Imposing sanctions is one of many tasks performed by TANF eligibility workers. As such, the procedures for imposing a sanction are often closely related to the procedures for handling other eligibility functions. Imposing a sanction usually involves several steps: (1) documenting program noncompliance, (2) sending sanction notices to clients, (3) conducting sanction conciliation reviews, (4) changing eligibility codes in the automated system to reflect changes in program status and the grant amount, and (5) monitoring the level and duration of the sanction. While the decision to impose a sanction involves considerable worker discretion, the actual process for imposing a sanction after that decision has been made is primarily procedural and involves little worker discretion.
In the study sites, the process for imposing a sanction ranges from relatively simple to highly complex. The more complex processes occurred at two stages. The first set of complexities occurred at the documentation stage and involved several levels of review to ensure the appropriate documentation of program noncompliance. The second set of complexities occurred at the eligibility stage and involved several actions on the part of eligibility workers to impose and then monitor the level and duration of a sanction. Early in the implementation of welfare reform, several of the sites struggled with how to impose sanctions efficiently. Simple processes for implementing TANF sanctions that do not require several levels of review make it easy for workers to impose sanctions but do not necessarily provide assurance that sanctions are implemented properly.
Design of the State's Sanction Policy. Two of the study states (Illinois and New Jersey) implemented gradual full-family sanctions; South Carolina implemented immediate full-family sanctions. Given the interaction of several factors, it is difficult to tell how much the design of the state's sanction policy influenced the ease with which sanctions were implemented. Nonetheless, the state sanction policies clearly influenced the sanction process. In South Carolina, the design of the sanction policy (immediate full-family sanction) makes it relatively straightforward to change a recipient's eligibility status to take the sanction into account--the case is simply closed with a code indicating that the sanction was the reason for the closure. Because Illinois's and New Jersey's sanction policies are more complex and require multiple grant changes, they require more staff attention. In both states, case workers must initially reduce the grant and then later close the case if the family does not come into compliance. To streamline the process of imposing a sanction, both offices in New Jersey created separate sanction units to process all the eligibility changes for sanctioned TANF recipients. In one office in Illinois, these changes all are handled by one worker.
State and Local Philosophy Toward Sanctions. The experience in South Carolina demonstrates the way in which the state and local philosophy toward sanctions can influence the implementation of sanctions. When South Carolina made an explicit decision to reduce the use of sanctions, the approach to implementing sanctions shifted dramatically. After the decision, one local site required case managers to submit a detailed two- to three-page report describing the client's barriers, assigned work activities, and missed appointments; the case manager's efforts to reengage the client in work activities; and the outcome of reengagement efforts. The change in philosophy resulted in the imposition of fewer sanctions, along with substantial safeguards to reduce the inappropriate imposition of sanctions. (When these changes were implemented in South Carolina, the fraction of cases closed due to a sanction dropped from 25 percent to just 5 to 10 percent.)
Automation of the Sanction Process. As noted above, Illinois and New Jersey operate under similar sanction policies with gradual full-family sanctions and several levels of sanction for repeat instances of noncompliance. In both states, workers initially enter a code to reduce the grant, then they must follow-up at the appropriate interval to eliminate the full grant or close the case. The automated eligibility system calculates the amount of the grant, taking the sanction into account. However, workers must prompt the eligibility system to go from the initial partial sanction to the full-family sanction.
Despite variation across the study sites in the ease with which a sanction could be imposed, all sites have processes in place to promote proper use of sanctions. Local advocacy groups in South Carolina and Illinois were particularly influential in increasing awareness about the appropriate use of sanctions. The sites we visited during the study use different review processes to promote proper use of sanctions. All of the study sites require conciliation or supervisory reviews before imposition of a sanction. South Carolina requires approval from the supervisor and the county TANF director, and case managers use formal conciliation reviews to determine why clients are not participating in work activities as well as informal reviews to attempt to address clients' problems before imposing sanctions. One office in Illinois invites employment service staff and other community partners to attend conciliation meetings. Clients in all the study sites can appeal a sanction after it is imposed, although they rarely do so. The only sites in which clients brought appeals regularly were in New Jersey; one local site in that state received about 50 sanction appeals in one year.
Review processes also are in place for identifying clients who still receive TANF even though they are not complying with work requirements. Case managers acknowledged that sometimes clients "fall through the cracks." In one local office, supervisors gather information from participation reports and meet regularly with case managers to discuss cases in which sanctions have not been imposed on nonparticipating clients. The purpose of the review processes is to support case managers and clients and to ensure equity in the imposition of sanctions.