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    "title": "TANF [Temporary Assistance for Needy Families] - High Performance Bonus - Final Rule Part II [binder] [4]",
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    "ocrText": "JUN-28-2000 15:09\nOFC LEGIS. AFFAIRS&BUDGET\n202 401 4562 P. 10/13\nHigh Performance Bonus Comments\nPage 5\nminimum, a participant assigned to a mandatory work activity as a\ncondition of receiving public assistance should not be sanctioned for\nrefusing to accept an assignment that displaces another worker.\nThese displacement remedies should be available regardless of which\nparty happens to bring the grievance, as the goal is to remedy improper\ndisplacement itself and to avoid creating conflicts of interest between\nregular employees and those being provided new work and training\nopportunities. Thus, if a program participant brings the grievance, the\nremedy should include both a non-displacing assignment for the\nparticipant and reinstatement or other appropriate relief for the person\nbeing displaced, even if not a grievant. Similarly, if a regular employee\nbrings a grievance, the remedy should both make the displaced worker\nwhole and ensure that the participant is not denied a work and/or\ntraining opportunity\nFinally, the state submission should include a statement clarifying that\nthese remedies should not be considered exclusive. Those who file\ngrievances should be assured that they are not relinquishing their right\nto bring a separate legal action under other applicable law or contract\nprovision.⁷\n2. Measuring Displacement & Working Conditions\nAfter the states submit the integrated procedure and protections that meet the\naforementioned conditions, the proposed non-displacement measure would require states\nto demonstrate that their work programs have not, in fact, resulted in displacement and\nviolations of working conditions. To measure displacement, counting successfully\nresolved complaints alone would not work because some high performing states may\nhave no grievances filed. Displacement should be measured by requiring all participating\nworksites with a ratio of at least one TANF program participant to five regular employees\nto submit payroll records so that the state can verify that there has been no reduction in\nregular employee work hours. While not a full proof method of detecting displacement,\nthis approach at least monitors those worksites where there is a fairly high ratio of TANF\nparticipants to employees. States that wish to compete for the non-displacement bonus\n\" ould be responsible for collecting this data from employers. While this is an additional\ndata collection burden, unfortunately there is no existing data that would provide as\naccurate a measure. If HHS objects to imposing additional data collection requirements,\nunemployment insurance records could be considered as an alternative. To establish\ncompliance with regard to working conditions, states should be required, as they are\nunder WIA (Section 195(4)), to provide evidence that employers who employ TANF\nThe current language in all three laws is not adequate. WIA, for instance, states that \"nothing in paragraph (3)\nshall be construed to prohibit a grievant or complainant from pursuing a remedy authorized under another Federal,\nState, or local law for a violation of this title (Section 181(c)(4)). Since some states have claimed that use of the\ngrievance procedure bars other remedies, it is necessary to clarify that invoking the grievance procedure will not\nprevent an individual from seeking other remedies for the same infraction."
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