Work Requirements: Key CBPP Reports

Last Updated: 09/13/2023

CBPP staff have written many papers on work requirements. Below, we provide links to many of them categorized by their main focus. We have a number of papers on the link between work requirements and deep poverty which we include under its own entry.

Participants’ Experience of Work Requirements

An Interview With Moriah Geer, Former TANF Recipient, on the Human Costs of Taking Assistance Away for Not Meeting Harsh Work Requirements | Center on Budget and Policy Priorities (cbpp.org)

Race and Work Requirements

States Have Flexibility to Move TANF Work Programs in an Antiracist Direction | Center on Budget and Policy Priorities (cbpp.org)

Description of TANF Work Requirements and the Problems with Them

Changes in TANF Work Requirements Could Make Them More Effective in Promoting Employment | Center on Budget and Policy Priorities (cbpp.org)

Problems with Expanding Work Requirements to Other Programs

Expanding Work Requirements Would Make It Harder for People to Meet Basic Needs | Center on Budget and Policy Priorities (cbpp.org)

Harm Caused by Work Requirements

TANF Studies Show Work Requirement Proposals for Other Programs Would Harm Millions, Do Little to Increase Work | Center on Budget and Policy Priorities (cbpp.org)

Summary of Evidence on Work Programs

Evidence Doesn’t Support Claims of Success of TANF Work Requirements | Center on Budget and Policy Priorities (cbpp.org)

Work Requirements Don’t Cut Poverty, Evidence Shows | Center on Budget and Policy Priorities (cbpp.org)

Descriptive Studies on Outcomes of TANF Work Programs

Most Parents Leaving TANF Work, But in Low-Paying, Unstable Jobs, Recent Studies Find | Center on Budget and Policy Priorities (cbpp.org)

Life After TANF in Kansas: For Most, Unsteady Work and Earnings Below Half the Poverty Line | Center on Budget and Policy Priorities (cbpp.org)

Study Praising Kansas’ Harsh TANF Work Penalties Is Fundamentally Flawed | Center on Budget and Policy Priorities (cbpp.org)

Ways to Improve TANF Work Requirements

TANF Improvements Needed to Help Parents Find Better Work and Benefit From an Equitable Recovery | Center on Budget and Policy Priorities (cbpp.org)

Opportunity-Boosting Job Preparedness Takes Significant Investment, Evidence Shows | Center on Budget and Policy Priorities (cbpp.org)

Improving Opportunity: Building on Past Successes | Center on Budget and Policy Priorities (cbpp.org)

5 Ways TANF Work Requirements Could Better Promote Work | Center on Budget and Policy Priorities (cbpp.org)

Blogs on the Failures of Work Requirements

Work Requirements Don’t Cut Poverty | Center on Budget and Policy Priorities (cbpp.org)

Work Requirements Don’t Work | Center on Budget and Policy Priorities (cbpp.org)

Work Requirements for Cash Assistance Fueled Rise in Deep Poverty | Center on Budget and Policy Priorities (cbpp.org)

Mandatory Work Programs Are Costly, Have Limited Long-Term Impact | Center on Budget and Policy Priorities (cbpp.org)

TANF Work Requirements Don’t Bring Stable Jobs, Higher Earnings | Center on Budget and Policy Priorities (cbpp.org)

The Empty Promise of Work Requirements | Center on Budget and Policy Priorities (cbpp.org)

Facts Don’t Support TANF’s “Work-First” Approach | Center on Budget and Policy Priorities (cbpp.org)

Quality Work and Direct Financial Assistance, Not Work Requirements, Stabilize Families | Center on Budget and Policy Priorities (cbpp.org)

Program Administrators Across the Political Spectrum Find TANF Work Requirements Incompatible With Recipients’ Needs | Center on Budget and Policy Priorities (cbpp.org)

The Myth That Single Mothers Don’t Work | Center on Budget and Policy Priorities (cbpp.org)

Work Requirements: The Basics

Last Updated: 09/13/2013

Work requirements are a key aspect of TANF programs and are at the core of many decisions made at the state level. There are many different aspects to TANF work requirements, some of which we cover in more detail under their own topic heading. Here, we provide resources that provide a broad overview of TANF work requirements.

This document written by CBPP staff provides a good overview of work requirements and the problems with them: Changes in TANF Work Requirements Could Make Them More Effective in Promoting Employment | Center on Budget and Policy Priorities (cbpp.org)

This document written by staff at the Congressional Research Service (CRS) does a really good job of making the distinction between what is required of states and what is required of individuals receiving assistance. The bottom line is that states have substantially more flexibility to decide what to require of recipients than they take advantage of: Temporary Assistance for Needy Families: Work Requirements (everycrsreport.com).

This document lays out a vision for how states can use the flexibility they have to move TANF work programs in an antiracist direction: States Have Flexibility to Move TANF Work Programs in an Antiracist Direction | Center on Budget and Policy Priorities (cbpp.org)

This paper summarizes research that lays out the harm caused by work requirements: TANF Studies Show Work Requirement Proposals for Other Programs Would Harm Millions, Do Little to Increase Work | Center on Budget and Policy Priorities (cbpp.org)

Work Requirements: Penalties

Last Updated: 09/13/2023

A state that does not meet the work participation rate for a year faces a penalty of up to 5 percent of the state’s TANF block grant.  The penalty amount grows by two percentage points each year for subsequent failures, up to a maximum of 21 percent of a state’s block grant funding.  States that are penalized must spend additional state funds to make up the amount of the federal penalty; any state that fails to do so is subject to an additional fiscal penalty and loses even more of its TANF block grant funds.

A state’s penalty can be reduced in some circumstances to reflect the extent to which it fell short in meeting the work participation rate — for example, if a state fails only the two-parent work rate, the penalty amount is prorated to reflect the share of the state’s caseload that consists of two-parent families.  Federal law also provides relief from penalties based on reasonable cause or extraordinary circumstances, which are narrowly defined in federal rules.  Finally, HHS does not impose a penalty against a state if the state corrects the violation — that is, if it meets the work participation rate (WPR) within the period covered by an HHS-approved corrective action plan. Unfortunately, HHS does not publish data on penalties that have been imposed on states, but experience suggests that few states ever face a penalty and when they do the penalties are small.

These two documents provide useful information on penalties states may face for failure to meet TANF requirements:

Q & A: Penalty Process | The Administration for Children and Families (hhs.gov)

The Temporary Assistance for Needy Families (TANF) Block Grant: A Primer on TANF Financing and Federal Requirements (congress.gov) (Appendix B)

Work Requirements: Caseload Reduction Credit

Last Updated: 09/13/2023

A state can reduce its target work participation rates (50 percent for all families and 90 percent for two-parent families) with a “caseload reduction credit” based on the number of percentage points by which the size of the state’s caseload has falls from an earlier year (specified in statute). What that means is that a state can help achieve its work rate by shrinking its caseload, as well as — or instead of — engaging more families in work activities.

Currently, the caseload reduction credit is calculated based on a comparison of the current number of families receiving TANF cash assistance with the caseload in 2005. The Fiscal Responsibility Act of 2023 changed the comparison year for calculation of the credit from 2005 to 2015. While this change will reduce the caseload reduction credit for most states, because TANF caseloads have declined substantially since 2015, only a few states will face a substantially higher work rate than they have had to meet in the past.

With this new provision in place, a state’s caseload reduction credit will be determined by two factors: (1) the change in the caseload the state reports to HHS from 2015 and (2) the amount of excess MOE the state reports on its financial reporting form (ACF-196 R). The caseload reduction credit for FY 2026 – the first year the new 2015 base year will be used– will be determined by the caseload and spending reported to HHS for FY 2025. Any caseload decline that occurred because of a policy change (e.g., implementation of a shorter time limit) has to be netted out of the caseload reduction credit (i.e., states cannot get caseload reduction credit for implementing harsher policies to reduce the caseload.) States have the option to use the caseload reduction credit for the full caseload or a separate calculation based on just the caseload reduction for two-parent caseload to adjust the work rate for two parent families.

HHS uses the caseload reduction credit to determine the state’s “Adjusted Standard” (i.e., the state’s target work rate) which is equal to the 50 percent minus the caseload reduction credit for all families and 90 percent minus the caseload reduction credit for two-parent families.  

You can find the details of how OFA calculates the caseload reduction credit in this program instruction: TANF-ACF-PI-2020-05 (Renewed Form ACF-202, Caseload Reduction Report) | The Administration for Children and Families (hhs.gov). The program instruction also includes a link to a spreadsheet which will allow you to calculate the credit for your state. (HHS will need to put out revised guidance once the new base year goes into effect.)

You can find the caseload reduction credit for previous years in Table 2 of the Work Participation Rate Data at this link: State TANF Data and Reports | The Administration for Children and Families (hhs.gov). You can find the state’s adjusted standard in Table 1.

Work Requirements: What Federal Law Requires of States

Last Updated: 09/13/2023

The TANF Statute lays out the specifics of work requirements in Section 407 of the Social Security Act: Social Security Act §407 (ssa.gov). This report by CRS is especially helpful in laying out what is required of states vs. what is required of individuals: Temporary Assistance for Needy Families: Work Requirements (everycrsreport.com)

There are four requirements of states in the statute related to work: (1) meet the work participation rate; (2) engage parents in work (as defined by the state); (3) reduce benefits for families with a member who refuses to participate in work; and (4) conduct an employability assessment.

Here is a summary of each requirement:   

Meet the work participation rate (WPR) 

A state’s work participation rate measures the share of work-eligible recipients that participate in work activities as defined in federal law.  Each year, states are required to meet a WPR for all families and a separate rate for two-parent families. Both are adjusted for the reduction in their caseload, after accounting for any eligibility changes. States often point to federal law as constraining their ability to operate work programs that would improve recipients’ long-term economic prospects.  But state — not federal — rules determine work requirements for individual TANF recipients, including which recipients to exempt from work requirements.

Federal law is prescriptive about the hours and activities in which recipients must be engaged to be counted in the WPR calculation as well as procedures states must follow to document their participation. Most states define what is expected of individual recipients to align with what is required for a recipient to “count” toward the WPR, but federal law does not require them to do so. This distinction is important as it clarifies why states have considerable flexibility to operate work programs that would better affirm recipients’ dignity and help them achieve economic mobility even with the WPR in place. States also have non-punitive options for meeting the WPR such as taking advantage of a caseload reduction credit and providing additional assistance to working families. Because most states have a very low WPR target rate they have considerable flexibility to design and implement work programs that are based on evidence and reflect the goals and aspirations of the family. A state that fails to meet the rate can be subject to a fiscal penalty, up to 21 percent of its block grant, but states also have a number of options for avoiding a penalty, including demonstrating good cause for not meeting the WPR and entering into a corrective action plan. For most states, the threat of a fiscal penalty is largely nonexistent.   

Engage parents in work (as defined by the state)  

States are expected to engage recipients in work when they are deemed job ready or within 24 months of their participation in TANF, but it is up to the state to decide what constitutes being engaged in work. A state’s definition of what it means to be engaged in work does not have to follow the federal rules for activities and hours that determine whether a family is counted as engaged in work for purposes of the WPR calculation. For example, a state could define participating in mental health treatment or other work readiness activities as engaged in work; they also do not have to include a specific number of hours. States also do not have to include all families that are included in the WPR calculation. For example, a state can choose to exempt participants from engaging in work who are homeless or experiencing mental health issues or caring for a child with special needs or under a specific age, or living in an area with extremely high unemployment and extremely limited transportation options, to name a few. There is no penalty to the state if they do not meet this requirement.   

Reduce benefits for families with a member who refuses to comply with work requirements 

States are required to impose a financial penalty (i.e., a sanction) when a family member “refuses” to comply with work requirements as defined by the state without “good cause.” States determine the penalty amount and duration, including whether benefits are taken away from the family member who has not met the requirement, or the entire family, including the children in the family. They also determine when to impose the penalty and define what constitutes “good cause” for not meeting a work requirement. In recent years, because of the mounting evidence that adversity in childhood has significant long-term consequences for children’s growth and development, some states have shifted their policies to minimize the harm to children. For example, in 2020, Maryland passed legislation that designates 75 percent of the benefit for children and 25 percent for the adult members of the assistance unit. The adult portion of the grant is reduced by 30 percent if the parent does not comply with work requirements which is about $55 for a single parent household with two children. Vermont reduces a family’s grant by $150. The penalty remains in place until the family is in compliance with work requirements for two weeks.  A state that does not have a sanction policy in place can face a penalty of between 1 and 5 percent of its block grant. This penalty has never been imposed on a state.  You can find more on recent state policies to minimize the harm to families by taking away benefits at this link: Ending Full Family Sanctions

Conduct an employability assessment  

States are expected to assess a recipient’s skills, work experience and employability within 90 days of participating in TANF. Some states use these assessments to develop an individualized service plan for recipients, but they are not required to do so. There is no penalty to the state if they do not meet this requirement. 

The Perils of Block Granting

Last Updated: 09/13/2023

Periodically, proposals are put forth to block grant other programs, using TANF as a model of “success.” We have written a number of pieces that show the opposite to be true. You can find links to them below.

Lessons from TANF: Block-Granting a Safety-Net Program Has Significantly Reduced Its Effectiveness | Center on Budget and Policy Priorities (cbpp.org)

TANF Shows Why Block Grants Are Bad Deal for States | Center on Budget and Policy Priorities (cbpp.org)

Lessons from TANF: Initial Unequal State Block-Grant Funding Formula Grew More Unequal Over Time | Center on Budget and Policy Priorities (cbpp.org)

TANF Block Grant Offers a Cautionary Tale for Medicaid | Center on Budget and Policy Priorities (cbpp.org)

Solely State Funded Programs

Last Updated: 09/12/2023

Would Some Families Be Better Served in a Program Outside the TANF/MOE Structure?

After the passage of the Deficit Reduction Act of 2005 (DRA), some states began serving select groups of families in what are referred to as “solely state funded” (SSF) programs. These programs are funded with state general fund dollars that states do not count toward their state Maintenance of Effort (MOE) requirement. To date, states have primarily served families who would have difficulty meeting the TANF work requirements in these programs. About half the states serve two-parent families in solely state funded programs and a handful serve families who face significant employment challenges. One state serves almost all of its families that receive monthly cash payments in a solely state funded program. While states often impose the same work and other behavioral requirements on these families as they do on TANF recipients, there is nothing that compels them to do so. However, because there are no federal TANF or state TANF MOE funds used to provide assistance to these families, states are not required to impose work or behavioral requirements on families as a condition of eligibility. That gives states the flexibility to offer programs and services to families that are aligned with their personal or family goals or to provide monthly cash payments with no behavioral requirements.  

In recent years, there has been growing interest in providing unconditional cash transfers to families. The earliest programs were funded almost exclusively with private dollars, but some of the more recent programs have been funded with public dollars, many of them using flexible funds provided to address additional needs that arose because of the pandemic. States that want to continue these programs after their current funding runs out could consider creating an SSF to continue to provide cash to families with no strings attached.

States may be able to set up an SSF without incurring additional costs. States that use state general fund dollars to provide services that meet one of TANF’s found broad purposes could potentially swap funding streams to free up state dollars to provide unconditional cash payments to some or all families with low incomes.  Because TANF’s purposes are so broad, there are many services that states may provide to families with low-incomes that are funded with state (or local) general fund dollars. Examples of services that states often provide with state general funds that could be funded with TANF dollars include such programs as after school programs, child care, and case management provided to families that are unhoused or fleeing domestic violence.

The primary advantage of providing cash assistance through an SSF rather than through TANF is that a state can design a program that they believe will best meet the needs of the families served. But, there are also other considerations.

  • Child Support. States must pass through all child support collected on behalf of SSF families to the families for whom the payments are collected. Whether a state gains or loses from this requirement depends on how they distribute child support payments. States that pass through all child support collected gain because they do not owe the federal government any share of the payments passed through. States that do not pass through child support payments that are collected will lose their share of the payments.
  • Contingency fund. In order to receive payments from the Contingency Fund, states must meet a higher MOE requirement (100 percent of their historical spending plus an amount equal to the amount of contingency funds they receive). Any funds spent on child care do not count towards the MOE requirement which means that states that count substantial child care spending to meet their MOE requirement will no longer qualify. States that receive contingency funds and want to continue doing so may find it harder to do a funding swap.

In considering whether to establish an SSF program, states should consider questions such as:

  • Which families should it serve?
  • What benefits and should it include?
  • How long should families be able to participate in the program.
  • How should it be financed?
  • Should recipients have a choice between the SSF program and the regular TANF program?

This piece written by CBPP staff is a bit dated but provides additional information for thinking about the design and implications of serving some TANF families through an SSF. Designing Solely State-Funded Programs | Center on Budget and Policy Priorities (cbpp.org)

This piece was written after the DRA when states were looking for strategies to meet the more stringent work requirements, but much of the information is relevant even if the reason for establishing an SSF is different (i.e., to provide an unconditional cash benefit to families).

Application Approvals and Denials

Last updated: 09/11/2023

The U.S. Department of Health and Human Services publishes data annually on TANF application approvals and denials. This information is useful for a number of different purposes. First, it is useful because it provides concrete information on need — there are many families applying for TANF every month who are not approved for assistance. Second, it provides data that you can use to begin to identify whether there are policies and/or administrative procedures that are keeping families from being able to access assistance. The data HHS publishes does not have a lot of detail, but it provides a starting point for assessing access to TANF.

You can find the data for 2020 through 2022 at this link: TANF Application Data (2020 to 2022) | The Administration for Children and Families (hhs.gov)

You can find the earlier data at these two links: TANF Application Data (2010 to 2019) | The Administration for Children and Families (hhs.gov) and TANF Application Data (2000 to 2009) | The Administration for Children and Families (hhs.gov)

CBPP’s Income Security Staff have compiled the data from 2000 through 2020. You can find the excel file under Additional Files at the right.

Work Requirements: Ending Full Family Sanctions

Updated: 09/11/2023

Background: A key aspect of TANF’s racist legacy is punishing families by taking away all or part of their cash benefits when they are unable to meet a work or other behavioral requirement. Federal law requires that states reduce a family’s benefit if they “refuse to comply” with work requirements, but it is up to states to decide when and how much of a family’s cash assistance is taken away. All except three states currently have or previously had “full family sanctions” that take away an entire family’s TANF benefit if they are unable to comply with meeting a work requirement. In recent years, advocates and administrators have been successful at eliminating full family sanctions in the District of Columbia and six states – Connecticut, Colorado, Illinois, Maine, Maryland, and Oregon.  California, New York and Vermont are the only states that have never adopted full family sanctions.

Advocate’s Goal: Advocates should aim to eliminate full family sanctions and reduce the use and severity of all sanctions. Where possible, advocates should seek to follow the example of DC, Illinois, and Maryland, who have structured their grant so that the maximum sanction is less than 10 percent of the grant. You can find the details of these and other states’ sanction policies and their legislative language in the document Approaches-to-Eliminating-Full-Family-Sanctions.Extrenal.docx (live.com) included in the Additional Files at the right. You can also find talking points at this link:  Talking-Points.docx (live.com)

Equity implications: All TANF sanctions are rooted in the racist idea that people with low-incomes, who are disproportionately Black, do not wish to work and must be coerced into doing so. Research shows that work-related sanctions are often applied inappropriately to families with high barriers to unemployment and disproportionately harm Black and other people of color. Research also shows that full-family sanctions have long-term detrimental impacts on families and have driven the steep decline in TANF caseloads since the program’s creation.

State Data:

Welfare Rules Database: Table III.B.3 contains data on states’ initial and most severe sanction for non-compliance with work requirements. Tables III.B.1 and III.B.2 contain details about work activities requirements and exemption policies. ALL DATA ARE FROM 2020 OR EARLIER AND DO NOT CAPTURE RECENT CHANGES.

Key resources:

TANF Studies Show Work Requirement Proposals for Other Programs Would Harm Millions, Do Little to Increase Work: This 2018 report summarizes a large body of research on the application and impact of sanctions. It finds that: 1) sanctions are often applied inappropriately to families with the greatest employment barriers, 2) African American recipients are significantly more likely to be sanctioned, indicating racial bias, 3) parents who leave TANF because of a sanction have poorer labor market outcomes than non-sanctioned parents, and 4) parents who leave TANF because of a sanction experience significant material hardship.

States Have Flexibility to Move TANF Work Programs in an Antiracist Direction: This 2022 report, part of CBPP’s “anti-racist vision for TANF” series, embeds eliminating full-family sanctions in a broader suit of policy changes states can make to improve their TANF work programs. The report also details the racist history that led to full-family sanctions in TANF.

Maine Joins Growing List of States Repealing TANF Full-Family Sanctions: This 2021 blog includes many of the talking points below on full-family sanctions, in the context of Maine. Advocates could use this blog as an example to craft their own blogs about full-family sanctions in their state.

Life After TANF in Kansas: For Most, Unsteady Work and Earnings Below Half the Poverty Line | Center on Budget and Policy Priorities (cbpp.org): This paper provides a detailed analysis of the employment outcomes of families after Kansas implemented significant policy changes that made it harder for families to receive assistance. The report disaggregates the employment outcomes by reason for exit, including sanctions. The data show that the majority of families who leave TANF because of a sanction do not find steady work.

Most Parents Leaving TANF Work, But in Low-Paying, Unstable Jobs, Recent Studies Find: This 2020 report summarizes findings from 13 studies that examined the outcomes of TANF leavers in 9 states between 2007 and 2019. Key findings include that, contrary to stereotypes, most parents on TANF work before, during, and after their stint on cash assistance, but for low-wages and unstable hours that lead them to remain in poverty and experience material hardship.

Spending: The Basics

Last Updated 09/08/2023

TANF is a block grant that provides states with considerable flexibility in how they spend their funds. There are many aspects to TANF Spending. below, we first provide a quick guide to TANF spending then provide links to additional resources. We also provide more detail in the Q and A document that you can find under Additional Files at the right.

Quick Guide to TANF Spending

  • TANF Funds (Federal and State) can only be spent on resources and programs that are aligned with TANF’s four purposes:
    • Provide assistance to needy families so that children may be cared for in their own homes or in the homes of relatives;
    • End the dependence of needy parents on government benefits by promoting job preparation, work, and marriage;
    • Prevent and reduce the incidence of out-of-wedlock pregnancies and establish annual numerical goals for preventing and reducing the incidence of these pregnancies; and
    • Encourage the formation and maintenance of two-parent families.
  • TANF funds can only be spent on families with children (but can be spent on the parents or the children in those families).
  • Federal TANF funds can be carried over and spent at any time but state funds must be spent in the current year.
  • When TANF funds are used to provide “assistance,” specific requirements are triggered, including time limits, child support cooperation requirements and work requirements.  The definition of assistance is defined in regulations and includes exceptions which make it possible to help families meet their basic needs without triggering these requirements. 

Some things to note regarding assistance:

  • Families receiving cash assistance are already receiving “assistance” so any additional benefits that help them meet their basic needs do not trigger any additional requirements.
  • Supportive services (e.g., transportation and child care) provided to working families are not considered assistance.
  • Short-term cash assistance (e.g., emergency assistance) is not considered assistance as long as it meets the criteria laid out in the regulations – intended to respond to a crisis or short-term need, not intended to meet ongoing needs, won’t extend more than four months.
  • Work subsidies and refundable earned income tax credits are not considered assistance.
  • Services (such as counseling or case management) are not considered assistance

Key Resources:

Additional Resources: