The present study is the first post-welfare reform study to take a detailed look at how sanctions are being implemented in local welfare offices operating under a range of different welfare reform policies. Based on our findings, we draw several conclusions about the implementation of TANF sanctions. First, it is clear that the implementation of TANF sanctions requires substantial staff effort. Three of the six local sites we visited during the study had restructured their staff responsibilities so that at least one staff member focused exclusively on the implementation of TANF sanctions. Monitoring program participation, contacting clients to reengage them in program activities, documenting the reason for imposing a sanction, and making eligibility changes are all extremely labor-intensive tasks.
Second, TANF case managers have considerable discretion in deciding whether to impose a sanction, although some tend to exercise that discretion more than others. Many factors influence their decisions, including their overall workload, the message they have received from program administrators regarding the use of TANF sanctions, the amount of work involved in imposing a sanction, client circumstances, and the relationship they have developed with their clients. When workloads are high, case managers tend to base their sanctioning decisions primarily on participation reports. When workloads are lower, however, case managers take a more individualized approach to sanctioning and make an extra effort to reengage clients in program activities.
Third, TANF case managers sometimes use the flexibility accorded them to adjust work requirements for clients experiencing personal, family, or logistical challenges that make participation in work activities difficult. However, some believe that the strong emphasis on the achievement of high work participation rates discourages the development of individualized employment plans and results in a mismatch between the level and type of participation that is expected and what clients can realistically achieve. Finally, local offices use various review mechanisms to encourage the proper use of sanctions. In some cases, the reviews occur before a sanction is imposed and, in others, after a sanction is imposed.