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    "ocrText": "JUN-28-2000 15:06\nOFC LEGIS. AFFAIRS&BUDGET\n202\n401\n4562\nP.03/13\n#43\nTANF High Performance Bonus, 64 Fed. Reg. 68202 et seq.\n(Dec.6,1999)\nForum: High Performance Bonus - Proposed Regulation\nDate: Thu, 03 Feb 2000 18:33:09 GMT\nFrom: Mary Mannix <[email protected]>\nOrganization: Welfare Law Center\nThese comments on proposed regulations setting forth the criteria for the TANF high performance\nbonus are submitted by the Welfare Law Center, a national law and policy organization that represents\nlow-income individuals and organizations and that works to assure that adequate income support is\navailable to those who need it. We are currently working to enforce the legal protections guaranteeing\nlow-income individuals and families access to Medicaid and Food Stamp benefits and to assure that\nfamilies are able to access the benefits and services, including cash assistance and child care, that they\nneed to transition into employment. In general the proposed regulations are a positive step insofar as\nthey look to state improvements in increasing Food Stamp and Medicaid and CHIP participation, but\nthey should be strengthened in several ways. I. Food Stamp and Medicaid measures should be\nstrengthened. 1. The amount of bonus funds allocated for improvements in Medicaid/CHIP and Food\nStamp performance should be increased. Proposed Sec. 270.8. The allocation of the bonus for the\nFood Stamp and Medicaid/CHIP measures (proposed $40 million total) should at least equal the\namount provided for the work measures (proposed $140 million total). Provision of Food Stamps and\nMedicaid to eligible families is not only mandated by federal law; it is also critical to families'\nwell-being and to their ability to prepare for and sustain employment. HHS should therefore allocate at\nleast as much of the overall bonus funds to Food Stamps and Medicaid performance as its does to the\nwork measures. 2. The Food Stamp measure should look to an increase in participation for all eligible\nfamilies, not just those who are employed. Proposed Sec. 270.4 (a). Many families who leave cash\nassistance are not employed and Food Stamps are critical for both their survival and their ultimate\nability to gain employment, and the criteria should therefore not focus exclusively on the Food Stamp\nparticipation of those who are employed 3. The Food Stamp and Medicaid qualifying conditions are\nan important element of the criteria but should be strengthened to focus on actual state compliance\nwith the stated policy requirements. The qualifying conditions essentially require states to demonstrate\nthat they have in place policies that reflect compliance with various federal Food Stamp and Medicaid\nrequirements relating to the application process, outreach, and protection of ongoing eligibility for\nFood Stamp and Medicaid after cash assistance is lost. Sec. 270.4 (c), (d). These qualifying conditions\nare an important recognition of the need to comply with federal mandates and take advantage of\nfederal options to assure that families receive the benefits Congress intended. The Food Stamp\nqualifying conditions do refer to compliance with application processing times and expedited service\nrequirements and avoidance of incorrect denials and terminations as evidenced by administrative\nreviews. The preamble also acknowledges that USDA is committed to vigorous enforcement of Food\nStamp laws and will investigate and take appropriate action on complaints about practices and that\nHCFA states' compliance with Medicaid qualifying conditions through state documentation and\nongoing oversight. From our day-to-day experience representing classes of welfare applicants and\nrecipients in New York City and in assisting low-income organizations and legal advocates across the\ncountry we are well aware of the abusive practices that result in illegal denials of Medicaid and Food\nStamps. These illegal practices are a reason for the recent sharp decline in program participation. For\nexample. a federal court in New York has found that the New York City welfare agency illegally\ndeters eligible individuals from applying for Food Stamps, Medicaid, and cash assistance. These\npractices include actively discouraging individuals by among other things, encouraging them to look\nelsewhere to food pantries and other sources of support, such as family members, and providing\nmisleading information; oral denials without providing an opportunity for a hearing; denying foods\nstamps and Medicaid when an individual fails to meet cash assistance employment requirements; and\nturning away individuals who arrive at the welfare office after a certain hour regardless of emergency\nneeds. Reynolds V. Guiliani, 35 F. Supp. 2d 331 (S.D.N.Y. 1999). In addition, New York City's illegal\n1 of 2\n2/4/00 9:49 A"
}