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United States General Accounting Office: 
GAO: 

Testimony: 

Before the Subcommittee on Human Resources, Committee on Ways and 
Means, House of Representatives: 

For Release on Delivery: 
Expected at 9:30 a.m. 
Thursday, March 7, 2002: 

Welfare Reform: 

States Are Using TANF Flexibility to Adapt Work Requirements and Time 
Limits to Meet State and Local Needs: 

Statement of Cynthia M. Fagnoni, Managing Director: 
Education, Workforce, and Income Security Issues 

GAO-02-501T: 

Mr. Chairman and Members of the Subcommittee: 

Thank you for inviting me here today to discuss the extent to which 
families receiving cash assistance are excluded from work requirements 
and time limits. The 1996 Personal Responsibility and Work Opportunity 
Reconciliation Act (PRWORA) significantly changed federal welfare 
policy for low-income families with children, building upon and 
expanding state-level reforms. When the Congress created the Temporary 
Assistance for Needy Families block grant (TANF) to replace the 
previous welfare program, it emphasized that the new program was to be 
transitional in nature and focus on moving welfare recipients into 
employment. To this end, states are required to enforce work 
requirements and time limits on most families receiving cash 
assistance. More specifically, states face financial penalties if they 
do not include a minimum percentage of adults receiving cash 
assistance in work or work activities each year, referred to as the 
mandated participation rate requirement. This mandated rate increased 
each year, reaching 50 percent of all families in fiscal year 2002. 
In addition, states are to enforce a 60-month lifetime limit on 
families with adults who receive cash assistance. To receive its TANF 
block grant, each state must also meet a maintenance-of-effort 
requirement, under which it must spend at least a specified amount of 
its own funds, referred to as state maintenance-of-effort funds (MOE). 

Along with these federal requirements, the law allows states 
considerable flexibility to exclude families from work requirements 
and time limits. First, these requirements only apply to families with 
an adult receiving aid, not to cases in which only children receive 
cash assistance. Second, PRWORA specifies that up to 20 percent of 
families receiving assistance may receive extensions to federal time 
limits. Third, states may provide cash assistance not subject to work 
requirements and time limits if they use their state MOE in specified 
ways, such as through a state program other than their TANF program. 

As the Congress considers reauthorization of TANF, you asked us to 
determine and assess the states’ implementation of these work 
requirements and time limits. More specifically, you asked us to 
determine (1) the extent of child-only cases among the cash assistance 
caseload funded by federal TANF and state MOE, (2) how states made use 
of work requirement flexibility, (3) the number of families states 
have excluded from time limits, and (4) key issues related to states’ 
experiences in applying TANF work requirements and time limits. The 
information we gathered came from site-visits in 4 states, telephone 
interviews with TANF officials in 8 other states, and a survey 
administered to TANF officials in all 50 states and the District of 
Columbia.[Footnote 1] We conducted our work from August 2001 through 
February 2002, in accordance with generally accepted government 
auditing standards. 

In summary, of the 2.1 million cash assistance cases funded by federal 
TANF or state maintenance-of-effort dollars in the fall of 2001, 
[Footnote 2] one-third of these cases, or 700,000, were composed of 
one or more children only. Because no adult in these families receives 
TANF or state MOE funded cash assistance, work requirements and time 
limits do not apply. Regarding work requirements, when PRWORA 
established federally mandated participation rates, it also included a 
“caseload reduction credit” provision. This provision specifies that 
each state’s mandated participation rate is to be reduced if its 
welfare caseload declines. Because of the dramatic declines in welfare 
caseloads that have occurred since 1996, states have generally faced 
greatly reduced mandated participation rates for the TANF programs. 
For example, in fiscal year 2000, caseload reduction credits reduced 
mandated participation rates to 0 in 31 states—-instead of the 
mandated rate of 40 percent specified in the law. As a result, 
states have increased flexibility in determining the numbers of adults 
that are to be involved in work or work activities. Regarding time 
limits, after accounting for child-only cases, states excluded 11 
percent of the remaining 1.4 million families with an adult from 
federal or state time limits. States’ experiences with implementing 
work requirements and time limits highlight key issues of interest for 
the reauthorization of TANF provisions, including the relatively 
limited number of families that have reached their time limits so far 
and the future adequacy of the federal 20 percent extension. 

Background: 

PRWORA made sweeping changes to national welfare policy, creating 
TANF and ending the federal entitlement to assistance for eligible 
needy families with children under Aid to Families With Dependent 
Children (AFDC). The Department of Health and Human Services (HHS) 
administers the TANF block grant program, which provides states with 
up to $16.5 billion each year through fiscal year 2002. TANF was 
designed to help needy families reduce their dependence on welfare and 
move toward economic independence. The law also greatly increased the 
discretion states have in the design and operation of their welfare 
programs, allowing states to determine forms of aid and the categories 
of families eligible for aid. TANF establishes time limits and work 
requirements for adults receiving aid and requires states to sustain 
75 to 80 percent of their historic level of welfare spending through a 
maintenance-of-effort requirement. In addition, TANF gives states 
funding flexibility, which allows states to exclude some families from 
federal time limits and work requirements. 

TANF Establishes Time Limits and Work Requirements for Adults 
Receiving Aid: 

TANF establishes a 60-month time limit for families receiving aid. 
States have the option of establishing shorter time limits for 
families in their state. A state that does not comply with the TANF 
time limit can be penalized by a 5 percent reduction in its block 
grant. While the intent of TANF is to provide temporary, time-limited 
aid, federal time limits do not apply to all forms of aid or to all 
families receiving aid. First, states are only to count toward the 60-
month time limit any month in which an individual receives a service 
or benefit considered “assistance,” which is defined in the TANF 
regulations as cash or other forms of benefits designed to meet a 
family’s ongoing basic needs.[Footnote 3] Second, time limits do not 
apply to the following types of cases: 

1. Cases in which the adult in the household does not receive cash 
assistance, typically called “child-only” cases.[Footnote 4] 

2. Families that received assistance while living in Indian country or 
an Native Alaskan village where 50 percent of the adults are not 
employed. 

Third, all states have the option to use federal funds to extend 
assistance beyond the federal 60-month limit for reasons of hardship, 
as defined by the state. States can extend assistance for up to 20 
percent of the average monthly number of families receiving assistance 
(“20 percent extension”).[Footnote 5] States can also extend 
assistance for victims of domestic violence through federally approved 
domestic violence waivers.[Footnote 6] Finally, assistance that is 
provided solely through state MOE is not subject to the federal time 
limit. 

TANF also establishes work requirements for adults receiving aid. 
After 2 years of assistance, or sooner if the state determines the 
recipient is ready, TANF adults are generally required to be engaged 
in work as defined by the state.[Footnote 7] In addition, TANF 
establishes required work participation rates—-a steadily rising 
specified minimum percentage of adult recipients that must participate 
in federally specified work or work-related activities each year. 
[Footnote 8] States were required in federal fiscal year 2002 to meet 
a work participation rate of 50 percent for all TANF families with 
adult members—-referred to as the rate for all families. States were 
also required to meet a much higher rate—-90 percent—-for two-parent 
families.[Footnote 9] States must meet these work participation rates 
to avoid financial penalties. 

While states have generally met the work participation rate for all 
families, many states have faced financial penalties due to failure to 
meet the two-parent required rate in recent years. HHS issued penalty 
notices to 19 states in fiscal year 1997, 14 in fiscal year 1998, 9 in 
fiscal year 1999, and to 7 states in fiscal year 2000. 

In addition to establishing federal participation rate requirements, 
PRWORA specified that the required rates are to be reduced if a state’s 
TANF caseload declines. States are allowed caseload reduction credits, 
which reduce each state’s work participation requirement by one 
percentage point for each percentage point by which its average monthly 
caseload falls short of its fiscal year 1995 level (for reasons other 
than eligibility changes). 

In addition, federal time limits and work requirements may not apply in 
some states that were granted federal waivers to AFDC program rules in 
order to conduct demonstration programs to test state reforms. 

States May Choose Various State Funding Options for Providing Cash 
Assistance: 

Previously, under AFDC, state funds accounted for 46 percent of total 
federal and state expenditures. Under PRWORA, the law requires states 
to sustain 75 to 80 percent of their historic level of spending on 
welfare through a maintenance-of-effort requirement to receive their 
federal TANF block grant. The federal TANF funds and state MOE funds 
can be considered more like funding streams than a single program and 
states may use their MOE to assist needy families in state programs 
other than their TANF programs. In fact, states have flexibility to 
expend their MOE funds for cash assistance in up to three different 
ways, some of which allow states to exclude some families from time 
limits and work requirements. 

* A state may use its state MOE funds in three different ways to 
provide cash assistance for needy families. 

* Commingling: A state can provide TANF cash assistance by commingling 
its state MOE with federal funds within its TANF program. 

* Segregating: A state can provide some TANF cash assistance with state 
MOE accounted for separately from its federal funds within its TANF 
program. 

* Separating: A state can use its state MOE to provide cash assistance 
to needy families in any one or more non-TANF state programs, referred 
to as “separate state programs.” 

Each state may choose one or more of these options to provide cash 
assistance. In some cases, in this testimony, we refer to the second 
and third options as using “state-only” funds when the distinction 
between segregating and separating funds is not necessary. In 
addition, we focus only on cash assistance and not on other forms of 
aid or services, including, for example, child care and 
transportation, for which time limits and work requirements generally 
do not apply. 

How a state structures its funds determines which TANF rules apply to 
the needy families being served. (See table 1.) When a state 
commingles funds, it must meet all TANF requirements. For example, 
states that commingle all their state MOE with federal funds are only 
able to exclude families from time limits through the 20 percent 
extension, cannot exclude families from counting towards the federal 
work participation rate, and cannot provide assistance to certain 
groups of legal immigrants. 

Table 1: Application of Key TANF Restrictions and Requirements on 
State MOE Funds under the Three Funding Options: 

Application of PRWORA rules by state funding option: 

Key program requirements and restrictions for cash assistance: Does 60-
month time limit apply? 
State TANF program with federal or commingled funds: Yes, except for 
up to 20 percent of the cash assistance caseload; 
State TANF program with state MOE accounted for separately from 
federal funds (referred to as segregated): No; 
State MOE for needy families in any non-TANF state program (referred 
to as separate state program): No. 

Key program requirements and restrictions for cash assistance: Do work-
activities count toward the federal work participation rate?
State TANF program with federal or commingled funds: Yes; 
State TANF program with state MOE accounted for separately from 
federal funds (referred to as segregated): Yes[A]; 
State MOE for needy families in any non-TANF state program (referred 
to as separate state program): No. 

Key program requirements and restrictions for cash assistance: Do 
restrictions on assistance to immigrants apply?[B]
State TANF program with federal or commingled funds: Yes; 
State TANF program with state MOE accounted for separately from 
federal funds (referred to as segregated): No; 
State MOE for needy families in any non-TANF state program (referred 
to as separate state program): No. 

[A] With this option, states have the flexibility to serve families 
they might not otherwise be able to serve in TANF, such as certain 
legal immigrants, but at the same time count their work activities 
toward meeting the federal participation target rate. 

[B] Immigrants arriving in the United States after August 22, 1996, 
are barred from the receipt of federal TANF assistance for a 5-year 
period. 

[End of table] 

States may exclude families from time limits by funding their cash 
assistance with state MOE, either through “segregated funds” or in any 
non-TANF state programs. More specifically, any month of cash 
assistance funded solely by state MOE funds does not count toward the 
federal 60-month limit and may be provided to families who have 
reached their federal time limit. States may exclude families from 
federal time limits if they 

* Stop the clock. States can “stop the clock” so that a family’s cash 
assistance does not count towards the federal time limit. This is 
accomplished by funding any month of cash assistance with state-only 
funds rather than with federal or commingled federal and state dollars. 
For example, if a state provides monthly cash assistance to working 
families with state-only funds, those months of assistance do not count 
toward the federal time limit. 

* Extend the time limit. States can provide cash assistance beyond the 
60-month time limit by using state-only funds. A state may extend a 
family’s time limit because it has determined that the adult needs more 
time to prepare for and find employment. 

Finally, while not required by federal law, states may choose to apply 
time limits on their state-funded assistance. In this case, states may 
also decide to stop the clock or extend time limits for certain 
families.[Footnote 10] 

In addition, families provided cash assistance funded by state MOE 
through non-TANF state programs are not subject to federal work 
requirements, though states may choose to impose their own work 
requirements on these families. 

One-Third of Families Receiving Cash Assistance Are Child-Only Cases 
Not Subject to Federal Work Requirements or Time Limits: 

States reported that in the fall of 2001, 2.1 million families 
received cash assistance funded with federal TANF or state MOE 
dollars, with about 700,000, or one-third, of these families composed 
of children only. Generally, child-only cases are not subject to work 
requirements or time limits.[Footnote 11] The most common types of 
child-only cases were families in which the: 

* caregiver is a nonparent, such as a relative, often a grandparent (40 
percent); 

* parent is receiving Social Security or Supplemental Security Income 
and not eligible for TANF (25 percent); 

* parent is a noncitizen ineligible for federally funded TANF (23 
percent);[Footnote 12] and; 

* parent is subject to sanctions (7 percent). (See figure 1.)[Footnote 
13] 

The breakdown of child-only cases varied significantly across states, 
however. For example, child-only cases in which the parent is an 
ineligible noncitizen ranged from 0 percent in ten states to 39 
percent in California and 77 percent in Texas; this variation is 
likely due to the variation in immigrant populations across the 
states. (For more information on each state’s child-only caseload, see 
Appendix I.) 

Figure 1: Reasons for Child-Only Cases: 

[Refer to PDF for image: pie-chart] 

Nonparental caregivers: 40%; 
Parent is receiving Social Security/SSI: 25%; 
Parent is ineligible noncitizen: 23%; 
Parent subject to sanctions: 7%; 
Other reasons: 5%. 

Source: GAO survey. 

Note: States were only able to report on 434,420 of the 700,000 
federally funded child-only cases. Eighteen states had no data on the 
reasons for their child-only cases. 

[End of figure] 

States Use Flexibility under PRWORA to Exempt Some Families from 
Federal Work Requirements: 

Reduced federal participation targets—due to declining caseloads and 
the caseload reduction credit—and states’ use of their MOE funds in non-
TANF programs give states considerable flexibility in implementing work 
requirements. (For more information on how states use their MOE funds, 
see Appendix II). Since the implementation of welfare reform, states 
have experienced strong economic growth and welfare caseloads have 
declined dramatically, from 4.4 million in August 1996 to 2.1 million 
as of September 2001, marking a 52 percent decline in the number of 
families receiving cash welfare. The work participation target rate 
for every state in fiscal year 2002 is 50 percent for all families. 
However, once the caseload reduction credit is taken into account, the 
target rates can be greatly reduced. For example, as shown in table 2, 
the actual rate for all families reported by HHS for fiscal year 2000 
was zero in 31 states and less than 25 percent in all but two states. 

Table 2: Fiscal Year 2000 Required All-Family Work Participation Rate 
for Each State after Factoring in Caseload Reduction Credit (Stated 
Rate Was 40 percent): 

State: Alabama; 
Target: 0%; 

State: Alaska; 
Target: 11%; 

State: Montana; 
Target: 0%; 

State: Arizona; 
Target: 0%; 

State: Arkansas; 
Target: 6%; 

State: California; 
Target: 8%; 

State: Colorado; 
Target: 0%; 

State: Connecticut; 
Target: 28%; 

State: Delaware; 
Target: 0%; 

State: D.C.; 
Target: 11%; 

State: Florida; 
Target: 0%; 

State: Georgia; 
Target: 0%; 

State: Hawaii; 
Target: 25%; 

State: Idaho; 
Target: 0%; 

State: Illinois; 
Target: 0%; 

State: Indiana; 
Target: 0%; 

State: Iowa; 
Target: 1%; 

State: Kansas; 
Target: 17%; 

State: Kentucky; 
Target: 0%; 

State: Louisiana; 
Target: 0%; 

State: Maine; 
Target: 9%; 

State: Maryland; 
Target: 1%; 

State: Massachusetts; 
Target: 0%; 

State: Michigan; 
Target: 0%; 

State: Minnesota; 
Target: 9%; 

State: Mississippi; 
Target: 0%; 

State: Missouri; 
Target: 0%; 

State: Nebraska; 
Target: 14%; 

State: Nevada; 
Target: 0%; 

State: New Hampshire; 
Target: 0%; 

State: New Jersey; 
Target: 1%; 

State: New Mexico; 
Target: 17%; 

State: New York; 
Target: 5%; 

State: North Carolina; 
Target: 0%; 

State: North Dakota; 
Target: 0%; 

State: Ohio; 
Target: 0%; 

State: Oklahoma; 
Target: 0%; 

State: Oregon; 
Target: 0%; 

State: Pennsylvania; 
Target: 0%; 

State: Rhode Island; 
Target: 24%; 

State: South Carolina; 
Target: 0%; 

State: South Dakota; 
Target: 3%; 

State: Tennessee; 
Target: 0%; 

State: Texas; 
Target: 0%; 

State: Utah; 
Target: 6%; 

State: Vermont; 
Target: 40%; 

State: Virginia; 
Target: 0%; 

State: Washington; 
Target: 2%; 

State: West Virginia; 
Target: 0%; 

State: Wisconsin; 
Target: 0%; 

State: Wyoming; 
Target: 0%. 

Source: The Administration for Children and Families, HHS. 

[End of table] 

As a result, states have had increased flexibility in determining the 
numbers of adults that are to be working or preparing for work and the 
types of activities required. For states to count families’ activities 
towards the work participation rate, families have to be participating 
in federally approved work activities. In a previous report, we found 
that some states included recipients in a range of work and work-
preparation activities that extend beyond those that meet federal work 
participation requirements, particularly to meet the needs of 
recipients considered hard to employ.[Footnote 14] Officials in one 
state told us that because the work participation rates are so low due 
to caseload reduction credits, states have more flexibility in the 
types of activities or services provided, for example, substance abuse 
treatment or mental health services, without fear of not meeting their 
federal work participation rates. In other cases, the lower target 
rates give states more flexibility in exempting TANF recipients 
considered hard to employ from meeting work requirements, as we found 
in our report on TANF recipients with mental and physical impairments. 
[Footnote 15] 

In addition to the flexibility provided by reduced federal target 
rates, many states have increased work requirement flexibility by 
using state MOE funds to provide cash assistance through non-TANF 
programs, as allowed by PRWORA. Twenty-six states use state MOE funds 
to provide cash assistance through separate state programs, which 
allows states to exclude families from federal work requirements and 
to serve certain immigrants ineligible for federal TANF. Sixteen of 
these states provide cash assistance to two-parent families through 
these programs. Several state officials told us they provide aid in 
this way to avoid the risk of financial penalties for failing to meet 
the federal two-parent work participation rate. State officials told 
us that two-parent families often have as many or more challenges as 
single parents, making the higher target rate for two-parent families 
difficult to meet.[Footnote 16] 

While states expressed concern about failing to meet the federal target 
rate for two-parent families, all 16 of these states imposed their own 
state work requirements on these families. Thirteen of the 26 states 
used state MOE in separate programs to provide cash assistance to 
certain legal immigrants not eligible for federal TANF aid; these 13 
states still apply a state work requirement for these families as 
well. Overall, approximately nine-tenths of the families receiving 
cash assistance in separate state programs are still subject to a 
state work requirement. While states generally imposed work 
requirements, about half of them also have policies in place to 
exclude families facing significant barriers to work from work 
requirements. For example, 13 states exclude families with an adult 
who is disabled and 13 states exclude families that care for someone 
with a disability. 

States Excluded 11 Percent of Adult Families from Federal and State 
Time Limits: 

States generally targeted time limit exclusions to families they 
considered hard to employ, families that were working but not earning 
enough to move off of TANF, and families that were cooperating with 
program requirements but had not yet found employment. During fall 
2001,[Footnote 17] states excluded from federal or state time limits 
11 percent of the 1.4 million cash assistance families with adults. 
The number of families excluded from time limits may increase in the 
future because most families have not yet reached their federal or 
state-imposed cash assistance time limit. 

Federal 20 Percent Extension and State-Funded Time Limit Exclusion 
Policies Generally Target Working or Hard-to-Employ Families: 

States targeted time limit exclusions to families they considered 
“hard to employ”, families that were working but not earning enough to 
move off of TANF, and families that were cooperating with program 
requirements. The majority of states excluded “hard-to-employ” 
families in which the parent had a disability or was caring for a 
child with a disability, families dealing with domestic violence, and 
families with a head of household of advanced age. (See figure 2.) 
Some of these exclusions are granted on a temporary basis (such as for 
disabled recipients pending transfer to the Supplemental Security 
Income program), and others are granted for longer periods of time 
(such as for family heads of advanced age). 

Figure 2: Number of States with Exclusions to Federal or State Time 
Limits by Recipient Characteristic: 

[Refer to PDF for image: horizontal bar graph] 

Reason for exclusion: Parent or caretaker with a disability; 
Number of states: 46. 

Reason for exclusion: Caring for disabled family member; 
Number of states: 46. 

Reason for exclusion: Domestic violence/extreme cruelty; 
Number of states: 42. 

Reason for exclusion: Family head is of advanced age; 
Number of states: 26. 

Reason for exclusion: Making good faith effort to find job; 
Number of states: 23. 

Reason for exclusion: Caring for young child; 
Number of states: 22. 

Reason for exclusion: Working or in work activity; 
Number of states: 22. 

Reason for exclusion: Parent completing education or training; 
Number of states: 21. 

Reason for exclusion: Family living in high unemployment area; 
Number of states: 19. 

Source: GAO survey. 

[End of figure] 

Twenty-two states exclude working families from time limits, either 
through the federal 20 percent extension or by using state-only funds. 
Maryland and Illinois, for example, “stop the clock” for working 
families by funding them with state-only dollars. Officials from both 
states told us that their states adopted this policy to reward working 
families for complying with program requirements. 

States that exclude families by using state-only funds use similar 
criteria to those used by states that rely solely on the federal 20 
percent hardship extension. Using the 20 percent extension, states are 
able to extend time limits for a broad range of families, such as 
families cooperating with program requirements or making a “good faith 
effort” to find employment. For example, officials from Michigan, a 
state that commingles all of its state funds with federal funds, told 
us that they will use the 20 percent extension for all recipients 
following the rules of the program; if the number of families they 
want to provide and extension to begins to exceed 20 percent, they 
plan to continue providing assistance through state funds. 

Almost half of the states exclude families making a good faith effort 
to find employment. 

While States Had Excluded 11 Percent of Families with Adults from Time 
Limits as of Fall 2001, This Percentage May Increase as More Families 
Reach Their Time Limits: 

States have excluded from time limits 11 percent of the approximately 
1.4 million families with adults receiving federal- or state-funded 
cash assistance. (See Appendix III for the percent of exclusions by 
state.) As shown in figure 3, 45 percent of these families—mostly in 
Illinois, Massachusetts, and New York—were excluded through states use 
of state-only funds. An additional 43 percent of the families were 
excluded from time limits under federal waivers granted to states 
before welfare reform to conduct demonstration programs. Many of these 
waivers remain in effect.[Footnote 18] 

Figure 3: Percentage of Families with Adults Excluded from Time Limits 
and Method of Exclusion: 

[Refer to PDF for image: pie-chart] 

Method of exclusion: 

Time-limited: 89%; 
Not time-limited: 11%: 
* Waivers: 43.4%; 
* Federal 20% hardship extension: 11.2%; 
* Exclusions using state-only funds: 45.2%. 

Source: GAO survey. 

Note: Exclusions do not total 100% due to incomplete data from states. 
Delaware was unable to provide us with caseload data and is not 
included in this figure. 

Even though states are free to exclude all state-funded families from 
time limits, 64 percent of state-funded families that include adults 
were still subject to a time limit imposed by the state. Twenty-six of 
the 33 states with state-only funds apply a state time limit to some 
or all of their state-funded cases. (See Appendix IV for additional 
information on state choices regarding funding and time limits.) 

The percentage of the caseload that is excluded from time limits may 
increase, since most families have not reached their time limit. In 22 
states TANF had not been in effect long enough for families to reach 
either the federal or the state time limit by the time we conducted 
our survey.[Footnote 19] Even in those states where it was possible to 
have received 60 months of cash assistance, many families had not 
reached their time limit because they have cycled on and off welfare, 
slowing their accrual of time on assistance. As a result, only 15 
states had begun to use the federal 20 percent hardship extension, and 
all of these states were applying it to less than 6 percent of their 
total caseload. One state we visited, California, told us it estimated 
that over 100,000 families with adults would reach the federal time 
limit in the next year. California plans to use state-only funds to 
continue aid beyond 60 months to children by removing the adult from 
the case. California also plans to continue aid to families that are 
making a good faith effort to find employment and to families that are 
hard to employ because the adult is aged, disabled, caring for a 
disabled family member, or experiencing domestic violence. 

States’ Experiences with TANF Highlight Issues for Reauthorization: 

States’ experiences with implementing TANF time limits and work 
requirements for families receiving cash assistance highlight key 
issues related to reauthorization of TANF provisions. Officials from 
the four states we visited and eight states we interviewed shared 
their views on work requirements and time limits, and the flexibility 
they have to implement them. Some state officials commented on the 
limited extent of states’ experiences with time limits, given that 
many families have not yet reached their time limits, as well as their 
inexperience with operating TANF during times of state budget 
pressures. State officials also highlighted their concerns about the 
federal 90 percent work participation requirements for two-parent 
families. 

States Support TANF Flexibility, but Some States Have Concerns: 

In general, state officials we spoke with were supportive of time 
limits and work requirements. For example, Maryland officials said 
that one advantage of time-limits assistance and work requirements was 
that families understood that the receipt of cash assistance was no 
longer an entitlement, thereby changing the culture of welfare. In 
addition, another Maryland official noted that time limits encourage 
caseworkers to link families, particularly the hard to employ, to the 
services they need to become self-sufficient. States also said that, 
for the most part, flexibility in implementing time limits and work 
requirements were important in allowing them to meet the needs of 
special populations while supporting the federal goal of reducing 
dependency. The flexibility in implementing their own time limits 
helps to ensure that states can adapt the federal program to meet 
state and local needs while still emphasizing the transitional nature 
of cash assistance through time limits. 

While state officials were generally supportive of TANF flexibility, 
officials in almost all of the states we spoke with expressed the 
desire to have more flexibility in counting education and training 
towards the federal work participation rate. Some states officials 
also expressed a desire to count activities such as mental health and 
substance abuse counseling towards the federal work participation 
rate. The states that did not opt for additional flexibility through 
the use of state-only funds expressed two general concerns. First, 
they were uncertain about the consequences of their funding 
flexibility under TANF. A Mississippi TANF official told us that the 
state plans to follow the federal regulations rather than risk 
penalties by establishing its own program rules that could become 
confused with the federal regulations. Second, Colorado state officials 
were concerned about the potential administrative burden that could 
result from creating separate funding or programs that used state-only 
funds. 

Changing Economic Conditions May Pose Difficult Choices for States 
in the Future: 

Up until very recently, TANF has been implemented under conditions of 
strong economic growth, with declining cash assistance caseloads and 
the resulting increase in resources available to states to assist 
families. This has fostered increased flexibility in how state 
officials use their federal TANF and state maintenance-of-effort 
dollars. Several states we interviewed now face budget pressures and 
increasing cash assistance caseloads, which could affect the policy 
choices they make about funding mechanisms and time limit exclusions 
in the future. This could affect some states’ choices regarding 
continued support for families that take longer to become self-
sufficient. California state officials noted that its plan to continue 
aid for all children whose parents have reached time limits may 
pose a future financial burden on the state. 

States’ Experiences with Adequacy of the 20 Percent Federal Extension 
May Change as More Families Reach Time Limits: 

State officials generally thought the 20 percent federal extension was 
adequate now, but were less sure about the future, given that many 
families have not yet reached the 60-month time limit. Given that 
states’ experiences with families reaching their time limits is still 
limited, it is important to emphasize that much remains unknown 
nationwide about the numbers, characteristics, and experiences of 
families who have reached or are close to reaching federal time limits 
on assistance. In the past we have recommended that HHS work with 
state officials on this issue to promote research and provide guidance 
that would encourage and enable state officials to identify who has 
reached the 60-month time limit before they are able to work. HHS has 
taken steps to do so.[Footnote 20] 

States Support the Goal of Helping Two-Parent Families Reduce Their 
Dependency but Would Like More Flexibility in the Federal Two-Parent 
Work Participation Rate: 

State officials cited their difficulties in meeting the federal work 
participation target rate for two-parent families and a few discussed 
their solutions—-serving two-parent families in separate state 
programs to avoid potential financial penalties. These states 
typically apply their own work requirements and time limits to these 
families, demonstrating the states’ expectation that these families 
take steps to reduce dependency in the absence of a federal 
requirement to do so. 

Mr. Chairman, this concludes my prepared statement. I will be happy to 
respond to any questions you or other members of the subcommittee may 
have. 

GAO Contacts and Acknowledgments: 

For future contacts regarding this testimony, please call Cynthia M. 
Fagnoni at (202) 512-7215 or Gale Harris at (202) 512-7235. Individuals 
making key contributions to this testimony included Sigurd Nilsen, 
Katrina Ryan, Elisabeth Anderson, Kara Kramer, Kim Reniero, and Patrick 
DiBattista. 

[End of section] 

Appendix I: States’ Child-Only Caseloads and Reasons for Child-Only 
Cases: 

Percentage of TANF and state MOE child-only cases by reason: 

State: Alabama; 
Percentage of total caseload that is child-only: 45%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Alaska; 
Percentage of total caseload that is child-only: 19%; 
Parent receiving SSI: 39%; 
Parent is ineligible noncitizen: 6%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 55%; 
Other reason: 0%. 

State: Arizona; 
Percentage of total caseload that is child-only: 44%; 
Parent receiving SSI: 0%; 
Parent is ineligible noncitizen: 33%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 63%; 
Other reason: 4%. 

State: Arkansas; 
Percentage of total caseload that is child-only: 42%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: California; 
Percentage of total caseload that is child-only: 34%; 
Parent receiving SSI: 14%; 
Parent is ineligible noncitizen: 39%; 
Parent is subject to sanctions: 16%; 
Nonparental caregivers: 23%; 
Other reason: 8%; 

State: Colorado; 
Percentage of total caseload that is child-only: 38%; 
Parent receiving SSI: 27%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 55%; 
Other reason: 17%. 

State: Connecticut; 
Percentage of total caseload that is child-only: 34%; 
Parent receiving SSI: 40%; 
Parent is ineligible noncitizen: 5%; 
Parent is subject to sanctions: 1%; 
Nonparental caregivers: 54%; 
Other reason: 0%. 

State: Delaware; 
Percentage of total caseload that is child-only: 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: D.C. 
Percentage of total caseload that is child-only: 19%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Florida; 
Percentage of total caseload that is child-only: 57%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Georgia; 
Percentage of total caseload that is child-only: 46%; 
Parent receiving SSI: 0%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 100%; 
Other reason: 0%. 

State: Hawaii; 
Percentage of total caseload that is child-only: 13%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Idaho; 
Percentage of total caseload that is child-only: 42%; 
Parent receiving SSI: 0%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 100%; 
Other reason: 0%. 

State: Illinois; 
Percentage of total caseload that is child-only: 40%; 
Parent receiving SSI: 58%; 
Parent is ineligible noncitizen: 10%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 28%; 
Other reason: 4%. 

State: Indiana; 
Percentage of total caseload that is child-only: 20%; 
Parent receiving SSI: 42%; 
Parent is ineligible noncitizen: 4%; 
Parent is subject to sanctions: 13%; 
Nonparental caregivers: 41%; 
Other reason: 0%. 

State: Iowa; 
Percentage of total caseload that is child-only: 25%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Kansas; 
Percentage of total caseload that is child-only: 33%; 
Parent receiving SSI: 35%; 
Parent is ineligible noncitizen: 4%; 
Parent is subject to sanctions: 5%; 
Nonparental caregivers: 56%; 
Other reason: 0%. 

State: Kentucky; 
Percentage of total caseload that is child-only: 44%; 
Parent receiving SSI: 0%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 100%; 
Other reason: 0%. 

State: Louisiana; 
Percentage of total caseload that is child-only: 45%; 
Parent receiving SSI: 45%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 55%; 
Other reason: 0%. 

State: Maine; 
Percentage of total caseload that is child-only: 24%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Maryland; 
Percentage of total caseload that is child-only: 33%; 
Parent receiving SSI: 18%; 
Parent is ineligible noncitizen: 1%; 
Parent is subject to sanctions: 1%; 
Nonparental caregivers: 76%; 
Other reason: 5%. 

State: Massachusetts; 
Percentage of total caseload that is child-only: 37%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Michigan; 
Percentage of total caseload that is child-only: 32%; 
Parent receiving SSI: 54%; 
Parent is ineligible noncitizen: 3%; 
Parent is subject to sanctions: 3%; 
Nonparental caregivers: 40%; 
Other reason: 0%. 

State: Minnesota; 
Percentage of total caseload that is child-only: 21%; 
Parent receiving SSI: 47%; 
Parent is ineligible noncitizen: 11%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 40%; 
Other reason: 2%. 

State: Mississippi; 
Percentage of total caseload that is child-only: 45%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Missouri; 
Percentage of total caseload that is child-only: 25%; 
Parent receiving SSI: 50%; 
Parent is ineligible noncitizen: 1%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 49%; 
Other reason: 0%. 

State: Montana; 
Percentage of total caseload that is child-only: 22%; 
Parent receiving SSI: 37%; 
Parent is ineligible noncitizen: 7%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 56%; 
Other reason: 0%. 

State: Nebraska; 
Percentage of total caseload that is child-only: 31%; 
Parent receiving SSI: 64%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 36%; 
Other reason: 0%. 

State: Nevada; 
Percentage of total caseload that is child-only: 31%; 
Parent receiving SSI: 9%; 
Parent is ineligible noncitizen: 12%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 76%; 
Other reason: 3%. 

State: New Hampshire; 
Percentage of total caseload that is child-only: 29%; 
Parent receiving SSI: 30%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 51%; 
Other reason: 19%. 

State: New Jersey; 
Percentage of total caseload that is child-only: 34%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: New Mexico; 
Percentage of total caseload that is child-only: 15%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: New York; 
Percentage of total caseload that is child-only: 32%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: North Carolina; 
Percentage of total caseload that is child-only: 50%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: North Dakota; 
Percentage of total caseload that is child-only: 25%; 
Parent receiving SSI: 18%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 32%; 
Nonparental caregivers: 50%; 
Other reason: 0%. 

State: Ohio; 
Percentage of total caseload that is child-only: 45%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Oklahoma; 
Percentage of total caseload that is child-only: 44%; 
Parent receiving SSI: 34%; 
Parent is ineligible noncitizen: 6%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 60%; 
Other reason: 0%. 

State: Oregon; 
Percentage of total caseload that is child-only: 35%; 
Parent receiving SSI: 28%; 
Parent is ineligible noncitizen: 25%; 
Parent is subject to sanctions: 3%; 
Nonparental caregivers: 37%; 
Other reason: 7%. 

State: Pennsylvania; 
Percentage of total caseload that is child-only: 28%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Rhode Island; 
Percentage of total caseload that is child-only: 18%; 
Parent receiving SSI: 52%; 
Parent is ineligible noncitizen: 32%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 16%; 
Other reason: 0%. 

State: South Carolina; 
Percentage of total caseload that is child-only: 45%; 
Parent receiving SSI: 41%; 
Parent is ineligible noncitizen: 1%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 58%; 
Other reason: 0%. 

State: South Dakota; 
Percentage of total caseload that is child-only: 57%; 
Parent receiving SSI: 22%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 78%; 
Other reason: 0%. 

State: Tennessee; 
Percentage of total caseload that is child-only: 28%; 
Parent receiving SSI: 41%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 58%; 
Other reason: 0%. 

State: Texas; 
Percentage of total caseload that is child-only: 34%; 
Parent receiving SSI: 0%; 
Parent is ineligible noncitizen: 77%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 0%; 
Other reason: 23%. 

State: Utah; 
Percentage of total caseload that is child-only: 29%; 
Parent receiving SSI: 30%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 70%; 
Other reason: 0%. 

State: Vermont; 
Percentage of total caseload that is child-only: 16%; 
Parent receiving SSI: 56%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 44%; 
Other reason: 0%. 

State: Virginia; 
Percentage of total caseload that is child-only: 27%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Washington; 
Percentage of total caseload that is child-only: 32%; 
Parent receiving SSI: 28%; 
Parent is ineligible noncitizen: 21%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 48%; 
Other reason: 3%. 

State: West Virginia; 
Percentage of total caseload that is child-only: 31%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

State: Wisconsin; 
Percentage of total caseload that is child-only: 61%; 
Parent receiving SSI: 51%; 
Parent is ineligible noncitizen: 0%; 
Parent is subject to sanctions: 0%; 
Nonparental caregivers: 49%; 
Other reason: 0%. 

State: Wyoming; 
Percentage of total caseload that is child-only: 73%; 
Parent receiving SSI: [Empty]; 
Parent is ineligible noncitizen: [Empty]; 
Parent is subject to sanctions: [Empty]; 
Nonparental caregivers: [Empty]; 
Other reason: [Empty]. 

Source: GAO survey. 

[End of table] 

[End of section] 

Appendix II: State Funding Choices: 

Most states use some form of state MOE funding to provide cash 
assistance to families. Eighteen states relied solely on federal or 
commingled federal and state funds in their TANF programs to provide 
cash assistance, as shown in figure 4. The other 33 states used at 
least one of the state MOE funding options in addition to commingled 
funds: 7 had segregated state funds; 17 had separate state programs; 9 
had both segregated funds and separate state programs. 

Figure 4: Number of States That Use Different Funding Mechanisms to 
Expend State Funds on Cash Assistance: 

[Refer to PDF for image: pie-chart] 

States that only commingle state MOE funds: 18; 
States with state MOE and commingled funds: 33: 
* Segregated funding: 7 states; 
* Segregated funding and separate state programs: 9 states; 
(Total of 16 states with segregated funds); 
* Separate state program: 17 states; 
(Total of 26 states with separated state programs). 

Source: GAO survey. 

[End of figure] 

States across the nation have opted to use state MOE funds to provide 
cash assistance. (See Table 3.) States with larger caseloads are more 
likely to use segregated funds or separate state programs than smaller 
states; similarly, states with the smallest caseloads are more likely 
to commingle all of their state and federal funds. 

Table 3: Funding Streams in All States and the District and Columbia 

Commingled funds: 
Alaska; 
Arkansas; 
Colorado; 
Idaho; 
Iowa; 
Kansas; 
Kentucky; 
Louisiana; 
Michigan; 
Mississippi; 
North Carolina[A]; 
North Dakota; 
New Hampshire; 
Ohio; 
Oklahoma; 
South Carolina; 
South Dakota; 
West Virginia; 
Total: 18. 

Commingled + segregated state funds: 
Arizona; 
Massachusetts; 
Minnesota; 
Nebraska; 
Oregon; 
Pennsylvania; 
Washington; 
Total: 7. 

Commingled + separate state programs: 
Alabama; 
Georgia; 
Hawaii; 
Indiana; 
Maine; 
Missouri; 
Montana; 
Nevada; 
New Jersey; 
New Mexico; 
New York; 
Tennessee; 
Texas; 
Utah; 
Virginia; 
Wisconsin; 
Wyoming; 
Total: 17. 

Commingled + segregated + separate state programs: 
California; 
Connecticut; 
District of Columbia; 
Delaware; 
Florida[B]; 
Illinois; 
Maryland; 
Rhode Island; 
Vermont; 
Total: 9. 

[A] North Carolina uses only federal funds to provide cash assistance. 

[B] Florida has segregated and separate state programs but no 
federal/commingled. 

Source: GAO survey. 

[End of table] 

Even though two-thirds of the states have opted to use segregated 
funds, separate state programs, or both to provide cash assistance, 
only 11 percent of the total number of families receiving cash 
assistance is funded with these funds. 

[End of section] 

Appendix III: Percentage of TANF or MOE Families with Adult Recipients 
in Each State Not Subject to Federal or State Time Limits: 

State: Alabama; 
Percentage: 1%. 

State: Alaska; 
Percentage: 0%. 

State: Arizona; 
Percentage: 76%. 

State: Arkansas; 
Percentage: 0%. 

State: California; 
Percentage: 0%. 

State: Colorado; 
Percentage: 0%. 

State: Connecticut; 
Percentage: 27%. 

State: Delaware; 
Percentage: [A]. 

State: D.C.; 
Percentage: 2%. 

State: Florida; 
Percentage: 2%. 

State: Georgia; 
Percentage: 0%. 

State: Hawaii; 
Percentage: 27%. 

State: Idaho; 
Percentage: 0%. 

State: Illinois; 
Percentage: 34%. 

State: Indiana; 
Percentage: 7%. 

State: Iowa; 
Percentage: 0%. 

State: Kansas; 
Percentage: 1%. 

State: Kentucky; 
Percentage: 0%. 

State: Louisiana; 
Percentage: 0%. 

State: Maine; 
Percentage: 25%. 

State: Maryland; 
Percentage: 9%. 

State: Massachusetts; 
Percentage: 53%. 

State: Michigan; 
Percentage: 8%. 

State: Minnesota; 
Percentage: 10%. 

State: Mississippi; 
Percentage: 0%. 

State: Missouri; 
Percentage: 6%. 

State: Montana; 
Percentage: 0%. 

State: Nebraska; 
Percentage: 26%. 

State: Nevada; 
Percentage: 0%. 

State: New Hampshire; 
Percentage: 3%. 

State: New Jersey; 
Percentage: 0%. 

State: New Mexico; 
Percentage: 0%. 

State: New York; 
Percentage: 28%. 

State: North Carolina; 
Percentage: 0%. 

State: North Dakota; 
Percentage: 0%. 

State: Ohio; 
Percentage: 4%. 

State: Oklahoma; 
Percentage: 1%. 

State: Oregon; 
Percentage: 97%. 

State: Pennsylvania; 
Percentage: 2%. 

State: Rhode Island; 
Percentage: 6%. 

State: South Carolina; 
Percentage: 26%. 

State: South Dakota; 
Percentage: 0%. 

State: Tennessee; 
Percentage: 29%. 

State: Texas; 
Percentage: 0%. 

State: Utah; 
Percentage: 4%. 

State: Vermont; 
Percentage: 

State: Virginia; 
Percentage: 54%. 

State: Washington; 
Percentage: 0%. 

State: West Virginia; 
Percentage: 0%. 

State: Wisconsin; 
Percentage: 0%. 

State: Wyoming; 
Percentage: 6%. 

[A] Delaware was not able to provide us with data on the families 
excluded from time limits in its caseload. 

Source: GAO survey. 

[End of table] 

[End of section] 

Appendix IV: State-By-State Information on State Funding, Application 
of Time Limits, and Use of 20 Percent Extension: 

State: Alabama; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Alaska; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Arizona; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Arkansas; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: California; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Colorado; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Connecticut; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Delaware; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [A]. 

State: D.C. 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Florida; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Georgia; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Hawaii; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Idaho; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Illinois; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Indiana; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Iowa; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Kansas; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Kentucky; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Louisiana; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Maine; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Maryland; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Massachusetts; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Michigan; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Minnesota; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Mississippi; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Missouri; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Montana; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Nebraska; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Nevada; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: New Hampshire; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: New Jersey; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: New Mexico; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: New York; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Check]. 

State: North Carolina; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: North Dakota; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Ohio; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Oklahoma; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Oregon; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Pennsylvania; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Rhode Island; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: South Carolina; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: South Dakota; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Tennessee; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Texas; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Utah; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Vermont; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Virginia; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Washington; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: West Virginia; 
Have state MOE funds in segregated and separate state programs: 
[Empty]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Check]; 
Were using 20 percent extension at time of survey: [Check]. 

State: Wisconsin; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Check]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

State: Wyoming; 
Have state MOE funds in segregated and separate state programs: 
[Check]; 
Apply state time limit to some/all Families served through state MOE 
funds: [Empty]; 
Have not reached federal and/or state time limit at time of survey: 
[Empty]; 
Were using 20 percent extension at time of survey: [Empty]. 

Total: 
Have state MOE funds in segregated and separate state programs: 33 
states; 
Apply state time limit to some/all Families served through state MOE 
funds: 26 states; 
Have not reached federal and/or state time limit at time of survey: 22 
states; 
Were using 20 percent extension at time of survey: 15 states. 

[A] Delaware was not able to provide data on their use of the federal 
20 percent extension. 

Source: GAO survey. 

[End of table] 

[End of section] 

Related GAO Products: 

Welfare Reform: More Coordinated Federal Efforts Could Help States and 
Localities Move TANF Recipients with Impairments Toward 
Employment. [hyperlink, http://www.gao.gov/products/GAO-02-37]. 
Washington, D.C.: October 31, 2001. 

Welfare Reform: Challenges in Maintaining a Federal-State Fiscal 
Partnership. [hyperlink, http://www.gao.gov/products/GAO-01-828]. 
Washington, D.C.: August 10, 2001. 

Welfare Reform: Moving Hard-to-Employ Recipients Into the Workforce. 
[hyperlink, http://www.gao.gov/products/GAO-01-368]. Washington, D.C.: 
March 15, 2001. 

Welfare Reform: Work-Site-Based Activities Can Play an Important Role 
in TANF Programs. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-00-122]. Washington, D.C.: July 
28, 2000. 

Welfare Reform: Improving State Automated Systems Requires 
Coordinated Federal Effort. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-00-48]. Washington, D.C.: April 
27, 
2000. 

Welfare Reform: State Sanction Policies and Number of Families 
Affected. [hyperlink, http://www.gao.gov/products/GAO/HEHS-00-44]. 
Washington, D.C.: March 31, 2000. 

Welfare Reform: Assessing the Effectiveness of Various Welfare-to-Work 
Approaches. [hyperlink, http://www.gao.gov/products/GAO/HEHS-99-179]. 
Washington, D.C.: September 7, 1999. 

Welfare Reform: Information on Former Recipients’ Status. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-99-48]. Washington, D.C.: April 
28, 1999. 

Welfare Reform: States’ Experiences in Providing Employment 
Assistance to TANF Clients. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-99-22]. Washington, D.C.: 
February 26, 1999. 

[End of section] 

Footnotes: 

1. We visited California, Illinois, Maryland, and New York and 
conducted telephone interviews with Colorado, Hawaii, Florida, 
Michigan, Massachusetts, Mississippi, Texas, and Wisconsin. The states 
were selected to represent a range of factors, including variation in 
caseload size and in TANF program funding choices. The survey had a 
100 percent response rate, although each state did not respond to all 
questions. 

2. This represents the number of families receiving cash assistance 
during 1 month between October and December of 2001. 

3. “Assistance” does not include things like nonrecurrent, short-term 
benefits, such as rent deposits or appliance repairs; work subsidies; 
work supports such as child care or transportation subsidies for 
working families; or any other services such as counseling, case 
management, and peer support that do not provide basic income support. 

4. HHS has indicated that it would be inconsistent with statutory 
intent for states to simply remove adults from assistance units once 
they reach their 60-month time limit and then continue to use federal 
dollars to pay benefits to the children as a child-only unit. States 
may choose to use their MOE funds to do this. 

5. In calculating the federal 20 percent extension, child-only cases 
are included in the denominator but not in the numerator. All things 
being equal, the larger the percentage of child-only cases in a state’
s caseload, the greater the number of families with adults whose 
time limit may be extended. 

6. States can elect the Family Violence Option allowing states to 
waive any TANF requirement, under certain conditions, for victims of 
domestic violence. If a state elects the Family Violence Option and 
waives the time limits for such recipients and later faces a penalty 
for extensions that exceed the 20 percent cap, the state may qualify 
for a reasonable cause penalty exception. 

7. States may not penalize parents with children under age 6 for not 
working if child care is not available. States have the flexibility to 
exclude other categories of recipients from work requirements, 
although they cannot remove these individuals from the work 
participation calculation. 

8. States may choose to exempt parents with children under age 1 from 
calculation in the work participation rate. Work activities that count 
for federal participation rate purposes include employment, work 
experience programs, on-the-job training, community service, providing 
child care for other TANF recipients, job search, and (under certain 
circumstances) education and training. 

9. The two-parent work participation rate of 90 percent means that 
each two-parent family must participate in a federally defined work 
activity for an average of at least 35 hours per week and that a 
specified number of hours be attributable to specific work activities. 
A state may have one parent participate for all 35 hours, or both 
parents may share in the work activities. HHS issued penalties for not 
meeting the two-parent work participation rate in fiscal year 2000 to 
Alaska, Arkansas, Minnesota, Mississippi, New Mexico, North Carolina, 
and Wisconsin. 

10. Nineteen states have chosen a time limit shorter than 60 months as 
allowed by PRWORA, with the most common limit being 24 months. 

11. Connecticut has a small number of state-funded child-only cases 
that are subject to a state-imposed time limit on state-funded 
assistance. The time limit exclusion rules in Connecticut’s separate 
state program are the same for both recipient and non recipient 
parents. 

12. Some households may include parents who are illegal immigrants or 
legal immigrants ineligible for cash assistance in addition to 
children who are citizens and eligible for cash assistance. 

13. States can sanction individuals not complying with TANF program 
requirements by taking away part or all their TANF cash benefits and 
possibly other public benefits as well. 

14. For more information, see U.S. General Accounting Office, Welfare 
Reform: Moving Hard-to-Employ Recipients into the Workforce, 
[hyperlink, http://www.gao.gov/products/GAO-01-368] (Washington, D.C.: 
Mar. 15, 2001). 

15. For more information on TANF and persons with disabilities, see 
our report entitled: U.S. General Accounting Office, Welfare Reform: 
More Coordinated Federal Effort Could Help States and Localities Move 
TANF Recipients With Impairments Toward Employment, [hyperlink, 
http://www.gao.gov/products/GAO-02-37] (Washington, D.C.: Oct. 31, 
2002). 

16. The caseload reduction credit would also decrease the 90 percent 
work participation requirement for two-parent families; however, some 
states told us that they still moved two-parent families into separate 
state programs because they did not want to rely on caseload 
reductions to avoid a financial penalty. 

17. In our survey, we asked states to provide us information for the 
most recent month for which they had complete data. Most states 
reported numbers from a month in the first quarter of federal fiscal 
year 2002. 

18. Eight states exclude federally funded families from time limits 
because of pre-existing waivers to their welfare programs that allow 
them to exempt federally funded families from the federal time limit. 
These states are Arizona, Hawaii, Indiana, Nebraska, Oregon, South 
Carolina, Tennessee, and Virginia. In addition, Connecticut was 
operating under a waiver through September 2001. As a result, the 
federal clock did not start on federally funded families that were 
exempt from Connecticut’s state time limit until October 2001. 
Therefore, Connecticut can extend cash assistance to some of its 
federally funded families well beyond 60 months without using the 
federal 20 percent extension. 

19. States responded to our survey using their most recent month of 
data available—-generally a month in the first quarter of fiscal year 
2002 (October through December of 2001). 

20. For more information, see [hyperlink, 
http://www.gao.gov/products/GAO-01-368]. 

[End of testimony]