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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

November 2014: 

Temporary Assistance for Needy Families: 

Action Is Needed to Better Promote Employment-Focused Approaches: 

GAO-15-31: 

GAO Highlights: 

Highlights of GAO-15-31, a report to congressional requesters. 

Why GAO Did This Study: 

The TANF block grant requires states to engage a certain percentage of 
work-eligible cash assistance recipients in specified work-related 
activities, such as job search assistance and training. Yet, data 
suggest that more TANF recipients could receive assistance that would 
help them gain employment and reduce their dependence. GAO was asked 
to provide examples of what some states are doing to achieve these 
goals and how to expand these efforts. 

This report (1) reviews some approaches that have been identified as 
holding promise for engaging TANF recipients in employment and 
increasing their earnings and examines ways in which selected states 
and localities have used them, and (2) identifies factors that 
influence their use. To first identify promising approaches, GAO 
reviewed summaries and syntheses of rigorous research on approaches 
that increase employment and earnings, and profiled 10 state and local 
programs that were nominated by experts familiar with welfare research 
and state and local efforts, and that were selected to represent a 
range of approaches. GAO also reviewed relevant federal laws, 
regulations, and agency guidance, and interviewed agency officials and 
experts with a range of views. 

What GAO Found: 

The 10 state and local programs GAO examined used various promising 
approaches to help Temporary Assistance for Needy Families (TANF) cash 
assistance recipients gain employment by meeting a range of 
participant needs. These approaches included the use of subsidized 
employment, employment alongside treatment for a health condition, and 
training for high-demand jobs. For example, for individuals in need of 
additional work experience, San Francisco’s TANF program has provided 
subsidies to employers to place participants in temporary, wage-paying 
jobs. To help individuals with mental and physical disabilities and 
substance abuse problems, nonprofit contractors for New York City’s 
TANF program have provided individualized assessment and treatment, 
often combined with employment. To prepare individuals with various 
skill levels for high-demand jobs, Minnesota and Washington have used 
a career pathways approach of combining occupation-specific training 
with basic skills education and support services. However, experts 
told us that some states have a misperception that this approach is 
not allowable under TANF rules, even though the Departments of Labor, 
Education, and Health and Human Services (HHS) support its use. HHS 
told us that states could still meet program requirements while using 
this approach, but the agency has not issued formal guidance 
clarifying this. Internal control standards for the federal government 
state that information should be communicated to managers in a form 
that enables them to carry out their responsibilities. As a result of 
these misperceptions, the career pathways approach may be underused by 
TANF agencies and TANF recipients could miss out on the potential 
benefits of this approach. 

Expertise and dedicated funds facilitated use of these promising 
approaches, but the federal TANF program, itself, lacks incentives for 
their wider adoption. Of the 10 programs GAO examined, 9 drew on the 
expertise of partner organizations-—including community college 
systems, workforce agencies, and nonprofits. The programs also 
benefited from decisions by state and local policymakers to dedicate 
funds—-including TANF funds-—for the selected programs, according to 
officials. However, incentives for large numbers of state and local 
TANF agencies to adopt and test promising approaches are lacking under 
the structure of the TANF program for several reasons. First, many 
program design and funding choices are left to the states, and GAO’s 
prior work has shown that state use of TANF funds for more costly 
welfare-to-work approaches can compete with other allowable uses of 
TANF funds. Second, TANF’s main performance measure does not 
necessarily encourage agencies to use certain approaches that 
incorporate longer-term education and training or treatment services, 
although states are not prohibited from doing so. Third, little 
incentive exists for TANF agencies to evaluate their programs. HHS’s 
authority over many aspects of TANF is limited and it has not proposed 
legislative changes to address these areas. Yet, because HHS oversees 
TANF, it is positioned to identify, suggest, and work in consultation 
with Congress on potential changes that would better address the lack 
of incentives for the use of promising approaches by states and to 
better meet the TANF goal of increasing employment. Without federal 
action, adoption and evaluation of promising approaches may continue 
to be limited to select states and localities, leaving TANF recipients 
in other locations without access to these promising approaches. 

What GAO Recommends: 

GAO recommends that HHS should issue guidance to clarify how the 
career pathways approach can be used by TANF agencies and identify 
potential changes to address the lack of incentives in the TANF 
program. HHS agreed with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-15-31]. For more 
information, contact Kay E. Brown at (202) 512-7215 or brownke@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Selected State and Local Programs Reflect Elements of Four Promising 
Approaches: 

Expertise and Dedicated Funds Facilitated the Use of Promising 
Approaches, but the TANF Program Lacks Incentives for Wider Adoption 
or Testing: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Categories of Federal Work Activities and Limitations on 
Counting Time in Those Activities: 

Appendix III: Selected Recent and Ongoing Department of Health and 
Human Services-Funded Evaluations: 

Appendix IV: Bibliography: 

Appendix V: Agency Comments from the Department of Health and Human 
Services: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Characteristics of Selected Programs: 

Table 2: Selected Program Partner Organizations and Technical 
Assistance: 

Table 3: Categories of Federal Work Activities: 

Figures: 

Figure 1: Percentage of Work-Eligible Individuals by Participation 
Status, April 2011-June 2011: 

Figure 2: Percentage of TANF Work-Eligible Individuals with Hours of 
Participation, by Work Activity, Fiscal Year 2011: 

Figure 3: Two Subsidized Employment Models: 

Figure 4: Treatment and Employment Services: 

Figure 5: Career Pathways: 

Figure 6: Modified Work-First Approach: 

Figure 7: D.C. TANF Program's Service Delivery Model: 

Figure 8: Example of Possible Allocation of TANF Funds by a State: 

Abbreviations: 

AFDC: Aid to Families with Dependent Children: 

HHS: Department of Health and Human Services: 

MOE: maintenance of effort: 

PRWORA: Personal Responsibility and Work Opportunity Reconciliation 
Act of 1996: 

TANF: Temporary Assistance for Needy Families: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

November 19, 2014: 

The Honorable Orrin Hatch: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable Dave Reichert: 
Chairman: 
Subcommittee on Human Resources: 
Committee on Ways and Means: 
House of Representatives: 

The Temporary Assistance for Needy Families (TANF) block grant, 
administered by the U.S. Department of Health and Human Services 
(HHS), provides $16.5 billion annually in federal funding to states 
for cash assistance as well as a variety of other benefits and 
services to meet the needs of low-income families with children. 
[Footnote 1] 

In March 2014, states used federal and state TANF funds to provide 
cash assistance to 1.6 million low-income families nationwide[Footnote 
2]. In keeping with a TANF goal of reducing families' dependence on 
government by promoting work, TANF requires states to engage a certain 
percentage of families with a work-eligible individual receiving cash 
assistance in specified work-related activities or face potential 
financial penalties. These work activities include, for example, 
unsubsidized employment, job search and job readiness assistance, 
certain training and education, and work experience. In recent years, 
some state TANF agencies have narrowed the scope of services they 
provide, reportedly in response to resource constraints and staff 
reductions. Related to this trend, data suggest that more TANF 
recipients--especially those considered hard to employ--could receive 
assistance that will help them to gain employment and reduce their 
dependence on cash assistance. 

GAO has been asked to provide examples of what some states are doing 
now to help TANF recipients reach these goals and how these efforts 
can be expanded. Our report (1) reviews some approaches that have been 
identified as holding promise to engage TANF recipients in employment 
and increase their earnings and examines ways in which selected states 
and localities have used them, and (2) identifies factors that 
influence the use of these and other promising approaches. 

To first identify promising approaches, we reviewed research summaries 
and syntheses of rigorous research on promising approaches for 
engaging TANF recipients in employment and increasing their earnings. 
[Footnote 3] To identify state and local programs that are currently 
using these approaches to serve TANF cash assistance recipients, we 
interviewed cognizant researchers; officials from HHS, the Department 
of Labor, and the Department of Education; and others with TANF 
expertise. We selected 12 experts based on their knowledge of the 
research and efforts under way at the state and local level, as well 
as to reflect a range of perspectives on welfare-to-work issues. We 
identified them through our literature review and through referrals 
from other experts. We selected 10 programs to profile (located in 6 
states--California, Kentucky, Minnesota, New York, Utah, and 
Washington--and the District of Columbia) from those nominated by 
experts to reflect diversity in approaches used, economic conditions, 
demographics, and geographic regions, among other factors. We 
conducted in-depth interviews, by phone and through four site visits, 
with program administrators and state and local TANF officials to 
learn about key program features that might increase employment and 
incomes. We obtained views from experts; federal, state, and local 
officials; and program administrators on factors that facilitate the 
use of promising approaches and that could broaden their use. We 
assessed information and communication HHS provides to states related 
to promising approaches against federal internal control standards. 
[Footnote 4] We obtained budget, performance, and other program data 
for the programs we selected, and reviewed HHS administrative data on 
states' engagement of TANF recipients in prescribed work activities. 
We assessed the reliability of these data by reviewing related 
documentation and interviewing knowledgeable officials and determined 
they were sufficiently reliable for providing contextual information 
on these programs and describing work participation trends, 
respectively. We also reviewed relevant GAO, HHS Office of Inspector 
General, and HHS reports, as well as relevant federal laws, 
regulations, and guidance. Appendix I describes our objectives, scope, 
and methodology in greater detail. 

We conducted this performance audit from January 2014 to November 2014 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

TANF and the Work Participation Rate: 

The Personal Responsibility and Work Opportunity Reconciliation Act of 
1996 (PRWORA) established four purposes for the TANF block grant: 

1. provide assistance to needy families so that children may be cared 
for in their own homes or homes of relatives; 

2. end dependence of needy parents on government benefits by promoting 
job preparation, work, and marriage; 

3. prevent and reduce out-of-wedlock pregnancies; and: 

4. encourage two-parent families.[Footnote 5] 

Within these goals, states have responsibility for designing, 
implementing, and administering their welfare programs to comply with 
federal guidelines, as defined by federal law and HHS, including 
imposing a 5-year lifetime limit on many families receiving cash 
assistance.[Footnote 6] In addition, the block grant includes a 
maintenance-of-effort (MOE) requirement, which requires states to 
maintain a significant portion of their historic financial commitment 
to welfare-related programs. In fiscal year 2013, states spent a total 
of $31.6 billion in federal TANF funds and state MOE funds, with 
federal funds accounting for 53 percent of the total. The federal law 
that established TANF also created a TANF Contingency Fund that states 
could access in times of economic distress.[Footnote 7] In creating 
the TANF block grant, Congress emphasized the importance of state 
flexibility, and restricted HHS's regulatory authority over the states 
except to the extent expressly provided in the law. 

In line with the second purpose, a key TANF goal is helping parents 
prepare for and find jobs. The primary means for measuring state 
efforts in this area has been TANF's work participation rate. 
Generally, states are held accountable for ensuring that at least 50 
percent of all families receiving TANF cash assistance and considered 
work-eligible participate in one or more of the federally-defined 
allowable activities for the required number of hours each month. 
[Footnote 8] The law also contains a provision known as the caseload 
reduction credit, which allows states to reduce the work participation 
rate they are required to meet based on reductions in the size of 
their TANF caseload.[Footnote 9] In addition, TANF regulations provide 
that states that spend more than their MOE requirements generally 
receive an increase in their caseload reduction credit.[Footnote 10] 

TANF Programs Currently Engage Recipients in a Limited Range of Work-
related Activities: 

Our work has shown that over the years, states have engaged about one 
third of families receiving TANF cash assistance in federally-defined 
work activities nationwide while still meeting their required work 
participation rates. Generally, this is because many states have 
relied on the caseload reduction credit and other allowable options to 
meet the requirement rather than engaging more families in specified 
work activities to reach a 50 percent rate. This has raised concerns 
among some policymakers that states are meeting the letter but not the 
spirit of the law. PRWORA established higher work participation rate 
requirements and eliminated many exemptions from these requirements 
for recipients compared to what was in place prior to TANF.[Footnote 
11] This reflected research that found that mandatory work 
requirements could reduce welfare receipt and increase employment 
among single mothers and help address concerns about long-term welfare 
receipt. In our prior work, we concluded that states' use of the 
modifications currently allowed in federal law and regulations, as 
well as states' policy choices, have diminished the usefulness of the 
work participation rate as a national TANF performance measure. 
[Footnote 12] 

The Claims Resolution Act of 2010 required states to report additional 
information on TANF recipients' engagement in activities.[Footnote 13] 
An HHS report to Congress, based on 2011 state data, found that that 
24 percent of work-eligible individuals met federal work participation 
rate standards, but more than 50 percent of work-eligible individuals 
had zero hours of participation (see figure 1).[Footnote 14] While 
some of these individuals were exempted from participation or excluded 
for some other reason such as caring for a child under age one, at 
least some of these individuals had not been engaged in work 
activities by the state or local TANF agency.[Footnote 15] HHS data 
show that federal and state spending on work-related activities, such 
as subsidized employment, has declined in the last 3 years for which 
data are available (fiscal years 2011-2013) and has been under 8 
percent of total TANF spending in each of these years. 

Figure 1: Percentage of Work-Eligible Individuals by Participation 
Status, April 2011-June 2011: 

[Refer to PDF for image: horizontal bar graph] 

Percentage of Work-Eligible Individuals: 

Participants meeting work participation standards rate: 24.2%; 
Not meeting work participation rate standards due to: 
Zero reported hours of participation: 54.5%; 
Insufficient hours: 15.7%; 
Hours in non-countable activities: 5.1%; 
Hours that do not meet verification standards: 2.6%; 
Uncountable hours (Participation in time-limited activities beyond a 
statutory limit): 2.0%; 
Unreported countable hours: 1.4%. 

Source: GAO analysis of Department of Health and Human Services (HHS) 
data. GAO-15-31. 

Note: The number of individuals in each of the categories sum to more 
than 100 percent since a work-eligible individual could be included in 
more than one category. According to HHS, the percentage of work-
eligible individuals that counts toward the work participation rate 
for the purpose of this analysis is likely to be lower than the 
official work participation rate for most states. This is due to 
methodological differences between the calculations. For example, work 
eligible individuals who are disregarded from the official work 
participation rate--such as certain single parent families with a 
child under the age of one or families subject to a work-related 
sanction--are included in this analysis. 

[End of figure] 

Almost half of individuals meeting the work participation rate 
standards did so through unsubsidized employment--working in a regular 
job while receiving cash assistance. This suggests that states' 
ability to meet the work participation rate relies heavily on the 
activities of individuals who are already able to work rather than 
providing special assistance to those who have the most difficulty 
finding and keeping jobs. In fiscal year 2011, unsubsidized employment 
was the most common work activity among individuals participating in 
at least one hour of a countable work activity per month.[Footnote 16] 
Job search and job readiness assistance, followed by vocational 
education training, were the next most common activities (see figure 
2). 

Figure 2: Percentage of TANF Work-Eligible Individuals with Hours of 
Participation, by Work Activity, Fiscal Year 2011: 

[Refer to PDF for image: horizontal bar graph] 

Percentage of individuals with hours of participation: 

Unsubsidized employment: 49.4%; 
Job search and job readiness assistance: 22.6%; 
Vocational education: 12.5%; 
Work experience: 9.4%; 
Community service: 7.4%; 
Job skills training: 5.6%; 
Satisfactory school attendance: 2.5%; 
Education related to employment: 2.2%; 
Subsidized public employment: 1.6%; 
Subsidized private employment: 1.0%; 
On-the-job training: 0.2%; 
Providing child care: 0.1%; 
Other: 9.4%. 

Source: GAO analysis of Department of Health and Human Services (HHS) 
data. GAO-15-31. 

Note: The number of individuals in each of the categories sum to more 
than 100 percent since a work-eligible individual could be included in 
more than one category. 

[End of figure] 

History of Welfare Program Experimentation, Research and State Waivers: 

Between 1987 and 1996, there was considerable experimentation with 
welfare-to-work programs under TANF's predecessor program, Aid to 
Families with Dependent Children (AFDC), as HHS granted waivers to 
states to test and evaluate new approaches. A body of HHS-sponsored 
research resulted, showing that welfare-to-work programs can increase 
employment and reduce welfare receipt. This research helped inform the 
creation of TANF. Between 1987 and 1996, 46 states received waivers 
from existing AFDC requirements to test and evaluate new approaches to 
improve employment outcomes for people on welfare. These initiatives 
were referred to as section 1115 waivers because they were granted 
under section 1115 of the Social Security Act.[Footnote 17] According 
to HHS officials, HHS required states that applied for and received 
waivers from federal program requirements to have an independent 
organization evaluate its program change, supported by HHS and state 
funding.[Footnote 18] These waiver initiatives included placing time 
limits on the receipt of benefits and strengthening work requirements, 
among others. According to HHS, many of the policies and concepts 
included in state waiver requests were later incorporated into TANF. 
States that received section 1115 waivers under AFDC were allowed, 
under PRWORA, to continue to operate under these waivers until their 
expiration. However, the last of these waivers expired in 2007, and no 
provision in law allowed these AFDC waivers to be extended. Questions 
have been raised as to whether HHS continues to have the authority 
under section 1115 to waive certain TANF program rules; this report 
does not address this issue.[Footnote 19] Under law, HHS is required 
to conduct TANF and related research[Footnote 20] and the agency 
supports a broad array of research and evaluations. See appendix III 
for a list of relevant recent and ongoing HHS-funded evaluations. 

Evolution of the TANF Block Grant: 

Since the 1996 welfare law replaced AFDC with the TANF block grant and 
gave states flexibility to set spending priorities, they have used a 
smaller share of the grant to provide cash assistance.[Footnote 21] 
Within the first 5 years of TANF, the number of families receiving 
cash assistance declined by over half and states shifted their TANF 
priorities to other forms of aid, or non-cash services. These can 
include any other services meeting TANF purposes, such as job 
preparation activities, child care and transportation assistance for 
parents, out-of-wedlock pregnancy prevention activities, and child 
welfare services. In fiscal year 1997, nationwide, states spent about 
23 percent of federal TANF and state MOE funds on non-cash services. 
In contrast, states spent more than 66 percent of federal TANF and 
state MOE funds for these purposes in fiscal year 2013. While the TANF 
block grant still serves as the nation's major cash assistance program 
for low-income families with children, states have also increasingly 
used it as a flexible funding stream for supporting a broad range of 
allowable services. However, we previously reported that the 
accountability framework currently in place in federal law and 
regulations has not kept pace with this evolution. Our prior work 
found that TANF's accountability framework provides incomplete 
information on how states' non-cash services are contributing to TANF 
purposes. We noted that Congress may wish to consider ways to improve 
reporting and performance information so that it encompasses the full 
breadth of states' uses of TANF funds.[Footnote 22] The composition of 
the overall TANF caseload has also changed, with the percentage of 
"child-only" cases increasing from about 23 percent in fiscal year 
1998 to about 46 percent in fiscal year 2011. These cases consist of 
families receiving cash assistance on behalf of children only, in 
contrast to other cases in which adults in the families also receive 
benefits on their own behalf.[Footnote 23] According to HHS, the 
increase in the percentage of child-only cases was primarily due to a 
sharp decline in the number of TANF cases with an eligible adult, 
rather than an increase in the number of child-only cases. 

Hard-to-Employ TANF Recipients: 

Some TANF cash assistance recipients are work-ready while others face 
challenges that make them harder to employ. According to the preamble 
to a TANF final rule from 1999, several provisions of the law, 
including time limits, higher participation rate requirements, and 
fewer individual exemptions from participation requirements, taken 
together, suggest that states should serve more clients beyond just 
those who are job-ready.[Footnote 24] However, some state TANF 
officials we interviewed for a 2012 report said the pressure to meet 
TANF work participation rate requirements causes them to focus on the 
"ready-to-work" cash assistance population, which can leave the "hard-
to-employ" population without services. Health issues, disability, 
substance abuse, criminal records, domestic violence, limited 
education, and responsibilities for disabled children or parents can 
all constitute employment challenges for TANF recipients, who may need 
enhanced assistance to prepare for, find, and keep jobs. States may 
generally only count a family's participation in job readiness 
assistance, which can include mental health and substance abuse 
treatment, towards the work participation rate for up to 12 weeks in a 
year. 

Selected State and Local Programs Reflect Elements of Four Promising 
Approaches: 

Research Indicates Several Promising Approaches for Increasing 
Employment and Earnings: 

A body of rigorous research points to four approaches that can be used 
to increase the employment and earnings of TANF cash assistance 
recipients: subsidized employment, treatment and employment services, 
career pathways, and modified work-first.[Footnote 25] While still 
relevant, some of this research is based on programs that operated, at 
least in part, during TANF's predecessor program, AFDC, and have since 
ended; and some of these older studies focused on programs that 
predominantly targeted women. Some prior studies have also focused on 
individuals with education levels that are higher, on average, than 
the TANF population. Further, although some of the programs discussed 
helped to increase participants' employment and earnings--and 
therefore, may have decreased dependence on public assistance--they 
did not necessarily increase household incomes. This is because the 
increased income from earnings can be offset by the loss of cash 
welfare, food assistance, and other support services. Ongoing 
research, including some of the current studies discussed below and in 
appendix III, aims to test updated versions of some of these 
approaches that might lead to longer-term results. 

Side bar: 

Research Snapshot: Subsidized Employment Evaluation of Florida's Back 
to Work program: 

Florida's Back to Work program used American Recovery and Reinvestment 
Act of 2009 funding to create subsidized jobs. Administered by 
regional workforce boards, it operated in 2010 and placed about 5,600 
individuals in subsidized jobs. For-profit, non-profit, and public 
sector employers received subsidies that covered 80 to 95 percent of 
program participants' wages for 6 months. For-profit organizations 
were asked to commit to hiring the participants after the subsidy 
ended and non-profits were encouraged to do the same. Program 
participants experienced significantly greater increases in 
unsubsidized employment compared to individuals who were eligible but 
did not take part in subsidized employment. Participants experienced a 
nearly $4,000 average increase in earnings over their prior earnings 
compared to about a $1,500 average increase for the comparison group. 

Source: Anne Roder and Mark Elliott, Stimulating Opportunity: An 
Evaluation of ARRA-Funded Subsidized Employment Programs, Economic 
Mobility Corporation, Inc. (New York, NY: September 2013). 

[End of side bar] 

* Subsidized employment - Subsidized employment broadly refers to the 
use of public funds to create or support temporary work opportunities 
for people who might otherwise be unemployed. One model of subsidized 
employment--transitional jobs--focuses on the hard-to-employ by 
providing temporary, wage-paying jobs, support services, and job 
placement help to individuals who have difficulty getting and holding 
jobs in the regular labor market. Subsidized employment programs have 
been used for decades to provide income support for people who are 
unable to find jobs in the regular labor market and improve 
employability for people with limited work experience.[Footnote 26] 
These programs can vary, for example, in terms of the amount of wages 
that are subsidized; prospects for permanent, unsubsidized employment; 
the degree of worksite supervision provided; and whether the worker is 
employed directly or through an intermediary (see figure 3). 

Figure 3: Two Subsidized Employment Models: 

[Refer to PDF for image: illustration] 

Direct hire: 
Participants are on employer’s payroll, but wage, payroll, and 
supervision costs are subsidized. 

Intermediary: 
Participants are on a third-party’s payroll and have built-in support 
activities while working for the employer. Employer pays supervision 
costs, but wage and payroll costs are paid by intermediary. 

Source: GAO depiction of two subsidized employment program models, as 
described in Anne Roder and Mark Elliott, Stimulating Opportunity: An 
Evaluation of ARRA-Funded Subsidized Employment Programs, Economic 
Mobility Corporation, Inc. (New York, NY: September 2013). GAO-15-31. 

[End of figure] 

Research has shown that subsidized employment can increase employment 
and earnings, although some studies suggest that these gains may not 
last beyond the subsidized position. Nevertheless, these programs can 
provide individuals who are hard to employ with work experience and 
can have indirect effects, such as reduced recidivism among former 
prisoners. Subsidized employment programs in the 1970s and 1980s, 
during the time of TANF's predecessor program, yielded positive 
results on employment and earnings. One such demonstration project 
tested a model in which 10,000 welfare recipients in seven locations 
received 4 to 8 weeks of training and spent up to one year in 
subsidized positions as home health aides.[Footnote 27] Most of the 
subsidized employment programs that produced long-term employment 
gains targeted women; disadvantaged men experienced fewer positive 
results following the period of subsidized employment. 

Following welfare reform, transitional jobs gained traction as a 
strategy to increase the employability of TANF recipients. The theory 
behind this approach is that people best learn to work through 
working. Program staff can observe and coach participants on skills 
such as developing good work habits and dealing with coworkers to 
improve their future success in an unsubsidized job. Participants may 
be able to subsequently acquire jobs they would not otherwise have 
access to. Recent studies of transitional jobs programs have not shown 
sustained increases in employment, although these programs had 
indirect effects of reducing recidivism and reliance on welfare 
receipt.[Footnote 28] 

As part of the American Recovery and Reinvestment Act of 2009, 
Congress provided funding through the TANF Emergency Contingency Fund 
that in part helped states cover the costs of increased expenditures 
for subsidized employment programs.[Footnote 29] Thirty-nine states 
and the District of Columbia reportedly used $1.3 billion from the 
Emergency Contingency Fund to create 260,000 subsidized jobs, 
according to research.[Footnote 30] Although these efforts were not 
focused solely on TANF cash assistance recipients, experts we spoke 
with said the availability of additional funds renewed interest among 
states in subsidized employment. According to one study, these efforts 
involved the private sector in creating subsidized positions to a 
greater extent than in the past.[Footnote 31] 

Two coordinated research initiatives are currently under way to 
evaluate the "next generation" of subsidized employment programs. The 
HHS-funded Subsidized and Transitional Employment Demonstration is 
evaluating seven subsidized employment programs that target current, 
former, or potential TANF recipients, low-income noncustodial parents, 
and others. The Department of Labor-funded Enhanced Transitional Jobs 
Demonstration is evaluating seven sites for which it has provided 
grants for transitional jobs programs that target either non-custodial 
parents or former prisoners. HHS and the Department of Labor entered 
into a memorandum of agreement to coordinate these studies through 
shared data collection instruments and evaluation sites and 
coordinated reporting efforts. Both projects incorporate lessons from 
earlier research on transitional jobs and test whether providing 
subsidies to private employers can be effective for less job-ready 
participants. Reports on the results of these studies are scheduled 
for 2015 through 2018. 

Research Snapshot: Treatment and Employment Services; Evaluation of New 
York City's Personal Roads to Individual Development and Employment 
(PRIDE): 

New York City's PRIDE was a large-scale welfare-to-work program for 
recipients with work-limiting medical or mental health conditions. 
This program operated from 1999 to 2004, and served more than 30,000 
people. Staff performed in-depth assessments of participants' work and 
education histories and medical conditions, then assigned them to 
activities--including unpaid work experience, education, and job 
placement assistance--that took account of their medical conditions. 
An evaluation of 3,000 randomly-assigned participants found that PRIDE 
significantly reduced the amount of welfare that participants 
received, in part because it generated increases in employment. Thirty-
four percent of participants worked in jobs covered by unemployment 
insurance within 2 years after entering the study, compared to 27 
percent of the control group. However, about two-thirds of 
participants never worked during the 2-year study period. 

Source: Dan Bloom, Cynthia Miller, and Gilda Azurdia, Results from the 
Personal Roads to Individual Development and Employment (PRIDE) 
Program in New York City, a report prepared by MDRC at the request of 
the U.S. Department of Health and Human Services (July 2007). 

[End of side bar] 

* Treatment and employment services - This approach provides treatment 
for mental health needs, substance abuse, or a physical disability as 
well as employment services in different combinations and sequences 
(see figure 4). The theory behind this approach is that treatment can 
help to stabilize a health condition to make steady work possible, 
while work experience can help participants learn how to manage 
problems that could otherwise prevent them from retaining a regular 
job. 

Figure 4: Treatment and Employment Services: 

[Refer to PDF for image: illustration] 

Conditions: 
Substance abuse; 
Mental disabilities; 
Physical disabilities. 

Services: 
Treatment services; 
Employment services. 

Leads to: 
Employment. 

Source: GAO analysis. GAO-15-31. 

[End of figure] 

Rigorous research has shown some limited impacts for this approach. 
Evaluation of one program that offered a mix of unpaid work 
experience, educational activities, and job search assistance to TANF 
recipients with work-limiting health conditions and disabilities 
showed, to some extent, increased employment that lasted for two 
years.[Footnote 32] Another evaluation for a program in which staff 
visited participants' homes to teach them life skills showed 
substantial increases in employment and earnings for those considered 
very hard to employ, but the larger population of participants 
receiving services experienced only small increases in employment and 
earnings.[Footnote 33] In terms of future research possibilities, HHS 
is considering whether emerging research from the fields of psychology 
and neuroscience on executive functioning--which is related to 
behaviors such as goal-setting, self-regulation, planning, and problem-
solving--could help adults succeed in employment.[Footnote 34] If so, 
it may have applications for TANF. 

* Career pathways - This approach has been defined in different ways, 
but can involve providing contextual learning to prepare individuals 
of various skill levels to advance in a high-demand occupation or 
industry. Reading, writing, and math skills are taught using real-life 
materials and situations from the industry in which they will be used. 
Employers in the targeted sectors help to determine what skills are 
required for participants to become employed and advance their careers 
in growing industries. Workers of varying skill levels can use 
multiple entry or exit points to advance within a specific sector or 
occupational field and gain industry-recognized credentials through a 
clear sequence of education, training, or a combination of education 
and training. Participants are provided career counseling and other 
support services (see figure 5). 

Figure 5: Career Pathways: 

[Refer to PDF for image: illustration] 

Employer: 
Employer identifies education and training needed for high-demand jobs. 

Worker in training: 
Jobs skills incorporated in all training; Workers can start or exit on 
any step: 
Support services; 
Secondary and adult education; 
Post-secondary education, including apprenticeships; 
Industry-recognized credential(s). 

Source: GAO depiction of career pathways elements, as described in 
Social Policy Research Associates, Career Pathways Toolkit: Six Key 
Elements for Success, U.S. Department of Labor, (Washington, D.C.: 
September 2011). GAO-15-31. 

[End of figure] 

This approach builds on results from a random-assignment evaluation of 
sector-based employment, indicating that programs offering sector-
specific training can increase the employment and earnings of low-
income individuals.[Footnote 35] The approach is also informed by 
lessons from prior research showing that adult basic education alone 
has not been successful in connecting low-skilled individuals to jobs. 
Research on education-oriented welfare-to-work programs that operated 
in the 1980s and 1990s showed that the most successful programs 
offered short-term assignments that did not allow participants to 
"languish" in activities without making progress. This is in contrast 
to remedial education and GED preparation programs that either had 
difficulty retaining participants or kept them for years without clear 
progress. These prior findings informed a call for training that 
promotes career advancement, integrates basic education and skills 
training, and engages local employers, while providing support 
services to TANF recipients to improve program retention.[Footnote 36] 

Side bar: 

Research Snapshot: Sector-Based Career Training: Public/Private 
Ventures' Sectoral Employment Impact Study: 

Results from Public/Private Ventures' Sectoral Employment Impact Study 
based on follow-up interviews 24 to 30 months after random assignment 
suggest that sectoral programs can increase the employment and 
earnings of traditionally disadvantaged workers. The study, launched 
in 2003, evaluated three sectoral programs that train workers for 
skilled positions in a range of industries, including healthcare, 
manufacturing, information technology, and construction. The study 
assessed impacts on employment, earnings, hourly wages and access to 
work-related benefits. Programs included in the study offered training 
that was focused on a specific sector or sectors and that took no more 
than a year to complete. Over the follow-up period, treatment group 
participants were employed an average of 1.3 months more than 
individuals in the control group. Individuals enrolled in training also 
earned about $4,500 more than individuals in the control group over a 
2-year period and were also more likely to work in jobs with higher 
wages and benefits. 

Sources: Sheila Maguire et al., Tuning In to Local Labor Markets: 
Findings from the Sectoral Employment Impact Study, Public/Private 
Ventures (Philadelphia, PA: 2010); and Alan Werner et al., Literature 
Review: Career Pathways Programs, OPRE Report #2013-24, Office of 
Planning, Research and Evaluation, Administration for Children and 
Families, Department of Health and Human Services (Washington, D.C.: 
June 24, 2013). 

[End of side bar] 

As confirmed by HHS officials, there are no completed rigorous 
experimental impact studies of a comprehensive career pathways 
program, but HHS is funding relevant ongoing evaluations, as part of 
an inter-agency effort with the Departments of Education and Labor to 
promote the use of career pathways.[Footnote 37] One of the studies, 
known as the Innovative Strategies for Increasing Self-Sufficiency 
project, is a nine-site, random assignment evaluation of career 
pathway programs. Initiated in 2007, the study will last 10 years, and 
early results are expected in the next 2 to 3 years. HHS also has a 
research portfolio for evaluating health care-related education and 
training programs operated with Health Profession Opportunity Grants 
(HPOG). These grants are targeted to TANF recipients and other low-
income individuals and aim to prepare them for occupations in the 
health care field that pay well and are expected to either experience 
labor shortages or be in high demand. Three of the HPOG grantees are 
to have site-specific impact evaluations as part of the Innovative 
Strategies for Increasing Self-Sufficiency project with reports 
expected in 2016. An interim analysis of the impacts of HPOG is 
expected in June 2016. HHS expects that further follow-up analysis of 
both Innovative Strategies for Increasing Self-Sufficiency and HPOG 
impacts will be released in 2018. 

The Department of Education, Department of Labor, and HHS have jointly 
promoted the use of career pathways approaches as a promising strategy 
for helping adults acquire marketable skills and industry-recognized 
credentials.[Footnote 38] The three agencies issued a Request for 
Information on the use of career pathways in April 2014 to inform 
policy development, strategic investments, and technical assistance 
activities and improve coordination of federal policy development. 
[Footnote 39] The agencies have begun a joint analysis of responses to 
the Request for Information. According to HHS officials, this 
information will yield insights on (1) the benefits of and challenges: 
to aligning diverse funding streams, programs, and stakeholders around 
career pathways systems; and (2) the current and potential future use 
of career pathways systems to help at-risk populations, including TANF 
cash assistance recipients, gain skills and access the middle class. 

Side bar: 

Research Snapshot: Modified Work-First Approach: The National 
Evaluation of Welfare-to-Work Strategies (NEWWS): 

NEWWS examined the long-term effects of 11 mandatory welfare-to-work 
programs, in seven sites, on welfare recipients and their children. 
These programs took different approaches to helping welfare recipients 
find jobs, advance in the labor market, and leave public assistance. 
During the 1990s, more than 40,000 single-parent families were tracked 
over 5-year follow-up periods. A Portland, Oregon program outperformed 
the other programs that were examined. It offered education or 
training to some participants, depending on the caseworkers' 
assessment of the individuals' skills and needs, and encouraged all 
participants to hold out for jobs that paid better than the minimum 
wage and offered stable employment. In the program's fifth year, it 
produced a 6.4 percent increase in employment and 14.6 percent 
increase in average earnings, compared to the control group. 

Source: Gayle Hamilton, Moving People from Welfare to Work: Lessons 
from the National Evaluation of Welfare-to-Work Strategies, Department 
of Health and Human Services, a report prepared by Manpower 
Demonstration Research Corporation at the request of the Department of 
Education (Washington, D.C.: 2002). 

[End of side bar] 

* Modified work-first - This approach entails a strong work focus and 
some upfront education or training, as needed (see fig 6). Research on 
welfare-to-work programs during the 1990s sought to test the 
effectiveness of programs that emphasized rapid employment ("work 
first") through mandatory job search compared to those that focused 
first on mandatory education and training. One program combined 
aspects of both of these approaches: it included a strong employment 
focus, the use of both job search and short-term education or 
training, and an emphasis on holding out for a good job, as opposed to 
participants taking the first job they were offered.[Footnote 40] 

Figure 6: Modified Work-First Approach: 

[Refer to PDF for image: illustration] 

Initial assessment: 
Education or training; 
Employment. 

Source: GAO analysis. GAO-15-31. 

[End of figure] 

Research shows that programs using this approach increased employment 
and earnings and reduced welfare receipt. This approach appears more 
effective than programs that focus solely on education and training or 
solely on job search. 

All Selected Programs Focus on Employment while Using Various Elements 
of the Approaches to Meet the Needs of Their Target Populations: 

We examined 10 ongoing programs that all help TANF cash assistance 
recipients to gain employment, using various different elements of the 
above cited promising approaches to meet a range of participant needs 
(see table 1).[Footnote 41] These populations included those whose 
limited prior work experience prevented them from gaining employment 
on their own, those with one or more work-limiting characteristic such 
as a mental or physical disability or substance abuse problem, and 
those in need of additional skills to enter a new field or to increase 
their employability. All of the selected programs serve TANF 
recipients: 5 of the 10 serve TANF recipients exclusively, while the 
other programs serve a broader population. 

Table 1: Characteristics of Selected Programs: 

Program name: San Francisco Jobs Now!; 
Program approach: 
Subsidized employment: [Check]; 
Treatment and employment services: [Empty]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: Adults divided into three tiers ranging from hard-
to-employ to work-ready; 
Percentage of participants who receive TANF cash assistance: 41%. 

Program name: Los Angeles County subsidized employment program; 
Program approach: 
Subsidized employment: [Check]; 
Treatment and employment services: [Empty]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: TANF recipients ranging from hard-to-employ to work-
ready; 
Percentage of participants who receive TANF cash assistance: 100%. 

Program name: Erie County (NY) Placing Individuals in Vital Opportunity 
Training (PIVOT); 
Program approach: 
Subsidized employment: [Check]; 
Treatment and employment services: [Empty]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: Job-ready TANF recipients who had not found jobs on 
their own or during "job club" activities; 
Percentage of participants who receive TANF cash assistance: 100 %. 

Program name: Utah Licensed Clinical Therapists; 
Program approach: 
Subsidized employment: [Empty]; 
Treatment and employment services: [Check]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: TANF recipients with substance abuse, domestic 
violence, or mental health problems; 
Percentage of participants who receive TANF cash assistance: 100%. 

Program name: New York City's Wellness, Comprehensive Assessment, 
Rehabilitation and Employment program (WeCARE); 
Program approach: 
Subsidized employment: [Empty]; 
Treatment and employment services: [Check]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: Adults with mental or physical health or substance 
abuse problems; 
Percentage of participants who receive TANF cash assistance: 18 %. 

Program name: Ramsey County (MN) Families Achieving Success Today 
(FAST); 
Program approach: 
Subsidized employment: [Empty]; 
Treatment and employment services: [Check]; 
Career pathways: [Empty]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: Adults with mental or physical health or substance 
abuse problems; 
Percentage of participants who receive TANF cash assistance: 9%. 

Program name: Washington State Integrated Basic Education and Skills 
Training (I-BEST); 
Program approach: 
Subsidized employment: 
Treatment and employment services: [Empty]; 
Career pathways: [Check]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: 
Low-skilled and low-literacy adults; 
Percentage of participants who receive TANF cash assistance: 15%. 

Program name: Minnesota Fast Training Resources and Credentialing Adult 
Career Pathways (FastTRAC); 
Program approach: 
Subsidized employment: [Empty]; 
Treatment and employment services: [Empty]; 
Career pathways: [Check]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: Low-wage, low-skilled adults; 
Percentage of participants who receive TANF cash assistance: 18%. 

Program name: Kentucky Ready to Work; 
Program approach: 
Subsidized employment: [Check]; 
Treatment and employment services: [Empty]; 
Career pathways: [Check]; 
Modified work first: [Empty]; 
Participant characteristics: 
Target population: TANF recipients interested in education; 
separate track for those with low literacy and math skills; 
Percentage of participants who receive TANF cash assistance: 100%. 

Program name: District of Columbia TANF program; 
Program approach: 
Subsidized employment: [Empty]; 
Treatment and employment services: [Empty]; 
Career pathways: [Empty]; 
Modified work first: [Check]; 
Participant characteristics: 
Target population: TANF recipients; separate tracks for those with 
different levels of education, experience, and skills and personal, 
health, or other barriers; 
Percentage of participants who receive TANF cash assistance: 100%. 

Source: GAO analysis of information provided by experts and program 
officials. GAO-15-31. 

[End of table] 

Some of the programs we examined offered subsidized employment to 
those whose limited prior work experience prevents them from gaining 
employment on their own. For example: 

* San Francisco's Jobs Now! program uses a community jobs model 
similar to a transitional employment program to place participants in 
employment positions. The program includes 6 months of subsidized 
employment and is targeted to those with limited experience or 
exposure to work. Some participants are placed in public service 
training programs where they are employed with the local human 
services agency or other city departments like the Office of Parks and 
Recreation. Other participants who are more job ready are placed in a 
wage-subsidy program with private businesses. Under this program tier, 
Jobs Now! subsidizes 100 percent of the wage for the first month, 75 
percent for the second month, and $1,000 for the next 3 months. 
Employers also agree to make a good faith effort to retain the 
employee after the subsidy ends. Administrators reported that the 
retention rate with private employers--once the subsidy ends--is 
between 75 and 80 percent. 

* Similarly, Erie County, New York's PIVOT wage subsidy program 
requires a commitment from employers to hire participants after the 
wage subsidy ends. PIVOT is designed to serve those TANF recipients 
who are among the more work-ready, but who did not find jobs on their 
own during previous job search activities. When participants are 
referred to the program through the local TANF agency, they receive a 
skills assessment and enter a job-readiness training program for 45 
days while their eligibility is being determined. Participants are 
screened to match their skill levels with employer needs. PIVOT places 
participants in local employment--in industries such as banking, 
hospitality, legal services, manufacturing, health, and childcare--for 
6 months during job training. Participants' days are typically split 
between a work experience program and other work activities such as 
GED classes or barrier remediation, such as English lessons for 
refugees with language barriers. 

* Los Angeles County's large subsidized employment program includes a 
component in which participants can gain work experience with for-
profits, nonprofits or government agencies, and an on-the-job training 
component that places participants with private sector employers. For 
the latter, a subsidy for the participants' wages is sent to a private 
job provider during the first two months of employment. After those 60 
days, the wage is paid directly by the employer, who receives $350 for 
each part-time employee and $500 for each full-time employee. 

Three of the ten programs we examined used the treatment and 
employment services approach to serve participants with one or more 
physical or mental disabilities, substance abuse, or other work-
limiting characteristics. 

* Utah's Licensed Clinical Therapist program provides services for 
clients with substance abuse, domestic violence, and mental health 
problems. An administrator said participants often enter the program 
under emotional turmoil that--if untreated--would prevent them from 
gaining stable employment. To address this need, clients receive a 
clinical assessment to diagnose mental health problems and they can 
participate in clinical therapy sessions offered by the program in 
combination with job search and resume building activities. 

* New York City WeCARE was designed to provide comprehensive services 
to hard-to-employ clients with mental or physical health needs or 
substance abuse problems. The program uses an in-house comprehensive 
assessment of physical, psychological, and social needs by a board-
certified doctor and social worker to determine whether a client is 
fully employable, can participate in work-related activities with 
limitations, needs treatment to stabilize a condition before engaging 
in work-related activities, or if the client could be eligible for 
federal disability benefits. One important program element is 
flexibility. For example, participants have a window of several days 
to make a scheduled appointment. A contractor told us that by offering 
flexibility, the program is better able to engage participants whom 
other programs might automatically sanction for non-
participation.[Footnote 42] 

* Ramsey County, Minnesota's FAST program is a partnership between 
agencies that co-locate services like mental health treatment, 
vocational rehabilitation, community health care, and TANF employment 
supports. Administrators said with the right supports and an 
individualized service plan, clients with mental or physical health or 
substance abuse problems -who are not eligible for federal disability 
benefits--can gain employment. FAST contracts services with Goodwill/ 
Easter Seals, which provides day-to-day supervision of participants 
and facilitates the individual placement and supports created for 
them. Home visits are used as needed to assess families' needs, and 
family supports, including employment retention services, can last up 
to 9 months or longer. 

Three of the ten programs we examined used multiple elements of the 
sector-based career pathways approach to increase the skills of 
participants looking to enter a new field or increase their 
employability. 

* Washington State's I-BEST program was developed to help participants 
increase their literacy and basic skills while earning certificates or 
degrees in order to qualify for in-demand jobs. The program is offered 
in 34 community and technical colleges in the state. The program 
curriculum is based on regional job market demands and resources. A 
college must demonstrate local demand for a career program and show 
that those who complete the program will be able to exit it and 
receive an average wage of $13/hour or more. Program administrators 
said they believe their program is successful because of its team-
taught, integrated service delivery model. Within I-BEST classrooms, 
two instructors work together to bolster basic skills while 
integrating career-related content into students' curriculum. Since 
the program's founding about 10 years ago, more than 200 career 
programs in fields such as health care, early childhood education, and 
advanced manufacturing have been approved by the Washington State 
Board for Community and Technical Colleges. 

* The Minnesota FastTRAC program aims to move low-wage, low-skilled 
adults into credit-bearing training. Participants typically enter the 
program after being referred by various sources including local TANF 
and workforce programs. Participants are screened to determine their 
education level and needs. Similar to the I-BEST program, clients then 
go to classroom-based programs, in which instruction in math and 
reading is provided within the context of a profession like 
healthcare. Clients may also participate in some job shadowing during 
this period. 

* Similarly, Kentucky officials perceived a need to increase 
educational attainment among the TANF population to improve their 
employability and launched the Ready to Work program about 16 years 
ago. The program is run statewide through the Kentucky Community and 
Technical College System. Unlike the I-BEST program, which focuses 
specifically on high-demand occupations, Ready to Work allows 
participants to select classes from the full catalogue of local 
courses. However, the program does offer counseling on job prospects 
in various career tracks. Participants also engage in on-or off-campus 
work study positions with public and private employers that are 
subsidized using TANF funds and connected to each participant's 
program of study and career goal. 

All of the programs we examined used some form of assessment to 
identify participants' service needs. Across the programs, factors 
assessed included skill levels, work history, interests, and physical 
and mental health. Additionally six of the 10 programs structured 
services or program offerings in two or more tiers or employment 
tracks for the purpose of better targeting the needs of participants. 

* For example, the D.C. TANF program, which uses elements of a 
modified work-first approach, was redesigned in 2008-2009 in response 
to complaints that under the program's "one size fits all" service 
delivery model, job-ready clients and those with significant barriers 
to employment were receiving the same services. Under the redesign, a 
continuum of services is available based on the client's needs at 
assessment. Clients are categorized into a service delivery tier based 
on their education, experience, and skills, as well as barriers they 
may face (see figure 7). 

Figure 7: D.C. TANF Program's Service Delivery Model: 

[Refer to PDF for image: illustrated grid] 

Vertical axis: Personal barriers (e.g., physical or psychological 
limitations): from Many to few or none. 

Horizontal axis: Education, work experience, and job skills: from low 
to high. 

Service delivery tiers: 

Financial support and barrier removal: 
Education, work experience, and job skills: low; 
Personal barriers: many. 

Work readiness: 
Education, work experience, and job skills: low; 
Personal barriers: few or none. 

Work support and barrier removal: 
Education, work experience, and job skills: high; 
Personal barriers: many. 

Job placement: 
Education, work experience, and job skills: high; 
Personal barriers: few or none. 

Source: GAO presentation of D.C. Temporary Assistance for Needy 
Families (TANF) program’s service delivery model. GAO-15-31. 

[End of figure] 

Selected Programs Emphasize Work Participation Rate to Varying Degrees: 

Although the programs we examined were all focused on work, they 
varied in the extent to which they were structured to help their 
states meet TANF's work participation rate requirements, according to 
state and program officials. Contributing to the work participation 
rate, such as by requiring participants to meet specific federally-
defined hours and activities requirements, was a goal of 5 of the 10 
programs, for at least some portion of the participants served. For 
example, a Kentucky Ready to Work program administrator said its work 
study component is its biggest asset for meeting the work 
participation rate requirements. Students are placed in private-
employment positions when possible and when positions are not 
available, administrators said students can work on campus or in 
volunteer positions to meet their hours requirements. In the D.C. TANF 
program, participants have different requirements depending on their 
service delivery tier. For example, job-ready participants are 
expected to meet both hours and activity requirements that are 
consistent with the federal work participation rate standards. Those 
who are less job ready must meet the hour requirements but may 
participate in any mix of activities even if it they do not count 
toward the District's work participation rate. An administrator told 
us the D.C. TANF program was designed based on what they thought would 
work best to get participants employed and with the expectation that 
this will also result in meeting the work participation rate 
requirements. 

The work participation rate requirement was given less emphasis by the 
other five programs we examined, according to state and program 
officials. These administrators said their programs did not emphasize 
the work participation rate because of a conscious choice to 
prioritize other program goals, or because their programs served too 
few work-eligible TANF recipients to affect the state's rate. Nearly 
all (9 of the 10 programs we examined) were components of larger TANF 
programs, meaning that states and localities may have a variety of 
other mechanisms for meeting the work participation rate requirements 
beyond these programs. Even without a strong emphasis on the work 
participation rate, these programs--like those that did emphasize the 
work participation rate--still maintained an employment focus and some 
offered activities that at least partially counted toward the work 
participation rate. 

Administrators in Los Angeles County's subsidized employment program 
said they do not over-emphasize contributing toward the work 
participation rate requirements, but instead focus on placing 
participants in work. Similar to the D.C. TANF program--where 
addressing participants' barriers and progressively increasing their 
engagement over time is thought to contribute to the work 
participation rate and increase long-term stable employment--Los 
Angeles County officials said if participants can be placed in 
employment, meeting the requirement is typically not an issue. 
Additionally, administrators said that because California allows 
clients to participate in some activities for longer durations than 
can be counted toward the federal requirement, they focus on keeping 
people engaged in work-related activities under the state rules. 
[Footnote 43] 

Because TANF cash assistance beneficiaries comprise only 15 percent of 
Washington State's I-BEST participants, contributing toward the work 
participation rate is not an explicit goal of this career pathways 
program. However, administrators said that time spent in the program's 
short-term training can count toward meeting the work participation 
rate requirements. Some experts who were knowledgeable about career 
pathways programs nationwide told us that some states have a 
misperception that the career pathways approach is not allowable under 
TANF rules, since only 12 months of vocational education training can 
be counted toward the work participation rate. However, HHS officials 
told us that states can allow TANF recipients to combine education 
with other work activities that count toward the work participation 
rate, meaning that within certain constraints, activities under the 
career pathways approach can be counted toward the work participation 
rate requirements. Some experts said that formal guidance from HHS, 
among other agencies, clarifying this fact might encourage broader 
use. Internal control standards for the federal government state that 
information should be communicated to managers and others who need it 
in a form that enables them to carry out their responsibilities. 
[Footnote 44] In TANF's decentralized block grant environment, state 
and local officials make many program decisions and it is important 
that they also receive pertinent information in a form that enables 
them to carry out their duties and responsibilities efficiently and 
effectively. While HHS's Administration for Children and Families has 
conducted webinars and regional workshops to help guide TANF agencies 
in the implementation of career pathways approaches, the agency has 
not issued any such formal guidance. Greater clarity regarding how 
activities related to the career pathways approach may be allowable 
under TANF rules could address misperceptions and encourage more 
widespread use of this approach by state and local TANF agencies. 

Expertise and Dedicated Funds Facilitated the Use of Promising 
Approaches, but the TANF Program Lacks Incentives for Wider Adoption 
or Testing: 

The Selected Programs Benefited from Partner Expertise and Dedicated 
Funding: 

Nearly all of the 10 programs we examined that currently use elements 
of promising approaches drew on expertise beyond the state or local 
TANF agency (see table 2). Nine of these programs involved 
partnerships with organizations and agencies such as community college 
systems, workforce agencies, and nonprofit organizations or contracted 
vendors. These partnerships provided the selected programs with access 
to the experience and expertise of a range of partners. For example: 

* Officials with the Los Angeles County TANF agency noted that 
partnership with a local workforce agency is a key facilitating factor 
in its subsidized employment program. The workforce agency has acted 
as the employer of record for payroll and insurance purposes, and had 
existing employer relationships, so the TANF agency did not need to 
develop these capacities. 

* While Kentucky's Ready to Work program is entirely funded by TANF, 
the program is administered by the state's community college system, 
and its case managers are located on campus and familiar with the 
college environment. According to program officials, clients generally 
pay their tuition through federal Pell Grants, so Ready to Work case 
managers help clients complete financial aid applications and ensure 
they remain eligible for the grants. 

* Officials with Ramsey County, Minnesota's FAST program that seeks to 
engage individuals with disabilities in work reported that the 
experience and credibility of the initiative's lead nonprofit partner 
was a key facilitating factor. They particularly valued the 
nonprofit's previous experience working with both rehabilitation and 
employment services, as opposed to other contractors that have only 
operated in the TANF employment context. 

Table 2: Selected Program Partner Organizations and Technical 
Assistance: 

Program name: San Francisco Jobs Now!; 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Empty]. 

Program name: Los Angeles County subsidized employment program; 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Check]; 
Nonprofit or vendor: [Empty]; 
Received technical assistance: [Check]. 

Program name: Erie County (NY) Placing Individuals in Vital Opportunity 
Training (PIVOT); 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Check]. 

Program name: Utah Licensed Clinical Therapists; 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [A]; 
Nonprofit or vendor: [Empty]; 
Received technical assistance: [Empty]. 

Program name: New York City's Wellness, Comprehensive Assessment, 
Rehabilitation and Employment program (WeCARE); 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Empty]. 

Program name: Ramsey County (MN) Families Achieving Success Today 
(FAST); 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Check]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Check]. 

Program name: Washington State Integrated Basic Education and Skills 
Training (I-BEST); 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Check]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Empty]; 
Received technical assistance: [Empty]. 

Program name: Minnesota Fast Training Resources and Credentialing Adult 
Career Pathways (FastTRAC); 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Check]; 
Workforce agency: [Check]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Check]. 

Program name: Kentucky Ready to Work; 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Check]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Empty]; 
Received technical assistance: [Check]. 

Program name: District of Columbia TANF program; 
Partner organizations in addition to state or local TANF agency: 
Community college system: [Empty]; 
Workforce agency: [Empty]; 
Nonprofit or vendor: [Check]; 
Received technical assistance: [Check]. 

Source: GAO summary of information provided by program officials. 
GAO-15-31. 

[A] Utah's TANF program is administered by the state workforce agency. 

[End of table] 

Six of the programs also received technical assistance from a federal 
agency or nonprofit, such as a policy research organization or 
foundation. For example, Minnesota officials cited participation in 
the federal Career Pathways Institute as an important step in the 
development of the state's career pathways program.[Footnote 45] 
Officials said participation in technical assistance activities 
connected them with many other programs that influenced elements of 
their work. Officials in Los Angeles and Ramsey County, Minnesota, 
said that taking part in an evaluation conducted by a research 
organization helped inform their program models, and Ramsey County 
officials said their participation had enabled them to access 
additional resources, such as training from national experts. 

Decisions by state and local policymakers to dedicate funds for the 
selected programs also facilitated the use of promising approaches, 
according to program officials. We have previously reported that when 
federal TANF funds are allocated to states, states do not necessarily 
direct the funding to state welfare agencies, but may allocate funds 
to support various programs depending on legislative priorities (see 
figure 8). Officials with 7 of the 10 programs we interviewed noted 
that state or local funding decisions had facilitated their use of 
promising approaches.[Footnote 46] For example, officials with the 
District of Columbia TANF program noted that the allocation of 
additional funding has been the key factor that has allowed the agency 
to continue to support its modified work-first approach. Officials 
reported that the approach requires more staff resources to assess 
clients' work readiness and determine appropriate activities than does 
the agency's prior model of "one size fits all." The allocation of 
additional resources has allowed the agency to support these staff. 
The allocation of additional funds by state and local governments also 
facilitated San Francisco's use of a subsidized employment approach 
for TANF cash assistance recipients, according to program officials. 
They reported that these funds have supported the agency's ability to 
increase its wage subsidy in an effort to attract higher-wage 
employers. 

Figure 8: Example of Possible Allocation of TANF Funds by a State: 

[Refer to PDF for image: illustration] 

Federal government: 
Department of Health and Human Services Administration for Children 
and Families: sends federal funds to: 

State government: 
State determines allocations to state agencies, which may also include 
state funds to meet maintenance of effort requirements. 

State agencies: 

Human services agency: 
Services: 
Cash assistance to recipients; 
Recipients: 
TANF caseload only. 

Workforce agency; Education department; Health department: 
Services: 
* Child welfare services (e.g., protective services, child abuse 
hotline, and adoption subsidies); 
* Child care;
* Support for homeless families; 
* Career training programs; 
* Job preparation (e.g., resume-writing and job search skills); 
* Pre-kindergarten program; 
* Teen pregnancy prevention program; 
* Substance abuse prevention and recovery; 
Recipients: 
Low-income families (deemed eligible by the state, including those on 
the TANF caseload). 

Source: GAO analysis based on examples of programs and services funded 
by Temporary Assistance for Needy Families (TANF) in various states. 
GAO-15-31. 

[End of figure] 

Additionally, in 3 of the 10 programs, TANF funds and other funding 
sources were mixed to support the program, which served both TANF 
clients and other low-income populations. For example, New York City's 
WeCARE program combined TANF funds with state and local funds to serve 
24,000 daily participants, which included TANF cash assistance 
recipients as well as low-income single adults and childless couples 
with clinical barriers to employment who received cash assistance 
through a state-funded program. These funding sources were combined to 
award contracts to vendors that provide treatment and employment 
services to any client regardless of his or her program affiliation. 
Officials with Minnesota's FastTRAC career pathways program said that 
initial funding for their program came from a foundation grant and 
subsequently from funds available under the American Recovery and 
Reinvestment Act of 2009. They noted that the state has been able to 
maintain the program after that funding was no longer available 
because the program is a partnership with multiple state agencies and 
a nonprofit organization, most of whom contribute some funding. These 
funds are combined and then sent to local providers of career pathways 
programs through competitive grants. While Minnesota officials 
suggested that combining resources across partners was key to their 
program, they also noted the challenges of reconciling different 
funding streams and performance measures. Experts knowledgeable about 
career pathways programs nationwide echoed these concerns to us. They 
suggested a need for federal guidance to clarify how various sources 
of federal funds can be used to support these programs, and that some 
TANF programs may be reluctant to use a career pathways approach in 
the absence of a clear statement that use of TANF funds for career 
pathways programs is explicitly allowable. As noted above, HHS has 
provided some information related to career pathways, but has not 
issued formal guidance. Consistent with internal control standards, 
guidance could help state and local officials to better carry out 
their responsibilities. Without explicit clarification that TANF funds 
may be used to finance career pathways activities, some state and 
local TANF agencies may be discouraged from attempting this approach. 

TANF Lacks Incentives for the Broader Adoption and Testing of 
Promising Approaches: 

As structured, the TANF program lacks incentives to encourage broader 
adoption of promising approaches by large numbers of state and local 
TANF agencies. The federal law that created TANF established a goal of 
increasing job preparation and employment, and included a provision 
addressing the development and evaluation of innovative approaches for 
reducing welfare dependency.[Footnote 47] However, several TANF 
program characteristics may not encourage states to adopt and test new 
approaches for increasing the employment and earnings of cash 
assistance recipients. HHS's authority over many aspects of TANF is 
limited and it has not proposed legislative changes to address these 
areas. Without federal action, adoption and evaluation of promising 
approaches may continue to be limited to select states and localities, 
leaving TANF recipients in other locations without access to these 
promising approaches. 

Program Design and Funding: 

TANF leaves many program design and funding choices to states. The law 
that created the TANF block grant established a goal of state 
flexibility, and restricted HHS's regulatory authority over the states 
except to the extent expressly provided in the law.[Footnote 48] This 
flexibility allows for multi-agency partnerships that can facilitate 
the use of promising approaches, as discussed above. It also allows 
states to spend TANF funds on a wide range of programs and services 
that are not necessarily related to welfare-to-work activities, as 
long as these services support one of TANF's four statutory purposes. 
[Footnote 49] In a 2012 report, we found that states spent significant 
amounts of TANF funds on services such as child welfare or child care, 
and that state use of federal TANF funds for these and other services 
can create tensions and trade-offs in state funding decisions. 
[Footnote 50] As a result, any additional resources needed for 
implementing more costly promising approaches for TANF cash assistance 
clients may compete with other allowable uses of TANF funds. Officials 
with three programs we interviewed that exclusively use TANF funds to 
implement elements of promising approaches noted that their programs 
had been continuously funded for many years and suggested that it 
would be difficult to find funding for the programs were they 
beginning today. 

Work Participation Rate Requirements: 

Additionally, the federal work participation rate requirements do not 
necessarily work as an incentive for states to implement certain 
promising approaches, according to our interviews and prior work. Some 
experts and HHS officials we interviewed suggested that limits on the 
amount of time that certain job readiness and training activities may 
be counted toward a state's work participation rate[Footnote 51] may 
discourage states from pursuing approaches that involve longer-term 
treatment or education. We have previously reported the concerns of 
state and local TANF officials that these limits do not allow 
sufficient time to address barriers to work for clients who have been 
out of the workforce for an extended period of time or to train 
clients for higher-wage employment that will prevent them from needing 
assistance in the future. 

Officials with 5 of the 10 programs we interviewed that were using 
promising approaches also expressed concerns about the limits. For 
example, officials with Ramsey County Minnesota's treatment and 
employment services program said the TANF work activities rules do not 
provide enough flexibility for families coping with mental illness in 
that the time limit on job search and job readiness assistance and the 
20-hour minimum for core work activities are not realistic for all. 
[Footnote 52] As a result, officials said most clients in the program 
receive cash assistance through a state program rather than through 
TANF.[Footnote 53] Yet, serving such clients through a state program 
instead of TANF likely limits the program's replicabilty in other 
state or local TANF agencies, as not all states may be willing to 
devote state funds for this purpose.[Footnote 54] Officials with 
Kentucky's Ready to Work program reported that the 12-month limit on 
counting vocational educational training toward the work participation 
rate[Footnote 55] has caused the program to rely more heavily on its 
work-study subsidized employment component, which has increased the 
program's cost. Further, one official said that while the subsidized 
work-study component is a critical program feature, the expectation 
that clients will work at least 20 hours a week once they have 
exhausted their allowable full-time education may affect academic 
outcomes. 

The work activity limits only apply to what states may count toward 
the work participation rate and do not prevent states from allowing 
clients to engage in these activities for longer periods of time. 
However, several experts we interviewed explained that many state 
policies on activities that are available to clients are shaped by the 
work participation rate requirements. That is, some states may design 
their programs to provide and support only those activities that count 
toward the work participation rate, while other states also provide 
and support activities that do not count toward the rate. In addition, 
we have previously found that states have relied on a combination of 
factors allowed in law to reduce the percentage of families they 
needed to engage in work to meet their work participation rate 
requirements.[Footnote 56] According to the most recent data available 
from fiscal year 2011, 23 states used these factors to reduce their 
required work participation rate for all TANF families from 50 percent 
to 0 percent. As a result, states may have less incentive to use 
promising approaches to engage hard-to-employ individuals in work 
activities, as they can meet their work participation rate 
requirements without engaging these individuals. In 2013, we noted 
that the work participation rate is complex and that any potential 
changes to the measure would likely have a profound impact on state 
TANF programs.[Footnote 57] 

Research and Evaluation: 

Finally, interviews conducted for this report and our previous work 
indicate that state and local TANF agencies have little incentive to 
test the effectiveness of new approaches. While several program 
administrators cited short-term or anecdotal evidence that their 
programs may contribute to increases in employment and earnings, only 
4 of the 10 programs had undergone or were currently involved in a 
rigorous impact evaluation.[Footnote 58] States are not required to 
conduct impact evaluations of their TANF programs under federal TANF 
law, although these evaluations can provide useful information on 
program effectiveness. A rigorous evaluation impact study with a 
random assignment design allows for comparison with a control group in 
order to distinguish the program's influence from other factors. 

Officials with some of the programs that had not undergone rigorous 
evaluations said they had not participated in these studies because of 
concerns about administrative burden, the newness of the program, or 
that a portion of their caseload would not receive services or count 
toward the work participation rate. Local Minnesota FastTRAC 
contractors said long-term follow ups with clients who had left the 
program would be burdensome to staff, who need to focus on newer or 
existing participants' needs. An official with the D.C. TANF program 
said it had not yet been evaluated formally because the program had 
only recently been redesigned. A Kentucky Ready to Work administrator 
said the program has not been rigorously evaluated through a random 
assignment study. The administrator said this was because the state 
TANF agency does not want to deny services to anyone who is eligible 
as a result of being assigned to a control group or miss an 
opportunity to contribute toward the work participation rate.[Footnote 
59] An administrator at one site that was undergoing a rigorous impact 
evaluation said that because only half of study participants would be 
selected for the program, recruitment for the study was challenging. 

We have previously found that although HHS has a strong tradition of 
leading and supporting rigorous welfare research, there are fewer 
incentives for states to evaluate their programs under TANF than 
existed under the previous welfare program with its evaluation and 
funding provisions.[Footnote 60] Indeed, although HHS maintains an 
active research agenda, TANF agency participation in some recent and 
ongoing HHS evaluations has been limited. For example, none of the 
four sites in the recently-completed Enhanced Services for the Hard-to-
Employ Demonstration and Evaluation were TANF agencies.[Footnote 61] 
In addition, in two ongoing evaluations of career pathways programs, 
participating sites consist primarily of community colleges and 
workforce agencies. According to HHS, these sites vary in the extent 
to which they serve TANF cash assistance recipients.[Footnote 62] An 
HHS official we interviewed reported that engaging TANF programs in 
evaluations of promising approaches is difficult because of the 
administrative burden on the state or locality. Officials added that 
HHS has no authority to require state agency participation in research 
and evaluation and no dedicated funding to provide states or 
localities incentives to participate. However, HHS officials also 
noted that often entities beyond TANF agencies serve TANF cash 
assistance recipients and research findings are still relevant for 
these partners. HHS has also taken steps to share research findings 
with local TANF programs, welfare researchers, and policymakers. For 
example, the agency has sponsored an annual Welfare Research and 
Evaluation Conference to share evaluations of welfare reform and 
formulate ways to incorporate these findings in the design and 
implementation of programs since 1998. HHS also makes research results 
available through presentations at other conferences related to 
welfare and low-income issues, their agency websites, and online 
announcements sent to subscribers. 

Conclusions: 

While the 10 state and local programs we examined are making use of 
some promising approaches for moving TANF recipients into employment 
and increasing their earnings, incentives are lacking for large 
numbers of state and local TANF agencies to adopt and test such 
approaches under the structure of the TANF program. This suggests a 
loss of opportunity. Data already suggest that state TANF programs 
currently engage recipients in a relatively limited range of 
activities and that more TANF recipients could be engaged in 
activities that are work-related. TANF's goals include ending needy 
families' dependence on government benefits by promoting work. 
However, the program's block grant structure means that many policy 
decisions are decentralized, and HHS has limited authority in 
directing state programmatic choices. This tends to leave innovation 
to individual localities and states. Yet other allowable uses of TANF 
funds compete with the adoption of promising welfare-to-work 
approaches. Further, limited participation by TANF agencies in HHS 
evaluations may slow the development and adoption of new promising 
approaches, leaving TANF without a continuous improvement process. In 
announcing its intention to exercise waiver authority, HHS noted that 
the purpose of its proposed waivers was to test alternative and 
innovative strategies, policies, and procedures designed to improve 
employment outcomes for needy families. However, as HHS officials told 
us, no state has applied for a waiver since its announcement in 2012. 
While we are not taking a position on whether HHS has authority to 
issue waivers, it is clear that this strategy has not encouraged 
states to innovate and test new approaches. We recognize that PRWORA 
limits HHS's authority over state program and funding choices and 
evaluations of state programs. Yet, HHS, as the federal agency that 
oversees TANF, is positioned to identify, suggest, and work in 
consultation with Congress on potential changes that would address the 
lack of incentives for states to adopt promising approaches. Absent 
federal action, adoption and evaluation of promising approaches may 
continue to be limited to select states and localities, leaving TANF 
recipients in other locations without access to these promising 
approaches. In the meantime, at least one promising approach--career 
pathways--appears to suffer from misperceptions about whether 
activities under the career pathways approach can be counted toward 
the work participation rate, or whether the career pathways approach 
is allowable with TANF funds. Without clarification that it is, 
indeed, allowable, TANF agencies may be discouraged from attempting it. 

Recommendations for Executive Action: 

To encourage broader adoption and evaluation of promising approaches 
and address impediments to the use of the career pathways approach 
among TANF agencies, we recommend that HHS should take the following 
two actions: 

* In consultation with Congress, identify potential changes that would 
address the lack of incentives for states and localities to adopt 
promising approaches and then develop and submit a legislative 
proposal outlining those changes. 

* Issue formal guidance to clarify how activities under the career 
pathways approach can be countable for the purpose of the work 
participation rate and that TANF funds may be used to finance the 
career pathways approach. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to HHS, the Department of 
Education, and the Department of Labor. The Departments of Education 
and Labor did not have comments. HHS provided written comments, 
reproduced in appendix V, in which the agency generally concurred with 
our recommendations. HHS also provided technical comments that we 
incorporated, as appropriate. 

HHS agreed with our recommendation that the agency consult with 
Congress on ways to address the lack of incentives for states and 
localities to adopt promising employment-focused approaches. HHS noted 
that in the Administration's Fiscal Year 2015 Budget Request, it 
stated, "when Congress takes up reauthorization, the Administration 
will be prepared to work with lawmakers to strengthen the program's 
effectiveness in accomplishing its goals. This effort should include 
using performance indicators to drive program improvement and ensuring 
that states have the flexibility to engage recipients in the most 
effective activities to promote success in the workforce, including 
families with serious barriers to employment." The budget request also 
included a legislative proposal to increase incentives for states to 
implement or strengthen subsidized employment programs by creating a 
new initiative funded by diverting existing TANF Contingency Funds to 
this new use. We were aware of these points in HHS's budget request 
and maintain that HHS should develop more concrete proposals to 
address the lack of incentives within the TANF program itself, and 
note that the agency need not wait for Congress to take up 
reauthorization to do so. HHS also noted that it has sponsored a large 
body of research that helps federal policy makers understand the wide 
variety of services provided by state TANF programs and provides 
credible information to state TANF decision-makers about possible 
innovative and effective approaches to serving their clients. At the 
same time, the agency acknowledged that gaps remain in the research on 
effective employment-focused approaches for low-income families and 
noted that additional research is needed. 

HHS also agreed with our recommendation that the agency issue formal 
guidance to clarify how the career pathways approach can be used by 
TANF agencies. HHS said that it will issue a formal Information 
Memorandum on the implementation of career pathways approaches in 
TANF, as part of the agency's ongoing technical assistance efforts. It 
also elaborated on the various ways it has promoted career pathways 
and other employment-focused approaches in recent years, as we 
acknowledged in the report. In addition to the need for guidance, HHS 
said that the 12-month limit on counting vocational education training 
toward the work participation rate is a constraint to the 
implementation of career pathways models in TANF programs. However, as 
we note in our report, states may allow TANF recipients to combine 
education with other work activities that count toward the work 
participation rate. Better clarification of this fact through formal 
guidance should help to address state misperceptions that the time 
limit on counting vocational education training prohibits the use of 
career pathways approaches. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Secretaries of Health and Human Services, Education, and Labor, and 
interested congressional committees. In addition, the report is 
available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made key contributions 
to this report are listed in appendix VI. 

Signed by: 

Kay E. Brown, Director: 
Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our report (1) reviews some approaches that have been identified as 
holding promise to engage TANF recipients in employment and increase 
their earnings and examines ways in which selected states and 
localities have used them, and (2) identifies factors that influence 
the use of these and other promising approaches. 

To first identify promising approaches, we reviewed research summaries 
and syntheses of rigorous research on approaches for engaging TANF 
recipients in employment and increasing their earnings.[Footnote 63] 
We primarily focused on studies that used a random assignment 
(experimental) research design. This type of design compares the 
outcomes for groups that were randomly assigned either to the 
treatment or to a nonparticipating control group before the 
intervention, in an effort to control for any systematic difference 
between the groups that could account for a difference in their 
outcomes. A difference in these groups' outcomes is believed to 
represent the program's impact.[Footnote 64] To help compile the 
research we reviewed, we conducted a literature search of 12 research 
databases, including EconLit, ProQuest Research Library, and Social 
Services Abstracts, using search terms such as "welfare to work." Our 
intent was not to describe all possible promising approaches, but 
rather to identify some key approaches. 

We considered approaches to be "promising" if a rigorous evaluation 
had determined that a program using this approach contributed to 
increased employment, income, or earnings, or reduced welfare receipt. 
Not all programs using the approach had to yield positive results in 
order for the approach to be considered promising. We realize that 
there is variation in how these approaches are implemented. Although a 
comprehensive career pathways program has not yet been rigorously 
evaluated, we included this approach because it was based on a 
rigorous evaluation of sector-based career training and lessons from 
other prior rigorous evaluations. 

We sought input on our list of approaches from researchers with MDRC, 
a nonprofit, nonpartisan education and social policy research 
organization. We also validated our list of approaches through the 
process of seeking expert nominations for programs currently using 
these approaches. For example, based on our review of the literature, 
we initially identified earnings supplements--the practice of 
supplementing low-wage workers' earnings with incentives to encourage 
employment and employment retention--as a possible promising approach. 
However, because we did not find any current examples of this approach 
being used to serve TANF cash assistance recipients, we did not 
include it in our final list of promising approaches. 

To identify state and local programs that are currently using these 
approaches to serve TANF cash assistance recipients, we interviewed 
cognizant researchers; officials from the Department of Health and 
Human Services (HHS), the Department of Labor, and the Department of 
Education; and others with TANF expertise. We selected 12 experts 
based on their knowledge of the research and efforts under way at the 
state and local level, as well as to reflect a range of perspectives 
on welfare-to-work issues. We identified them through our literature 
review and through referrals from other experts. We asked the experts 
and agency officials to identify state and local programs that are 
currently using the promising approaches we identified through our 
literature review to serve TANF cash assistance recipients. We asked 
the experts to indicate the specific reasons why they recommended 
these programs and whether evaluation results or outcome data were 
available for the programs; however, these programs have generally not 
been rigorously evaluated. 

From the programs identified by experts, we selected 10 programs to 
profile (located in 6 states--California, Kentucky, Minnesota, New 
York, Utah, and Washington--and the District of Columbia) to reflect 
diversity in approaches used, economic conditions, demographics, and 
geographic regions. We also considered how the program was connected 
to TANF and whether the program was in an area where TANF is state-or 
county-administered.[Footnote 65] We did not report on work 
participation rates for the states in which these programs are 
operated because some are state programs and others are locally 
administered. Work participation rates are calculated only on the 
state level by HHS, based on data reported by the states, and 
generally available after the end of the fiscal year. We conducted in-
depth interviews, by phone and through four site visits, with program 
administrators and state and local TANF officials to learn about key 
program features that help increase employment and earnings. For 3 
programs, we also interviewed local contractors. We obtained views 
from experts; federal, state, and local officials; and program 
administrators on factors that facilitate the use of promising 
approaches and that could broaden their use. We assessed information 
and communication HHS provides to states related to promising 
approaches against federal internal control standards.[Footnote 66] 

We obtained budget, performance, and other program data for the 
programs we selected, as well as HHS administrative data on states' 
engagement of TANF recipients in prescribed work activities. We 
assessed the reliability of these data by reviewing related 
documentation and interviewing knowledgeable officials and determined 
they were sufficiently reliable for providing contextual information 
on these programs and describing work participation trends, 
respectively. We also reviewed relevant GAO, HHS Office of Inspector 
General, and HHS reports, as well as relevant federal laws, 
regulations, and guidance. 

We conducted this performance audit from January 2014 to November 2014 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Categories of Federal Work Activities and Limitations on 
Counting Time in Those Activities: 

In meeting the 30-hour average weekly requirement, individuals must 
spend at least 20 of the hours in certain activities (referred to as 
core activities). Any additional hours needed to meet the requirement 
can come from non-core or core activities. 

Table 3: Categories of Federal Work Activities: 

"Core" activities: 

Activity: Unsubsidized employment; 
Definition: Full-or part-time employment in the public or private 
sector that is not subsidized by TANF or any other public program; 
At least daily supervision required: [Empty]; 
Limitations on counting time (for all families): [Empty]. 

Activity: Subsidized private sector employment; 
Definition: Employment in the private sector for which the employer 
receives a subsidy from TANF or other public funds to offset some or 
all of the wages and costs of employing an individual; 
At least daily supervision required: [Empty]; 
Limitations on counting time (for all families): [Empty]. 

Activity: Subsidized public sector employment; 
Definition: Employment in the public sector for which the employer 
receives a subsidy from TANF or other public funds to offset some or 
all of the wages and costs of employing an individual; 
At least daily supervision required: [Empty]; 
Limitations on counting time (for all families): [Empty]. 

Activity: Work experience; 
Definition: A work activity, performed in return for welfare, that 
provides an individual with an opportunity to acquire the general 
skills, knowledge, and work habits necessary to obtain employment. The 
purpose of work experience is to improve the employability of an 
individual who cannot find unsubsidized full-time employment; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): [Empty]. 

Activity: On-the-job training; 
Definition: Training in the public or private sector that is given to 
a paid employee while he or she is engaged in productive work and that 
provides knowledge and skills essential to the full and adequate 
performance of the job; 
At least daily supervision required: [Empty]; 
Limitations on counting time (for all families): [Empty]. 

Activity: Job search and job readiness assistance; 
Definition: The act of seeking or obtaining employment, preparation to 
seek or obtain employment, including life-skills training, and 
substance abuse treatment, mental health treatment, or rehabilitation 
activities. Such treatment or therapy must be determined to be 
necessary and documented by a qualified medical, substance abuse, or 
mental health professional; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): Participation in this 
activity may be counted for 6 weeks (12 weeks in certain 
circumstances) in a fiscal year. 

Activity: Community service programs; 
Definition: Structured programs and embedded activities in which 
individuals perform work for the direct benefit of the community under 
the auspices of public or nonprofit organizations. Community service 
programs must be limited to projects that serve a useful community 
purpose in fields such as health, social service, environmental 
protection, education, urban and rural redevelopment, welfare, 
recreation, public facilities, public safety, and child care. 
Community service programs are designed to improve the employability 
of individuals not otherwise able to obtain unsubsidized full-time 
employment. A state agency shall take into account, to the extent 
possible, the prior training, experience, and skills of an individual 
in making appropriate community service assignments; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): [Empty]. 

Activity: Vocational educational training; 
Definition: Organized educational programs that are directly related 
to the preparation of individuals for employment in current or 
emerging occupations; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): Participation in this 
activity is limited to 12 months in an individual's lifetime. 

Activity: Caring for a child of a recipient in community service; 
Definition: Providing child care to enable another cash welfare 
recipient to participate in a community services program. This is an 
unpaid activity and must be a structured program designed to improve 
the employability of participating individuals; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): [Empty]. 

"Non-core" activities: 
Activity: Job skills training directly related to employment; 
Definition: Training or education for job skills required by an 
employer to provide an individual with the ability to obtain employment 
or to advance or adapt to the changing demands of the workplace; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): Must be combined with 
20 hours per week in a "core" activity. 

Activity: Education directly related to employment (for those without a 
high school diploma or equivalent certificate); 
Definition: Education related to a specific occupation, job, or job 
offer; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): Must be combined with 
20 hours per week in a "core" activity. 

Activity: Attendance in a secondary school program or course of study 
leading to a certificate of general equivalence (for those who have not 
completed secondary school or gotten a certificate of general 
equivalence); 
Definition: Regular attendance, in accordance with the requirements of 
a secondary school or course of study, at a secondary school or in a 
course of study leading to a certificate of general equivalence, in 
the case of a work-eligible individual who has not completed secondary 
school or received such a certificate; 
At least daily supervision required: [Check]; 
Limitations on counting time (for all families): Must be combined with 
20 hours per week in a "core" activity. 

Source: GAO analysis of relevant federal laws and regulations. 
GAO-15-31. 

[End of table] 

[End of section] 

Appendix III: Selected Recent and Ongoing Department of Health and 
Human Services-Funded Evaluations: 

Recent Studies: 

Employment Retention and Advancement Project (ERA): This study ran 
from 1998 to 2011. Under the study, Health and Human Services issued 
planning grants to 13 states to develop new programs. The goal was to 
test strategies for helping employed individuals keep their jobs and 
advance in the workforce. Only 3 of the programs were found to 
increase employment retention and advancement: the Texas sites (Corpus 
Christi and Fort Worth), Chicago, and Riverside PASS ERA programs. An 
ERA report was published in April 2010, "The Employment Retention and 
Advancement Project: How Effective Are Different Approaches Aiming to 
Increase Employment Retention and Advancement? Final Impacts for 
Twelve Models," which can be viewed at: [hyperlink, 
http://www.acf.hhs.gov/programs/opre/resource/the-employment-retention-
and-advancement-project-how-effective-are]. Among the participating 
sites, 8 were led by TANF agencies at either the state or local level. 
The Texas ERA program offered monthly stipends of $200 to former TANF 
recipients working at least 30 hours per week. The Chicago program was 
a work-focused advancement program, offering targeted job search 
assistance and help identifying and accessing career ladders. These 
services were provided to participants by staff in a private, for-
profit firm, and TANF recipients were required to have regular contact 
with program staff to continue to receive TANF benefits. In contrast, 
the Riverside PASS ERA program provided voluntary, individualized 
retention and advancement services provided primarily by three 
community-based organizations and community colleges. Each of these 
programs targeted a specific population's service needs. 

Enhanced Services for Hard-to-Employ Demonstrations and Evaluations: 
This demonstration tested several strategies for helping hard-to-
employ parents find and sustain employment. One of the four sites in 
the study included TANF participants: the Transitional Work 
Corporation in Philadelphia conducted a subsidized employment 
demonstration exclusively for TANF clients. Other sites included 
programs in Kansas, Missouri, New York, Pennsylvania, and Rhode 
Island. This 10-year evaluation was completed in 2012. Findings from 
this study were used to influence the design of two new federal 
subsidized employment initiatives. Final evaluation reports can be 
viewed at: [hyperlink, http://www.mdrc.org/publication/what-strategies-
work-hard-employ]. 

Temporary Assistance for Needy Families/Supplemental Security Income 
Disability Transition Project (TSDTP): This study is an effort to 
identify the extent of overlap between TANF and SSI programs and 
populations and develop pilot programs aimed to improve a variety of 
outcomes for individuals with disabilities and work-limiting barriers 
to employment. The study is a collaboration between ACF and the Social 
Security Administration through a contract with MDRC. This study is 
complete. Reports were published throughout 2013 and 2014. TSDTP 
included Ramsey County, Minnesota--a program highlighted in this GAO 
report--which participated in a pilot-phase experiment to increase 
employment among TANF participants with work limitations and 
disabilities. Los Angeles County, California and Muskegon County, 
Michigan were also involved in the study, implementing pilot tests of 
approaches to serving individuals with disabilities either through the 
provision of services to TANF participants with work-limiting 
barriers, streamlining the Supplemental Security Income application 
process, or improving coordination between the two systems. 

Ongoing Studies: 

Behavioral Innovations to Increase Self-Sufficiency (BIAS) study: 
Launched in 2010, BIAS is the first major opportunity to apply a 
behavioral economics lens to programs that serve poor families in the 
United States. The goal of the study is to learn how tools from 
behavioral science can improve the well-being of low-income children, 
adults and families. The study is being conducted by OPRE and MDRC in 
partnership with behavioral experts. One site within the study is the 
Los Angeles county TANF agency. Results are planned for rolling 
release in 2014 and 2015. Two reports on BIAS were issued in April and 
August of 2014. 

Health Professions Opportunities Grant (HPOG): HPOG was established by 
the Patient Protection and Affordable Care Act with the goal of 
providing training programs in high-demand healthcare professions to 
TANF recipients and other low-income individuals. In 2010, the 
Administration for Children and Families (ACF) awarded five-year 
grants to 32 grantees in 23 states. The program includes post-
secondary educational institutions, workforce investment boards, state 
and local government agencies, and community-based organizations. Two 
of the 27 non-tribal HPOG grantees are Departments of Human or Social 
Services agencies and also administer the TANF program. One of the 
five tribal sites also administers the Tribal TANF program. However, a 
number of HPOG grantees also serve as the employment services 
providers for TANF agencies. ACF's Office of Planning, Research, and 
Evaluation (OPRE) is evaluating HPOG demonstration projects. An 
interim analysis of the impacts of HPOG is expected in June 2016. 

Innovative Strategies for Increasing Self-Sufficient Project: The 
Innovative Strategies for Increasing Self-Sufficiency evaluation began 
in 2007 as a multi-site, random-assignment evaluation of promising 
strategies for increasing employment and self-sufficiency among low-
income families. It is under the direction of ACF. This study focuses 
on the career pathways approach as the main intervention. One of the 
nine ISIS sites--Seattle/King County Workforce Development 
Corporation--is a contracted employment services provider for a local 
TANF agency and serves both TANF and non-TANF clients. Other sites in 
the study include: Des Moines Area Community College, I-BEST in 
Washington State, Instituto del Progreso Latino, Madison Area 
Technical College, Pima Community College, San Diego Workforce 
Partnership, and Valley Initiative for Development and Advancement. 

Job Search Assistance (JSA) Strategies: This study was launched by 
OPRE in fall 2013 and features a multi-site, random-assignment 
evaluation to measure the relative impact of specific job search 
services offered by TANF programs on short-term labor market outcomes 
such as earnings and time to employment. The JSA evaluation aims (1) 
to provide information about the relative impacts of various JSA 
services and the manner in which agencies provide them, and (2) to 
provide actionable and policy-relevant feedback to the TANF field, 
including federal TANF policymakers, state and local TANF 
administrators, and frontline caseworkers. Site recruitment is 
ongoing, and initial findings could be reported as early as the end of 
2016. 

Subsidized and Transitional Employment Demonstration (STED): The STED 
study was launched by ACF in 2010 with the goal of demonstrating and 
evaluating the next generation of subsidized employment models for 
critical low-income populations. The project is led by MDRC, under 
contract with ACF, and examines strategies for providing counter-
cyclical employment and for successfully transitioning individuals 
from short-term subsidized employment to unsubsidized employment. STED 
is being conducted in coordination with the Department of Labor's 
Enhanced Transitional Jobs Demonstration Project. Random assignment 
began at the first sites in early 2012 and continued through late 
2013. Of the seven STED sites, three are TANF agency-operated 
including Los Angeles, San Francisco, and Minnesota. The evaluation is 
scheduled to run through 2017. 

[End of section] 

Appendix IV: Bibliography: 

Bloom, Dan. Transitional Jobs: Background, Program Models, and 
Evaluation Evidence. Prepared by MDRC for the Department of Health and 
Human Services. Washington, D.C.: 2010. 

------, Cynthia Miller, and Gilda Azurdia. Results from the Personal 
Roads to Individual Development and Employment (PRIDE) Program in New 
York City. MDRC. July 2007. 

------, Pamela J. Loprest, and Sheila R. Zedlewski. TANF Recipients 
with Barriers to Employment. Washington. D.C.: Urban Institute, August 
2011. 

Derr, Michelle and LaDonna Pavetti. Assisting TANF Recipients Living 
with Disabilities to Obtain and Maintain Employment: Creating Work 
Opportunities. Prepared by Mathematica Policy Research, Inc. for the 
U.S. Department of Health and Human Services. Washington, D.C.: 
February 2008. 

Greenberg, David H., Victoria Deitch, and Gayle Hamilton. "A Synthesis 
of Random Assignment Benefit-Cost Studies of Welfare-to-Work 
Programs."Journal of Benefit-Cost Analysis, vol. 1, issue 1, article 3 
(2010). 

Gueron, Judith M. and Gayle Hamilton. The Role of Education and 
Training in Welfare Reform. The Brookings Institution, Policy Brief 
no. 20 (April 2002). 

Hamilton, Gayle. Improving Employment and Earnings for TANF 
Recipients. Prepared by the Urban Institute for the Department of 
Health and Human Services. Washington, D.C.: March 2012. 

------. Moving People from Welfare to Work: Lessons from the National 
Evaluation of Welfare-to-Work Strategies. Prepared by MDRC for the 
Department of Health and Human Services and Department of Education. 
Washington, D.C.: 2002. 

Hendra, Richard, Keri-Nicole Dillman, Gayle Hamilton, Erika Lundquist, 
Karin Martinson, and Melissa Wavelet. The Employment Advancement 
Project: How Effective Are Different Approaches Aiming to Increase 
Employment Retention and Advancement? Final Impacts for Twelve Models. 
Prepared by MDRC for the Department of Health and Human Services. 
Washington, D.C.: April 2010. 

Kirby, Gretchen, Heather Hill, LaDonna Pavetti, Jon Jacobson, Michelle 
Derr, and Pamela Winston. Transitional Jobs: Stepping Stones to 
Unsubsidized Employment. Washington, D.C.: Mathematica Policy 
Research, Inc., April 2002. 

Maguire, Sheila, Joshua Freely, Carol Clymer, Maureen Conway, and 
Deena Schwartz. Tuning In to Local Labor Markets: Findings from the 
Sectoral Employment Impact Study. Philadelphia, PA: Public/Private 
Ventures, 2010. 

Roder, Anne, and Mark Elliott. Stimulating Opportunity: An Evaluation 
of ARRA-Funded Subsidized Employment Programs. Economic Mobility 
Corporation, New York, NY: September 2013. 

Werner, Alan, Catherine Dun Rappaport, Jennifer Bagnell Stuart, and 
Jennifer Lewis. Literature Review: Career Pathways Programs, OPRE 
Report #2013-24, Office of Planning, Research and Evaluation, 
Administration for Children and Families, U.S. Department of Health 
and Human Services (Washington, D.C.: June 24, 2013). 

[End of section] 

Appendix V: Agency Comments from the Department of Health and Human 
Services: 

Department of Health & Human Services: 
Office of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

November 3, 2014: 

Kay E. Brown: 
Director, Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Ms. Brown: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) report entitled, "Temporary Assistant for Needy Families: Action 
is Needed to Better Promote Employment Focused Approaches" (GAO-15-31). 

The Department appreciates the opportunity to review this report prior 
to publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office's Draft Report Entitled: 
Temporary Assistance For Needy Families: Action Is Needed To Better 
Promote Employment-Focused Approaches (GAO-15-31): 

The Department appreciates the opportunity to review and comment on 
this draft report. 

GAO Recommendation 1: 

The Government Accountability Office (GAO) recommends that the U.S. 
Department of Health and Human Services (HHS) should take the 
following action: In consultation with Congress, identify potential 
changes that would address the lack of incentives for states and 
localities to adopt promising approaches and then develop and submit a 
legislative proposal outlining those changes. 

HHS Response: 

HHS appreciates GAO's attention to employment-focused approaches in 
the Temporary Assistance for Needy Families (TANF) program. HHS has 
maintained a strong focus on encouraging states to better help TANF 
recipients and other low-income parents obtain jobs, sustain 
employment, and make progress in the labor force. This focus is, and 
will continue to be, a major part of the ACF research agenda, TANF 
technical assistance efforts, and ongoing communication with state human
service agencies. 

HHS has sponsored a large body of research that both helps federal 
policy makers understand the wide variety of services provided by 
state TANF programs and, more importantly, provides credible and 
thoughtful information to state TANF decision-makers about possible 
innovative and effective approaches to serving their clients. HHS 
currently has underway major multi-site experiments in the areas of 
employment-focused post-secondary education and training, job
search strategies, subsidized and transitional employment, and 
behaviorally informed interventions where tests in a variety of 
program areas (including TANF, child support and child care) will have 
broad applicability. Beyond HHS's randomized control trials, our TANF-
focused research portfolio includes studies that provide useful, 
applicable knowledge to state administrators and case workers. These 
studies help answer questions ranging from more specific strategies 
for how to best serve individuals with disabilities to the overarching 
question of how to engage clients and match them with the services 
that have the greatest likelihood of supporting their family's 
economic well-being and ultimate self-sufficiency. 

HHS's technical assistance and messaging to TANF agencies follows the 
same focus by highlighting the importance of innovative employment and 
skill-building strategies. In the last several years, HHS has 
published various Dear Colleague Letters on developing career pathways
models, funding and implementing summer youth employment programs, and 
helping youth transition from high school to postsecondary education 
and the workforce. We also published an Information Memorandum on 
using TANF funds for employment and other services for homeless 
families, and continually works with states through regional meetings 
and ongoing conversations on strategies for helping TANF recipients 
with barriers to employment enter and move up in the labor force. In 
2015, HHS will be announcing a policy academy initiative to provide 
more intensive technical assistance and support to a select group of 
TANF agencies committed to achieving better employment outcomes for 
families. 

HHS commends GAO for identifying and disseminating research on 
promising employment-focused approaches for TANF recipients. HHS notes 
that, while the research can provide useful information to 
policymakers at the state and federal level, additional research is 
needed. For example, the report points out that, "there are no 
completed rigorous experimental impact studies of a comprehensive 
career pathways program," and notes that HHS is currently funding an
evaluation of such programs. Additionally, the effectiveness of the 
modified work-first approach is attributed to a single study from the 
1990s, and more evidence would help identify promising practices 
within this approach. 

In July 2014, the Departments of Labor, Commerce, Education, and 
Health and Human Services issued a synthesis of research entitled, 
What Works in Job Training: A Synthesis of the Evidence. The paper 
highlighted the importance of expanding our knowledge of what works and
filling the gaps in evidence by expanding the analysis on the long-
term impacts of training approaches that have shown to have strong 
short-term impacts and appear to be the most job-driven, such as 
industry-recognized certificates, apprenticeships, and career pathways 
models. The paper notes that ongoing and future research should aim to 
disaggregate subgroup impacts to better understand how promising 
approaches can best serve specific populations, including the long-
term unemployed, persons with disabilities, youth, and those with 
barriers to employment. Additionally, the paper recommends an expanded 
analysis to understand the effectiveness of specific program model 
components as well as replication and ongoing evaluation of promising 
approaches in different contexts to understand how implementation
might work across settings. 

HHS will continue the ongoing research described above and work to 
fill in research gaps to better understand effective employment-
focused approaches for low-income families. This key research is 
funded by welfare research funding authorized in the Social Security 
Act, and HHS believes it is critical to maintain this allocation. 

GAO Recommendation 2: 

GAO recommends that the U.S. Department of Health and Human Services 
(HHS) should take the following action: Issue formal guidance to 
clarify how activities under the career pathways approach can be 
countable for the purposes of the work participation rate and that 
TANF funds may be used to finance the career pathways approach. 

HHS Response: 

HHS concurs with GAO's recommendation to issue a formal Information 
Memorandum (IM) on the allowability of career pathways programs in 
TANF. However, we note that HHS has provided significant technical 
assistance on career pathways approaches through a number of mediums 
over the past several years, and continues to do so. Topics of HHS-
sponsored in-person and virtual technical assistance from 2008 to the 
present have included: career pathways implementation, broadening the 
scope of TANF work activities, meeting employer needs, stackable 
credentials, administrative and program flexibility, and multiple 
funding streams and partnerships to support postsecondary education 
for low-income individuals. Within the past two years, HHS has hosted
workshops on career pathways implementation at annual regional 
meetings of TANF administrators to highlight best practices, sponsored 
a podcast on the Arkansas Career Pathways Initiative, jointly
authored a Dear Colleague letter with the Departments of Labor and 
Education encouraging partnerships to help transition students from 
high school graduation to postsecondary education and the workforce, 
and created an online catalog of career pathways toolkits. In 2014, 
HHS facilitated conversations on career pathways and other employment-
focused approaches in all of the five regional meetings convened with 
TANF administrators, and hosted, in conjunction with the Departments 
of Labor and Education, the National Dialogue on Career Pathways. 
Additionally, in 2013, HHS commissioned a paper entitled Navigating 
TANF and WIA to Build Health Profession Career Pathways - A Guide for 
HPOG Programs that has been broadly shared to highlight the
challenges and opportunities that exist in partnerships between TANF 
and career pathways programs. HHS continues to work with state, 
county, and tribal TANF programs to develop and strengthen career 
pathways models as part of a broader effort to facilitate improved 
program outcomes. 

State Adoption of Employment-Focused Approaches: 

Beyond the need for guidance, states face a number of issues in the 
adoption and implementation of employment-focused approaches for their 
TANF programs. 

For example, while career pathways models are allowable under TANF and 
promoted through significant TANF technical assistance, the GAO report 
correctly points out that only 12 months of vocational education 
training can be counted toward the work participation rate. This 
statutory limitation is indeed a constraint to the implementation of 
career pathways models in TANF programs, and we recommend that GAO 
should be explicit about this issue. 

Additionally, GAO correctly notes that both TANF's block grant 
structure and limitations on federal authority regarding programmatic 
choices have reduced state incentives to adopt and test the types of 
program interventions described in the report. GAO attributes part of 
this problem to the diversion of funding from basic assistance and 
work activities to other allowable purposes. Indeed, in FY 2013, only 
28% of total TANF and Maintenance-of-Effort (MOE) funds used were 
expended on basic assistance and only 6% were expended on work-related 
activities. HHS has recently made substantial changes to the way 
states report financial data that will provide a much better 
understanding of how states are spending their TANF block grant funds. 
However, ultimately, States have broad discretion in choices about how 
they use their TANF funds among allowable activities, and that will 
remain the case unless the law itself is changed Lastly, it is 
important to appreciate that the existing federal participation rate 
requirement establishes a list of countable activities, but does not 
expressly require or encourage states to take evidence-based 
approaches to promoting employment. While states are free to engage 
individuals in activities that do not count toward participation 
rates, the reality is that state choices are heavily shaped by the 
rules on what does and does not count toward the rate. Moreover, the 
fact that the participation rate structure only measures 
participation, not successes in employment outcomes, means that states 
may have less incentive to identify and implement the most effective 
strategies for connecting families with employment or promoting 
employment stability. A number of states are still engaged in a range 
of innovative approaches, as reflected by the GAO's examples in the
report. However, in order to encourage States to take more strongly 
evidence-based approaches to promoting employment, HHS can, and will, 
continue to emphasize the importance of research and technical 
assistance, but there will also be a virtue in considering additional 
legislation approaches when Congress reauthorizes the program. 

Working with Congress: 

HHS concurs with GAO's recommendation to consult with Congress on ways 
to address the lack of incentives for states and localities to adopt 
promising employment-focused approaches. In the Administration's 
Fiscal Year (FY) 2015 Budget Request, HHS stated that, "when Congress 
takes up reauthorization, the Administration will be prepared to work 
with lawmakers to strengthen the program's effectiveness in 
accomplishing its goals. This effort should include using performance 
indicators to drive program improvement and ensuring that states have 
the flexibility to engage recipients in the most effective activities 
to promote success in the workforce, including families with serious 
barriers to employment." The FY 2015 Budget Request also included a 
legislative proposal to increase incentives for states to implement or
strengthen subsidized employment programs. The proposed Pathways to 
Jobs initiative would support work opportunities through subsidized 
employment for low-income parents, guardians, and youth, including 
summer jobs for youth. 

GAO notes that no state has formally applied for a waiver following 
the issuance of a July 2012 HHS Information Memorandum encouraging 
states to test innovative strategies designed to improve employment 
outcomes for needy families. Congressional concern about HHS waiver
authority may have caused uncertainty and discouraged states from 
submitting formal waiver requests to HHS, despite state interest in 
testing new approaches. 

Need for Ongoing Research and Technical Assistance: 

HHS appreciates the synthesis of research prepared by GAO for this 
report. The Department reiterates that ongoing research on employment-
focused approaches for low-income individuals is needed in order to 
facilitate implementation of promising practices in TANF programs 
across the country and improve employment outcomes for TANF 
recipients. HHS will continue its focus on encouraging TANF agencies 
to better help their clients to obtain jobs, sustain employment, and
make progress in the labor market. Per GAO's recommendation, HHS will 
issue a formal IM on the implementation of career pathways approaches 
in TANF, as part of ongoing technical assistance efforts. HHS will 
also continue to share with Congress its recommendations for how best to
promote the adoption of promising employment-focused approaches, 
including the need for continued funding for welfare research and a 
review of the work participation rate requirement structure. 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Kay E. Brown at (202) 512-7215 or brownke@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Gale Harris (Assistant 
Director), Kristen Jones (Analyst-in-Charge), Holly Hobbs, and Michael 
Pahr made significant contributions to all aspects of this report. 
Also contributing to this report were James Bennett, Sue Bernstein, Ed 
Bodine, Alexander Galuten, Ashley McCall, Sheila McCoy, Almeta 
Spencer, and Walter Vance. 

[End of section] 

Footnotes: 

[1] 42 U.S.C. § 601 et seq. 

[2] Federal law governing TANF generally refers to the term 
"assistance" and does not make distinctions between different forms of 
aid funded by TANF. However, HHS draws distinctions between 
"assistance" and "nonassistance." HHS regulations define assistance to 
include cash, payments, vouchers, or other forms of benefits designed 
to meet families' ongoing, basic needs. 45 C.F.R. § 260.31. HHS also 
generally includes in assistance services, such as child care and 
transportation assistance for parents who are unemployed. HHS uses the 
term nonassistance to refer to TANF expenditures that fulfill one of 
the four TANF purposes, but do not meet this regulatory definition. In 
our report, we refer to HHS's definition of assistance as "cash 
assistance." 

[3] Specifically, we primarily focused on studies that used a random 
assignment (experimental) research design. This type of design 
compares the outcomes for groups that were randomly assigned either to 
the treatment or to a nonparticipating control group before the 
intervention, in an effort to control for any systematic difference 
between the groups that could account for a difference in their 
outcomes. A difference in these groups' outcomes is believed to 
represent the program's impact. 

[4] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[5] Pub. L. No. 104-193, sec. 103(a)(1), § 401, 110 Stat. 2105, 2113. 

[6] According to HHS, most states either have a shorter and more 
restrictive time limit, or use state funds or a hardship exemption to 
exempt or extend assistance to families. 

[7] Pub. L. No. 104-193, § sec. 103(a)(1), § 403(b), 110 Stat. 2105, 
2122. For example, collectively, states in economic distress can 
access up to $612 million in the TANF Contingency Fund in each of 
fiscal years 2013 and 2014, but they must spend more than a specified 
amount of state funds to do so. 

[8] The work participation rate requirement for two-parent families is 
generally 90 percent. 

[9] 42 U.S.C. § 607(b)(3). 

[10] 45 C.F.R. § 261.43. 

[11] See 64 Fed. Reg. 17,720, 17,722 (Apr. 12, 1999). Further, the 
Deficit Reduction Act of 2005, which reauthorized the TANF block 
grant, was generally expected to strengthen these work requirements by 
adding several provisions to improve the reliability of work 
participation data and program integrity and by modifying the caseload 
reduction credit. 

[12] GAO, Temporary Assistance for Needy Families: Implications of 
Recent Legislative and Economic Changes for State Programs and Work 
Participation Rates, [hyperlink, 
http://www.gao.gov/products/GAO-10-525] (Washington, D.C.: May 28, 
2010). 

[13] Pub. L. No. 111-291, § 812, 124 Stat. 3064, 3160. 

[14] In fiscal year 2011, about 54 percent of families receiving cash 
assistance included an individual who was considered work-eligible for 
the purpose of the work participation rate. Work-eligible individuals 
are generally adult recipients of cash assistance or certain non-cash 
recipient parents of children receiving assistance, who count toward 
the work participation rate. 

[15] HHS reported that the data from states indicate that individuals 
with zero hours of participation represent a range of situations 
including the following: individuals who are non-compliant and are in 
the sanction process; families disregarded from the participation rate 
because they were caring for a child under age one, subject to a work-
related sanction, or participating in a Tribal work program; 
individuals the state or local agency failed to engage; and 
individuals who were exempt due to illness or disability. 

[16] In meeting the 30-hour average weekly requirement, individuals 
must spend at least 20 of the hours in certain activities (referred to 
as core activities). Any additional hours needed to meet the 
requirement can come from non-core or core activities. (See appendix 
II for the 12 categories of federal work activities and limitations on 
counting time in those activities.) Some activities have restrictions 
on the amount of time that can be spent in them and still be counted 
toward the work participation rate. For example, counting 
participation in job search and job readiness assistance is limited to 
no more than six weeks in a 12-month period (or 12 weeks in a 12-month 
period if the state meets the definition of a "needy state" for the 
TANF Contingency Fund) and no more than four consecutive weeks. 
Vocational educational training is limited to 12 months over an 
individual's lifetime, and no more than 30 percent of the families 
that a state counts toward its federal work participation rates may do 
so through participation in vocational educational training. 

[17] AFDC and, subsequently, TANF, were authorized under the Social 
Security Act, as amended. 

[18] States could claim the cost of evaluation as a regular AFDC 
expenditure and receive matching federal funding, according to HHS 
officials. 

[19] Some members of Congress have raised concerns about a 2012 
announcement by HHS that the agency would use waiver authority to 
allow states to test various strategies, policies, and procedures 
designed to improve employment outcomes for needy families. HHS made 
this announcement in a July 2012 Information Memorandum, Transmittal 
No. TANF-ACF-IM-2012-03. On September 4, 2012, we held that this 
Information Memorandum constitutes a rule and is subject to the 
Congressional Review Act's requirement that it be submitted to 
Congress and the Comptroller General before taking effect. See B-
323772, Sept. 4, 2012. While questions have been raised about the 
extent of HHS's authority to take this action, neither this report nor 
our issued products, B-323772, Sept. 4, 2012 or [hyperlink, 
http://www.gao.gov/products/GAO-12-1028R], Sept. 19, 2012, address 
whether the Information Memorandum is a valid interpretation of 
statutes or regulations. The potential for waivers has been 
controversial and the House of Representatives passed a bill in 2013 
aimed at preventing HHS from implementing them (Preserving the Welfare 
Work Requirement and TANF Extension Act of 2013, H.R. 890, 113th Cong. 
(2013)). This legislation has not been enacted. According to HHS, as 
of November 3, 2014, no state had formally submitted a request for a 
waiver related to TANF work requirements. 

[20] 42 U.S.C. § 613(a). 

[21] In this report, we focus on TANF cash assistance recipients. 

[22] GAO, Temporary Assistance for Needy Families: More Accountability 
Needed to Reflect Breadth of Block Grant Services, [hyperlink, 
http://www.gao.gov/products/GAO-13-33] (Washington, D.C.: Dec. 6, 
2012). 

[23] Generally, in child-only cases, the parent or adult caregiver is 
not eligible for benefits for one or more of a variety of reasons, 
such as receipt of certain other federal benefits or immigration 
status. See GAO, TANF and Child Welfare Programs: Increased Data 
Sharing Could Improve Access to Benefits and Services, [hyperlink, 
http://www.gao.gov/products/GAO-12-2] (Washington, D.C.: Oct. 7, 2011). 

[24] 64 Fed. Reg. 17,720, 17,722 (Apr. 12, 1999). 

[25] See appendix IV for a bibliography. 

[26] The New Deal's Works Progress Administration, which employed more 
than 8 million people in infrastructure projects in the 1930s, was an 
early subsidized employment program. See Dan Bloom, Transitional Jobs: 
Background, Program Models, and Evaluation Evidence, a report prepared 
by MDRC at the request of U.S. Department of Health and Human 
Services, 2010. 

[27] The AFDC Homemaker Home Health Aid demonstration produced 
increases in employment and earnings in most of the seven sites that 
were sustained for 3 years. Transitional Jobs, 5. 

[28] The Center for Employment Opportunities and the Transitional Work 
Corporation, both part of the HHS Enhanced Services for the Hard-to-
Employ project, generated decreases in recidivism and welfare receipt, 
respectively. The Center for Employment Opportunities program targeted 
former prisoners. Reductions in recidivism, relative to a control 
group, continued for program participants even after employment gains 
dissipated. According to the Center for Employment Opportunities 
evaluation, relationships with program staff or attitudinal changes 
resulting from program participation may have contributed to this 
reduction. Meanwhile, participants in the Transitional Work 
Corporation program experienced reductions in TANF receipt of about 
$600 per person over the first 18 months of the follow-up period. 
Transitional Jobs, 26, 33, 35. 

[29] The American Recovery and Reinvestment Act of 2009 created a $5 
billion Emergency Contingency Fund for state TANF programs, available 
in fiscal years 2009 and 2010. Pub. L. No. 111-5, § 2101(a)(1), 123 
Stat. 115, 446. 

[30] Anne Roder and Mark Elliott, Stimulating Opportunity: An 
Evaluation of ARRA-Funded Subsidized Employment Programs, Economic 
Mobility Corporation, Inc. (New York, NY: September 2013). 

[31] Stimulating Opportunity, 7. 

[32] This refers to the Personal Roads to Individual Development and 
Employment program. See Dan Bloom, Cynthia Miller, and Gilda Azurdia, 
Results from the Personal Roads to Individual Development and 
Employment (PRIDE) Program in New York City, a report prepared by MDRC 
at the request of the Department of Health and Human Services (July 
2007). 

[33] The Building Nebraska Families program produced significant 
increases in employment, earnings, and other outcomes for very hard-to-
employ participants. See Dan Bloom, Pamela J. Loprest, and Sheila R. 
Zedlewski, TANF Recipients with Barriers to Employment, Urban 
Institute (Washington. D.C.: August 2011). 

[34] See Administration for Children and Families, Department of 
Health and Human Services, "Executive Function Meeting of Experts," 
accessed August 6, 2014, [hyperlink, 
http://www.acf.hhs.gov/opre-executive-function-meeting-of-experts]. 

[35] Sheila Maguire et al., Tuning In to Local Labor Markets: Findings 
from the Sectoral Employment Impact Study, Public/Private Ventures 
(Philadelphia, PA: 2010). 

[36] Judith M. Gueron and Gayle Hamilton, "The Role of Education and 
Training in Welfare Reform," The Brookings Institution, Policy Brief 
no. 20 (April 2002). 

[37] Although a comprehensive career pathways program has not yet been 
rigorously evaluated, we included this approach because it was based 
on a rigorous evaluation of sector-based career training and lessons 
from other prior rigorous evaluations. 

[38] In a joint letter issued on April 4, 2012, the agencies defined 
career pathways as "a series of connected education and training 
strategies and support services that enable individuals to secure 
industry relevant certification and obtain employment within an 
occupational area and to advance to higher levels of future education 
and employment in that area." In addition, the Workforce Innovation 
and Opportunity Act makes several references to career pathways. For 
example, one purpose of the title of the Act dealing with adult 
education and literacy is to create partnerships to assist adults in 
the transition to postsecondary education and training, including 
through career pathways. 

[39] 79 Fed. Reg. 22,662 (Apr. 23, 2014). 

[40] Gayle Hamilton, Moving People from Welfare to Work: Lessons from 
the National Evaluation of Welfare-to-Work Strategies, a report 
prepared by Manpower Demonstration Research Corporation at the request 
of the Department of Education (Washington, D.C.: 2002). 

[41] We did not review any state laws or regulations. All information 
on state laws or regulations was provided by state and local officials. 

[42] Unforeseen circumstances, such as caring for a sick child, may 
cause a TANF recipient to miss a scheduled appointment or some hours 
of work activity. Some states use sanctions, such as a reduction in 
the amount of TANF cash assistance or gradual or immediate termination 
of TANF cash assistance, to encourage recipients to participate in 
program activities, according to one study. 

[43] According to officials, California allows TANF recipients to 
participate in up to 24 months of education or training, even though 
only 12 months of vocational educational training is countable toward 
the federal work participation rate. 

[44] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[45] In 2010, the Departments of Labor and Education initiated a one-
year Career Pathways Initiative that funded nine states and two tribal 
entities to develop sustainable career pathways and promote linkages 
among system partners. As part of the initiative, two Career Pathways 
Institutes brought together grantee teams and subject matter experts, 
state and local practitioners, and federal staff. 

[46] In addition to federal TANF funds, selected programs reported 
receiving funds from state and local sources. However, some of these 
funds may have included federal TANF funds that were being allocated 
by state and local entities. In addition, some of these state or local 
funds may have been used by states to meet their TANF maintenance of 
effort requirement. 

[47] Pub. L. No. 104-193, § 103(a)(1), 110 Stat. 2105, 2112. 

[48] 42 U.S.C. §§ 601(a), 617. Accordingly, HHS has limited authority 
to influence state program choices and cannot compel states to adopt 
particular approaches for their welfare-to-work programs. 

[49] 42 U.S.C. §§ 601(a), 604(a). 

[50] In this report, we concluded that while states still spend some 
portion of TANF funds on welfare-to-work programs for the cash 
assistance population, their new and varied uses of TANF funds for non-
cash services over time beyond this population raise questions about 
how state efforts are contributing to TANF purposes. We recommended 
that HHS develop a plan for revising its financial reporting 
categories to better understand how states use TANF funds. HHS 
subsequently published an information memorandum and Federal Register 
notices on a revised reporting form for collecting more detailed and 
accurate TANF expenditure data. See 78 Fed. Reg. 56,236 (Sept. 12, 
2013), 79 Fed. Reg. 2444 (Jan. 14, 2014). The agency said it plans to 
implement the revised form in fiscal year 2015 and provide technical 
assistance to states through this transition. GAO, Temporary 
Assistance for Needy Families: More Accountability Needed to Reflect 
Breadth of Block Grant Services, [hyperlink, 
http://www.gao.gov/products/GAO-13-33], (Washington, D.C.: Dec. 6, 
2012). 

[51] See 42 U.S.C. § 607(c). 

[52] See 42 U.S.C. § 607(c). 

[53] In 2010, we reported that some states have opted to fund cash 
assistance for certain low-income families with state dollars not 
counted toward the state's maintenance of effort requirement, known as 
solely state funds. Families provided with cash assistance through 
solely state funds are not included in the work participation rate 
calculation. We reported that families for whom states use solely 
state funds to provide cash assistance are those that typically have 
the most difficulty meeting the TANF work requirements, such as 
families that included a parent with disabilities. See Temporary 
Assistance for Needy Families: Implications of Recent Legislative and 
Economic Changes for State Programs and Work Participation Rates, 
[hyperlink, http://www.gao.gov/products/GAO-10-525] (Washington, D.C.: 
May 28, 2010). According to HHS, families in a solely state funded 
program are not in the numerator or denominator used to calculate the 
work participation rate, but they could affect the calculation of the 
caseload reduction credit because any such shift would be considered 
an eligibility change. A reduced caseload due to an eligibility policy 
change does not count toward a caseload reduction credit. 

[54] As of our 2010 report, for which we surveyed all 50 states and 
the District of Columbia, 14 states provided cash assistance to low-
income families with significant barriers to employment using solely 
state funds. The report found that in 9 of these 14 states, work 
participation rules were generally not the same for these families as 
for families in the state's TANF program. We did not collect 
information on what employment services, if any, are provided to these 
families. 

[55] See 42 U.S.C. § 607(d)(8). 

[56] [hyperlink, http://www.gao.gov/products/GAO-10-525] and Temporary 
Assistance for Needy Families: Update on Families Served and Work 
Participation, [hyperlink, http://www.gao.gov/products/GAO-11-880T] 
(Washington, D.C.: Sept. 8, 2011). 

[57] In this report, we identified a number of potential options that 
could improve TANF performance and oversight, based on our prior work, 
and that might be considered as part of an extension or 
reauthorization of TANF. GAO, Temporary Assistance for Needy Families: 
Potential Options to Improve Performance and Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-13-431] (Washington, D.C.: May 15, 
2013). 

[58] These programs are participating or have participated in rigorous 
impact evaluations sponsored by HHS. The Los Angeles County subsidized 
employment program and non-TANF clients in San Francisco Jobs Now! are 
being included in the Subsidized and Transitional Employment 
Demonstration. Washington's I-BEST is part of the Innovative 
Strategies for Increasing Self-Sufficiency project. Ramsey County's 
FAST program was evaluated as part of the TANF/Supplemental Security 
Income Disability Transition Project. For more information on these 
studies, see Appendix III. 

[59] In our prior work, we have noted that the ethical concern that 
the control group should not be harmed by withholding needed services 
can be addressed by providing the control group with whatever services 
are considered standard practice. In this case, however, the 
evaluation will no longer be testing whether a new approach is 
effective at all; it will instead test whether it is more effective 
than standard practice. GAO, Program Evaluation: A Variety of Rigorous 
Methods Can Help Identify Effective Interventions, [hyperlink, 
http://www.gao.gov/products/GAO-10-30] (Washington, D.C.: Nov. 23, 
2009). 

[60] GAO, Welfare Reform: More Information Needed to Assess Promising 
Strategies to Increase Parents' Incomes, [hyperlink, 
http://www.gao.gov/products/GAO-06-108] (Washington, D.C.: Dec. 2, 
2005). 

[61] One of the sites was a nonprofit that conducted a program 
exclusively for TANF clients. 

[62] According to HHS, in preliminary analysis for the Innovative 
Strategies for Increasing Self-Sufficiency evaluation approximately 14 
percent of all sample members were receiving TANF at baseline, with a 
high of nearly 40 percent in one site. In preliminary analysis for the 
Health Profession Opportunity Grants evaluation, similarly, 15 percent 
of participants were receiving TANF, with a number of sites reporting 
a quarter or more as being TANF recipients. 

[63] Research shows that welfare-to-work programs that increase 
employment and earnings do not necessarily increase household incomes. 
This is because the increased income from earnings can be offset by 
the loss of cash welfare, food stamps, and other support services. 

[64] GAO, Program Evaluation: A Variety of Rigorous Methods Can Help 
Identify Effective Interventions, [hyperlink, 
http://www.gao.gov/products/GAO-10-30] (Washington, D.C.: Nov. 23, 
2009). 

[65] According to HHS, the majority of states centrally administer 
TANF, but some states (California, Colorado, Minnesota, New Jersey, 
New York, North Dakota, Ohio, and Wisconsin) play a supervisory role 
and delegate administration of TANF to the counties. 

[66] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[End of section] 

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