Views of Responding Officials: The Department agrees with the finding and will implement corrective action.
Hawaii implemented an upfront work participation requirement as a condition of eligibility for TANF applicants beginning 2009. The purpose of the upfront work participation is to prepare applicant families to engage in the TANF work program. Our state temporarily amended its TANF State Plan in response to the COVID 19 pandemic, suspending the upfront work participation requirements, described in Part B, section 15.1, effective March 27, 2020. This suspension coupled with relaxed administrative policies for all means-tested programs which included TANF, Supplemental Nutrition Assistance Program, and our state-funded General Assistance and Aid to the Aged, Blind and Disabled, and operational changes statewide allowed the Department to process applications expeditiously ensuring eligible families have access to their financial assistance benefits quickly.
In March 2020, Hawaii’s unemployment rate was as low as 2.2% (seasonally adjusted) but it increased considerably to 22.6% in April 2020 following the state’s first shut-down due to the COVID 19 pandemic. The state’s TANF caseload increased by about 177%, from March 2020 with 3,969 recipient families to 7,040 families in December 2020 following the state’s second shut-down.
While the upfront work program participation was suspended as a condition of eligibility for TANF applicants, Hawaii still required recipients to participate with the work program after they were determined eligible for TANF benefits. The good cause provision was exercised judiciously and to the extent allowable under TANF federal regulations and Hawaii administrative rules. Our TANF work program extended its services to provide families the opportunities to receive additional support such as case management and counseling services; to access information and referrals to community resources such as housing assistance and food distribution events; and to receive assistance in navigating through programs, benefits, and services that our department and other government agencies have available during this period of economic downturn resulting from the health emergency.
It was not until March 25, 2022, when then Governor David Y. Ige ended the state’s emergency proclamation relating to COVID 19. The Department continued to suspend the upfront work participation requirements through May 31, 2023, allowing a transition period to adjustour operations. The upfront work participation requirement as a condition of eligibility was reinstated for families who applied for TANF financial assistance benefits beginning June 1, 2022, with only four months remaining in the fiscal year. Other administrative policies that were temporarily suspended or amended in response to the pandemic were reinstated effective July 1, 2022.
The public health emergency and heightened period of COVID 19 restrictions forced the Benefit, Employment and Support Services Division (“BESSD”), who oversees the TANF and other means-tested public assistance programs, to immediately modify its operations statewide, ensuring the continuity of its programs and services and making them more accessible to the public. It was important to provide BESSD a transition period to review its policies and operational procedures and allow its staff of over 650 employees to adjust after two years of operating programs and services in a manner that was unprecedented for the division.
On January 17, 2024, the TANF program office met with the Statewide Branch Administration (“SBA”), who oversees the state First To-Work (“FTW”) program staff, to discuss the concerns regarding the work participation rates, active TANF recipients who were referred to FTW but not yet participating in the program, and strategies to address the concerns. Subsequently, on January 25, 2024, SBA held a meeting with the state FTW unit supervisors to share the concerns raised on the work participation rates and to solicit comments and suggestions. TANF program administrator and lead program specialist were in attendance to notate comments and suggestions.
Corrective Action Taken or Planned: Pursuant to 45 CFR 262.5, the Department requested consideration for reasonable cause from the Administration for Children and Families (“ACF”), for not meeting the two parent work participation rate for fiscal year 2022. Response and determination from ACF is pending.
The FTW unit supervisors were instructed, during the January 25, 2024 meeting, to invite and schedule the active TANF recipients, who were referred but not yet participating, to attend a work program orientation as soon as possible. It is expected that remaining active TANF recipients will be invited to the FTW program by March 31, 2024.
TANF program office is exploring the suggestions received during the January 25, 2024 meeting with SBA and FTW unit supervisors. For example, it was suggested that the FTW program provide additional supportive service payments to participants, who are in countable non employment related work activities, to incentivize them to maintain their program engagement. However, this suggestion has a fiscal impact and will require the FTW program administrative rules to be amended before it can be implemented.
The TANF program office plans to require both parents of two parent households to participate in the FTW program. Due to capacity issues of both state and contract staff, only one parent is required to participate and meet work program requirements for the TANF recipient household. The TANF caseloads have declined; therefore, capacity is no longer a concern.
Expected Completion Date: March 31, 2025
Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator