Verification of income and employment is relatively difficult for immigrants and other low-wage workers who have seasonal or otherwise unstable work schedules and therefore receive less predictable earnings. In Dallas, for example, eligibility workers described the challenges involved with verifying employment with some large firms. These employers often have their headquarters outside the metropolitan area or the state, and applicants or workers must find staff at the headquarters that can verify their wages. Since there was a shortage of eligibility workers in Dallas at the time of our visit, there was usually insufficient staff time to contact such employers, and thus the responsibility by and large fell to the applicant.
Immigrants, particularly those who are undocumented, also often work "off the books" or for a contractor, for instance, in construction or landscaping. In such cases, they are usually required to get a letter from the employer because they do not receive a formal pay stub.15 If the employer is a contractor who mostly hires undocumented immigrants, then he or she may be unwilling to cooperate. One worker said that sometimes immigrants do not even know the last names, telephone numbers or addresses of their employers.
Eligibility workers often have difficulty calculating average monthly income for immigrants who work irregular hours. In Raleigh, many immigrants work in agriculture or landscaping, industries in which hours worked vary greatly depending on the season and the weather on any given day. Earnings are higher during busier times, and lower when employment is slack. As a result, eligibility workers must ask for more pay stubs — sometimes up to six or eight weeks' worth — to determine average monthly income accurately.
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Based on our discussions with agency staff, administrators, and observations at the six sites, non-citizen eligibility provisions are nested within a larger set of eligibility determination rules, all of which present implementation challenges for welfare agencies and carry special implications for immigrants. Overall, it appears that the combination of automation and heavy reliance on documents significantly reduces, although does not eliminate, the margin for error in determining non-citizen eligibility. The risk for error increases when non-citizen applicants present rare or unusual immigration documents or workers are not aware of post-PRWORA eligibility rule changes.
For those non-citizens who are still eligible for benefits or who have eligible children, the application of specific PRWORA non-citizen eligibility rules is typically perceived as far less problematic than certain eligibility rules and procedures that affect all applicants. Some documentation and verification requirements — especially those in the TANF and food stamp programs for items such as household composition, employment, income and expenses — can pose more difficulties for non-citizens.
The eligibility determination process can become time-consuming for applicants when they must provide multiple pieces of paper verification (for instance, pay stubs, leases and utility bills) or collateral contacts (i.e., letters or forms filled out by employers, landlords and neighbors). Documentation and verification is particularly difficult for immigrant families when they must provide information about undocumented individuals living in the household who are not applying for benefits; statements from landlords that might reveal illegal subletting situations; or letters from employers admitting that they hired someone "under the table."
Our discussions with agency staff at all levels further suggest that more than any single factor, it is the combination of factors associated with applying for benefits — including some of the eligibility determination rules and verification procedures discussed above and language issues considered in the next chapter — that can make the application process especially challenging for immigrants. Additionally, outreach workers, advocates, and applicants in focus groups indicated that non-citizens are very concerned about the consequences of benefit receipt for their immigration status and naturalization and that many are also uncertain or misinformed about the relationship between their eligibility status and their immigration status.