TANF
State Approaches to Screening for Domestic Violence Could Benefit from HHS Guidance Gao ID: GAO-05-701 August 16, 2005The Temporary Assistance for Needy Families (TANF) program introduced specific work requirements and benefit time limits. However, the Family Violence Option (FVO) requires states that adopt the FVO to screen TANF clients for domestic violence and grant waivers from program requirements for clients in domestic violence situations. TANF also allows the use of TANF funds for marriage and responsible fatherhood programs. Given states' broad discretion in implementing the TANF program, including most aspects of the FVO and marriage and responsible fatherhood programs, this report examines (1) how states identify victims of domestic violence among TANF recipients, (2) how states address domestic violence among TANF recipients once they are identified, and (3) the extent to which states spend TANF funds on marriage and responsible fatherhood programs, and how, if at all, these programs are addressing domestic violence.
Forty-eight states have adopted the FVO or a comparable state policy. Most of these states actively screened clients by directly questioning them about domestic violence, whereas five states simply notified clients of domestic violence waivers without making a direct inquiry. Most states provide staff with a screening tool, but the detail and depth of these tools vary. State officials said that staff in local TANF offices often have limited skills in dealing with domestic violence issues, and policies regarding staff training vary. To address this issue, some state TANF offices employ domestic violence specialists. Although HHS has compiled and disseminated information about domestic violence screening, HHS has not issued guidance regarding best practices in domestic violence screening. State TANF programs help clients address domestic violence issues by granting waivers that exempt victims from TANF requirements, and by referring clients for domestic violence services. Most states will waive the TANF program's federal requirements pertaining to work, the 5-year lifetime limit on cash assistance, and the child support requirements. However, the conditions of these waivers vary from state to state. For example, 27 states required that clients participate in domestic violence services. Limited data on the number of domestic violence waivers indicates that a comparatively small portion of TANF recipients obtain such waivers. Most states have used TANF funds for marriage or responsible fatherhood programs or both. Specifically, 15 states reported funding marriage programs and 28 reported funding responsible fatherhood programs. States that provided usable data reported spending about 5 percent or less of their federal TANF budget on these programs. In addition, some states funded these programs through other funding sources or had programs in development. According to research and practitioners in the field, these programs generally do not explicitly address domestic violence, and HHS has stated that all future Healthy Marriage projects should include domestic violence protections.
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.
Director: Team: Phone:GAO-05-701, TANF: State Approaches to Screening for Domestic Violence Could Benefit from HHS Guidance
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
August 2005:
TANF:
State Approaches to Screening for Domestic Violence Could Benefit from
HHS Guidance:
GAO-05-701:
GAO Highlights:
Highlights of GAO-05-701, a report to The Honorable Max Baucus, United
States Senate and the Honorable Pete Stark, House of Representatives.
Why GAO Did This Study:
The Temporary Assistance to Needy Families (TANF) program introduced
specific work requirements and benefit time limits. However, the Family
Violence Option (FVO) requires states that adopt the FVO to screen TANF
clients for domestic violence and grant waivers from program
requirements for clients in domestic violence situations. TANF also
allows the use of TANF funds for the promotion of marriage and
responsible fatherhood. Given states‘ broad discretion in implementing
the TANF program, including most aspects of the FVO and marriage and
fatherhood promotion programs, this report examines (1) how states
identify victims of domestic violence among TANF recipients, (2) how
states address domestic violence among TANF recipients once they are
identified, and (3) the extent to which states spend TANF funds on
marriage and fatherhood promotion programs, and how, if at all, these
programs are addressing domestic violence.
What GAO Found:
Forty eight states have adopted the FVO or a comparable state policy.
Most of these states actively screened clients by directly questioning
them about domestic violence, whereas five states simply notified
clients of domestic violence waivers without making a direct inquiry.
Most states provide staff with a screening tool, but the detail and
depth of these tools vary. State officials said that staff in local
TANF offices often have limited skills in dealing with domestic
violence issues, policies regarding training vary. To address this
problem, some state TANF offices employ domestic violence specialists.
Although HHS has compiled and disseminated information about domestic
violence screening, HHS has not issued guidance or specified minimal
standards for domestic violence screening.
State TANF programs help clients address domestic violence issues by
granting waivers that exempt victims from TANF requirements, and by
referring clients for domestic violence services. Most states will
waive the TANF program‘s federal requirements pertaining to work, the 5-
year lifetime limit on cash assistance, and the child support
requirements. However, the conditions of these waivers vary from state
to state. For example, twenty-seven states required that clients
participate in domestic violence services. Limited data on the number
of domestic violence waivers indicates that a comparatively small
portion of TANF recipients obtain such waivers.
Most states have used TANF funds for marriage or fatherhood promotion
programs or both. Specifically, 15 states reported funding marriage
promotion programs and 28 reported funding fatherhood programs. States
that provided usable data reported spending about five percent or less
of their federal TANF budget on these programs. In addition, some
states funded these programs through other funding sources, or had
programs in development. According to research and practitioners in the
field, these programs generally do not explicitly address domestic
violence, though such programs may do so implicitly through an emphasis
on healthy relationships.
Number of States with Particular Policies Regarding Frequency of
Domestic Violence Training:
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO recommends that the Department of Health and Human Services (1)
examine current domestic violence screening practices of states, and
consider whether certain practices should be specifically encouraged in
agency guidance; and (2) consider establishing minimum screening
standards for states which have adopted the FVO.
www.gao.gov/cgi-bin/getrpt?GAO-05-701.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Cindy M. Fagnoni at (202)
512-7215 or fagnonic@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Most States Have Adopted the Family Violence Option, and States' TANF
Programs Take Differing Approaches to Screening for Domestic Violence:
To Address the Needs of Victims of Domestic Violence, Most States Use
Waivers and Refer Clients to Local Service Providers:
Most States Used Federal TANF Funds for Marriage or Responsible
Fatherhood Programs, but Take Differing Approaches to Addressing
Domestic Violence:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the Department of Health and Human Services:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Number of States That Grant FVO Waivers:
Table 2: Number of States and Evidence Required for a Waiver to Be
Granted:
Figures:
Figure 1: TANF Process:
Figure 2: States' Status Regarding Adoption of the Family Violence
Option or a Comparable Policy:
Figure 3: Number of States Requiring Follow-up Domestic Violence
Screening at Specific Points in the TANF Process:
Figure 4: Number of States with Particular Policies Regarding Frequency
of Domestic Violence Training:
Figure 5: States Using Federal TANF Dollars to Fund Marriage and
Responsible Fatherhood Programs:
Abbreviations:
ACF: Administration for Children & Families:
DVA: Domestic Violence Advocate:
FVO: Family Violence Option:
HHS: Department of Health and Human Services:
PREP: Prevention and Relationship Enhancement Program:
TANF: Temporary Assistance for Needy Families:
United States Government Accountability Office:
Washington, DC 20548:
August 16, 2005:
The Honorable Max Baucus:
United States Senate:
The Honorable Pete Stark:
House of Representatives:
The Temporary Assistance for Needy Families (TANF) program provided
about $17 billion in federal funds to states in fiscal year 2004 for
cash assistance and services to low-income families. This program
includes specific work requirements and a 5-year benefit time limit
that some TANF clients may be unable to meet. Recognizing that not all
clients will be ready to work and that some may need assistance beyond
5 years, the program also offers various exceptions to these
requirements. One exception--the Family Violence Option--requires that
states screen clients for domestic violence and allows them to grant
waivers from program requirements for clients in domestic violence
situations. Adopting the Family Violence Option is not mandatory, and
states that choose not to do so may nonetheless adopt comparable
policies. Although the Department of Health and Human Services (HHS)
oversees the TANF program, states have broad discretion in implementing
the program, including most aspects related to the Family Violence
Option.
Currently, the Congress is considering various changes to the TANF
program, including proposals that would establish matching grants to
promote marriage and discourage divorce, as well as measures
emphasizing responsible fatherhood. While spending TANF funds on these
activities is currently allowed under TANF, the amount states spend on
such program is relatively small compared to their total TANF budgets.
Concerned about these issues, you asked us to examine how state TANF
programs were addressing the issue of domestic violence and how, if at
all, these programs have funded or promoted marriage and fatherhood
efforts. As agreed with your offices, we responded to the following
questions:
* What are states doing to identify victims of domestic violence among
TANF recipients?
* What are states doing to address domestic violence among TANF
recipients once victims have been identified?
* To what extent are state TANF programs spending TANF funds on
marriage and responsible fatherhood programs, and how, if at all, are
these programs addressing domestic violence?
To answer these questions, we conducted a survey of the TANF programs
of the 50 states and the District of Columbia. In this survey, we asked
detailed questions about state policies regarding screening TANF
clients for domestic violence, how states addressed domestic violence
situations once clients have disclosed them, and the extent to which
states have used TANF funds for marriage and responsible fatherhood
programs. To supplement the data obtained through the survey, we
conducted in-depth visits to five states--Colorado, Georgia, New York,
Oklahoma, and Washington. We selected these states because their
practices for screening TANF clients for domestic violence have been in
place for various amounts of time; only one of these states, Oklahoma,
has not adopted the Family Violence Option. We selected one state--
Oklahoma--in part because of its TANF-funded marriage program, and
another state--Georgia--because of its TANF-funded responsible
fatherhood program. During each of these visits, we conducted detailed
discussions with state officials about state policies, obtained
documentation of state policies, and visited two local service delivery
offices in each state to discuss and observe how the policies were
implemented. We visited three states--Illinois, Iowa, and Wisconsin--
while designing our study, and pre-tested the survey with officials in
Maryland, Michigan, and Pennsylvania. Finally, we contacted researchers
and policy analysts knowledgeable about the TANF program, domestic
violence, and marriage and responsible fatherhood programs. We also
reviewed pertinent literature concerning each of these areas. A more
detailed discussion of methodology is contained in appendix I.
We conducted our work in accordance with generally accepted government
auditing standards between May 2004 and May 2005.
Results in Brief:
All but three states have either certified adoption of the Family
Violence Option or have adopted a comparable policy, and the large
majority of these states screen for domestic violence. To meet the
requirements of the Family Violence Option, states have implemented a
range of policies concerning screening techniques, privacy, as well as
domestic violence training requirements for local staff who conduct the
screening. While most states provide staff with a questionnaire or
other screening tool, the detail and depth of these tools varies. Some
in-depth questionnaires probe for various aspects of domestic violence,
while others include a single-line prompt for domestic violence. In
addition to the use of formal tools, state TANF officials and others
emphasized the importance of informal screening, including unstructured
conversations and observation of clients. Five states that have adopted
the Family Violence Option or a comparable policy indicated that they
do not require a specific inquiry about domestic violence, but instead
rely on notifying clients of available domestic violence waivers. Of
the states that have adopted the Family Violence Option or a comparable
policy, most have not established policies regarding the physical
setting of screening or who may be present while a client is screened.
Further, state officials and domestic violence experts indicated that
the ability, skills, and inclination of caseworkers that conduct such
inquiries vary widely. To aid in screening and assessing TANF clients
for domestic violence, some state TANF programs employ domestic
violence specialists. Although HHS has taken some actions to compile
and disseminate information about domestic violence screening, HHS has
not issued guidance regarding best screening practices.
In the states we visited, TANF programs helped clients address domestic
violence issues by providing exemptions from TANF requirements as
needed and by ensuring that clients have access to services. While most
states will grant waivers for work, time limit, and child support
requirements, the specific conditions of these waivers vary from state
to state. For example, some states require recipients to provide
evidence that they are victims of domestic violence before the work
requirement will be waived. Some of the eight states we visited had
limited data on the number of domestic violence waivers issued, and in
these states it appears that only a small percentage of clients who
have disclosed domestic violence were granted waivers. While TANF staff
generally refer victims to domestic violence services--such as
counseling and emergency shelter--these services are typically provided
by other agencies. However, TANF offices in some states offer in-house
services to domestic violence victims. For example, domestic violence
specialists in Washington state can provide ongoing, in-house domestic
violence counseling. In addition, we found, in the states that we
visited, services for domestic violence victims were less available in
rural areas.
Thirty-one states reported using federal TANF funds for marriage or
responsible fatherhood programs, and limited research indicates that
such programs generally do not specifically address domestic violence.
Twenty eight states reported using federal TANF funds for responsible
fatherhood programs, and 15 have done so for marriage programs over the
last 3 years. Of the states that provided usable budget data, no state
reported spending more than about 5 percent of its total federal TANF
expenditures on either marriage or responsible fatherhood programs for
fiscal years 2002 or 2003. However, states may fund marriage or
responsible fatherhood programs with other funding sources or be in the
process of developing programs that may or may not use TANF funds.
According to researchers and practitioners in the field of marriage and
responsible fatherhood, marriage and responsible fatherhood programs do
not typically raise awareness of domestic violence explicitly, but may
do so implicitly through emphasis on healthy and constructive
techniques for conflict resolution without specifically addressing or
identifying domestic violence.
This report contains recommendations that HHS (1) examine domestic
violence screening practices of states in order to identify
particularly promising approaches, and (2) provide states with
information on such practices and encourage their adoption in agency
guidance or memoranda.
Background:
The TANF program was established by the Personal Responsibility and
Work Opportunity Reconciliation Act of 1996 (PRWORA), and was designed
to provide cash assistance to needy families with children, while at
the same time ending the dependence of needy families on government
benefits by promoting job preparation, work, and marriage. As the
responsible federal agency, HHS provides an annual TANF block grant to
each state. In fiscal year 2004, states spent about $26 billion of
federal and state funds to assist low-income families, including
providing monthly cash assistance to about 2 million families as of
June 2004. States have considerable flexibility in administering TANF
programs, and in turn, offices in localities throughout each state are
responsible for interacting with TANF clients and running the day-to-
day aspects of the program.
The TANF program encourages recipients to work, places limits on the
length of time that a family can receive federal cash benefits and
requires that clients cooperate with child support authorities.
Specifically, in accordance with the authorizing legislation, TANF
regulations state that all clients must participate in work activities
as soon as the state determines they are ready to do so, or after 24
months of cash benefits, whichever occurs earlier.[Footnote 1] Further,
clients may not obtain federal TANF cash benefits for more than a total
of 60 months during their lifetime. TANF also requires that all
families with children for whom paternity has not been established or
for whom a child support order needs to be established, cooperate with
child-support enforcement agencies. The TANF program both gives states
incentives to enforce these requirements, as well as the flexibility to
waive these requirements if necessary. For example, states must engage
a certain percentage of their overall and two-parent caseloads in work
activities, or face financial penalty. In practice, states can waive
the work and time limit requirements for clients in a number of ways.
For example, states can provide cash benefits beyond the 5-year time
limit to for up to 20 percent of their caseload. Some states also
provide cash assistance with only state funds when a client has
difficulty meeting federal requirements.
States enroll applicants in the TANF program through a process that is
roughly comparable, though the particulars may vary from state to state
(see fig. 1). A TANF client may meet with a worker who verifies that
the cash assistance program is appropriate for the client's needs and
that the client qualifies for cash assistance. The client is typically
assigned a caseworker who conducts a review of the client's employment
prospects, including the client's education, work history, skills, and
aspects of the client's personal life that may affect their ability to
hold a job. Based on this review, the caseworker develops an individual
responsibility plan that outlines actions that the client is to take in
order to obtain employment and become financially self sufficient. This
plan may require that a client immediately begin a job search or that
the client first take actions to address aspects of the client's life
that pose a barrier to work. After this plan is established, the
caseworker meets with the client periodically, in order to ensure that
the client is making progress toward the goals outlined in the plan.
Some states also require a more in-depth, comprehensive review of the
client's progress at regular intervals or if the client is having
difficulty meeting aspects of the individual responsibility plan.
Figure 1: TANF Process:
[See PDF for image]
[End of figure]
The Family Violence Option Gives States Incentives to Address Domestic
Violence among the Client Population:
The TANF legislation also established a provision known as the Family
Violence Option, under which states commit to screen clients for
domestic violence, and refer those who are identified as domestic
violence victims to domestic violence services. Further, states that
have adopted the Family Violence Option can waive program requirements-
-including those related to work, the 5-year federal time limit, and
cooperation with child support authorities--if compliance would make it
more difficult for clients to escape domestic violence, or would
unfairly penalize domestic violence victims.
States that have adopted the Family Violence Option may also avoid
financial penalties related to the work requirements and the 5-year
time limit, if their failure to meet these requirements is at least
partly attributable to clients who have been granted federally
recognized, good cause domestic violence waivers.[Footnote 2] In order
for the domestic violence waiver to be federally recognized, it must
specify which program requirements are being waived, be granted based
on need as determined by a person trained in domestic violence, and be
accompanied by a services plan. States may report federally recognized
good cause domestic violence waivers to HHS, and HHS requires that such
waivers not be reported unless they meet the regulatory definition. As
with other aspects of the TANF program, states have broad flexibility
regarding the detailed implementation of the Family Violence Option.
Studies Indicated Domestic Violence Is Prevalent among Low-Income Women
and Can Be a Barrier to Employment:
Domestic violence affects a substantial percentage of low-income women,
according to existing research. Further, research shows that it can, in
some cases, pose a barrier to work and financial independence. In 1998,
we reported that studies indicated that between 15 percent to 56
percent of welfare recipients are, or have been, victims of domestic
violence.[Footnote 3] Since that time, additional studies with similar
findings have been published. For example, a 2001 report summarized the
prevalence of domestic violence among a random sample of women in the
TANF caseload of an urban county in Michigan.[Footnote 4] This study
found that about 51 percent of the women had been severely abused at
some time in their life, and about 15 percent had been severely abused
by a partner at least once in the preceding year.[Footnote 5] Further,
61 percent reported being threatened with violence or other retribution
at some point in their lifetime, and 24 percent reported such an
experience had occurred in the preceding 12 months.
Past research has also revealed that domestic violence can, in some
cases, be a barrier to work and financial independence. In our 1998
report, we reported that various studies found that women who were or
had been victims of domestic violence were employed at about the same
rates as women who reported never having been abused. However, we also
cited one study that found abused women experienced higher job turnover
and more spells of unemployment than women who had never been abused.
Further, our 1998 report, as well as other research, has outlined how
domestic violence can impede successful employment for some women. For
example, several studies have shown that abusers may be threatened by
any steps a woman takes toward financial independence, and may thwart a
job search or employment by interfering with transportation to work, or
by making harassing phone calls to a woman while she is in the
workplace.
Prompting Disclosure of Domestic Violence Can Be Difficult:
State TANF programs face significant challenges addressing domestic
violence, in part because it can be especially difficult to detect.
Many victims of domestic violence may be reluctant to disclose such a
personal and potentially humiliating aspect of their life. Researchers
in the field of domestic violence and state officials stated that
domestic violence victims may be unwilling to disclose domestic
violence out of shame and embarrassment. Victims may also fear
retribution by the abuser.
TANF clients may be particularly reluctant to disclose abuse in the
TANF program setting. Advocates for victims of domestic violence
explained that TANF clients often see TANF staff as government
officials who cannot be trusted to keep the disclosure of domestic
violence confidential. Further, some clients may fear that any
disclosure of domestic violence to government officials could result in
the loss of custody over their children. As a result, disclosure may be
thwarted, at least until a trusting working relationship can be
developed. Caseworkers may also lack specific skills that facilitate
disclosure. For example, according to some experts, caseworkers may
lack empathy for domestic violence victims. Additionally, given the
heavy workload that some caseworkers face--in busy urban areas, some
have over 100 clients--they may not effectively screen for domestic
violence. According to some researchers, some caseworkers may see
addressing domestic violence as conflicting with the overall goal of
ensuring that clients become employed. Finally, HHS officials told us
that the physical setting of domestic violence screening--which in many
offices can occur in open cubicles or public spaces--may not facilitate
disclosure of domestic violence, as clients may fear being overheard.
The difficulty of identifying domestic violence is compounded by a lack
of consensus about the best techniques for screening clients. Some
state officials and researchers reported the benefit of screening tools
composed of multiple questions asking about various aspects of domestic
violence--such as physical abuse, verbal abuse, or stalking. They
believe such an approach helps clients who may not think of themselves
as domestic violence victims and yet may respond affirmatively to a
question about a specific behavior. On the other hand, some research
has found that detailed questions about specific aspects of domestic
violence may be considered overly intrusive, which can put clients on
the defensive and make disclosure less likely. A 1999 study on the
state TANF programs' efforts to assist victims of domestic violence
found that screening instruments should avoid intrusive questions about
the specific actions of an abuser, as such questions can be too
personal or shaming.[Footnote 6]
Federal TANF Funds May Be Used to Fund Marriage and Responsible
Fatherhood Programs:
Because the TANF program includes a variety of goals, federal TANF
funds can be used for purposes other than cash assistance to needy
families. Because one of the purposes of the TANF program is to
encourage the formation and maintenance of two-parent families, some
states have opted to use TANF funds for marriage programs. Such
programs attempt to achieve these goals through various measures, such
as education. Similarly, some states have opted to use TANF funds for
responsible fatherhood programs. These programs are designed to
encourage the active and responsible involvement of non-custodial
fathers in the lives of their children.
State officials, practitioners, and the domestic violence services
community have stressed the importance of involving the domestic
violence services community in development and implementation of
marriage and responsible fatherhood programs. States that have used
this approach have indicated that the involvement of the domestic
violence services community was necessary to ensure that marriage and
responsible fatherhood programs address individual safety. HHS
Administration for Children and Families has echoed this sentiment in
an information memorandum that strongly recommends that states consult
with experts in domestic violence or with relevant community domestic
violence coalitions as they design marriage initiatives. Further, HHS
has stated that its Healthy Marriage Initiative--which seeks to promote
healthy marriages though activities such as marriage and pre-marriage
education--requires grantees to develop domestic violence protocols
that address screening for domestic violence and referrals to local
domestic violence services.
Most States Have Adopted the Family Violence Option, and States' TANF
Programs Take Differing Approaches to Screening for Domestic Violence:
While the large majority of states have adopted the Family Violence
Option or a comparable policy, states take a broad range of approaches
to identifying domestic violence. Most states require that clients be
formally screened for domestic violence, though techniques can vary
significantly from state to state. A few states do not actively screen,
but require that clients be notified of available domestic violence
waivers. Comparatively few states have policies regarding the privacy
of screening, although officials in most states we contacted
acknowledged its importance. Finally, most states reported that
domestic violence screening is performed by staff that may have little
or no training in recognizing and discussing domestic violence. To
address this issue, some states have employed domestic violence
specialists.
Most States Have Adopted the Family Violence Option or an Equivalent
Policy:
Forty states have certified adoption of the Family Violence Option (see
fig. 2). Eight states reported that they had not certified the Family
Violence Option, but had adopted similar policies. Each of these states
reported that they make some effort to screen clients for domestic
violence, refer clients to domestic violence services, and offer
waivers of certain TANF program requirements.
Figure 2: States' Status Regarding Adoption of the Family Violence
Option or a Comparable Policy:
[See PDF for image]
[End of figure]
Officials in only three states--Maine, Oklahoma, and Ohio--reported
that they had not adopted the Family Violence Option or a comparable
policy. According to Oklahoma officials, adoption of the Family
Violence Option was not seen as necessary because the state already
required some of the actions called for by the Family Violence Option,
though the provisions may not be precisely comparable.
States Take a Broad Range of Approaches to Screening for Domestic
Violence:
States screen for domestic violence using a broad range of strategies
and techniques.[Footnote 7] Some require that staff use formal
screening tools at specific points in the TANF process. Such tools vary
in detail and depth of inquiry. Five states notify clients of domestic
violence waivers, but do not require that staff specifically inquire
about domestic violence. In addition, state TANF program staff can at
any time also use informal domestic violence screening techniques, such
as observing a client's demeanor or interaction with their partner.
Formal Screening at Specified Times:
Officials in the large majority of states (43) reported that their
state actively inquires about domestic violence, and most of these
states rely on a mandatory screening tool. Specifically, 26 states
responding to our survey reported that they provide local offices with
a specific screening tool that must be used, while another 4 said the
tool they provide is optional. Eight states reported that they provide
staff with guidance such as regulations, staff manuals, or memoranda,
in lieu of a specific screening tool.
We learned during our visits to states that the breadth and technique
of the screening tools vary considerably. For example, the state of
Washington uses a nine-question, electronic screening tool that prompts
TANF staff to inquire about various aspects of domestic violence,
including queries about threats, angry outbursts or controlling
behavior by the client's partner. This screening tool is administered
by case managers, who generally go through these questions verbatim,
and record the client's responses in a data base. In contrast, the
state of Iowa uses a tool designed to be self-administered by the
client that makes a single query about sexual or physical violence in a
table that covers a variety of health related issues. This tool does
not ask specific or probing questions about domestic violence, but
prompts the client to enter a checkmark if physical or sexual violence
is an issue for any member of the client's family.
The large majority of states that require formal screening require it
early in the TANF process, with follow-up screenings at certain points.
As figure 3 indicates, subsequent screenings occur either at regular
intervals, or when it becomes apparent that a client is having
difficulty meeting program requirements. For example, our survey data
show that 24 states screen during a TANF eligibility review that in
some states, such as New York, can take place every 6 months. Many
states also screen when the client exhibits difficulty in meeting TANF
program goals or requirements. For example, 20 states screen when a
client fails to meet the conditions of cash assistance. State officials
told us that such follow-up screenings are important because the client
may be reluctant to disclose domestic violence initially or because it
may emerge as a problem after entry into the TANF program.
Figure 3: Number of States Requiring Follow-up Domestic Violence
Screening at Specific Points in the TANF Process:
[See PDF for image]
Note: States could report more than one point in the process;
therefore, numbers do not total to 48.
[End of figure]
Notification Only:
Five states that have adopted the Family Violence Option or a
comparable policy reported that they do not actively screen TANF
clients for domestic violence. These states indicated that they have no
screening requirements beyond informing clients about available
domestic violence waivers. An official of one such state--Pennsylvania-
-referred to this process as "universal notification" and explained
that the policy was developed in consultation with the state coalition
that advocates for domestic violence victims. The policy was developed
in the belief that it is best not to probe clients about domestic
violence and risk putting them in an uncomfortable situation, but to
spell out the program flexibilities that exist for domestic violence
victims. This policy allows domestic violence victims to disclose, if
necessary, at a time of their choosing.
Informal Screening throughout TANF Process:
Staff in local TANF offices can also conduct "informal" screening
through casually conversing with or observing clients. For example, a
client's demeanor or physical appearance may provide evidence of
domestic violence. Several officials told us that such informal
screening can occur at any time in the TANF process and is especially
important because a client may not be ready to disclose a domestic
violence situation at the time of formal screening, and because a
domestic violence situation may arise after the formal screening. For
example, caseworkers and other officials in Wisconsin told us that
disclosure of domestic violence often occurred in the course of
informal discussions and consultations between clients and staff.
Fewer Than Half of States Reported Having Policies Regarding Privacy
for Screening:
Sixteen states reported that they have established policies regarding
the physical setting in which screenings occur. For example, Colorado
officials explained that, while screening will often begin in open
cubicles, the state's policy is that the meeting will be moved to a
private office if a situation of domestic violence has been identified.
In our visits to TANF offices in seven other states, we learned that
screening often occurs in the course of much broader discussions that
occur in open cubicles near staff and other clients.[Footnote 8] During
our site visits, several state officials told us that although private,
confidential settings are important, many local offices would face
constraints in providing such settings. For example, an official in one
state said that the degree of privacy available varies considerably
from office to office, and the setting in some offices dictates that
screening take place at desks near a lobby full of clients. While this
is not ideal, the local offices must work within the constraints of the
facilities in which they are located.
Ten states said that they have policies regarding individuals who may
be present during screening. For example, officials in the state of
Washington told us that, if a couple comes in to the TANF office to
apply for benefits together, it is state policy that they be separated
before domestic violence will be discussed. According to the Washington
"Work First" handbook, which provides written guidance for caseworkers
and other staff in the state's TANF program, caseworkers are not to ask
about family violence in the presence of the partner, because this may
endanger the client. Similarly, the screening tool used in Illinois
advises caseworkers to ask questions regarding domestic violence at a
later time if the client's partner is present. We also found that,
although some states do not have policies in this regard, some
caseworkers in these states nonetheless ensure a client is alone for
domestic violence screening. A local office official in New York, which
does not have a privacy policy, said that before questions about
domestic violence are asked, they will separate couples with a
contrived reason, if necessary. For example, they may tell the partner
that he must meet with another staff member about another topic, such
as his job history.
In contrast, most states have no explicit policy about who can be
present during a client's domestic violence screening. For example, an
official at a local office in Iowa said that the initial meeting with
the caseworker takes place with both partners present because it is
important to see how a couple interacts. If the caseworker suspects
domestic violence, they may try to separate the couple for a subsequent
discussion. Other states explained that they encourage a middle
approach, explicitly relying on the judgment of the caseworker.
Similarly, in New York, state policy directs that the domestic violence
screening form can be mentioned with both partners present, but that it
not be addressed further if the clients are not interested. However,
the policy also advises that caseworkers may need to be creative in
finding a way to mention the domestic violence screening form again in
a private setting.
Screening Is Typically Performed by Caseworkers, but Some States also
Use Domestic Violence Specialists:
Forty-five states reported that caseworkers or intake workers are the
staff that typically conduct domestic violence screening, a fact
acknowledged by officials during our site visits.[Footnote 9] As figure
4 indicates, most state policies require little training for these
staff. Twenty states indicated that the state either had no policy
regarding domestic violence-related training, or may provide training
only once in caseworker's career. Another 25 states require training
once in a staff members' career and make additional training optional.
Figure 4: Number of States with Particular Policies Regarding Frequency
of Domestic Violence Training:
[See PDF for image]
[End of figure]
Officials in each state we visited told us that the skills, abilities,
and inclinations of staff to conduct domestic violence screening vary
considerably. For example, one state official told us that the
personalities and style of caseworkers range across the board. This
official said that many staff are technical people who have spent their
careers stressing program qualifications, and addressing domestic
violence and other "soft" issues is difficult adjustment. An official
of another state TANF program said that even with the best of best
training and screening policies, screening effectiveness is dependent
on the effectiveness of individual caseworkers, and some caseworkers
may simply skim the screening questions and not ask the full range.
These comments were reinforced during our observations of domestic
violence screening in several local TANF offices. At one office, we
observed one caseworker who stressed certain aspects of the TANF
experience, such as the need to obtain employment or attend training
services, but gave very peremptory attention to other issues, such as
domestic violence and mental health. At another office, we witnessed
screening performed by a social worker, who paused at length over these
issues, and sensitively asked follow-up questions regarding the
client's home life, and took the initiative to gently and patiently
describe a local organization that could provide alternative living
arrangements, if this were necessary.
In order to supplement the skills of the caseworkers, three of the
states we visited--Georgia, New York, and Washington--employed domestic
violence specialists to conduct in-depth screening and assessment after
a client disclosed that domestic violence was an issue.[Footnote 10]
This practice is implemented statewide in Georgia and New York, and has
been established for almost all of the TANF offices in Washington
state. In all three states, the domestic violence specialist serves to
"backup" the screening conducted by the regular caseworker. For
example, New York's policy requires that a client be referred to a
specialist--known as a domestic violence liaison--as soon as a client
discloses that domestic violence is an issue. State officials told us
that the meeting with the specialist is scheduled as soon as possible
and all further inquiry regarding domestic violence is left to the
domestic violence liaison. The specialist then conducts a more in-depth
inquiry and informs clients about options for protective services and
other assistance.
State officials told us that domestic violence specialists can play an
important role in addressing the needs of domestic violence victims and
are important given the limited skills of many caseworkers in dealing
with domestic violence. Officials in Washington, for example, said that
the presence of a domestic violence specialist increases the likelihood
that a domestic violence victim will attend counseling or other
services to address the problem. A caseworker can immediately walk a
client over to the desk of the domestic violence specialist, who then
conducts an in-depth assessment, provides some degree of counseling,
and makes referrals to other agencies for ongoing services. They
explained that if the domestic violence specialist were not there, they
believe that many clients would ignore the referrals to outside
agencies, and the domestic violence issue festers. During one of our
site visits, we learned firsthand of the importance of effective
interpersonal skills in domestic violence screening. We interviewed an
employee of a local TANF office who was a former TANF recipient and a
domestic violence victim. She explained that, when she was screened for
domestic violence, she was in a desperate situation fleeing from her
abuser and needed assistance right away. Nonetheless, the attitude of
the screening staff was so perfunctory and indifferent that, had she
not immediately been routed to a domestic violence specialist, she said
she probably would not have returned to that office. The former victim
further noted that many caseworkers are overwhelmed by other demands,
and felt that the caseworker she dealt with was not equipped to handle
domestic violence issues.
State officials also told us that domestic violence specialists can
enhance the ability of other office staff in dealing with clients'
domestic violence issues. In Washington, caseworkers at a local TANF
office stated that an onsite domestic violence specialist serves as an
important source of technical assistance for caseworkers. For example,
the specialist has provided training for staff, and made them aware of
the "red flags" that may indicate domestic violence is an issue. The
officials repeatedly praised the domestic violence specialist for this
"cultural" impact on this TANF office.
HHS Has Taken Some Steps to Provide States with Guidance on Domestic
Violence Screening:
HHS has, since the establishment of the TANF program, taken a number of
measures to identify and disseminate information on what states are
doing to screen for domestic violence. For example, HHS funded a 1999
report that summarized how states had implemented the Family Violence
Option, including the basic techniques each state used to screen for
domestic violence, and a number of detailed examples of how domestic
violence screening was conducted at specific locations. [Footnote 11]
Further, an HHS-funded report published in 2000 provided in-depth
descriptions how 7 counties in different states identified domestic
violence victims and assisted those who disclosed.[Footnote 12] These
reports also made observations regarding the benefits and drawbacks of
various screening practices. For example, the report published in 2000
noted the usefulness of a more extensive domestic violence screening
tool--covering verbal, emotional, and sexual abuse--that could be used
once a worker has some indication that a client may have domestic
violence issues.
Although HHS has funded research on state TANF program approaches to
domestic violence screening, HHS officials also told us that the agency
has not provided state TANF programs with specific advice in the form
of policy guidance or memoranda regarding best practices in domestic
violence screening. Further, it has not specified minimal acceptable
standards for domestic violence screening. Agency officials explained
that the legislation establishing the TANF program gives states
considerable flexibility in implementing the Family Violence Option,
and does not provide HHS with authority to require particular
approaches to screening.
To Address the Needs of Victims of Domestic Violence, Most States Use
Waivers and Refer Clients to Local Service Providers:
State TANF programs play an important role by offering victims of
domestic violence waivers from TANF program requirements and helping
them obtain needed services. Although most states will waive certain
TANF requirements, the provisions of these waivers vary from state to
state. Further, limited data from two states that we visited indicates
that a comparatively small portion of all TANF recipients obtain
domestic violence waivers. Although all state TANF offices rely on
local service agencies to provide domestic violence services, some also
provide in-house domestic violence services and most actively monitor
clients for participation in services. While the full range of services
is generally available to victims in urban areas, services in rural
areas are generally less available.
Most States Waive Requirements for Work, Time Limits, and Child
Support:
Of the 48 states that adopted the Family Violence Option or an
equivalent policy, the majority will waive the requirement that TANF
clients work or engage in work-related activities, the 5-year federal
lifetime limit on TANF benefits, and cooperation with the child support
authorities to collect child support, as shown in table 1.
Table 1: Number of States That Grant FVO Waivers:
Federal or state TANF requirement: Work requirement;
Number of states granting waivers: 43.
Federal or state TANF requirement: Time limit for cash assistance;
Number of states granting waivers: 43.
Federal or state TANF requirement: Cooperation with child support
authorities;
Number of states granting waivers: 47.
Federal or state TANF requirement: Required aspects of individual
personal plan;
Number of states granting waivers: 38.
Federal or state TANF requirement: Other;
Number of states granting waivers: 6.
Source: GAO survey.
[End of table]
Some states will waive other requirements as well. Thirty-eight states
indicated that they will waive specific requirements included in a
client's individual responsibility plan, which is intended to lead to
work and financial independence. For example, an Illinois official told
us that the individual plan of many clients requires them to meet with
their caseworker in order to continue receiving benefits. If a client
misses a meeting and can demonstrate that the failure to make the
appointment was due to domestic violence, the requirement can be
temporarily waived and cash benefits will not be interrupted. Another
six states reported that they will, if necessary, waive other program
requirements in the event that domestic violence makes them difficult
to meet. For example, an Oregon official reported that they will waive
certain financial eligibility requirements in the event of domestic
violence. For example, if a domestic violence victim must use part of
her income to flee an abuser and pay for temporary housing, this
portion of the income will be temporarily excluded from eligibility and
benefit calculations.
Conditions for Receiving Waivers Varied by State:
Federal TANF regulations allow states considerable flexibility
regarding the conditions for clients to obtain good cause domestic
violence waivers. For example, some states reported that they required
recipients to provide evidence of domestic violence before granting a
waiver, while others reported that the client's word was sufficient. As
table 2 indicates, 25 states do not require evidence beyond a client's
statement in order to grant a waiver from work requirements. For
example, a Washington official said that additional evidence before
granting a waiver was not needed because officials expect clients to
participate in domestic violence services, which clients would not want
to do unless such services are needed. In contrast, Illinois requires
that recipients provide additional documentation such as a written
statement from a third party, a police report, or documentation from a
domestic or sexual violence program.
Table 2: Number of States and Evidence Required for a Waiver to Be
Granted:
Domestic violence waiver: Work requirement;
Requires only a client statement: 10;
Requests but does not require documentation in addition to the client
statement: 15;
Requires documentation in addition to the client statement: 18;
Total states: 43.
Domestic violence waiver: Time limit for cash assistance;
Requires only a client statement: 8;
Requests but does not require documentation in addition to the client
statement: 11;
Requires documentation in addition to the client statement: 24;
Total states: 43.
Domestic violence waiver: Cooperation with child support authorities;
Requires only a client statement: 5;
Requests but does not require documentation in addition to the client
statement: 18;
Requires documentation in addition to the client statement: 23;
Total states: 46.
Source: GAO survey.
[End of table]
Twenty-seven states reported that they also require domestic violence
victims to participate in domestic violence services in order to waive
program requirements. For example, officials in Iowa and Washington
said that clients must demonstrate that they are making an effort to
address the domestic violence by attending counseling or other
services. In contrast, an Illinois official explained that the state
also requires that caseworkers provide waiver recipients with
information about available domestic violence services and encourage
them to attend; however, they cannot require their participation.
Officials said that some clients do not want to participate in services
provided through an agency but prefer to use an informal network for
support and assistance such as family, friends, or church ministers.
Some states may also tailor waivers to fit a client's particular
circumstances and will help clients maximize compliance with program
requirements. For example, New York offers "partial waivers," which
state officials believe help to ensure a victim's safety while still
participating in program activities. For example, a partial waiver
could be granted to a client who is taking job readiness classes but
not actively searching for a job because of safety concerns. In such a
case, the partial waiver would allow the client to fulfill part of the
work requirement without interrupting cash benefits. Similarly, a
partial child support waiver would be granted if it would put the
client in danger to appear in court to pursue child support (this is in
contrast to a full child support waiver in which a client would not be
required to pursue child support at all if doing so would threaten
their safety).
Limited Data Indicates That a Small Portion of the TANF Population Use
Domestic Violence Waivers:
Reliable national data on the number of domestic violence waivers
issued by the states does not exist, according to an HHS official
responsible for tracking state data reporting.[Footnote 13] During our
site visits, some of the eight states were able to provide data on
domestic violence waivers from the work requirement. For example,
Georgia officials reported that from July 2003 through June 2004, local
TANF offices in Georgia granted 925 waivers from the work requirement,
which was less than 2 percent of the 52,515 clients who were receiving
TANF benefits during that time. In contrast, Washington officials
reported that from October 2003 through September 2004, local TANF
offices in Washington granted 5,162 waivers from the work requirement,
more than 9 percent of the 52,515 clients receiving TANF benefits.
The number of waivers granted in some states may be relatively small
because clients may opt out of TANF requirements in other ways or
because domestic violence victims can comply despite their situation.
For example, some domestic violence victims may face multiple barriers
and could obtain a state "hardship" waiver that will extend the 5-year
time limit without coding it as a domestic violence waiver. Officials
in most states that we visited said that many victims prefer to work
because they consider financial independence as the best way out of an
abusive situation. For example, a caseworker in Colorado who works
exclusively with domestic violence victims said that she rarely grants
a waiver for the work requirement because most clients want to work,
and even if they only work part-time, the participation in domestic
violence services is included in the work plan as a work activity. She
said that she only grants a waiver from work requirements to
individuals that are in such a critical situation that they can only
deal with their domestic violence issues. Officials in New York also
said that most domestic violence victims prefer to work but that many
also participate in the domestic violence services that are offered.
Clients May Be Referred to Outside Service Providers or in Some Cases
Obtain In-House Services, but Degree of Monitoring and Service
Availability Varies:
While all states reported that clients are referred to separate local
agencies for domestic violence services such as counseling, some
offices also offer such services in-house. During our site visits, some
states reported that the availability of services varied, with some
states reporting that domestic violence services were less available in
rural areas. Further, some states appear to be more active than others
in monitoring the progress of clients who obtain domestic violence
services.
Thirty-eight states reported that their local TANF offices relied
exclusively on separate local agencies to provide services to their
domestic violence clients. These services generally include counseling,
crisis intervention, safety planning, support groups, legal and court
advocacy, and emergency shelter. In contrast, 13 states reported that
they provided some domestic violence services on-site in the local TANF
office in addition to using separate local agencies. For example,
officials in Washington said that most of the state's local TANF
offices have a Domestic Violence Advocate (DVA) on-site who works
exclusively with domestic violence victims providing services such as
safety planning and counseling. The benefit of having this service
located on-site is that it gives the victim immediate access to
services, and increases the chances that the clients will follow
through with services. Also, because the DVA is located at the TANF
office, the client may receive services without the knowledge of the
abuser. For other domestic violence services, such as shelter and legal
advocacy, clients were referred to a separate local service provider.
The kind of services offered to domestic violence victims is determined
by their need and the availability of such services in the community.
However, among the states that we visited, we found that the kinds of
services available varied--urban areas generally provided a full range
of services, while services in rural areas were less available. For
example, a Colorado official cited one area of the state that had only
one shelter serving five counties and officials in one rural county
expressed a need for more counseling services. New York officials also
said that services were less available in rural areas, but that it was
simply not cost-effective to have a full range of services in sparsely
populated areas. In addition, officials in several states that we
visited said that transportation is less available in the rural areas
and access to services can be difficult for victims living many miles
from the nearest provider. For example, officials in a rural office in
Oklahoma said that the shelter serving their clients was 26 miles away
and that caseworkers often have to call the local police to transport
domestic violence victims that are unable to transport themselves.
While most states required that local TANF offices monitor client
participation and progress when referred for these services, some
states more actively monitor a client's progress. In responding to our
survey, 29 states reported that, in some or all cases, clients referred
to a domestic violence service provider must be monitored for progress.
For example, Washington officials said that communication with
providers is required monthly to monitor clients' progress so that they
can determine when they are able to move into work activities that will
allow them to become self-sufficient. In contrast, 16 states indicated
that they had no such policy. For example, New York officials said that
they discourage communication between the TANF office and the domestic
violence service agency. An official explained that the providers, who
operate independently, want to maintain confidentiality to ensure the
victim's safety.
Most States Used Federal TANF Funds for Marriage or Responsible
Fatherhood Programs, but Take Differing Approaches to Addressing
Domestic Violence:
Thirty-one states reported using federal TANF funds for marriage or
responsible fatherhood programs, and limited research indicates that
such programs generally do not specifically address domestic violence.
States that reported funding marriage programs most frequently
supported adult and youth marriage and education programs. States that
reported funding responsible fatherhood programs most frequently
supported programs that deliver services to non-custodial fathers to
enhance ability to meet parental obligations. Data show that a
relatively small portion of TANF funds were used for marriage programs
in 7 states and responsible fatherhood programs in 21 states. While
research indicates that these programs do not explicitly address the
issue of domestic violence, they may nonetheless do so by emphasizing
better communications and healthy relationships, and constructive
techniques for dispute resolution. Debate exists as to the best
approaches for marriage and responsible fatherhood programs to address
domestic violence.
Most States Used Federal TANF Dollars to Fund Marriage or Responsible
Fatherhood Programs in the Last 3 Years:
Thirty-one states reported using TANF funds for marriage programs,
responsible fatherhood programs, or both in the last 3 years.
Specifically, 15 states reported funding marriage programs, and 28
states reported funding responsible fatherhood programs from 2002 to
2004. Of these, 12 states reported funding both marriage and
responsible fatherhood programs. See figure 5.
Figure 5: States Using Federal TANF Dollars to Fund Marriage and
Responsible Fatherhood Programs:
[See PDF for image]
[End of figure]
States that funded marriage and responsible fatherhood programs with
TANF dollars in the last 3 years reported supporting various types of
efforts. Most frequently, states that funded marriage programs with
TANF dollars in the last 3 years reported funding adult and youth
relationship and marriage education programs. Such programs are
generally based on a standard curriculum, presented in a classroom-
style format, and attempt to change attitudes and dispel myths about
marriage and to teach relationship skills. For example, the Oklahoma
Marriage Initiative works to improve relationships through services
that provide skill-based relationship training. Workshop leaders are
trained to teach Prevention and Relationship Enhancement Program (PREP)
courses, which are designed to prevent divorce and enhance marriage, in
their communities and organizations across the states. Most workshops
are voluntary and participants learn about the program through the
Internet, referrals, word of mouth, local advertising, and churches.
One local TANF office required participants to attend PREP or PREP-like
courses. Similarly, youth marriage education programs can be taught
using one of several nationally recognized curricula for building
successful relationships and marriages. Several states also reported
funding activities such as media campaigns and conferences relating to
marriage.
States that supported responsible fatherhood programs using TANF
dollars in the last 3 years typically funded collaborative fatherhood
programs between government and private agencies or funded direct
services to non-custodial fathers to enhance their ability to meet
parental obligations. We visited one state--Georgia--that has
fatherhood programs in both these categories. These programs were
initiated by the Director of the Division of Family and Children
Services, who believed some fathers were not "deadbeats but dead broke"
and appointed a special consultant to develop fatherhood programs.
Georgia's Fatherhood Program is a partnership with several state
agencies and other organizations. The program's mission is to assist
non-custodial parents in training and educational opportunities leading
to employment paying above minimum wage and encouraging increased
involvement in the lives of their children. The program contracts with
the Georgia Department of Technical and Adult Education to provide job
skills and placements for unemployed or underemployed non-custodial
parents. Georgia's other responsible fatherhood program, the Child
Access and Visitation Program, is designed to assist non-custodial
parents with improving visitation with their children and addressing
the children's relationship with the custodial parent. This program is
run through a contract with an outside service provider and funded
through a grant from HHS' Administration for Children and Families.
Two states that reported not using federal TANF funds for marriage
programs told us that they address factors that cause stress in
marriages without implementing marriage programs. For example, Illinois
chose to emphasize direct support for low-income families by providing
material support, such as childcare, transportation, and cash
assistance rather than implementing marriage programs. An Illinois
official also noted that a key variable in successfully promoting
marriage was increasing the economic status of the couple so that they
feel marriage is a viable alternative. New Jersey also reported in its
survey that the state funded programs that address factors that can
cause stress in marriages, as well as efforts that indirectly promote
and preserve marriage.
Limited Data Suggest States Use Small Amounts of Federal TANF Funds for
Marriage and Responsible Fatherhood Programs and Some Rely on Other
Funding Sources:
States that reported using federal TANF funds for marriage or
responsible fatherhood programs did not report using a large proportion
of their total federal TANF budget for this purpose. Specifically, no
state providing usable data reported spending more than about 5 percent
of its total federal TANF expenditures on marriage or responsible
fatherhood programs for 2002 or 2003.[Footnote 14] While according to
HHS officials more complete national data does not exist, a
Congressional Research Service report also found that states were not
spending large portions of TANF funds on marriage programs.[Footnote
15] Similarly, according to another report, states spend relatively
small amounts of TANF funds on responsible fatherhood
programs.[Footnote 16]
Some states reported that they fund marriage and responsible fatherhood
programs with funding sources other than federal TANF dollars. Five
states in survey commentary[Footnote 17] and one state in a site visit
indicated that that they fund marriage programs with monies other than
federal TANF funds. [Footnote 18] Two additional states indicated that
they currently fund programs with distinct marriage components, but
they did not consider them marriage programs per se.[Footnote 19] A
Georgia official told us that the state will soon be implementing a
marriage program similar to the Oklahoma Marriage Initiative. The
program will use an ACF grant under the authority of section 1115 of
the Social Security Act and private funding rather than federal TANF
funds. Furthermore, since state fiscal year 2004, eight states
indicated in survey responses or during our site visit that they are
implementing or developing new marriage programs that may or may not
use federal TANF funds.[Footnote 20]
Similarly, some states are supporting responsible fatherhood programs
through other means. For example, some states also support responsible
fatherhood programs with monies other than federal TANF funds.[Footnote
21] The state of Washington collaborated with Alaska and Oregon using
non-TANF funds to create public service videos to encourage fathers to
be involved with their children. One national fatherhood report also
indicated that responsible fatherhood programs remain largely funded
through foundations.
Generally, Marriage and Fatherhood Programs Do Not Explicitly Address
Domestic Violence:
According to research and practitioners in the field of marriage and
responsible fatherhood, domestic violence is generally not explicitly
included as a component of marriage and responsible fatherhood
programs. Recent research funded by HHS found that many of the widely
available marriage education programs were designed and tested with
middle income, college-educated couples, and do not assess for or
address a variety of issues--including domestic violence--that place
considerable stress on couple relationships.[Footnote 22] A researcher
in the field of marriage programs stated that such programs do not
address domestic violence because marriage education is an emerging
field and developers did not initially see the need for discussion of
domestic violence within these programs. Similarly, two representatives
of national fatherhood advocacy organizations indicated that most
responsible fatherhood programs have not addressed domestic violence or
lack the resources to deal with domestic violence. Furthermore, one
found that this was because practitioners in responsible fatherhood
programs usually do not have expertise in domestic violence issues.
Nonetheless, some marriage and responsible fatherhood programs do
address domestic violence implicitly through an emphasis on healthy,
egalitarian relationships and constructive conflict resolution. For
example, the Oklahoma Marriage Initiative program focuses on
communication and conflict resolution between couples without an
explicit discussion of domestic violence. The Oklahoma program covers
danger signs of marital problems, such as negative communication habits
that can escalate into anger and frustration, a pattern of constantly
putting down or disregarding the thoughts and feelings of a partner, or
a habit of negative interpretations of the actions and comments of a
partner.
There is a range of opinions on how marriage and responsible fatherhood
programs should address domestic violence. Some state officials
indicated that marriage programs that address domestic violence through
an emphasis on healthy relationships and conflict resolution alone can
reduce and help prevent violence in marriages by reducing the stress
that often leads to violence. For example, New York indicated that
programs designed to encourage healthy relationships will have the
positive benefit of reducing the likelihood of physical violence and
emotional abuse. Some practitioners have noted the need to address
domestic violence explicitly and have begun to take steps toward
explicitly including domestic violence in marriage programs and have
sought program advice from local domestic violence coalitions. For
example, while the Oklahoma Marriage Initiative does not explicitly
cover domestic violence in its marriage curriculum, it recently created
a handout to assist clients in identifying domestic violence and where
to obtain help.
Nonetheless, other evidence suggests that domestic violence should be
explicitly addressed in marriage and responsible fatherhood programs.
The HHS-funded research on marriage and responsible fatherhood programs
found, for example, that many unmarried parents face a variety of
challenges that may impede their ability to form a stable marriage. It
further states that assessment of barriers--in particular domestic
violence--could point out the need for referral to other kinds of
appropriate help. State officials and advocates told us that addressing
domestic violence specifically is important to ensuring that programs
address the dangers of domestic violence. Further, HHS has stated that
all future projects funded by its Healthy Marriage Initiative--which
seeks to promote healthy marriages through activities such as marriage
and pre-marriage education--are to fully incorporate domestic violence
protections, including project specific policies regarding screening
for domestic violence.
Conclusions:
The TANF program emphasizes that recipients move toward economic self-
sufficiency, but also recognizes that some recipients may face barriers
that may make it difficult or impossible for them to work immediately,
or meet specific timelines for attaining self-sufficiency. One of these
provisions--the Family Violence Option--requires states that adopt it
to screen clients for domestic violence, and offer other assistance to
those who need it in overcoming this potential barrier to self-
sufficiency. The Family Violence Option offers states considerable
flexibility in how they screen for domestic violence, and states have
taken a range of approaches to doing so. While this flexibility is
consistent with the overall TANF emphasis on allowing states latitude
in designing and administering their programs, guidance on effective
approaches to domestic violence screening could provide states with
additional information on promising screening practices.
Specifically, there may be certain practices that could benefit all
state programs, assuming they are affordable and practicable. For
example, in the states we visited, domestic violence specialists appear
to offer multiple benefits to local TANF offices, including offering
greater expertise and more refined skills in dealing with extremely
personal issues than is typical of many caseworkers. This is especially
important, given the limited domestic violence training and varying
levels of skills and abilities among the caseworkers. Some states also
appear, more than others, to stress privacy in conducting domestic
violence screening. Although HHS has taken a number of actions to
provide states with information about approaches to screening, it has
not identified and encouraged the adoption of certain best practices
through official guidance or memoranda.
Recommendations for Executive Action:
We recommend that the Secretary of the Department of Health and Human
Services:
* examine current domestic violence screening practices of states, and
determine whether certain practices--such as employing and training,
where possible, domestic violence specialists--are particularly
promising approaches to screening for domestic violence, and:
* provide states with information on these practices, and, through
agency guidance or memoranda, encourage their adoption.
Agency Comments and Our Evaluation:
We provided a draft of this report to HHS for its review. Overall, HHS
agreed with the report's findings and provided some comments on the
report's conclusions and recommendations. Regarding the report's
conclusions, HHS correctly states that there is a lack of consensus
among domestic violence services professionals about the best
techniques for screening clients and that it would be reluctant to
advocate particular screening approaches over others. It further states
that its regulatory authority is limited in this and many other areas
of the program. We agree that there is no documented consensus about
which screening practices are the most effective and, consistent with
current TANF regulations, state programs should retain flexibility in
designing the approaches they believe are most effective. However, we
believe that there may be some practices that are sufficiently
promising that all states should be made fully aware of their merits,
so that they can choose to adopt them if practicable. While some of
these promising practices might not be applicable in each and every
situation, we continue to believe that state TANF programs would
benefit from HHS guidance on the advantages and limitations associated
with particular promising practices. Further, HHS' advocacy of these
practices would continue to allow state TANF programs and local TANF
offices to retain the flexibility and latitude to select approaches
that best meet the needs of their programs. We have revised our
conclusions and recommendations to more clearly suggest that HHS should
make information on promising screening approaches available to states
and to encourage their adoption.
HHS also provided technical comments on the draft report, which we have
incorporated where appropriate. HHS' entire comments are reproduced in
appendix II.
As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter. At that time, we will send copies to
interested congressional committees and Members, and the Secretary of
Health and Human Services. We will also make copies available to others
upon request. In addition, our report will be available at no charge on
GAO's Web site at http://www.gao.gov.
Contact points for our Office of Congressional Relations and Office
Pubic Affairs may be found on the last page of this report. GAO staff
who made major contributions to this report are listed in appendix III.
Signed by:
David Bellis, Director:
Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report were to determine (1) what states are
doing to identify victims of domestic violence among Temporary
Assistance for Needy Families (TANF) recipients, (2) what states are
doing to address domestic violence among TANF recipients once they have
been identified, and (3) the extent to which states are spending TANF
funds on marriage and responsible fatherhood programs, and how, if at
all, these programs are addressing domestic violence.
To address each of these objectives, we:
* conducted a survey of the TANF agencies in all 50 states and the
District of Columbia;[Footnote 23]
* conducted site visits to state TANF agencies and local TANF service
delivery offices in 8 states; and:
* interviewed researchers and representatives of national organizations
with expertise in the issues of TANF and domestic violence, as well as
marriage and fatherhood programs.
More detailed information on each of these aspects of our research is
presented below. We conducted our work in accordance with generally
accepted government auditing standards between May 2004 and May 2005.
Survey development and implementation:
The survey addressed all three objectives, and included questions about
states' adoption of the family violence option or similar state
policies, screening for domestic violence, and the use of waivers and
domestic violence services to address victim's needs. In addition, we
asked states about their use of TANF funds to support marriage and
responsible fatherhood programs.
The survey was developed based on knowledge obtained during our
preliminary research. This included a review of pertinent literature
and interviews with members of academia and representatives of
organizations that conduct research and policy analysis on TANF,
domestic violence, and marriage and fatherhood programs. We also
conducted visits to TANF offices in Illinois, Iowa, and Wisconsin to
obtain an understanding of their state TANF programs, how they identify
domestic violence victims and address their needs, and the use of TANF
funds for marriage and responsible fatherhood programs. The survey was
pre-tested with state TANF officials in Maryland, Michigan, and
Pennsylvania to determine whether respondents would understand the
questions the way we intended. These states were selected to ensure
that we pre-tested with at least one state that (1) had adopted the
Family Violence Option (FVO)--(Maryland and Pennsylvania); (2) had not
adopted the FVO, but was reputed to have adopted a similar state policy
(Michigan); (3) administered the TANF program through state offices
(Pennsylvania and Michigan); and (4) administered the TANF program
through county offices (Maryland). In addition, Maryland was known to
have developed a responsible fatherhood program and Michigan had both
responsible fatherhood and marriage programs. Revisions to the survey
were made based on comments received during the pretests.
We sent the first mailing of the survey in November 2004 followed by a
second mailing in January 2005; telephone call reminders followed each
mailing. The collection of survey data ended in February 2005 with a
100 percent response rate. We did not independently verify the
information obtained through the survey. We did not attempt to verify
the respondents' answers against an independent source of information;
however, questionnaire items were tested by probing pretest
participants about their answers using in-depth interviewing
techniques. Interviewers judged that all the respondents' answers to
the questions were correct. Answers to the final questionnaire items on
expenditures were compared to HHS ACF data (form 196) for 2002-2003 and
information we received from other researchers in this area. These data
are not directly comparable to data obtained in our survey, but do
indicate whether survey respondents' answers were reasonable. We
conducted follow-up phone calls to clarify responses where there
appeared to be discrepancies.
Although no sampling errors were associated with our survey results,
the practical difficulties of conducting any survey may introduce
certain types of errors, commonly referred to as non-sampling errors.
For example, differences in how a particular question is interpreted or
differences in the sources of information that participants use to
respond can introduce unwanted variability into the survey results. We
included steps in both the data collection and data analysis stages to
reduce such non-sampling errors. Specifically, we pre-tested three
versions of the questionnaire, social science survey specialists
designed draft questionnaires, and edits were performed to identify
inconsistencies and other indications of error prior to analysis of
data. Data from the mail survey were double-keyed and verified during
data entry and we performed computer analyses to identify
inconsistencies and other indications or error. Finally, a second,
independent analyst checked all computer analyses. We conducted our
survey work from July 2004 to February 2005.
State site visits:
To obtain a detailed understanding of states' TANF programs' efforts to
screen for and address domestic violence, we conducted visits to eight
states. We visited three states--Illinois, Iowa, and Wisconsin--during
a preliminary phase of our work, and another five states--Colorado,
Georgia, New York, Oklahoma, and Washington in a later phase. We
selected these five states in order to ensure we covered (1) states in
different regions of the United States; (2) states that had adopted the
FVO recently and a state that had not adopted the FVO; (3) a state in
which the TANF program is state administered, and a state in which TANF
is county administered; and (4) a state that had used TANF funds to
support a marriage program, and a state that had used TANF funds to
support a fatherhood program.
In each state, we interviewed officials at both the state-level policy
setting office, as well as officials in two local service delivery
offices. During both the state level, and local office interviews, we
used a standard interview protocol that enabled us to obtain more
detailed--yet comparable--information than states were able to provide
in the survey. In all five state-level interviews, we discussed state
policies for domestic violence screening, and policies regarding how
victim's needs are met once identified. In addition, we asked officials
about marriage and responsible fatherhood programs, how these programs
were implemented, and the sources of funding. During the interviews in
local TANF offices, we discussed the implementation of state policies,
and toured the offices. In addition, in seven local TANF offices in
five states, we were able to observe caseworkers interviewing a client
applying for TANF benefits, which included questions about domestic
violence. In Georgia, New York, and Washington we also interviewed
domestic violence specialists who were located at the local TANF
offices specifically to identify and address the needs of domestic
violence victims. Finally, we interviewed officials from each state's
coalition against domestic violence to obtain their views about their
state's program for identifying domestic violence victims, meeting
victim's needs, and the existence of marriage and/or responsible
fatherhood programs. Our site visit work was conducted between December
2004 and February 2005.
Other:
As part of our work, we reviewed pertinent literature and interviewed
representatives of the following organizations:
* The Center for Law and Social Policy;
* The Urban Institute;
* The Center for Impact Research;
* The Center on Budget and Policy Priorities;
* The American Enterprise Institute;
* The American Public Human Services Association;
* The Brookings Institution;
* MDRC;
* The National Governors Association;
* Public Strategies;
* The National Fatherhood Initiative; and:
* The Center for Fathers, Families, and Workforce Development.
[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:
JUL 19 2005:
Mr. David D. Bellis:
Director, Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Bellis:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO's) draft report entitled, "TANF: State
Approaches to Screening for Domestic Violence Could Benefit from HHS
Guidance" (GAO-05-701). 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:
Daniel R. Levinson:
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 U.S. Government
Accountability Office reports. OIG has not conducted an independent
assessment of these comments and therefore expresses no opinion on
them.
HHS COMMENTS ON THE U.S. GOVERNMENT ACCOUNTABILITY OFFICE'S DRAFT
REPORT ENTITLED, "TANF: STATE APPROACHES TO SCREENING FOR DOMESTIC
VIOLENCE COULD BENEFIT FROM HHS GUIDANCE" (GAO-05-701):
The Department of Health and Human Services (HHS) appreciates the
opportunity to comment on the U.S. Government Accountability Office's
(GAO) draft report.
General Comments:
We appreciate the work that GAO has done to compile information about
State approaches to domestic violence among clients of the Temporary
Assistance for Needy Families (TANF) program. The report documents
varying approaches that States use to identify and assist victims of
domestic violence. It highlights the challenges to such endeavors,
especially in rural settings. It also provides information on State use
of TANF funds for marriage and fatherhood education programs.
GAO Recommendations:
We recommend that the Secretary of the Department of Health and Human
Services:
1. Examine current domestic violence screening practices of States, and
consider whether certain practices such as employing, where possible,
domestic violence specialists-should be specifically encouraged by
agency guidance or memoranda, and:
2. Consider establishing minimum acceptable screening standards, which
could include a requirement for a specific inquiry about domestic
violence, for States which have certified adoption of the Family
Violence Option (FVO).
HHS Response.
The HHS Administration for Children and Families (ACF) has shown and
continues to show a strong commitment to reducing domestic violence and
to helping victims of domestic violence obtain the safety and
supportive services they need. One way ACF has demonstrated that
commitment is by promoting the adoption of the FVO, a TANF State-plan
provision that provides a specific method for addressing the needs of
domestic violence victims receiving welfare. In turn, ACF holds States
that adopt the FVO and grant specialized waivers harmless from
financial penalties if the penalties would otherwise result from State
efforts to assist victims of domestic violence. We have shown
considerable success in this regard. As the report documents, 40 States
have adopted the FVO and 8 other States have similar policies in place.
The report recommends that we consider encouraging the use of certain
domestic violence screening practices by issuing guidance to States.
ACF agrees that it would be beneficial for State TANF programs to have
an array of best practices of domestic violence screening techniques on
which to draw in order to assist their clients. However, as the report
indicates on page 9, there is a lack of consensus among domestic
violence services professionals about the best techniques for screening
clients. With disagreement among experts in the field, ACF is reluctant
to advocate particular screening approaches over others, allowing the
State and local entities the latitude to determine the techniques that
serve their clients best.
Although we have found that we do not have sufficient evidence of
superiority to advocate specific screening methods over others, in an
effort to provide technical assistance, training, and information on
responding to and preventing domestic violence, ACF funds the National
Resource Center on Domestic Violence. The center serves organizations
and individuals nationwide, including State and local government
agencies.
ACF does, however, commend GAO for noting the shortfall that can occur
when there is a lack of trained staff or persons with experience and
available expertise to work through a domestic violence issue with a
TANF client. Services staff, as the report adequately demonstrates,
understand that domestic violence expertise is an unused resource that
should be available on relatively short notice. It is critical that the
report maintain its focus on the need for States to utilize existing
domestic violence expertise, i.e., whether States believe that it is
more useful to initiate the discussion of domestic violence issues
early or to let those discussions occur later in the interview process.
It is also critical for States to utilize some of the existing
expertise to assist caseworkers and intake workers in their attempt to
provide for self-improvement for their clients.
The report also recommends that the Department consider establishing
minimum acceptable screening standards, which could include a
requirement for a specific inquiry about domestic violence for States
that have certified adoption of the FVO. For States that adopt the FVO,
the State's first requirement is to have and enforce procedures to
screen and identify TANF recipients with a history of domestic violence
while maintaining recipient's confidentiality. However, as we noted
above and as the report itself highlights, the domestic violence
prevention community does not agree about screening techniques. You
cite an example on page 14 of a State that, on the advice of the State
coalition that advocates for domestic violence victims, does not make a
specific inquiry but gives the client the freedom to come forward
whenever he or she is comfortable discussing domestic violence.
It is also important to understand that the FVO is just that: optional.
We want to encourage States to use it. If we add restrictions, we run
the risk that States will simply bypass the option entirely. We believe
that this would be counterproductive for victims of domestic violence,
particularly in the absence of evidence for establishing minimum
standards. Moreover, our regulatory authority is limited in this and
many areas of the program. The spirit of the Personal Responsibility
and Work Opportunity Reconciliation Act (PRWORA), which created TANF,
is one that affords States broad discretion over the design of their
programs within broad Federal parameters.
Finally, with respect to the recommendations, we suggest that GAO
qualify its conclusions. We believe that it would be helpful if the
report mentioned that the conclusions are based on perceptions of what
constitutes good practice. We also believe that GAO may well be correct
in these perceptions, but presently there is little evaluation to
support particular approaches.
Other Comments:
We would also like to comment on the report's discussion of marriage
and fatherhood programs. Throughout the report, you refer to "marriage
and fatherhood promotion" programs. ACF does not consider its Healthy
Marriage Initiative to be "marriage promotion" but rather an initiative
that offers healthy marriage education, i.e., education for those
interested in marriage; our fatherhood programs are responsible
fatherhood projects, not "fatherhood promotion." ACF believes the
difference is noteworthy and we hope that GAO will correct the report
before publication.
GAO also notes on page 29 that domestic violence is generally not
explicitly included as a component in marriage and fatherhood programs.
ACF is not aware of general practice in State-initiated programs, but
it is our stated policy for all Federally funded Healthy Marriage
Initiative projects to require grantees to develop domestic violence
protocols that set forth project-specific policies with regard to
screening for domestic violence and referrals to local domestic
violence services. ACF is committed to ensuring that all future Healthy
Marriage Initiative projects fully incorporate domestic violence
protections.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
David Bellis, Director, (415) 904-2272:
Acknowledgments:
David Lehrer, Assistant Director, Michael Hartnett, Analyst-in-Charge,
Deirdre Gleeson-Brown, Gale Harris, Alison Martin, Nancy Purvine, and
Amber Yancey-Carroll also made significant contributions to this
report.
Important contributions were also made by Jen Popovic, Corinna
Nicolaou, and Daniel Schwimer.
FOOTNOTES
[1] States have some discretion in defining "work" under this
requirement. For example, work can include job search and job readiness
assistance, or vocational educational training.
[2] States that have not adopted the Family Violence Option may also
screen for domestic violence and offer waivers to program requirements.
However, these states are not eligible to avoid financial penalties
related to the work requirement and 5-year time limit.
[3] GAO, Domestic Violence: Prevalence and Implications for Employment
among Welfare Recipients, GAO/HEHS-99-12 (Washington, D.C.: November
1998).
[4] Richard M. Tolman and Daniel Rosen, Domestic Violence in the Lives
of Women Receiving Welfare: Mental Health, Substance Dependence, and
Economic Well Being in Violence Against Women, Vol. 7, No. 2 (February
2001).
[5] Severe abuse is defined as including experiences such as being
beaten, being hit with a fist or an object that could cause harm, and
being threatened with a weapon.
[6] Jody Raphael and Sheila Haennicke, Keeping Battered Women Safe
through the Welfare to Work Journey: How Are We Doing? Taylor Institute
(September 1999).
[7] In our survey of the states, we defined "screening" as a technique
used by local TANF office staff to identify domestic violence victims.
Techniques may include a single question, investigative interviewing,
or use of a detailed questionnaire.
[8] In some states we visited, domestic violence screening takes place
in the course of a much broader conversation that can cover issues such
as the clients educational and employment history, the client's family
situation, and TANF rules and regulations.
[9] In our survey, states were able to indicate more than one type of
staff "typically" conducts domestic violence screening.
[10] Because our survey did not include questions about domestic
violence specialists, we do not know how many states employ such
specialists in TANF offices. However, a 1999 report on domestic
violence and the TANF program--Raphael and Haennicke--indicates that
this practice is used by other states as well.
[11] Raphael and Haennicke.
[12] Martha R. Burt, Janine M. Sweig, and Kathryn A. Schlichter,
Strategies for Addressing the Needs of Domestic Violence Victims within
the TANF Program (Urban Institute, June 2000).
[13] Federal regulations applicable to the TANF program do not require
states to report the number of domestic violence waivers granted,
unless a state is seeking penalty relief.
[14] States were asked in the survey to provide data for a 3-year
period, 2002-2004. However, 2004 data was determined to be unusable
because there were numerous notes indicating that data were not
available or states supplied obligated figures rather than
expenditures. State data were determined usable if no participant notes
accompanied the survey response explaining why data did not conform to
our question parameters and if data were not the same dollar amount for
all 3 years except in cases where a follow-up call confirmed that the
expenditures were accurate. Five states reported usable marriage
program data for 2002 and six states for 2003. Seventeen states
reported usable fatherhood program data for 2002 and 20 states for
2003.
[15] Welfare Reform: How TANF Addressed Family Structure (Washington,
D.C.: Congressional Research Service, Apr. 15, 2003).
[16] Kathleen Sylvester and Kathleen Reich, Making Fathers Count:
Assessing the Progress of Responsible Fatherhood Efforts (Washington,
D.C.: Social Policy Network, 2002).
[17] These are additional, voluntary survey comments.
[18] Colorado, Florida, Idaho, North Carolina, and Utah reported in
survey comments and Georgia in a site visit using other funding sources
for marriage programs. Examples of funding sources reported included
non-TANF grants, Title IV-B of the Social Security Act funds, private
funds, and child support funds.
[19] Two states, South Carolina and Virginia, indicated in survey
comments that they funded programs that they do not consider marriage
programs per se. For example, Virginia funded an initiative to reduce
the number of out-of-wedlock births among young adults. Programs
focused on relationships and marriage, discouraging risky sexual
behavior, and promoting waiting until marriage to have children.
[20] These states are Alaska, Delaware, Georgia, Kansas, Kentucky,
Mississippi, Texas, and West Virginia. Seven of these states that did
not previously fund marriage programs and one, Mississippi, is
implementing a new marriage program, but was already funding existing
programs.
[21] Six states--Colorado, Florida, Georgia, Massachusetts, North
Carolina, and Washington--stated in survey comments or an interview
that they funded responsible fatherhood programs with other sources
such as Social Services Block Grant funds, Title IV-B and D of the
Social Security Act funds, child support collection incentive funds,
and state general fund monies.
[22] M. Robin Dion and Barbara Devaney, Strengthening Relationships and
Supporting Healthy Marriages among Unwed Parents (Mathematica Policy
Research, Inc; Apr. 2003).
[23] Consistent with the report, we refer to all respondents to the
survey as "states."
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