum consisting of the 100 counties
with the largest populations was 92 percent. The response rate for our
sample of the remaining U.S. counties was 87 percent.
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