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JUN-06-2000 08:08
OFC LEGIS. AFFAIRS&BUDGET
202 401 4562
P.04/12
February 3, 2000
Letter on Proposed HHS Reg
Page Two
Although I believe that the Department's proposal moves us in the right direction, I also believe
that there are certain aspects of the proposed regulation that are cause for concern
Work Measures
There can be no question that one of the principle goals of welfare reform is to move families
into the workforce, and I am encouraged by HHS' efforts to develop thoughtful measures of how
recipients are faring at work. However, numerous recent studies have made it clear that many
former recipients who enter the labor market do so at the lowest economic rung, typically
working in low-paying occupations that offer few benefits and Little room for advancement. As a
result, it is not clear that the current work measures used in the High Performance Bonus
accurately reflect how well leaver families are doing. For instance, we know that low-income
workers often cycle in and out of the labor market, making a measure of job entry rates
somewhat less telling. The job retention measure is also affected by this pattern - rather than
simply measuring whether a recipient is employed from one quarter to the next, there should be
some attempt to understand if they are employed in the same job over time. Staying in one job
and moving up the job ladder is a significantly different experience than moving from one entry-
level job to another.
Furthermore, the measure of earnings should be set as an absolute rather than a relative measure.
Currently states can be rewarded for moving families into work that pays far below a living
wage, so long as there is some relative gain in earnings over time. Should a state be rewarded for
placing a welfare recipient in a job that not only pays poorly initially, but despite
increases over time continues to pay poorly? I would encourage HHS to consider a minimum
earnings threshold before states can compete on this measure, or at least include a component of
this measure that rewards those states that take pains to place recipients in jobs that pay 8 living-
wage.
Finally, I would strongly urge HHS to include child care as a measure of state high performance
in meeting TANF goals. Child care is essential in enabling TANF recipients, primarily single
women with children, to successfully enter the labor market. Indeed, the preamble to the
proposed regulation states that there is "widespread bi-partisan agreement" that "parents should
receive the child care they need to protect their children as they move from welfare to work."
Yet there is overwhelming evidence that affordable, adequate child care remains one of the single
most significant barriers parents face when they try to move into the workforce. HHS' own
studies show that only 10 percent of eligible families receive the child care subsidies to which
they are entitled. It is critical that we do whatever is necessary to ensure that states increase
efforts to provide affordable, quality child care. It is wholly unreasonable to demand that TANF
recipients work without at least acknowledging the need to simultaneously provide affordable,
accessible, quality child care. That TANF goals cannot be accomplished without the provision of
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"ocrText": "JUN-06-2000 08:08\nOFC LEGIS. AFFAIRS&BUDGET\n202 401 4562\nP.04/12\nFebruary 3, 2000\nLetter on Proposed HHS Reg\nPage Two\nAlthough I believe that the Department's proposal moves us in the right direction, I also believe\nthat there are certain aspects of the proposed regulation that are cause for concern\nWork Measures\nThere can be no question that one of the principle goals of welfare reform is to move families\ninto the workforce, and I am encouraged by HHS' efforts to develop thoughtful measures of how\nrecipients are faring at work. However, numerous recent studies have made it clear that many\nformer recipients who enter the labor market do so at the lowest economic rung, typically\nworking in low-paying occupations that offer few benefits and Little room for advancement. As a\nresult, it is not clear that the current work measures used in the High Performance Bonus\naccurately reflect how well leaver families are doing. For instance, we know that low-income\nworkers often cycle in and out of the labor market, making a measure of job entry rates\nsomewhat less telling. The job retention measure is also affected by this pattern - rather than\nsimply measuring whether a recipient is employed from one quarter to the next, there should be\nsome attempt to understand if they are employed in the same job over time. Staying in one job\nand moving up the job ladder is a significantly different experience than moving from one entry-\nlevel job to another.\nFurthermore, the measure of earnings should be set as an absolute rather than a relative measure.\nCurrently states can be rewarded for moving families into work that pays far below a living\nwage, so long as there is some relative gain in earnings over time. Should a state be rewarded for\nplacing a welfare recipient in a job that not only pays poorly initially, but despite\nincreases over time continues to pay poorly? I would encourage HHS to consider a minimum\nearnings threshold before states can compete on this measure, or at least include a component of\nthis measure that rewards those states that take pains to place recipients in jobs that pay 8 living-\nwage.\nFinally, I would strongly urge HHS to include child care as a measure of state high performance\nin meeting TANF goals. Child care is essential in enabling TANF recipients, primarily single\nwomen with children, to successfully enter the labor market. Indeed, the preamble to the\nproposed regulation states that there is \"widespread bi-partisan agreement\" that \"parents should\nreceive the child care they need to protect their children as they move from welfare to work.\"\nYet there is overwhelming evidence that affordable, adequate child care remains one of the single\nmost significant barriers parents face when they try to move into the workforce. HHS' own\nstudies show that only 10 percent of eligible families receive the child care subsidies to which\nthey are entitled. It is critical that we do whatever is necessary to ensure that states increase\nefforts to provide affordable, quality child care. It is wholly unreasonable to demand that TANF\nrecipients work without at least acknowledging the need to simultaneously provide affordable,\naccessible, quality child care. That TANF goals cannot be accomplished without the provision of"
}