Implementing Welfare Reform Requirements for Teenage Parents:
Lessons from Experience in Four States

V.  MINOR PARENT LIVING ARRANGEMENT REQUIREMENT

The PRWORA of 1996 specifies that states must deny cash assistance to unmarried minor custodial parents who do not live in an adult-supervised setting, unless certain exceptions apply. At the time of our site visits in early 1997, three of the four study states---Arizona, Massachusetts, and Virginia---had implemented similar policies under waivers to the AFDC program and had been operating under these policies for more than a year.(1) Using the experience of these three states as a guide, we outline some of the decisions facing other states as they develop living arrangement policies for minor parents receiving cash assistance. In addition, based on the experiences of these three states, we highlight lessons for other states to consider when developing and implementing their own living arrangement policies.

DECISIONS FOR STATES

States implementing a requirement governing the living arrangements of minor parents must make decisions on several issues of policy and program design. For example, they must determine what living arrangements are acceptable and how they will substantiate a minor's claim that her parents' home is unsafe. States must also determine how they will verify compliance with the requirement on a regular basis. Here, we outline some of the key decisions facing states, using the choices of our study states as a guide. Table 3 summarizes the living arrangement policies in these three states.

What living arrangements will be allowed for minor parents receiving cash assistance?

When states first implement a living arrangement requirement, they will have to determine the set of living arrangements they consider acceptable for minor parents receiving cash assistance. The study states vary on the set of acceptable living arrangements for minor parents. Arizona and Massachusetts allow minor parents to live with a parent, an adult relative, or a legal guardian.(2) However, they do not allow minor parents to live with unrelated adults who have not been declared their legal guardians. In contrast, Virginia allows minor parents to live with any adult, provided the local welfare agency considers the adult able to function as an appropriate guardian for the minor and her child.

TABLE 3
MINOR PARENT LIVING ARRANGEMENT POLICIES IN THREE STATES
  Arizona Massachusetts Virginia
When did policy take effect? November 1995 November 1995 July 1995
What are the acceptable living arrangements for minor parents? With an adult relative

With a legal guardian

With an adult relative

With a legal guardian

In a state-sponsored group home for teenage parents

With a responsible adult
Does the state welfare agency fund teenage parent group homes? No Yes No
Under what circumstances can minor parent live independently? No parent or legal guardian available

OR

Child protective services substantiates the minor's claim the home is unsafe

OR

Minor has lived independently for at least 12 months prior to applying for assistance

17 years old and regularly attending school

AND

Child welfare authorities assigns client low priority for placement in a state-sponsored group home

No parent or legal guardian available

OR

Local welfare agency concludes that the minor parent or her child's well-being would be jeopardized by living with the parent or guardian

What is the process for investigating allegations that the parental home is unsafe? Referral to child protective services Referral to child protective services Local welfare agency determines process
What is the process for monitoring living arrangements? Notes from landlords

Other "third party" verification

Forms completed by landlords Consulting school records

Consulting housing authority records

Landlord verification

Will the state welfare agency fund teenage parent group homes?

Some advocates and policymakers have argued that, if federal or state governments impose a requirement that minor parents receiving cash assistance must live in an adult-supervised setting, they should provide funding for teenage parent group homes. These homes would serve as an alternative for minor parents unable to live with their parents because the parent is dead, in prison, or cannot be located. The group homes could also serve as an alternative adult-supervised living arrangement when the minor parent makes a substantiated claim of abuse or neglect on the part of her parent. The PRWORA does not provide funding for states to establish teenage parent group homes. The legislation does, however, direct state welfare agencies to assist minor parents who have no adult relative or guardian with whom they can live in locating a group home or other appropriate adult-supervised living arrangement.

Of the states in our study, only Massachusetts has funded group homes for teenage parents in conjunction with imposing a living arrangement requirement. As part of its welfare reform initiative, the state has committed $5 million annually to fund group homes for teenage parents who receive cash assistance and cannot live with an adult relative. This funding supports 22 group homes statewide that can serve more than 100 teenage parents and their children. The average annual cost of the program's housing and other services is about $45,000 per participating teenage parent.

Under what circumstances will a minor parent be able to live independently?

When establishing a living arrangement policy, states also will have to determine under what circumstances, if any, they will allow minor parents to live independently. The study states all allow minor parents to live independently under certain limited circumstances; however, the particular circumstances vary across the states. For example, Arizona allows minor parents to continue to live independently if they have been living independently for at least 12 months before applying for cash assistance; Massachusetts and Virginia do not.

Massachusetts has a particularly narrow set of circumstances under which a minor parent receiving cash assistance can live independently. The minor parent must (1) be 17 years old, (2)attend school regularly or already possess a high school diploma or GED, and (3) be ruled by child welfare authorities to be capable of living independently. In contrast, Arizona and Virginia allow minor parents to live independently when no parent or guardian is living or can be located or when there is a substantiated claim of abuse or neglect on the part of the minor's parent. Under these circumstances, Massachusetts requires minor parents to live in a state-sponsored group home.

What will the process be for determining whether the parental home is unsafe?

States also must decide how the welfare agency will determine whether the minor custodial parent or her child is at risk of physical or emotional harm if they reside in the home of the parent or legal guardian. In particular, when a minor parent alleges that she is at risk in her parent's home, the cash assistance agency must determine whether the allegation is true. Arizona and Massachusetts have imposed specific guidelines at the state level, giving child protective services the responsibility for making this determination. In Virginia, local welfare agencies are responsible for making this determination. However, these local agencies may involve the child protective services if these agencies deem it appropriate to do so.

How will living arrangements be monitored?

When a state imposes a living arrangement requirement for minor parents, it must develop procedures for verifying compliance with the policy. In the states in our study, local welfare staff verify compliance with the living arrangement requirement when an unmarried minor parent applies for cash assistance as the head of a case and again at regular case reviews. Local welfare agencies also require verification of living arrangements whenever a minor parent who heads her own case reports a change of address. Local agencies monitor only the living arrangements of minor parents who head their own cash assistance cases, because those who are not case heads are presumed to be living with an adult guardian (the case head).

The specific methods of verifying living arrangements differ somewhat across the states studied. In Massachusetts, an unmarried minor parent who heads her own cash assistance case must have her landlord and the primary tenant on the lease complete a form verifying where and with whom the minor lives. She must also provide proof of relationship to the primary tenant, typically with a birth certificate. In addition, teen specialists conduct mandatory annual home visits for all teenage parents receiving cash assistance (including those on someone else's case). State welfare officials report that these visitsare intended primarily to monitor the general quality of the teenage parent's home environment. However, the visits also will serve as a means of monitoring compliance with the living arrangement requirement.

In Virginia, when a minor parent applies for cash assistance, intake workers first consult local school district records to try to verify a minor parent's address and the name of her guardian. Local staff in one large agency visited for the study are able to access this information from the welfare office through a direct link to the district's computer system. For minor parents living in public housing, intake workers are also able to verify living arrangements by using the local welfare agency's computer data link to local housing authority records.

IMPLEMENTATION LESSONS

Arizona, Massachusetts, and Virginia had all been operating under their minor parent living arrangement policies for more than a year at the time of our site visits. Based on discussions with state and local welfare staff in these states, several broad implementation lessons emerged.

A very restrictive living arrangement requirement may create implementation difficulties.

If a state imposes a very restrictive living arrangement requirement, it may encounter local agency opposition and other difficulties. For example, when the Virginia Department of Social Services (VDSS) wrote the original regulations for the state's living arrangement policy, the agency imposed a requirement that minor parents live with a parent if at all possible. Under the original rules, a minor parent living with her grandmother was required to move back in with her mother or father, unless there were strong reasons to suspect that the minor parent would be at risk of physical or emotional abuse. If a minor parent refused to move back in with her parents, her cash assistance case was closed, even if she was living with another adult relative.

According to state-level VDSS staff, local agencies found this policy difficult to enforce. Moreover, they considered it bad policy to force minor parents out of stable living situations with an adult relative to return them to their parent's home. Because of these local concerns, VDSS changed the policy a year after implementing the living arrangement requirement. Under current VDSS policy, a minor parent must live either with her parent or with an adult considered by the local welfare agency to be an appropriate guardian. Since the change in policy, application denials for violation of the policy have dropped from five or six per month statewide under the old policy to one or two per month under the new policy.

Funding group homes may enable states to have fewer exemptions to the requirement.

Having space readily available in teenage parent group homes may make it easier for states to allow only a narrow set of living arrangements for minor parents. For example, Massachusetts allows minor parents to live independently only in very limited circumstances. In early 1997, no unmarried minor parents receiving cash assistance in Massachusetts lived independently. In spite of the state's strict living arrangement policy, Massachusetts has a low rate of case closings for violation of the living arrangement requirement relative to other study states.

Massachusetts' Teen Living Program, which funds group homes for teenage parents throughout the state, allows welfare staff to tell young mothers they can provide a safe alternative if their parental home is not safe. Without this option, program staff might be forced to pursue one of three alternative approaches: (1) allow more minor parents to live independently; (2) accept a broader interpretation of what constitutes an acceptable adult-supervised arrangement; or (3)accept that some minor parents who do not meet the state's requirements will be denied cash assistance. It appears that the Teen Living Program enables Massachusetts to adopt a strict definition of acceptable living arrangements and to allow few exceptions to the policy, without resorting to frequent case closings and application denials.

Group homes offer a safe, structured, and supportive environment.

Group homes, such as those sponsored by the Teen Living Program in Massachusetts, offer substantial advantages for some teenage parents. In Teen Living Program group homes, a program staff member is on-site 24 hours a day, seven days a week, to provide supervision and security, as well as counseling for problems and crises. Residents must attend an education or job training activity for a minimum of 20 hours each week. They must also participate in several hours each week of parenting and life skills training, help with household chores, and abide by curfews and other requirements. Constructive involvement with program staff and peers may help some teenage parents feel much less isolated and alone. Teenage parents who are emotionally immature or who suffer from depression, low self-esteem, or other emotional problems may particularly benefit from the program's structure and support services. For those who come from chaotic and dangerous living situations, group homes provide a safe, stable alternative.

Even when space is readily available, only a small fraction of teenage parents are likely to reside in group homes.

Despite these advantages, only a small fraction of teenage parents may reside in group homes. Since it began operation, the Teen Living Program has continually had the capacity to serve additional teenage parents and their children. Throughout the first half of 1997, the vacancy rate for the group homes throughout Massachusetts remained over 20 percent. Therefore, the program appears to be more than meeting the demand for group homes among teenage parents receiving cash assistance in the state. Even so, less than two percent of teenage parents receiving cash assistance in Massachusetts reside in group homes, including four percent of minor parents and one percent of 18- and 19-year-old parents. The director of one local welfare office serving a large number of teenage parents suggested that these small numbers were evidence that many teenage parents found the program's curfews and its restrictions on visitors and other activities unappealing.

Although costs per resident are high, overall costs of teenage parent group homes may be relatively modest.

The average annual cost of the Teen Living Program's housing and other services is about $45,000 per resident. This relatively high cost is due primarily to the program's high staff-to-client ratio. For example, one group home visited for the study had seven full-time staff members (a program director, four counselors, and two overnight staff) serving eight teenage parents and their families. In spite of high costs per resident, because a very small percentage of teenage parents end up residing in group homes, the overall costs of providing group homes are relatively modest. If Massachusetts's experience is typical, a state can expect to spend only about $800 per teenage parent cash assistance recipient annually to meet the demand among this population for similarly structured group homes. However, if participation rates are higher in other states, their overall costs of providing group homes may also be higher.

Assessing the safety of the parental home will most likely require involvement of child protective services.

When establishing a living arrangement requirement for minor parents, state welfare agencies may need to work with child protective services (CPS) to develop policies and procedures. For example, states may want to consult with CPS officials when determining the specific living arrangements considered acceptable for minor parents receiving cash assistance. Moreover, because local welfare staff may lack the necessary training to assess the safety and appropriateness of a minor parent's living situation, welfare agencies may need to work with CPS to develop procedures for investigating claims by minor parents that their parent's home is unsafe for them or their babies.

The study states varied in how they involved CPS in administering the living arrangement policy. In Arizona and Massachusetts, state policy requires caseworkers to refer all claims by a minor that her parent's home is unsafe to CPS. In Virginia, however, it is up to individual caseworkers to determine whether compliance with the living arrangement requirement threatens the physical or emotional well-being of the minor parent and whether an unrelated adult with whom the minor is living can serve as an appropriate guardian. According to Virginia welfare officials, during the planning phase for the living arrangement requirement, some welfare caseworkers expressed concerns that they did not have adequate training to make determinations concerning the appropriateness of a minor parent's living arrangement. The state agency addressed this concern by allowing local welfare offices to involve CPS social workers in the process if the local offices considered this appropriate.

Monitoring the living arrangements of minor parents is a small burden on staff time because it involves so few cases.

Local welfare staff interviewed for the study consistently reported that monitoring the living arrangements of minor parents was a small burden because so few cases required monitoring. Only one or two percent of cash assistance cases contain a minor parent, most of whom do not head their own cases. Since welfare agencies assume that minor parents on someone else's case are in compliance with the living arrangement requirement (and therefore do not monitor them), welfare agencies monitor only the very small fraction of cases that are headed by a minor parent (0.2 to 0.6 percent of cases in the states we examined).

1. The fourth study state, California, was developing a minor parent living arrangement policy at the time of our visit and planned to implement the policy in mid-1997.

2. A legal guardian is someone who has been granted custody and has been declared responsible for the child by a judge.

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