The requirements will force most states to modify their current information systems or develop entirely new systems. "It's going to be an incredible undertaking," said Hud Croasdale, director of Virginia's Council of Information Management and chair of the committee investigating welfare reform for the National Association of State Information Resource Executives (NASIRE).
Meanwhile, Congress is awaiting a report from the Department of Health and Human Services (HHS) on the readiness of state information systems for welfare reform as it applies to cash assistance. State officials and experts who have seen a draft version of the report are not happy with its emphasis on developing an interstate case tracking system. They believe the real issue lies with data-tracking and system interfaces within individual states.
"It's the intrastate, not the interstate exchange of information that's going to be the most difficult and most expensive part to implement," commented Terry Maxwell, executive director of the New York State Forum for Information Resource Management. "The report doesn't even deal with that aspect." For state policymakers facing the prospect of choosing between funding services for needy families and the information systems that support the human service programs, finding funds for a federally-required tracking system could prove painful.
The Welfare Reform Act gives states new power to design and run human service programs that affect needy families and the elderly. Within the act are dozens of provisions that radically alter how states can deliver these programs. They include: mandates on eligibility, work requirements, data-collection and reporting requirements.
For example, the federal cash-assistance program, TANF, establishes new categories of families and individuals who are barred from receiving benefits. They include: families with a minor child absent from home for a significant period, unmarried teen parents not living at home or in an adult-supervised setting, individuals who violate probation or parole, unmarried teen parents not attending school, and the list goes on.
Under TANF, states must track recipients of cash assistance based on new time limits. They will have to prohibit a range of noncitizens from receiving benefits, as well as certain classes of criminals. In addition, there are new school-attendance requirements, work requirements and data-collection, and reporting mandates that go beyond anything states have ever done in the past.
In its report, A Shock to the Systems: Automating Welfare Reform in the States, the APWA points out that automation is severely lacking for nearly all the provisions, or that a lack of integration with federal systems makes information sharing extremely difficult. Using data taken from a survey of welfare systems from all 50 states, APWA found the following problems for just the provisions in the TANF program:
* Time-Limited Benefits: "Tracking ... requires states to make substantial modifications or replacements to information systems hardware, software and communications networks. States will be required to develop new system applications, ... increase data storage capacity ... and improve transaction processing speeds."
* Noncitizen Prohibitions: "The range of citizens prohibited from public assistance ... and how these individuals are treated ... are particularly challenging from an information systems perspective. ... The Immigration and Naturalization Service does not provide complete information on immigrant status categories."
* Criminal Prohibitions: "Neither an automated nor a manual system for matching state human service agency records with national criminal justice records exists."
* School Attendance Requirements: "An automated system to support the task of tracking and verifying [unmarried minor parents] does not exist."
* Work Requirements: "The ... overwhelming majority of states [are] in only the early stages of making systems modifications to track the work requirements and calculate the state's work participation rate."
* Data Collection and Reporting: "Requirements compel states to substantially expand the capacity of their current systems; ... reprogram their systems to allow for collection and storage of new elements; and modify data elements that have been revised under the new law."
APWA found similar shortcomings with welfare systems that process information for child care, child support, child welfare, food stamps and Medicaid. Unfortunately, the financing provisions for computer systems in the welfare-reform law force states to bear a large share of the expenses.
State costs for automating their welfare systems could drop if some of the goals of the act are reached using non-automated means. For example, some states may have to track such a low number of noncitizens that an expensive computer program might not be necessary.
Clouding the issue of which provision to automate and which to run manually is the problem of due diligence. "We don't have any regulations in place [for due diligence] now, so we don't know the level of system design that's going to be required to verify information," said Maxwell. As an example, he cited the requirement that unmarried minor parents must attend school on a regular basis. "Is self-reporting by the recipient going to be enough, or is it going to require a direct connection between the school districts and the social services department?"
Because elementary and secondary schools are so numerous at the local level, the development of an automated school attendance verification and tracking system is practically impossible, according to APWA. Further, most schools don't keep automated records. If self-reporting is accepted by the feds, then the requirement may be met at a modest cost. But a higher level of reporting may prove extremely costly in terms of automation, time and labor.
Tug of War
State officials and government organizations are particularly concerned about the federal emphasis on developing an interstate tracking system. The reform act requires HHS to prepare a report for Congress that examines the status of state welfare information systems, and determine "what would be required to establish a system capable of both tracking participants in public programs over time ... and to determine whether individuals are participating in the public programs of two or more states."
To help HHS examine the status of state systems, a number of state organizations -- including APWA, NASIRE and the National Governors' Association -- assisted by surveying state welfare agencies. The same groups spent time with HHS in what they thought was a cooperative effort to come up with common objectives concerning data-tracking and system interfaces. But according to Croasdale, the group effort became a power issue between HHS and the states. "It wasn't much of a partnership," he said.
"HHS has always seen their role as dictating the solutions for meeting
federal requirements."
HHS stopped sharing information with the states at one point, according to a source familiar with the meetings. Eventually, HHS wrote a draft that so alarmed state organizations, they drafted a joint letter to Olivia Golden, assistant secretary for Children and Families Designate, to voice their concerns about the report's recommendations for an interstate tracking system. Their alarm has centered on the draft report's emphasis on developing a national tracking system, despite the fact that the act does not require such a system.
Additionally, the draft report underestimates the total cost of developing such a system and does not emphasize that funds for assistance programs would be siphoned off to design and build it.
In response, HHS said that it has incorporated the comments of states and state organizations into the report, which is not meant to be the final judgment on automating welfare reform. "This [report] represents just the beginning of a discussion that will take place on a broader scale with Congress and the states," said Michael Kharfen, HHS spokesman. The report, which was originally set for release last February 22, is expected to be ready sometime this fall.
Larry Singer, president of Public Interest Breakthroughs, Inc., a not-for-profit organization working with state and local governments on welfare-reform issues, is not surprised by how HHS is handling the evaluation. "HHS has always been a dictator," said Singer. He compared the role played by HHS with that of the departments of Labor and Justice, both of which have acted as coordinators of local and state activities and systems. They act as facilitators, willing to sit down and work with states to solve their problems. "But HHS has always seen their role as dictating the solutions for meeting federal requirements."
Also part of the problem, according to Singer, is the lack of a strong central organization that can rally state views and present them cohesively to the feds. The result, he believes, is that the states are waiting for the feds to decide how things should be done.
Maxwell feels that problems concerning the HHS report on interstate tracking and how state welfare systems will cope with the act's many provisions is more fundamental. "I really see that a lot of the information that's required in the act is based on people's views of the old [welfare] system," he said. "We're starting to realize that maybe a lot of the information the feds are requesting is not really important information.
What's important, according to Maxwell and others, is the information about how long a person stays out of the welfare system once they leave it and why they are, or are not, able to maintain employment. "That's an entirely different information collection system from what we find in traditional welfare systems, which focused on the recipient while they were in welfare," explained Maxwell.
Scramble Underway
Certain provisions of the Welfare Reform Act began kicking in as early as July 1. To cope with the initial requirements, states have been prioritizing their information-system needs. For example, they are working aggressively to implement time limits on cash-assistance benefits, according to the APWA report. Nearly all states or territories were progressing toward automation of tracking the 60-month time limit on TANF benefits.
Specifically, 24 states and territories anticipate modifying various hardware, software and network components of their AFDC (Aid to Families with Dependent Children) systems, while 28 states and territories expect to both modify and replace system components.
But with states struggling to meet other deadlines, such as correcting the year 2000 problem and the 1997 deadline for child support information systems, few have the resources to move forward on all fronts in automating welfare reform.
A big problem is, of course, funding. For instance, under TANF, states face a 15 percent cap on administrative costs. Information system costs are exempted, but any additional funds spent on automation means fewer dollars available for services that support TANF.
To ease the pain of automating welfare reform, groups -- such as APWA -- would like to see HHS ease its costly and time-consuming certification process for information systems and change its philosophy towards systems development, financing and procurement. As one welfare expert puts it, "HHS needs to shift its philosophy from supervisor of state welfare systems to partner."
Other changes called for to ease the current situation include the establishment of a state/federal information-technology partnership that addresses barriers and solutions to IS development, and an escalation in the scope and level of federal technical assistance to states.
But some people remain dismayed at the number of federal provisions and believe they are getting in the way of welfare reform itself. "Welfare reform legislation is forcing the states to focus their limited resources on meeting federal requirements," observed Singer, "instead of achieving the objective of welfare, which is returning people to work."
For more information, contact Terry Maxwell, New York State Forum for IRM, 518/443-5001; Larry Singer, Public Interest Breakthroughs Inc., 703/242-6300.
November Table of Contents
