Privatization in Practice: Case Studies of Contracting for TANF Case Management. Policy Compliance


In monitoring policy compliance, agencies evaluate whether contractors abide by established TANF rules  which may include collecting documentation from clients, meeting standards for timeliness in service delivery, and adequately justifying decisions (such as sanction recommendations). In sites that have privatized eligibility determination, contractors must comply with regulations for the correct determination of benefits and appropriate application of sanctions.

Agencies verify program compliance through a combination of automated and manual methods. Computer systems in some sites collect information on the timeliness of service delivery, such as the length of time it takes to process an application for benefits or the lapse between a clients referral to and engagement by a contractor. Monitoring compliance with other program rules generally requires periodic reviews of random samples of case files. These inspections tend to focus on whether files include all required documents, case notes provide sufficient justification for decisions, and the correct supportive service benefits have been offered.

The experiences of study sites highlight the particular importance of monitoring both public and private agencies roles in sanctioning clients. In several sites where public agencies must approve sanctions recommended by contractors, agency employees noted that they often lack the necessary time and information for a thorough review of the recommendations. Public agency administrators and advocates in Delaware found, early on, that some contractors recommended a sanction after only one failed attempt to engage a client, while others made additional attempts. As a result, the public agency changed its contracts to establish minimum standards for outreach. A state auditor in Wisconsin found cases in which sanctions were inappropriately applied (Wisconsin Legislative Audit Bureau 2001).

The methods public agencies use to monitor client sanctions depend on the degree of responsibility transferred to contractors. In sites where contractors recommend sanctions that public agencies impose, the agencies control is intended as a form of monitoring. Once contractor case workers send a recommendation for a sanction, public employees are responsible for determining whether it is appropriate and taking the required action. San Diego County relies on a central sanction reviewer, in addition to employees managing individual cases, to ensure that requests from all contractors are handled similarly. In Palm Beach County and Wisconsin, where eligibility determination is privatized, contractor employees both recommend and impose sanctions. Public agencies in these sites rely exclusively on the monitoring methods used for other aspects of policy compliance: data from computer systems and case file reviews.

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