Evidence accumulated quickly, as the WtW grants program was implemented, that congressionally defined eligibility criteria were slowing enrollment and limiting participation. Ninety percent of respondents to the first evaluation grantee survey agreed moderately or strongly that eligibility rules were excluding people from the program who were truly among the hard-to-employ but who did not meet the criteria as specified in the WtW statute. The restrictive eligibility criteria were an important factor in the slow startup of many programs. In this evaluation, exploratory visits were made to 23 grantees as part of the search for in-depth study sites, and most of those grantees had found the eligibility criteria to be a serious constraint on their ability to meet their enrollment targets (Nightingale et al. 2000). Some of the grantees visited had already been compelled to turn away or place on a waiting list individuals who met criteria for the "30 percent category," but not the "70 percent category," rather than risk audit exceptions and financial penalties if they failed to comply with the requirements for serving mostly individuals in the latter category. A similar finding emerged from another study of first-year operations, based on discussions with and visits to the first 11 states that received WtW formula funds (Nightingale, Trutko, and Barnow 1999). The early exploratory visits that were part of the national WtW evaluation also suggested that grantees who intended to serve noncustodial parents were finding it difficult to recruit them, in part, because they failed to meet the stringent criteria pertaining to employment barriers or because the custodial parents of their children were not long-term TANF recipients.
Such concerns have led to amendments in the eligibility criteria for the WtW grants program. In the FY 2000 budget appropriations act for the departments of Labor, Health and Human Services, Education, and related agencies, passed in November 1999, several provisions make it easier for both TANF recipients and noncustodial parents to qualify for WtW services. The amendments left intact the requirement that 70 percent of WtW funds be spent on a defined category of participants, but broadened this category in two ways:
- TANF Participants Qualify Simply by Being Long-Term Recipients. The amendments remove the requirement that long-term TANF recipients exhibit additional barriers to employment. TANF recipients are eligible under the amended criteria if they have received assistance for at least 30 months, are within 12 months of reaching a time limit, or have exhausted their TANF benefits due to time limits.
- Noncustodial Parents Qualify Under Less Restrictive Rules. Under the amended criteria, noncustodial parents are eligible if: (1) they are unemployed, underemployed, or are having difficulty making child support payments; (2) their minor children are receiving or eligible for TANF, or received TANF in the past year, or are receiving or are eligible for assistance under the Food Stamp, Supplemental Security Income, Medicaid, or Children's Health Insurance programs; and (3) they make a commitment to establish paternity, pay child support, and participate in services to improve their prospects for employment and paying child support.(8)
The definition of the 30 percent category was also broadened to include youth who have received foster care in the past, custodial parents with incomes below the poverty level, and TANF recipients who face barriers specified by the local WIB. Other program changes were also made: (1) allowing WtW funds to be used for pre-employment vocational education and job training for up to six months; (2) allowing competitive grantees other than WIBs to provide job readiness, placement, and post-employment services directly rather than only through contracts or vouchers; (3) streamlining reporting requirements; and (4) permitting child support enforcement agencies to share information on noncustodial parents with WIBs, to help carry out WtW programs.
These amendments expand the population that WtW grantees might enroll in their programs, but the effect of the change will occur in stages. Beginning January 1, 2000, competitive grant funds may be expended on participants eligible for WtW services under the new rules. For formula grantees, the new rules are in effect beginning July 1, 2000, and newly eligible participants can be enrolled. However, federal funds cannot be used until October 1; state matching funds can be used for newly eligible participants beginning July 1, 2000.(9) The amendments thus take effect well after the period of operations about which grantees could report in the second evaluation survey in late 1999.