Differences in How States Define Work Activities Result in Inconsistent Measurement of Work Participation across States and over Time

We found that differences in how states define the 12 categories of federal  work activities result in some states counting hours recipients spend in  activities that other states do not consider allowable activities for meeting  federal work participation requirements. Also, some states have made  changes in their definitions of some categories of federal work activities,  making what is measured by those states’ work participation rates  inconsistent from year to year. Some States Do Not Have Internal Controls Needed for Reporting Data in Accordance with HHS Guidance, while Other States Do

Some of the states we reviewed did not have internal controls to help  ensure that reported hours of participation in work activities are in  accordance with HHS guidance. Insufficient monitoring to verify that hours were reported  correctly. Some States Have Systematic Approaches for Verifying Reported Data

While some of the states we reviewed lacked internal controls, other states  have implemented systematic practices to help ensure that reported data  are in accordance with HHS guidance. HHS Has Provided Minimal Oversight of States’ Definitions of Work Activities

Under PRWORA, HHS has authority to regulate states’ definitions of work  activities. However, HHS has chosen not to issue regulations for this  purpose in order to promote the flexibility PRWORA provided states and  in response to calls from states for as much flexibility as possible in  designing their TANF programs, according to HHS officials. HHS Has Provided Limited Guidance to States on the Appropriate Hours to Report

Although HHS has provided states with general guidance on reporting  actual hours of work participation, the guidance lacks specific criteria for  determining the appropriate hours to report. Because of the  differences among states in the activities that they count in calculating the  work participation rate and in the internal controls over the data used in  the calculation, states are being measured by different standards, and the  work participation rates cannot be used to compare the performance of  states. Appendix I: Elements of the Work Participation Requirement and How the Work Participation Rate Is Calculated

The Temporary Assistance for Needy Families (TANF) work participation  requirement is composed of (1) a requirement for a minimum number of  hours recipients must participate in order to be counted as engaged in  work activities and (2) a requirement for the percentage of TANF families  with an adult (or minor head of household) a state must have engaged in  work activities. Welfare to Work:  JOBS Participation Rate Data Unreliable for Assessing  States’ Performance.
Why GAO Did This Study

The debate over reauthorization of the Temporary Assistance for Needy Families (TANF) block grant has focused on work requirements and brought attention to the measure of TANF work participation. The measure is used to assess states' performance and determine whether a state is subject to penalty for not meeting TANF work requirements. The 2003 work participation rates ranged from 9 to 88 percent for the 50 states based on data they submit to the U.S. Department of Health and Human Services (HHS). To help Congress understand these rates, GAO looked at (1) how selected states are defining the categories of work activities, (2) whether selected states have implemented internal controls over the work participation data, and (3) what guidance and oversight HHS has provided states.

What GAO Found

Differences in how states define the 12 categories of work that count toward meeting TANF work participation requirements have resulted in some states counting activities that other states do not count and, therefore, in an inconsistent measurement of work participation across states. For example, 5 of the 10 states we reviewed considered caring for a disabled household or family member to count toward the federal work participation requirement, while 5 did not consider hours spent in this activity to be countable. We also found that some states made significant changes in their definitions of the categories of work. As a result, the work participation rates for these states cannot be compared from year to year. Some of the states in our review have implemented internal controls to help report work participation hours in accordance with HHS guidance, while other states lack such internal controls. Some states have not issued guidance on how to verify that reported hours were actually worked, nor do they monitor data reported by their staff to help ensure that hours are reported correctly. In contrast, a few states have systematic approaches for verifying that hours reported were worked. HHS has provided limited oversight and guidance to states on appropriately defining work activities and reporting hours of work participation. According to HHS officials, HHS has the authority to regulate states' definitions of work activities. However, to promote state flexibility, HHS chose not to issue regulations for this purpose. Further, HHS's guidance lacks specific criteria for determining the appropriate hours to report. Given that HHS has not exercised oversight of states' definitions and internal controls, states are making different decisions about what to measure. Therefore, there is no standard basis for interpreting states' rates, and the rates cannot effectively be used to assess and compare states' performance.