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Report to the Chairman, Subcommittee on Human Resources, Committee on 
Ways and Means, House of Representatives:

United States Government Accountability Office:

GAO:

September 2004:

TANF and SSI:

Opportunities Exist to Help People with Impairments Become More Self-
Sufficient:

GAO-04-878:

GAO Highlights:

Highlights of GAO-04-878, a report to the Chairman, Subcommittee on 
Human Resources, Committee on Ways and Means, House of Representatives: 

Why GAO Did This Study:

The nation’s social welfare system has been transformed into a system 
emphasizing work and personal responsibility, primarily through the 
creation of the Temporary Assistance for Needy Families (TANF) block 
grant. The Supplemental Security Income (SSI) program has expanded 
policies to help recipients improve self-sufficiency. Given that SSA 
data indicate an overlap in the populations served by TANF and SSI, 
and the changes in both programs, this report examines (1) the extent 
that TANF recipients with impairments are encouraged to apply for SSI 
and what is known about how SSI caseload growth has been affected by 
such TANF cases, (2) the extent that work requirements are imposed on 
TANF recipients applying for SSI, and the range of services provided 
to such recipients, and (3) the extent that interactions exist between 
the SSI and TANF programs to assist individuals capable of working to 
obtain employment.

What GAO Found:

In our nationwide survey of county TANF offices, we found that nearly 
all offices reported that they refer recipients with impairments to 
SSI, but the level of encouragement to apply for SSI varies. While 
almost all of the county TANF offices stated that they advise such 
recipients with impairments to apply for SSI, 74 percent also follow 
up to ensure the application process is complete, and 61 percent assist 
recipients in completing the application. Because TANF offices are 
referring individuals with impairments to SSI, these referrals will 
have some effect on the SSI caseload. However, due to data limitations, 
the magnitude of the effect these referrals have on SSI caseload growth 
is uncertain. While SSA can identify whether SSI recipients have income 
from other sources, it cannot easily determine whether this income 
comes from TANF or some other assistance based on need. In addition, 
past research has not found conclusive evidence regarding the impact 
that TANF referrals have on SSI caseload growth.

Estimates from our survey found that although some TANF offices impose 
work requirements on individuals with impairments, about 86 percent of 
all offices reported that they either sometimes or always exempt adult 
TANF recipients awaiting SSI determinations from the work requirements. 
One key reason for not imposing work requirements on these recipients 
is the existence of state and county TANF policies and practices that 
allow such exemptions. Nevertheless, county TANF offices, for the most 
part, are willing to offer noncash services, such as transportation and 
job training, to adult recipients with impairments who have applied for 
SSI. However, many recipients do not use these services. This low 
utilization may be related to exempting individuals from the work 
requirement, but it may also be due to the recipients’ fear of 
jeopardizing their SSI applications. Another reason for the low 
utilization of services is that many services are not necessarily 
available; budgetary constraints have limited the services that some 
TANF offices are able to offer recipients with impairments.

Many county TANF offices’ interactions with SSA include either having 
a contact at SSA to discuss cases or following up with SSA regarding 
applications for SSI. Interactions that help individuals with 
impairments increase their self-sufficiency are even more limited. In 
all the states we visited, we found that such interactions generally 
existed between TANF agencies and other agencies (such as the 
Departments of Labor or Education). In addition, 95 percent of county 
TANF offices reported that their interactions with SSA could be 
improved. State and county TANF officials feel they have to take the 
lead in developing and maintaining the interaction with SSA. One SSA 
headquarters official stated that SSA has no formal policy regarding 
outreach to TANF offices but would consider a partnership provided 
there is some benefit for SSA. Still, about 27 percent of county TANF 
offices reported that they were discouraged in their attempts to 
establish a relationship with SSA because staff at the local SSA field 
office told them that they did not have the time or the interest.

What GAO Recommends:

GAO recommends that SSA, in a new demonstration project, work with 
TANF officials to identify recipients with impairments capable of 
working and coordinate services to help them improve self-sufficiency. 
GAO also recommends that HHS use its Web site as a clearinghouse for 
information regarding opportunities for TANF agencies to work with SSA. 
Both SSA and HHS generally agreed with our recommendations.

www.gao.gov/cgi-bin/getrpt?GAO-04-878.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cindy M. Fagnoni (202) 
512-7215 fagnonic@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

TANF Recipients with Impairments Are Encouraged to Apply to SSI; Impact 
on SSI Caseload Growth Is Inconclusive:

TANF Offices Differ in Their Exemptions from Work Requirements, but 
Utilization of Noncash Services Is Generally Low:

Some Interaction Between County TANF Offices and SSA Exists, but 
Opportunities Exist for Improvement:

Conclusions:

Recommendations:

Agency Comments and Our Response:

Appendix I: Scope and Methods:

Appendix II: Comments from the Department of Health and Human Services:

Appendix III: Comments from the Social Security Administration:

Appendix IV: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Tables:

Table 1: County TANF Office Policies for Referring Adult Cash 
Recipients to SSI:

Table 2: Information Used by County TANF Offices to Determine whether 
to Refer Adult Recipients to SSI:

Table 3: Agencies or Programs That Support TANF Offices by Providing 
Services to At Least Some Adult TANF Cash Recipients Awaiting SSI 
Eligibility Determinations:

Abbreviations:

AFDC: Aid to Families with Dependent Children:

ALJ: Administrative Law Judge:

DDS: Disability Determination Service:

DI: Disability Insurance:

HHS: Department of Health and Human Services:

PRWORA: Personal Responsibility and Work Opportunity Reconciliation Act 
of 1996:

SSA: Social Security Administration:

SSI: Supplemental Security Income:

TANF: Temporary Assistance for Needy Families:

United States Government Accountability Office:

Washington, DC 20548:

September 15, 2004:

The Honorable Wally Herger: 
Chairman, Subcommittee on Human Resources: 
Committee on Ways and Means:
House of Representatives:

Dear Mr. Chairman:

Over the past several years, the nation's social welfare system has 
been transformed from a system emphasizing income support to one 
emphasizing work and personal responsibility. Central to this 
transformation was the creation of the Temporary Assistance for Needy 
Families (TANF) block grant in 1996. Administered by the Department of 
Health and Human Services (HHS), TANF provides states with $16.5 
billion each year. The Social Security Administration's (SSA) 
disability programs, including the Supplemental Security Income (SSI) 
program, have also recently expanded policies and initiated 
demonstration projects aimed at helping recipients enter the workforce 
and achieve self-sufficiency. SSI, which serves adults with low income 
and assets, paid about $18.6 billion in benefits in 2002 to about 3.8 
million working age (18-64) recipients with blindness or other 
disabilities.[Footnote 1]

SSA's disability determination process can be lengthy, extending over 2 
years when all administrative appeals are included. Concerns exist 
whether TANF recipients with impairments who are applying for SSI 
receive employment-related services while waiting for an eligibility 
determination. The disability management literature has emphasized that 
the longer an individual with an impairment remains out of the 
workforce the less likely the individual is to ever return to work. 
Providing such services in a timely manner also has implications for 
TANF recipients running up against the TANF program's 5-year time limit 
because in 2000, nearly 59 percent of all working age applicants for 
SSI were denied benefits.[Footnote 2]

While TANF caseloads have decreased since the program's inception, in 
1996, not all recipients leave TANF to go to work. Some recipients with 
impairments severe enough to qualify them for SSI leave TANF once they 
are determined eligible for SSI. SSA administrative data have shown an 
overlap in the populations served by TANF and SSI: Up to 25 percent of 
the SSI caseload age 18 to 64 received income assistance based on need 
(including TANF) prior to becoming eligible for SSI, and this figure 
has remained fairly stable over the past few years.[Footnote 3]

Given the new environment in which both programs have placed increased 
emphasis on encouraging recipients to find employment, and the overlap 
in both populations, this report examines (1) the extent to which TANF 
recipients with impairments are encouraged to apply for SSI and what is 
known about how SSI caseload growth has been affected by such TANF 
cases; (2) the extent to which work requirements are imposed by TANF 
agencies on their recipients who are applying for SSI, and the range of 
services TANF agencies provide to such recipients with impairments; and 
(3) the extent to which interactions exist between the SSI and TANF 
programs to assist individuals capable of working obtain employment.

To do this work, we conducted a mail survey of a stratified random 
sample of 600 county TANF offices,[Footnote 4] representative of county 
TANF offices nationwide. The survey gathered data on the extent that 
TANF recipients with impairments are encouraged to apply for SSI, 
whether work requirements are imposed and the type of services provided 
during the period of SSI eligibility determination, and the extent that 
interactions exist between the SSI and TANF programs. Our survey 
achieved an 88 percent response rate, and we weighted the results to 
generalize our findings to all county TANF offices nationwide.[Footnote 
5] To determine what is known about how SSI caseload growth has been 
affected by TANF referrals for SSI, we identified and reviewed reports 
studying this issue and assessed each study's findings. We also visited 
five states (Arizona, Colorado, Iowa, Oregon, and Vermont) known for 
providing employment-related services to TANF recipients with 
impairments, to gain an understanding of the types of interactions that 
exist between the SSI and TANF programs and to assess whether there are 
opportunities for improving these agencies' efforts at assisting their 
recipients with impairments into employment. In each of these states, 
we interviewed state and county TANF officials, and SSA field office 
staff, as well as SSA headquarters officials. We conducted our work 
between June 2003 and May 2004 in accordance with generally accepted 
government auditing standards. See appendix I for a more detailed 
discussion of our methods.

Results in Brief:

Estimates from our nationwide survey of county TANF offices indicated 
that almost all offices reported that they encourage at least some TANF 
recipients with impairments to apply for SSI, but the effect these TANF 
referrals have had on SSI caseload growth is inconclusive. In order to 
better serve individuals with impairments, nearly all TANF offices rely 
on one or more methods to identify impairments. Although nearly all 
county TANF offices reported that they refer recipients with 
impairments to SSI, the level of encouragement that these individuals 
receive to apply for SSI appears to vary. While almost all county TANF 
offices stated that they advise such recipients with impairments to 
apply for SSI, about 74 percent also follow up to ensure the 
application process is complete, and about 61 percent assist recipients 
in completing the application. Because TANF offices are referring 
individuals with impairments to SSI, these referrals will have some 
effect on the SSI caseload. However, due to data limitations, the 
magnitude of the effect these referrals have on SSI caseload growth is 
uncertain. While SSA can identify whether SSI applicants have income 
from other sources, it cannot easily determine whether this income 
comes from TANF or some other assistance based on need. Furthermore, 
SSA does not collect any data indicating whether an applicant is 
referred from another program. In addition, past research has not found 
conclusive evidence regarding the impact that TANF referrals have on 
SSI caseload growth.

Although some TANF offices impose work requirements on individuals with 
impairments, about 86 percent of all offices reported that they either 
sometimes or always exempt adult TANF recipients with impairments 
awaiting SSI eligibility determinations from the work requirement. One 
key reason, cited by some county TANF officials we interviewed, for not 
imposing work requirements on adult TANF recipients with impairments 
awaiting SSI is the existence of state or county TANF policies and 
practices that exempt recipients from the work requirements. 
Nevertheless, county TANF offices, for the most part, are willing to 
offer noncash services, such as transportation and job training, to 
adult recipients with impairments who have applied for SSI. However, 
our survey and interviews with state and county TANF officials indicate 
that many recipients do not use these services. This low utilization 
may be related to exempting individuals from the work requirement, but 
there are other reasons. Some TANF officials we interviewed in the 
states we visited said that one of the reasons recipients with 
impairments do not use these services is because of the recipient's 
fear of jeopardizing their SSI applications. Another reason for the low 
utilization of services is that many services are not necessarily 
available. Forty percent of county TANF offices noted that one of the 
reasons adult TANF recipients with impairments were not participating 
in work activities was an insufficient number of job training or 
related services. Some state and county TANF officials we interviewed 
indicated that budgetary constraints have also limited the services 
that they are able to offer recipients with impairments.

Interactions between TANF offices and SSA are limited. Our survey 
showed that some TANF offices have stated an interest in developing a 
relationship with SSA. However, estimates from our survey showed that 
53 percent of counties reported that their interactions included having 
a contact with SSA, and 64 percent reported that their interactions 
included following up with SSA regarding a recipient's application for 
SSI. According to our survey results and interviews with TANF officials 
in the states we visited, interactions that help individuals with 
impairments increase their self-sufficiency are limited. In the states 
we visited, we found that such interactions generally existed between 
TANF agencies and other agencies (such as the Department of Labor or 
Department of Education). Nevertheless, county TANF offices would like 
to improve their interactions with SSA, with 95 percent of county TANF 
offices reporting that their interactions could be improved. For 
example, about 57 percent of counties reported that receipt of training 
on the SSI application process and eligibility requirements is a useful 
interaction. However, only 6 percent of counties reported that they 
would like to improve interactions with SSA specifically related to 
providing SSA with information on employment-related services, such as 
vocational rehabilitation, that recipients received prior to applying 
for SSI. Some state and county TANF officials that we interviewed also 
said that they felt they had to take the lead in developing and 
maintaining interactions with SSA. One SSA headquarters official 
indicated that SSA has no formal policy regarding outreach to TANF 
offices but would consider such a partnership provided there is some 
benefit for SSA. The official also added that they will always respond 
to TANF training or information requests. However, about 27 percent of 
county TANF offices reported that they were discouraged in their 
attempts to establish a relationship with SSA because the local SSA 
field office told them that they did not have the time or the interest.

In order to help individuals with impairments increase self-sufficiency 
and to address the gap in continuous work services between TANF and 
SSI, we are recommending that SSA, as part of a new demonstration 
project, work with TANF agencies to identify those low-income 
individuals with impairments who while potentially eligible for SSI may 
also have the capacity to work, and coordinate services to increase the 
likelihood that such individuals can obtain employment and become more 
self-sufficient. In order to facilitate and encourage a sharing of 
information among TANF offices to increase self-sufficiency of 
recipients with impairments, we are recommending that HHS provide space 
on its Web site to serve as a clearinghouse for information regarding 
best practices and opportunities for TANF agencies to interact with 
SSA. HHS should be able to minimize its work and expense by using its 
Web site to share this information. Both SSA and HHS generally agreed 
with our recommendations and indicated that they look forward to 
working together to help low-income individuals with impairments become 
more self-sufficient.

Background:

The Personal Responsibility and Work Opportunity Reconciliation Act of 
1996 (PRWORA) replaced the individual entitlement to benefits under the 
61-year-old Aid to Families with Dependent Children (AFDC) program with 
TANF block grants to states and emphasized the transitional nature of 
assistance and the importance of reducing welfare dependence through 
employment. Administered by HHS, TANF provides states with $16.5 
billion each year,[Footnote 6] and in fiscal 2002, the total TANF 
caseload consisted of 5 million recipients. PRWORA provides states with 
the flexibility to set a wide range of TANF program rules, including 
the types of programs and services available and the eligibility 
criteria for them. States may choose to administer TANF directly, 
devolve responsibility to the county or local TANF offices, or contract 
with nonprofit or for-profit providers to administer TANF. Some states 
have also adopted "work first" programs, in which recipients typically 
are provided orientation and assistance in searching for a job; they 
may also receive some readiness training. Only those unable to find a 
job after several weeks of job search are then assessed for placement 
in other activities, such as remedial education or vocational training.

While states have great flexibility to design programs that meet their 
own goals and needs, they must also meet several federal requirements 
designed to emphasize the importance of work and the temporary nature 
of TANF aid. For example, TANF established stronger work requirements 
for those receiving cash benefits than existed under AFDC. Furthermore, 
to avoid financial penalties, states must ensure that a steadily rising 
specified minimum percentage of adult recipients are participating in 
work or work-related activities each year. To count toward the state's 
minimum participation rate, adult TANF recipients in families must 
participate in a minimum number of hours of work or a work-related 
activity a week, including subsidized or unsubsidized employment, work 
experience, community service, job search, providing child care for 
other TANF recipients, and (under certain circumstances) education and 
training. If recipients refuse to participate in work activities as 
required, states must impose a financial sanction on the family by 
reducing the benefits, or they may opt to terminate the benefits 
entirely. States must also enforce a 60-month limit (or less at state 
option) on the length of time a family may receive federal TANF 
assistance,[Footnote 7] although the law allows states to provide 
assistance beyond 60 months using state funds.[Footnote 8]

The TANF caseload includes, as did AFDC, low-income individuals with 
physical or mental impairments considered severe enough to make them 
eligible for the federal SSI program. Administered by SSA, SSI is a 
means-tested income assistance program that provides essentially 
permanent cash benefits[Footnote 9] for individuals with a medically 
determinable physical or mental impairment that has lasted or is 
expected to last at least 1 year or to result in death and prevents the 
individual from engaging in substantial gainful activity. To qualify 
for SSI, an applicant's impairment must be of such severity that the 
person is not only unable to do previous work but is also unable to do 
any other kind of substantial gainful work that exists in the national 
economy. Work is generally considered substantial and gainful if the 
individual's earnings exceed a particular level established by statute 
and regulations.[Footnote 10] SSA also administers the Disability 
Insurance program (DI), which uses the same definition of disability, 
but is not means-tested and requires an individual to have a sufficient 
work history.

For both DI and SSI, SSA uses the Disability Determination Service 
(DDS) offices to make the initial eligibility determinations.[Footnote 
11] If the individual is not satisfied with this determination, he or 
she may request a reconsideration of the decision with the same 
DDS.[Footnote 12] Another DDS team will review the documentation in the 
case file, as well as any new evidence, and determine whether the 
individual meets SSA's definition of disability. If the individual is 
not satisfied with the reconsideration, he or she may request a hearing 
before an Administrative Law Judge (ALJ). The ALJ conducts a new review 
and may hear testimony from the individual, medical experts, and 
vocational experts. If the individual is not satisfied with the ALJ 
decision, he or she may request a review by SSA's Appeals Council, 
which is the final administrative appeal within SSA.[Footnote 13] 
Despite recent improvements to the process, going through the entire 
process, including all administrative appeals, can average over 2 
years.

In most states, SSI eligibility also entitles individuals to Medicaid 
benefits. TANF recipients may apply for Medicaid benefits and are 
likely to qualify, but receipt of TANF benefits does not automatically 
qualify a recipient for Medicaid.

While SSA has recently expanded policies and initiated demonstration 
projects aimed at helping DI and SSI beneficiaries enter or return to 
the workforce and achieve or at least increase self-sufficiency, its 
disability programs remain grounded in an approach that equates 
impairment with inability to work. This approach exists despite medical 
advances and economic and social changes that have redefined the 
relationship between impairment and the ability to work. The disconnect 
between SSA's program design and the current state of science, 
medicine, technology, and labor market conditions, along with similar 
challenges in other programs, led GAO in 2003 to designate modernizing 
federal disability programs, including DI and SSI, as a high-risk area 
urgently needing attention and transformation.[Footnote 14]

The Ticket to Work and Work Incentives Improvement Act of 1999 amended 
the Social Security Act to create the Ticket to Work and Self-
Sufficiency Program (Ticket Program). This program provides most DI and 
SSI beneficiaries with a voucher, or "ticket," which they can use to 
obtain vocational rehabilitation, employment, or other return-to-work 
services from an approved provider of their choice. The program, while 
voluntary, is only available to beneficiaries after the lengthy 
eligibility determination process. Once an individual receives the 
ticket, he or she is free to choose whether or not to use it, as well 
as when to use it. Generally, disability beneficiaries age 18 through 
64 are eligible to receive tickets. The Ticket Program has been 
implemented in phases and is to be fully implemented in 2004.

The Social Security Advisory Board[Footnote 15] (Advisory Board) has 
questioned whether Social Security's definition of disability is 
appropriately aligned with national disability policy. The definition 
of disability requires that individuals with impairments be unable to 
work, but then once found eligible for benefits, individuals receive 
positive incentives to work.[Footnote 16] Yet the disability management 
literature has emphasized that the longer an individual with an 
impairment remains out of the workforce the more likely the individual 
is to develop a mindset of not being able to work and the less likely 
the individual is to ever return to work.[Footnote 17] Having to wait 
for return-to-work services until determined eligible for benefits may 
be inconsistent with the desire of some individuals with impairments 
who want to work but still need financial and medical assistance. The 
Advisory Board, in recognizing that these inconsistencies need to be 
addressed, has suggested some alternative approaches. One option they 
discussed in a recent report is to develop a temporary program, which 
would be available while individuals with impairments were waiting for 
eligibility determinations for the current program. This temporary 
program might have easier eligibility rules and different cash benefit 
levels but stronger and more individualized medical and other services 
needed to support a return to work.[Footnote 18]

SSA has also realized that one approach may not work for all 
beneficiaries, and in recent years it has begun to develop different 
approaches for providing assistance to individuals with disabilities. 
One example of these efforts is the proposed Temporary Allowance 
Demonstration, which would provide immediate cash and medical benefits 
for a specified period to individuals who meet SSA's definition of 
disability and who are highly likely to benefit from aggressive medical 
care. SSA is also in the process of developing the Early Intervention 
Demonstration. This demonstration project will test alternative ways to 
provide employment-related services to disability applicants. Although 
both of these demonstration projects only cover the DI program, SSA 
also has the authority to conduct other demonstration projects with SSI 
applicants and recipients.

TANF Recipients with Impairments Are Encouraged to Apply to SSI; Impact 
on SSI Caseload Growth Is Inconclusive:

Estimates from our nationwide survey of county TANF offices indicated 
that almost all offices reported that they refer at least some 
recipients with impairments to apply for SSI. But the level of 
encouragement these individuals receive from their local TANF office to 
apply for SSI varies, with many offices telling the individual to apply 
for SSI and some offices helping the recipient complete the 
application. Because TANF offices are referring individuals to SSI, 
these referrals will have some effect on the SSI caseload. However, 
findings regarding the impact that these SSI referrals from TANF have 
on SSI caseload growth are inconclusive, due to data limitations.

Nearly All County TANF Offices Refer Recipients with Impairments to 
Apply for SSI, but the Level of Encouragement Varies:

Based on estimates from our survey, 97 percent of all counties refer at 
least some of their adult TANF recipients with impairments to SSA to 
apply for SSI. As table 1 shows, 33 percent of county TANF offices said 
that it is their policy to refer to SSI only those adults whose 
impairments are identified as limiting or preventing their ability to 
work. However, another 32 percent of county TANF offices said that it 
is their policy to refer all TANF recipients identified with 
impairments to SSI for eligibility determinations.

Table 1: County TANF Office Policies for Referring Adult Cash 
Recipients to SSI:

Policy: Refer all recipients with impairments; 
Percent: 32%.

Policy: Refer based on criteria from SSI eligibility determination 
process; 
Percent: 13%.

Policy: Refer only those who are work limited; 
Percent: 33%.

Policy: No policy; 
Percent: 20%.

Source: Percentages are estimated from GAO survey of county TANF 
offices.

Note: Respondents were also given the option of indicating that their 
policy was something other than those listed above, and 2 percent of 
respondents indicated other.

[End of table]

TANF offices reported that they rely on several methods to identify an 
individual's impairment and assess whether the individual could work or 
should be referred to SSI. Estimates from our survey indicated that all 
county offices rely on the applicant to disclose his or her impairment. 
In addition, 96 percent of all counties rely on caseworker observation, 
about 57 percent use a screening tool, and about 60 percent use an 
intensive assessment.

Once recipients are identified as having impairments, TANF offices need 
to decide which individuals to refer to SSI. As table 2 shows, many 
counties rely on multiple forms of documentation or other information 
to make this decision, rather than referring all individuals with 
impairments. Specifically, 94 percent of all counties reported that 
they use documentation from a recipient's physician, and 95 percent 
reported that they use self-reported information from the recipient.

Table 2: Information Used by County TANF Offices to Determine Whether 
to Refer Adult Recipients to SSI:

Information: Documentation from recipient's physician; 
Percent: 94%.

Information: Documentation from medical professional other than a 
physician; 
Percent: 80%.

Information: Evaluation by an on-site or vendor medical professional; 
Percent: 31%.

Information: Evaluation of recipient's ability to work by state 
vocational rehabilitation worker; 
Percent: 70%.

Information: Informal evaluation by caseworker or social worker; 
Percent: 85%.

Information: Documented evaluation by caseworker; 
Percent: 49%.

Information: Behavior observed by caseworker; 
Percent: 82%.

Information: Self-reported information from recipient; 
Percent: 95%.

Source: Percentages are estimated from GAO survey of county TANF 
offices.

[End of table]

While nearly all county TANF offices reported that they refer at least 
some individuals with impairments to SSI, the level of encouragement 
such individuals receive from their local TANF office appears to vary. 
About 98 percent of county TANF offices reported that they tell these 
recipients to call or go to SSA to apply for SSI. About 61 percent 
reported that they will also assist a recipient in completing the SSI 
application, and about 74 percent reported that they follow up to 
ensure the application process is complete. Some of the variation in 
the level of encouragement may be explained by the fact that some 
states are work first states. Officials we interviewed in four states 
acknowledged that they try to get all TANF recipients to work, 
including recipients with impairments. Therefore, while they make 
referrals to SSI, officials in these work first states told us that 
they try to encourage work more than the SSI application 
process.[Footnote 19] However, officials in all five of the states we 
visited stated that if they feel an individual has a severe impairment, 
they would have the individual apply for SSI.

Findings About How SSI Caseload Growth Has Been Affected by Referred 
TANF Recipients with Impairments Are Inconclusive due to Data 
Limitations:

Since county TANF offices refer individuals with impairments to SSI, 
these referrals will have some effect on the SSI caseload. To determine 
the magnitude of the effect that these TANF referrals have had on SSI 
caseload growth, SSA would need to know who among their applicants are 
TANF recipients. However, SSA headquarters officials told us that the 
agency does not know who is referred or how people are referred because 
it does not collect those data. Although the SSI application 
specifically asks whether the applicant is receiving TANF, this 
information is combined with other income assistance based on need in 
SSA's database.[Footnote 20] Therefore, while the working age (18-64) 
SSI caseload has increased 33 percent over the last decade, SSA does 
not have an easy way to accurately determine the magnitude of the 
effect that the TANF referrals have had on the growth of the SSI 
rolls.[Footnote 21]

Also, in a study funded by SSA and conducted by The Lewin Group, 
researchers found little, if any, evidence that TANF had increased 
referrals to SSI.[Footnote 22] Only one of the five states the 
researchers visited remarked of a perceptible increase in transitions 
to SSI. The authors noted that the likely reason for not finding a 
significant increase in referrals due to welfare reform is the fact 
that referrals to SSI had already been occurring under AFDC, and that 
the full impact of the welfare reform changes would not be known until 
the time limit for benefit receipt had elapsed.[Footnote 23] However, 
to date there have not been any studies that looked at this issue.

In addition to SSA not knowing the magnitude of the effect that TANF 
referrals have had on SSI caseload growth, TANF officials we 
interviewed stated that they generally do not have historical data on 
SSI referrals, approvals, and denials. But officials in most states 
that we visited said they are in the process of improving their data 
collection in this respect, including tracking methods to determine the 
status of an SSI application, which should provide them with better 
data in the future.

TANF Offices Differ in Their Exemptions from Work Requirements, but 
Utilization of Noncash Services Is Generally Low:

TANF offices vary in whether they make work requirements mandatory for 
their adult recipients with impairments awaiting SSI eligibility 
determinations. Even though estimates from our survey showed that 83 
percent of county TANF offices reported offering noncash services to 
TANF recipients with impairments who are awaiting SSI eligibility 
determinations, these services may not be available or are not fully 
utilized. Reasons for this low service utilization may include 
exemptions from the work requirements and an insufficient number of job 
training or related services.

Work Requirements Are Not Always Mandatory for Those TANF Recipients 
with Impairments Awaiting SSI Eligibility Determinations:

Estimates from our survey showed that about 86 percent of county TANF 
offices have policies that always or sometimes exempt from the work 
requirements adult TANF recipients with impairments who are referred to 
SSI for eligibility determinations. Also, about 31 percent of county 
TANF offices consider the number of times a recipient is denied and 
appeals an SSI decision as a factor when deciding to exempt recipients 
from the work requirements.

Our survey further found that 82 percent of counties reported exempting 
recipients, in part, on the basis of the degree to which the impairment 
limits the recipient's ability to work. In addition, about 69 percent 
of county TANF offices reported that the severity of the impairment was 
a major factor in their decisions to exempt people with impairments who 
are awaiting SSI determinations from work requirements. One TANF 
official we interviewed told us that the recipients' impairments were 
too great to participate in work activities.

However, some of the state and county TANF officials we interviewed 
explained that they have developed alternative practices to help 
recipients with impairments participate in work activities. TANF 
officials from two of the states we visited told us that they have 
developed a modified work requirement for adult TANF recipients with 
impairments.[Footnote 24] A TANF official from one of these states said 
that the modified work requirements encourage individuals with 
impairments to work, but they do not expect that these individuals will 
be able to work in a full-time capacity. One county TANF official we 
interviewed explained that the work requirements and services provided 
for their recipients with impairments are very individualized, based on 
recommendations of the doctors who meet with the recipients. However, 
in all of the states and counties we visited, TANF officials said that 
individualized services can be costly. One state official said that his 
state's program does not have the funds to pay for the training needed 
by people with learning disabilities. The official added that when 
people with impairments need substantial help, there were limits as to 
what could be funded in a work first state.

A Broad Range of Services Are Offered to Recipients Awaiting SSI 
Determinations, but Utilization Is Low:

Even though about 51 percent of county TANF offices do not require 
adult TANF recipients awaiting SSI determinations to participate in any 
type of job services, education services, work experience programs, or 
other employment services, 83 percent of county TANF offices reported 
that they are still willing to provide work-related or support services 
to this population. One state official we interviewed reported that the 
services provided are the same for persons with or without impairments. 
Officials in this state explained that these services include 
transportation, child care, medical assistance, tuition assistance, 
vocational rehabilitation, and assistance with obtaining SSI benefits.

Even though county TANF offices may be willing to offer noncash 
services to their recipients, among those counties that could provide 
us with information on service utilization, utilization of these 
services tended to be low. While the low utilization of services may be 
due to exemptions from the work requirements, service availability may 
also be an issue. Estimates from our survey showed that 40 percent of 
county TANF offices reported one of the reasons adult TANF recipients 
with impairments, who are awaiting SSI eligibility determinations, are 
not participating in work activities is that there are an insufficient 
number of job training or related services available for them to use. 
In addition, some TANF officials that we interviewed cited not only 
limited funding, but also their offices' own TANF policies as factors 
that might explain why services may not be available to recipients with 
impairments. For example, a state TANF official we interviewed said 
that state budget cuts have resulted in trimming of support services 
made available to recipients. Another state official explained that 
adult recipients with impairments who are placed in an exempted status 
are allowed access to medical services but not work-related support 
services, such as transportation, clothing, or vehicle repairs. The 
official further explained that those services are limited to those 
individuals who are in work activities.

In addition, estimates from our survey showed that 50 percent of county 
TANF offices reported recipients' motivation to apply for SSI was one 
of the conditions that might challenge or hinder their offices in 
providing employment services. Some state and county TANF officials we 
interviewed also believe that one of the main reasons why there is low 
utilization of services is recipients' fear of jeopardizing their SSI 
applications. While participation in a work activity does not 
necessarily preclude an individual from obtaining disability benefits 
from SSA, estimates from our survey showed that 41 percent of county 
TANF offices reported that their recipients with impairments, awaiting 
SSI eligibility determinations, are unsure whether or not the 
demonstration of any work ability would hinder or disqualify their 
chances for SSI eligibility. State and county TANF officials we 
interviewed explained that recipients applying for SSI or awaiting an 
SSI decision fear participating in work activities. Some of the county 
TANF officials we interviewed explained that this population does not 
want to participate in work-related services for fear of jeopardizing 
their applications. These officials noted that compounding recipients' 
fears are attorneys who may be attempting to protect their clients' 
interests by sending TANF offices notices saying that any work activity 
could jeopardize their clients' SSI applications. These fears have led 
to TANF workers having some difficulty in getting their recipients with 
impairments to explore work options during the time they are applying 
for SSI. One state TANF official we interviewed pointed out that 
conversations with their recipients about work activities have 
generally occurred because the recipients want to volunteer for such 
activities. A county TANF official explained that there is a challenge 
in providing work services to this population, as the recipients are so 
focused on getting on SSI that it is difficult to get them to focus on 
anything else.

Yet another reason for the low use of noncash service is that some of 
the county TANF officials we interviewed expressed some uncertainty as 
to how to best serve their adult TANF recipients with impairments, 
explaining that they are sending mixed signals when it comes to 
encouraging work. One county TANF official we interviewed said that on 
one hand, recipients are being told about using TANF services to obtain 
employment, and then, on the other hand, recipients are being told to 
apply for SSI benefits, which require an applicant to focus on his or 
her inability to work. Some TANF offices also allow TANF recipients 
with impairments to count applying for SSI as a work activity. 
Estimates from our survey showed that about 30 percent of county TANF 
offices reported that they consider the SSI application process an 
activity that satisfies the work requirement. Also, another county 
official we interviewed stated that if a client goes into an exempted 
status, the client must participate in at least one activity a week, 
but not necessarily a work activity. It can be any service the TANF 
office has to offer, including physical therapy or assistance in 
completing the SSI application.

Some Interaction Between County TANF Offices and SSA Exists, but 
Opportunities Exist for Improvement:

Some county TANF offices have developed interactions with SSA offices, 
but such interactions have been of a limited nature and have focused on 
the SSI application process. Estimates from our survey indicated that 
some TANF offices have some form of interaction with SSA. Estimates 
from our survey also showed that two frequently reported forms of 
interaction between county TANF offices and SSA include having a 
contact at SSA with whom to discuss cases and following up with SSA 
regarding applications for SSI.

In describing his office's interactions with SSA, one state TANF 
official we interviewed said that his office, SSA, and DDS have a good 
working relationship, which includes cross training between the 
agencies and discussions concerning the SSI application process. 
However, estimates from our survey showed about 95 percent of county 
TANF offices reported that they would like to develop a relationship, 
or improve their relationship, with their local SSA field office with 
regard to adult TANF recipients applying for SSI. One state TANF 
official that we interviewed said that his office does not have much of 
a relationship with SSA. He noted that he had no contacts within SSA 
but would like to develop a formal relationship with DDS so that they 
could make faster determinations for the deferred TANF caseload. A 
county TANF official we interviewed said that her office's 
communication with SSA is largely one-sided. This TANF official 
explained that even though her office sends documentation that supports 
a recipient's SSI application, SSA does not inform them of any 
eligibility decisions it makes with TANF applicants. As a result, TANF 
staff must rely on their recipients telling them about decisions or on 
a computer system that indicates if an individual is receiving 
benefits. Finally, in all of the states we visited, TANF officials told 
us that they interact with SSA to assist their TANF recipients with 
impairments get onto SSI. Estimates from our survey also showed that 64 
percent of counties reported that their interactions were TANF 
officials following up with SSA regarding a recipient's SSI 
application, and 53 percent reported having a contact at SSA to discuss 
cases.

TANF offices identified a number of ways they would like to improve 
interactions with SSA, but most of these focused on making the SSI 
application process more efficient and not on working together to 
assist TANF recipients with impairments toward employment and self-
sufficiency. Estimates from our survey showed about 57 percent of the 
county TANF offices said that they would like to receive training from 
SSA regarding the SSI application process and eligibility requirements, 
50 percent said they would like to have a contact at SSA with whom to 
discuss cases, and 41 percent said they would like to have regular 
meetings or working groups with SSA regarding interactions and other 
issues related to serving low-income individuals with impairments. In 
addition, one TANF official we interviewed would like interactions with 
SSA to be improved and thinks they could be if he knew what DDS was 
looking for in the application process, such as what it requires for 
evidence. In contrast, only 6 percent of county TANF offices reported 
that they would like to improve interactions with SSA specifically 
related to providing SSA with information on employment-related 
services received while on TANF.

Although TANF offices reported an interest in developing a close 
working relationship with SSA, based on their interactions with SSA, 
some state and county TANF officials believed that they had to take the 
lead in developing these relationships. For example, one TANF official 
we interviewed explained that he had attempted to make contact with SSA 
to discuss a potential partnership and address some of the county's 
issues with the SSI application process but received no response. The 
county official then wrote a letter to a top SSA regional official 
asking about partnering opportunities. In response, the regional 
official instructed the SSA area director, along with the local SSA and 
state DDS office, to meet with county officials.

One SSA headquarters official we interviewed told us there is no SSA 
policy that directs or encourages their field offices to interact with 
TANF offices. The official also told us that SSA would consider such a 
partnership with TANF offices but would want assurances of what the 
benefits would be for SSA. In addition, the official said that the 
agency does not want to start up a partnership that would overly tax 
its already high workloads. The official further said that if it were 
to develop a relationship with TANF offices, SSA would then have to 
develop a training program and then administer it to all operations 
personnel. The official noted that developing and administering such a 
training program would not be a small task. SSA officials did state 
that if a TANF office makes a request for training sessions, SSA would 
be willing to provide training on the application process. However, 
about 27 percent of county TANF offices reported that they were 
discouraged in their attempts to establish a relationship with SSA 
because the local SSA field office told the TANF office that SSA did 
not have the time or the interest.

While officials at SSA headquarters stated that they are largely 
unaware of any partnerships or interactions between TANF offices and 
local SSA field offices, some local SSA officials have found such 
relationships beneficial. In particular, one SSA official has found his 
office's relationship with the local TANF office to be a form of 
outreach for SSA by helping his office identify people who would 
qualify for SSI. He explained that his local SSA office does not always 
have the time or staff to conduct outreach. He further explained that 
TANF case managers can explain the benefits and provide assistance to 
the TANF recipient applying for SSI. Thus, when a letter comes from the 
DDS that initially denies the claim, the individual is less likely to 
throw it away, as he or she is more aware of the process. This could 
save SSA time and money as the applicant knows that he or she must 
appeal within a certain amount of time, thereby reducing the need to 
start over because of missed deadlines.

While 34 percent of those county TANF offices that provide services to 
recipients awaiting SSI eligibility determinations reported 
interacting with SSA in some manner to serve adult TANF recipients with 
impairments, a much higher proportion reported receiving assistance 
from other agencies or programs. For example, as table 3 shows, 91 
percent of county TANF offices reported that at least some of their 
recipients awaiting SSI determinations received assistance from the 
state vocational rehabilitation agencies, and 86 percent of all offices 
reported that at least some of their recipients received assistance 
from the state or local mental health agency. Further, in all of the 
states we visited, TANF offices reported working with other agencies, 
such as the Department of Education and the Department of Labor, to 
help TANF recipients with impairments find work.

Table 3: Agencies or Programs That Support TANF Offices by Providing 
Services to At Least Some Adult TANF Cash Recipients Awaiting SSI 
Eligibility Determinations:

Agencies: State Vocational Rehabilitation; 
Percent: 91%.

Agencies: Other U.S. Department of Education Programs; 
Percent: 67%.

Agencies: Social Security Administration; 
Percent: 34%.

Agencies: U.S. Department of Labor; 
Percent: 69%.

Agencies: State or Local Mental Health Agency; 
Percent: 86%.

Agencies: Community Programs; 
Percent: 67%.

Agencies: Other; 
Percent: 9%.

Agencies: None; 
Percent: 1%.

Source: Percentages are estimated from GAO survey of county TANF 
offices.

[End of table]

Conclusions:

With the new emphasis on work and self-sufficiency taken by TANF and 
SSI, and the overlap in the populations served by both programs, 
opportunities exist to improve the way these two programs interact in 
order to help individuals with impairments become more self-sufficient. 
While some interactions between TANF offices and SSA do exist, they are 
often limited to how best to assist a TANF recipient with impairments 
become eligible for essentially permanent cash benefits under SSI. 
Moreover, the practice by most TANF offices of exempting individuals 
from work requirements while awaiting SSI eligibility determination, as 
well as SSA's policy of offering return-to-work services and incentives 
only after a lengthy eligibility process, undermines both programs' 
stated goals of promoting self-sufficiency. In addition, this practice 
runs counter to the disability management literature that has 
emphasized that the longer an individual with an impairment remains out 
of the workforce the less likely the individual is to ever return to 
work. In recognition of this, SSA is planning demonstration projects 
that will test alternative ways to provide benefits and employment 
supports to DI applicants. However, TANF recipients with impairments, 
because of their low income and assets, are more likely to apply and 
qualify for SSI. Moreover, TANF recipients with impairments often 
receive assessments of their conditions and capacity to work while on 
TANF. Since SSA cannot easily identify who among its applicants are 
TANF recipients, SSA is also unable to systematically identify the 
types of services that the SSI applicant may have received through TANF 
or know whether the SSI applicant has been assessed as having the 
capacity to work or not. Being able to identify the receipt of TANF 
benefits, as well as the noncash services received through TANF, may 
help SSA accomplish its mission of promoting the employment of 
beneficiaries with impairments. By sharing information and establishing 
better working relationships with TANF agencies, SSA could identify, 
among its applicants who are or were TANF recipients, those individuals 
capable of working and could then target them for employment-related 
services and help them achieve self-sufficiency or at least reduce 
their dependency on cash benefits. Although the disconnect in work 
requirements between TANF and SSA's disability programs and the timing 
of when employment-related services are provided to SSI recipients 
could be barriers to establishing a continuity of services, the earlier 
provision of employment-related services, as part of a demonstration 
project, could mitigate these potential barriers.

While some county TANF officials we interviewed have developed working 
relationships with their local SSA office, other counties have not or 
may be unaware of the possibilities for interactions with SSA and how 
to go about establishing these relationships. Sharing best practices 
about how TANF agencies can distinguish, among the recipients they have 
referred to SSI, those individuals without the capacity to work from 
those with the capacity to work and who could benefit from employment-
related services could help ensure that those individuals with work 
capacity be given the assistance they need to help them obtain 
employment. Moreover, sharing best practices for establishing useful 
interactions with SSA could help ensure that employment-related 
services could continue after the person becomes eligible for SSI.

Recommendations:

To help individuals with impairments become more self-sufficient and to 
address the gap in continuous work services between the TANF and SSI 
programs, we are recommending that SSA, as part of a new demonstration 
project, work with TANF offices to develop screening tools, 
assessments, or other data that would identify those TANF recipients 
with impairments who while potentially eligible for SSI may also be 
capable of working. Once these recipients have been identified, the 
TANF offices and SSA could work together to coordinate aggressive 
medical care and employment-related services that would help the 
individual obtain employment and achieve or at least increase self-
sufficiency.

In order to facilitate and encourage a sharing of information among 
TANF offices regarding the development of interactions with SSA that 
might increase self-sufficiency of recipients with impairments, we are 
recommending that HHS provide space on its Web site to serve as a 
clearinghouse for information regarding best practices and 
opportunities for TANF agencies to interact with SSA. This would allow 
state and county TANF officials to share information on what they are 
doing, what works, and how to go about establishing relationships with 
SSA. It would also provide states and counties with access to the 
research of federal agencies, state and county offices, and other 
researchers that they may need in order to develop a strong functional 
relationship with SSA and help TANF recipients with impairments move 
toward economic independence. HHS should be able to minimize its work 
and expense by using its Web site to share this information.

Agency Comments and Our Response:

We provided a draft of this report to HHS and SSA for comment. Both 
agencies generally agreed with our recommendations and indicated that 
they look forward to working together to help low-income individuals 
with impairments become more self-sufficient. Specifically, SSA stated 
that it would be pleased to work with HHS on the planning and design of 
a demonstration project. Likewise, HHS stated that it would be pleased 
to have its staff work with SSA to develop a process or criteria for 
identifying individuals who could benefit from employment services.

In addition, in response to the findings of our report, SSA said it 
would take immediate measures to ensure that it responds to all 
requests from TANF offices for training on SSA's programs.

Also in its comments, SSA suggested that we include in our report the 
fact that states may exempt up to 20 percent of their caseload from the 
time limits and that many states waive work requirements for persons 
applying for SSI. In both the draft we sent to SSA and the final 
version, we included a footnote explaining the time limit exemptions, 
and in the body of the report we discussed the issue of work 
requirement exemptions for persons applying for SSI.

HHS' comments appear in appendix II and SSA's comments appear in 
appendix III. In addition, both HHS and SSA provided technical 
comments, which we have incorporated as appropriate.

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution until 30 days after the date 
of this letter. At that time, we will send copies to the Secretary of 
HHS, the Commissioner of Social Security, appropriate congressional 
committees, and other interested parties. The report is also available 
at no charge on GAO's Web site at http://www.gao.gov. If you have any 
questions about this report, please contact me or Carol Dawn Petersen 
on (202) 512-7215. Other staff who made key contributions are listed 
in appendix IV.

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

[End of section]

Appendix I: Scope and Methods:

To determine the extent that Temporary Assistance for Needy Families 
(TANF) recipients with impairments are encouraged to apply for 
Supplemental Security Income (SSI), whether work requirements are 
imposed, the range of services provided during the period of SSI 
eligibility determination, and the extent that interactions exist 
between the SSI and TANF programs, we conducted a nationally 
representative survey of 600 county TANF administrators from October 
14, 2003, through February 20, 2004.

For the most part, TANF services are provided at the county level, so 
we selected a random probability sample of counties for our survey. We 
derived a nationwide listing of counties from the U.S. Bureau of the 
Census's county-level file with 2000 census data and yearly population 
estimates for 2001 and 2002. We selected a total sample of 600 counties 
out of 3,141 counties. To select this sample, we stratified the 
counties into two groups. The first group consisted of the 100 counties 
in the United States with the largest populations, using the 2002 
estimates. The second group consisted of the remaining counties in the 
United States. We included all of the 100 counties with the largest 
populations in our sample to ensure that areas likely to have large 
concentrations of TANF recipients were represented. From the second 
group, consisting of all the remaining counties, we selected a random 
sample of 500 counties.

After selecting the sample of counties, we used the American Public 
Human Services Association's Public Human Services Directory (2002-
2003) to determine the name and address of the TANF administrator for 
each county. In states with regional TANF programs, we asked the 
regional director to fill out a questionnaire for each county in the 
region. We obtained responses from 527 of 600 counties, for an overall 
response rate of about 88 percent.[Footnote 25] The responses are 
weighted to generalize our findings to all county TANF offices 
nationwide. Sample weights reflect the sample procedure, as well as 
adjusting for nonresponse.

Because we followed a probability procedure based on random selections, 
our sample is only one of a large number of samples that we might have 
drawn. Since each sample could have provided different estimates, we 
express our confidence in the precision of our particular sample's 
results at a 95 percent confidence level at an interval of plus or 
minus 5 percentage points. This is the interval that would contain the 
actual population value for 95 percent of the samples we could have 
drawn. In other words, we are 95 percent confident the confidence 
interval will include the true value of the study population.

In addition to the reported sampling errors, the practical difficulties 
of conducting any survey may introduce other types of errors, commonly 
referred to as nonsampling errors. For example, differences in how a 
particular question is interpreted, the sources of information 
available to respondents, or the types of people who do not respond can 
introduce unwanted variability into the survey results. We included 
steps in both the data collection and data analysis stages for the 
purpose of mitigating such nonsampling errors.

[End of section]

Appendix II: Comments from the Department of Health and Human Services:

DEPARTMENT OF HEALTH & HUMAN SERVICES:

Office of Inspector General:

Washington, D.C. 20201:

AUG 23 2004:

Ms. Cynthia M. Fagoni: 
Managing Director, 
Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
Washington, D.C. 20548:

Dear Ms. Fagoni:

Enclosed are the Department's comments on your draft report entitled, 
"TANF and SSI - Opportunities Exist to Help People with Impairments 
Become More Self-Sufficient" (GAO-04-878). The comments represent the 
tentative position of the Department and are subject to reevaluation 
when the final version of this report is received.

The Department provided several technical comments directly to your 
staff.

The Department appreciates the opportunity to comment on this draft 
report before its publication.

Sincerely,

Signed by: 

Lewis Morris:

Chief Counsel to the Inspector General:

Enclosure:

The Office of Inspector General (OIG) is transmitting the Department's 
response to this draft report in our capacity as the Department's 
designated focal point and coordinator for Government Accountability 
Office reports. OIG has not conducted an independent assessment of 
these comments and therefore expresses no opinion on them.

COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) ON THE 
GOVERNMENT ACCOUNTABILITY OFFICE'S (GAO's) DRAFT REPORT ENTITLED "TANF 
AND SSI--OPPORTUNITIES EXIST TO HELP PEOPLE WITH IMPAIRMENTS BECOME 
MORE SELF-SUFFICIENT" (GAO-04-878):

General Comments:

HHS appreciates the opportunity to comment on GAO's draft report. HHS 
is in general agreement with GAO's conclusions and would like to see 
States establishing closer relationships with Social Security 
Administration (SSA) offices in order to improve services for those 
potentially eligible for Supplemental Security Income (SSI). The 
Temporary Assistance for Needy Families (TANF) program seeks to help 
each of its clients achieve the highest degree of self-sufficiency 
possible. Doing this requires properly assessing both the abilities and 
limitations of disabled clients and finding, when possible, appropriate 
work settings and training that can give each client the opportunity to 
work. When possible, clients who have impairments should not be 
exempted from work activities but helped to find accommodating settings 
through which they could provide for their families. At the same time, 
TANF provides important assistance in helping interested clients apply 
for SSI.

It is important, however, to appreciate that TANF efforts to promote 
maximum family self-sufficiency through work while helping some clients 
apply for SSI are inherently in conflict. Since SSI is intended for 
clients who cannot provide for themselves through work, participation 
in accommodating work activities while on TANF can be used as evidence 
against a client's application for SSI. Therefore, when TANF agencies 
assess a client as being potentially SSI eligible, efforts at helping 
such clients pursue work are frequently abandoned.

Opportunities exist for better coordination and collaboration among 
TANF and SSI offices during the application process and afterwards to 
help individuals with impairments pursue work training, return to work 
services, and become more self-sufficient. We would be pleased to have 
ACF work with SSA to develop a process or criteria for identifying 
individuals who could benefit from employment services.

GAO Recommendation:

To help individuals with impairments become more self-sufficient and to 
address the gap in continuous work services between the TANF and SSI 
programs, we are recommending that SSA, as part of a new demonstration 
project, work with TANF offices to develop screening tools, 
assessments, or other data that would identify those TANF recipients 
with impairments who while potentially eligible for SSI may also be 
capable of working. Once these recipients have been identified, the 
TANF offices and SSA could work together to coordinate aggressive 
medical care and employment-related services that would help the 
individual obtain employment and achieve or at least increase self-
sufficiency.

HHS Comment:

While this recommendation is directed to SSA, ACF welcomes the 
opportunity to work with SSA on developing model screening tools, 
assessments, or other data that would be useful in matching clients to 
appropriate work settings.

GAO Recommendation:

In order to facilitate and encourage information sharing among TANF 
offices regarding the development of interactions with SSA that might 
increase self-sufficiency of recipients with impairments, we are 
recommending that HHS provide space on its website to serve as a 
clearinghouse for information regarding best practices and 
opportunities for TANF agencies to interact concerning SSA. This would 
allow State and county TANF officials to share information concerns 
what they are doing, what works, and how to go about establishing 
relationships with SSA. It would also provide States and counties with 
access to the research of Federal agencies, State and county offices, 
and other researchers that they may need in order to develop a strong 
functional relationship with SSA and help TANF recipients with 
impairments move toward economic independence. HHS should be able to 
minimize its work and expense by using its website to share this 
information.

HHS Comment:

ACF's Office of Family Assistance (OFA) website already offers a 
connection to OFA's Welfare Peer Technical Assistance Network. The 
network provides peer technical assistance to other agencies and 
solicits innovative programs and practices under a variety of headings. 
OFA will explore establishment of a new category of TANF/SSI 
interaction and solicit information that will be useful.

Based on SSA data which states that up to 25 percent of the SSI 
caseload ages 18-64 received income assistance based on need (including 
TANF), the report (see Highlights section and page 2) indicates that 
there is "overlap" between the SSI and TANF populations. In fact, all 
States prohibit individuals receiving SSI benefits from simultaneously 
receiving TANF benefits; thus, what is being described as an "overlap" 
is a subset of the SSI population who used to receive TANF benefits. It 
would be helpful to clarify whether the data cited in the report were 
collected at the time of application for SSI and whether they include 
benefits received for other family members, as a parent may receive SSI 
on his/her own behalf and TANF on behalf of his/her children.

The report (see page 12) cites a 2000 report finding little increase in 
referrals to SSI from TANF in the wake of welfare reforms, but also 
states, "...the full impact of the welfare reform changes would not be 
known until the time limit for benefit receipt had elapsed." At this 
point, recipients in all States have reached the 5-year national time 
limit; however, all States are under the 20 percent limit on 
extensions, so there is no reason to expect a sharp increase in 
referrals to SSI. 

[End of section]

Appendix III: Comments from the Social Security Administration:

SOCIAL SECURITY:

The Commissioner:

August 17, 2004:

Ms. Cynthia M. Fagnoni:
Director, Education, Workforce and Income Security Issues:
U.S. Government Accountability Office: 
Washington, D.C. 20548:

Dear Ms. Fagnoni:

Thank you for the opportunity to review and comment on the draft report 
"Temporary Assistance for Needy Families (TANF) and Supplemental 
Security Income (SSI): Opportunities Exist to Help People with 
Impairments Become More Self-Sufficient" (GAO-04-878).

Our response and technical comments to the draft report are enclosed. 
If your staff has questions about the comments, they may contact 
Candace Skurnik, Director, Audit Management and Liaison Staff, at (410) 
965-4636.

Sincerely,

Signed by: 

Jo Anne B. Barnhart:

Enclosure:

SOCIAL SECURITY ADMINISTRATION	BALTIMORE MD 21235-0001:

COMMENTS ON THE GOVERNMENT ACCOUNTABILITY OFFICE (GAO) DRAFT REPORT, 
"TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) AND SUPPLEMENTAL 
SECURITY INCOME (SSI) OPPORTUNITIES EXIST TO HELP PEOPLE WITH 
IMPAIRMENTS BECOME MORE SELF-SUFFICIENT" GAO-04-878:

We appreciate the opportunity to comment on the draft report. We are 
concerned to discover from the report that one-fourth of the TANF 
offices that responded to GAO's survey claimed to be rebuffed when they 
contacted an SSA Field Office to request training on our programs. We 
have two positions within the Regional Offices (RO) specifically 
dedicated to responding to that type of request, Public Affairs 
Specialists and Area Work Incentive Coordinators. We will ensure that 
our ROs respond to such requests from TANF offices and enhance 
communications on TANF nationwide. By improving our communications with 
TANF offices, we may benefit by seeing some reduction in the number of 
persons referred who clearly are not disabled under SSA rules.

Additionally, we currently have under development two demonstration 
projects designed for Title II applicants that should provide valuable 
lessons to consider in connection with development of a TANF/SSI early 
intervention project.

To enhance this report, we suggest you include the fact that States can 
set up waivers for any group on TANF provided they do not waive more 
than 20 percent of their total recipients. Many States, such as 
Illinois, waive work requirements and time limits if the person is 
applying for SSI, or if the State has determined that the person is 
unable to work due to medical condition, even if his SSI application 
was denied.

Our response to the specific recommendation and technical comments are 
below.

Recommendation 1:

As part of a new demonstration project, SSA staff should work with TANF 
offices to identify recipients with impairments capable of working and 
to coordinate services to help individuals improve self-sufficiency.

Comment:

We agree. As noted above, SSA has plans underway for several 
demonstration projects aimed at assisting individuals with disabilities 
to achieve self-sufficiency through work. Although we do not currently 
have plans for a demonstration project involving TANF and SSI, we 
believe that such a project could benefit both of these groups of 
individuals. We will be pleased to work with HHS on the planning and 
design for this proposed project. 

[End of section]

Appendix IV: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Carol Dawn Petersen, (202) 512-7215: 
Michael J. Collins, (202) 512-7215:

Staff Acknowledgments:

In addition to those named above, David J. Forgosh, Cady Summers, Megan 
Matselboba, Christopher Moriarity, and Luann Moy made key contributions 
to this report.

FOOTNOTES

[1] SSI also provides income assistance to children with disabilities 
and the aged who have low income and assets.

[2] This includes individuals who may have been denied benefits and 
abandoned their claims before exhausting all appeals.

[3] A field in SSA's database does indicate whether an applicant 
receives assistance based on need, but this includes TANF as well as 
other forms of income assistance based on need. While this does not 
give an accurate estimate of the portion of SSI recipients who were 
TANF recipients, it does provide an upper bound.

[4] The surveys were mailed to either the director of the county TANF 
office or the regional director, depending on the structure of the TANF 
program in each state. The surveys were completed by the director or 
his/her designee. 

[5] Sampling errors for estimates presented in this report did not 
exceed 5 percentage points. See appendix I for a more detailed 
discussion of sampling errors.

[6] In addition to federal funds, states must also provide funding for 
TANF. However, states are not required to spend all of their block 
grant in the year the money is received; instead they can accumulate 
unused funds to be used at a later time. Therefore, total TANF 
expenditures in 2002, including federal, state, and accumulated funds, 
totaled $28.4 billion.

[7] A state may exempt up to 20 percent of its average monthly caseload 
for hardship or having been subjected to domestic violence.

[8] Estimates from our survey show that only 2 percent of counties 
always, and 16 percent sometimes, move TANF recipients with impairments 
awaiting SSI determinations to state only funded cash assistance.

[9] While the SSI regulations do not guarantee permanent benefit 
status, only 0.4 percent of SSI disability recipients leave SSI because 
of work, and only 6.8 percent are no longer eligible because of medical 
improvement. Excess income or resources can also end a person's SSI 
benefits.

[10] In 2004 the substantial and gainful activities level for nonblind 
individuals is $810 per month, and for blind individuals is $1,350 per 
month, of countable earnings. Both levels are indexed to the average 
wage index. 

[11] There are 54 primarily state-operated DDS offices; their staff 
consists generally of a variety of positions such as disability 
examiners, medical consultants, vocational specialists, and quality 
assurance personnel.

[12] In September 2003, the Commissioner testified before the House 
Committee on Ways and Means, saying that she intended to revise the 
disability determination process. For example, she proposed eliminating 
the reconsideration and the Appeals Council stages of the current 
process.

[13] If the individual is not satisfied with the Appeals Council 
action, the individual may appeal to a federal district court. The 
individual can continue legal appeals to the U.S. Circuit Court of 
Appeals and ultimately to the Supreme Court of the United States.

[14] GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.: 
Jan. 1, 2003).

[15] The Social Security Advisory Board is an independent, bipartisan 
board created by the Congress and appointed by the President and the 
Congress to advise the President, the Congress, and the Commissioner of 
Social Security on programs and matters related to SSA.

[16] In addition to the Ticket Program, SSA also offers other work 
incentives to disability beneficiaries aimed at encouraging work. For 
SSI recipients, these work incentives include such things as earned 
income exclusions (which are intended to make work more enticing since 
some earned income is excluded from countable income), a deduction for 
impairment-related work expenses, and continuation of SSI, which allows 
beneficiaries to work and continue receiving benefits until their 
countable income exceeds the SSI limit.

[17] GAO, SSA Disability: Return-to-Work Strategies From Other Systems 
May Improve Federal Programs, GAO/HEHS-96-133 (Washington, D.C.: July 
11, 1996).

[18] Social Security Advisory Board, The Social Security Definition of 
Disability, (Washington, D.C.: Oct. 2003).

[19] The labor market may also be a contributing factor in deciding to 
refer an individual with an impairment to SSI.

[20] In order for SSA to obtain this information, special processing 
runs are required. Based upon recent work, SSA determined that 95 
percent of the reported income based on need was from TANF.

[21] Over the last few years, the percentage of the SSI caseload age 18 
to 64 that received income assistance based on need prior to becoming 
eligible for SSI has remained fairly stable at 25 percent. While this 
does not give an accurate estimate of the portion of SSI recipients who 
were TANF recipients, it does provide an upper bound. 

[22] Cornell University and The Lewin Group, Policy Brief: Transitions 
from AFDC to SSI Prior to Welfare Reform, (Ithaca, NY: Feb. 1, 2000).

[23] HHS pointed out that recipients in all states have reached the 5-
year national time limit. However, all states are under the 20 percent 
limit on extensions, so there is no reason to expect a sharp increase 
in referrals to SSI.

[24] A modified work policy, for example, allows TANF recipients with 
impairments to work fewer hours than the federal work requirement 
without being sanctioned. Modified work policies are defined by the 
state and are not federally approved. 

[25] The response rate for the stratum consisting of the 100 counties 
with the largest populations was 92 percent. The response rate for our 
sample of the remaining U.S. counties was 87 percent.

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