TANF: State Approaches to Screening for Domestic Violence Could  
Benefit from HHS Guidance (16-AUG-05, GAO-05-701).		 
                                                                 
The Temporary Assistance for Needy Families (TANF) program	 
introduced specific work requirements and benefit time limits.	 
However, the Family Violence Option (FVO) requires states that	 
adopt the FVO to screen TANF clients for domestic violence and	 
grant waivers from program requirements for clients in domestic  
violence situations. TANF also allows the use of TANF funds for  
marriage and responsible fatherhood programs. Given states' broad
discretion in implementing the TANF program, including most	 
aspects of the FVO and marriage and responsible fatherhood	 
programs, this report examines (1) how states identify victims of
domestic violence among TANF recipients, (2) how states address  
domestic violence among TANF recipients once they are identified,
and (3) the extent to which states spend TANF funds on marriage  
and responsible fatherhood programs, and how, if at all, these	 
programs are addressing domestic violence.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-701 					        
    ACCNO:   A33077						        
  TITLE:     TANF: State Approaches to Screening for Domestic Violence
Could Benefit from HHS Guidance 				 
     DATE:   08/16/2005 
  SUBJECT:   Crime victims					 
	     Disadvantaged persons				 
	     Evaluation criteria				 
	     Evaluation methods 				 
	     Families						 
	     Federal aid programs				 
	     Federal funds					 
	     Federal grants					 
	     Federal/state relations				 
	     Funds management					 
	     Grant monitoring					 
	     Program evaluation 				 
	     Program management 				 
	     Public assistance programs 			 
	     State-administered programs			 
	     Strategic planning 				 
	     Waivers						 
	     Domestic abuse					 
	     Temporary Assistance for Needy Families		 
	     Program						 
                                                                 

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GAO-05-701

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

August 2005

TANF

State Approaches to Screening for Domestic Violence Could Benefit from HHS
                                    Guidance

GAO-05-701

[IMG]

August 2005

TANF

State Approaches to Screening for Domestic Violence Could Benefit from HHS
Guidance

What GAO Found

Forty-eight states have adopted the FVO or a comparable state policy. Most
of these states actively screened clients by directly questioning them
about domestic violence, whereas five states simply notified clients of
domestic violence waivers without making a direct inquiry. Most states
provide staff with a screening tool, but the detail and depth of these
tools vary. State officials said that staff in local TANF offices often
have limited skills in dealing with domestic violence issues, and policies
regarding staff training vary. To address this issue, some state TANF
offices employ domestic violence specialists. Although HHS has compiled
and disseminated information about domestic violence screening, HHS has
not issued guidance regarding best practices in domestic violence
screening.

State TANF programs help clients address domestic violence issues by
granting waivers that exempt victims from TANF requirements, and by
referring clients for domestic violence services. Most states will waive
the TANF program's federal requirements pertaining to work, the 5-year
lifetime limit on cash assistance, and the child support requirements.
However, the conditions of these waivers vary from state to state. For
example, 27 states required that clients participate in domestic violence
services. Limited data on the number of domestic violence waivers
indicates that a comparatively small portion of TANF recipients obtain
such waivers.

Most states have used TANF funds for marriage or responsible fatherhood
programs or both. Specifically, 15 states reported funding marriage
programs and 28 reported funding responsible fatherhood programs. States
that provided usable data reported spending about 5 percent or less of
their federal TANF budget on these programs. In addition, some states
funded these programs through other funding sources or had programs in
development. According to research and practitioners in the field, these
programs generally do not explicitly address domestic violence, and HHS
has stated that all future Healthy Marriage projects should include
domestic violence protections.

Number of States with Particular Policies Regarding Frequency of Domestic
Violence Training

At special intervals

Once in career

                              No state requirement

Once in careeradditional optional

Source: GAO survey.

United States Government Accountability Office

Contents

Letter

Results in Brief
Background
Most States Have Adopted the Family Violence Option, and States'

TANF Programs Take Differing Approaches to Screening for Domestic Violence
To Address the Needs of Victims of Domestic Violence, Most States Use
Waivers and Refer Clients to Local Service Providers

Most States Used Federal TANF Funds for Marriage or Responsible Fatherhood
Programs, but Take Differing Approaches to Addressing Domestic Violence

Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation

                                       1

                                      2 4

10

19

24 30 31 31

Appendix I Objectives, Scope, and Methodology

Appendix II	Comments from the Department of Health and Human Services

Appendix III GAO Contact and Staff Acknowledgments

Tables

Table 1: Number of States That Grant FVO Waivers 20 Table 2: Number of
States and Evidence Required for a Waiver to Be Granted 21

Figures

Figure 1: TANF Process 6 Figure 2: States' Status Regarding Adoption of
the Family Violence Option or a Comparable Policy 11 Figure 3: Number of
States Requiring Follow-up Domestic Violence Screening at Specific Points
in the TANF Process 13

Figure 4: Number of States with Particular Policies Regarding Frequency of
Domestic Violence Training 16 Figure 5: States Using Federal TANF Dollars
to Fund Marriage and Responsible Fatherhood Programs 25

Abbreviations

ACF Administration for Children & Families
DVA Domestic Violence Advocate
FVO Family Violence Option
HHS Department of Health and Human Services
PREP Prevention and Relationship Enhancement Program
TANF Temporary Assistance for Needy Families

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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copyright holder may be necessary if you wish to reproduce this material
separately.

United States Government Accountability Office Washington, DC 20548

August 16, 2005

The Honorable Max Baucus United States Senate

The Honorable Pete Stark House of Representatives

The Temporary Assistance for Needy Families (TANF) program provided about
$17 billion in federal funds to states in fiscal year 2004 for cash
assistance and services to low-income families. This program includes
specific work requirements and a 5-year benefit time limit that some TANF
clients may be unable to meet. Recognizing that not all clients will be
ready to work and that some may need assistance beyond 5 years, the
program also offers various exceptions to these requirements. One
exception-the Family Violence Option-requires that states screen clients
for domestic violence and allows them to grant waivers from program
requirements for clients in domestic violence situations. Adopting the
Family Violence Option is not mandatory, and states that choose not to do
so may nonetheless adopt comparable policies. Although the Department of
Health and Human Services (HHS) oversees the TANF program, states have
broad discretion in implementing the program, including most aspects
related to the Family Violence Option.

Currently, the Congress is considering various changes to the TANF
program, including proposals that would establish matching grants to
promote marriage and discourage divorce, as well as measures emphasizing
responsible fatherhood. While spending TANF funds on these activities is
currently allowed under TANF, the amount states spend on such program is
relatively small compared to their total TANF budgets.

Concerned about these issues, you asked us to examine how state TANF
programs were addressing the issue of domestic violence and how, if at
all, these programs have funded or promoted marriage and fatherhood
efforts. As agreed with your offices, we responded to the following
questions:

o  	What are states doing to identify victims of domestic violence among
TANF recipients?

o  	What are states doing to address domestic violence among TANF
recipients once victims have been identified?

o  	To what extent are state TANF programs spending TANF funds on marriage
and responsible fatherhood programs, and how, if at all, are these
programs addressing domestic violence?

To answer these questions, we conducted a survey of the TANF programs of
the 50 states and the District of Columbia. In this survey, we asked
detailed questions about state policies regarding screening TANF clients
for domestic violence, how states addressed domestic violence situations
once clients have disclosed them, and the extent to which states have used
TANF funds for marriage and responsible fatherhood programs. To supplement
the data obtained through the survey, we conducted in-depth visits to five
states-Colorado, Georgia, New York, Oklahoma, and Washington. We selected
these states because their practices for screening TANF clients for
domestic violence have been in place for various amounts of time; only one
of these states, Oklahoma, has not adopted the Family Violence Option. We
selected one state-Oklahoma-in part because of its TANF-funded marriage
program, and another state- Georgia-because of its TANF-funded responsible
fatherhood program. During each of these visits, we conducted detailed
discussions with state officials about state policies, obtained
documentation of state policies, and visited two local service delivery
offices in each state to discuss and observe how the policies were
implemented. We visited three states- Illinois, Iowa, and Wisconsin-while
designing our study, and pre-tested the survey with officials in Maryland,
Michigan, and Pennsylvania. Finally, we contacted researchers and policy
analysts knowledgeable about the TANF program, domestic violence, and
marriage and responsible fatherhood programs. We also reviewed pertinent
literature concerning each of these areas. A more detailed discussion of
methodology is contained in appendix I.

We conducted our work in accordance with generally accepted government
auditing standards between May 2004 and May 2005.

All but three states have either certified adoption of the Family Violence
Option or have adopted a comparable policy, and the large majority of
these states screen for domestic violence. To meet the requirements of the
Family Violence Option, states have implemented a range of policies
concerning screening techniques, privacy, as well as domestic violence
training requirements for local staff who conduct the screening. While
most states provide staff with a questionnaire or other screening tool,
the detail and depth of these tools varies. Some in-depth questionnaires
probe for various aspects of domestic violence, while others include a
single-line

  Results in Brief

prompt for domestic violence. In addition to the use of formal tools,
state TANF officials and others emphasized the importance of informal
screening, including unstructured conversations and observation of
clients. Five states that have adopted the Family Violence Option or a
comparable policy indicated that they do not require a specific inquiry
about domestic violence, but instead rely on notifying clients of
available domestic violence waivers. Of the states that have adopted the
Family Violence Option or a comparable policy, most have not established
policies regarding the physical setting of screening or who may be present
while a client is screened. Further, state officials and domestic violence
experts indicated that the ability, skills, and inclination of caseworkers
that conduct such inquiries vary widely. To aid in screening and assessing
TANF clients for domestic violence, some state TANF programs employ
domestic violence specialists. Although HHS has taken some actions to
compile and disseminate information about domestic violence screening, HHS
has not issued guidance regarding best screening practices.

In the states we visited, TANF programs helped clients address domestic
violence issues by providing exemptions from TANF requirements as needed
and by ensuring that clients have access to services. While most states
will grant waivers for work, time limit, and child support requirements,
the specific conditions of these waivers vary from state to state. For
example, some states require recipients to provide evidence that they are
victims of domestic violence before the work requirement will be waived.
Some of the eight states we visited had limited data on the number of
domestic violence waivers issued, and in these states it appears that only
a small percentage of clients who have disclosed domestic violence were
granted waivers. While TANF staff generally refer victims to domestic
violence services-such as counseling and emergency shelter- these services
are typically provided by other agencies. However, TANF offices in some
states offer in-house services to domestic violence victims. For example,
domestic violence specialists in Washington state can provide ongoing,
in-house domestic violence counseling. In addition, we found, in the
states that we visited, services for domestic violence victims were less
available in rural areas.

Thirty-one states reported using federal TANF funds for marriage or
responsible fatherhood programs, and limited research indicates that such
programs generally do not specifically address domestic violence. Twenty
eight states reported using federal TANF funds for responsible fatherhood
programs, and 15 have done so for marriage programs over the last

3 years. Of the states that provided usable budget data, no state reported
spending more than about 5 percent of its total federal TANF expenditures
on either marriage or responsible fatherhood programs for fiscal years
2002 or 2003. However, states may fund marriage or responsible fatherhood
programs with other funding sources or be in the process of developing
programs that may or may not use TANF funds. According to researchers and
practitioners in the field of marriage and responsible fatherhood,
marriage and responsible fatherhood programs do not typically raise
awareness of domestic violence explicitly, but may do so implicitly
through emphasis on healthy and constructive techniques for conflict
resolution without specifically addressing or identifying domestic
violence.

This report contains recommendations that HHS (1) examine domestic
violence screening practices of states in order to identify particularly
promising approaches, and (2) provide states with information on such
practices and encourage their adoption in agency guidance or memoranda.

The TANF program was established by the Personal Responsibility and Work
Opportunity Reconciliation Act of 1996 (PRWORA), and was designed to
provide cash assistance to needy families with children, while at the same
time ending the dependence of needy families on government benefits by
promoting job preparation, work, and marriage. As the responsible federal
agency, HHS provides an annual TANF block grant to each state. In fiscal
year 2004, states spent about $26 billion of federal and state funds to
assist low-income families, including providing monthly cash assistance to
about 2 million families as of June 2004. States have considerable
flexibility in administering TANF programs, and in turn, offices in
localities throughout each state are responsible for interacting with TANF
clients and running the day-to-day aspects of the program.

The TANF program encourages recipients to work, places limits on the
length of time that a family can receive federal cash benefits and
requires that clients cooperate with child support authorities.
Specifically, in accordance with the authorizing legislation, TANF
regulations state that all clients must participate in work activities as
soon as the state determines they are ready to do so, or after 24 months
of cash benefits, whichever

  Background

occurs earlier.1 Further, clients may not obtain federal TANF cash
benefits for more than a total of 60 months during their lifetime. TANF
also requires that all families with children for whom paternity has not
been established or for whom a child support order needs to be
established, cooperate with child-support enforcement agencies. The TANF
program both gives states incentives to enforce these requirements, as
well as the flexibility to waive these requirements if necessary. For
example, states must engage a certain percentage of their overall and
twoparent caseloads in work activities, or face financial penalty. In
practice, states can waive the work and time limit requirements for
clients in a number of ways. For example, states can provide cash benefits
beyond the 5-year time limit to for up to 20 percent of their caseload.
Some states also provide cash assistance with only state funds when a
client has difficulty meeting federal requirements.

States enroll applicants in the TANF program through a process that is
roughly comparable, though the particulars may vary from state to state
(see fig. 1). A TANF client may meet with a worker who verifies that the
cash assistance program is appropriate for the client's needs and that the
client qualifies for cash assistance. The client is typically assigned a
caseworker who conducts a review of the client's employment prospects,
including the client's education, work history, skills, and aspects of the
client's personal life that may affect their ability to hold a job. Based
on this review, the caseworker develops an individual responsibility plan
that outlines actions that the client is to take in order to obtain
employment and become financially self sufficient. This plan may require
that a client immediately begin a job search or that the client first take
actions to address aspects of the client's life that pose a barrier to
work. After this plan is established, the caseworker meets with the client
periodically, in order to ensure that the client is making progress toward
the goals outlined in the plan. Some states also require a more in-depth,
comprehensive review of the client's progress at regular intervals or if
the client is having difficulty meeting aspects of the individual
responsibility plan.

1States have some discretion in defining "work" under this requirement.
For example, work can include job search and job readiness assistance, or
vocational educational training.

Figure 1: TANF Process

Client not No Yes eligible for

                                      TANF

The TANF legislation also established a provision known as the Family
Violence Option, under which states commit to screen clients for domestic
violence, and refer those who are identified as domestic violence victims
to domestic violence services. Further, states that have adopted the
Family Violence Option can waive program requirements-including those
related to work, the 5-year federal time limit, and cooperation with child
support authorities-if compliance would make it more difficult for clients
to escape domestic violence, or would unfairly penalize domestic violence
victims.

States that have adopted the Family Violence Option may also avoid
financial penalties related to the work requirements and the 5-year time

Close TANF case

                             Source: GAO analysis.

The Family Violence Option Gives States Incentives to Address Domestic
Violence among the Client Population

limit, if their failure to meet these requirements is at least partly
attributable to clients who have been granted federally recognized, good
cause domestic violence waivers.2 In order for the domestic violence
waiver to be federally recognized, it must specify which program
requirements are being waived, be granted based on need as determined by a
person trained in domestic violence, and be accompanied by a services
plan. States may report federally recognized good cause domestic violence
waivers to HHS, and HHS requires that such waivers not be reported unless
they meet the regulatory definition. As with other aspects of the TANF
program, states have broad flexibility regarding the detailed
implementation of the Family Violence Option.

Studies Indicated Domestic Violence Is Prevalent among Low-Income Women
and Can Be a Barrier to Employment

Domestic violence affects a substantial percentage of low-income women,
according to existing research. Further, research shows that it can, in
some cases, pose a barrier to work and financial independence. In 1998, we
reported that studies indicated that between 15 percent to 56 percent of
welfare recipients are, or have been, victims of domestic violence.3 Since
that time, additional studies with similar findings have been published.
For example, a 2001 report summarized the prevalence of domestic violence
among a random sample of women in the TANF caseload of an urban county in
Michigan.4 This study found that about 51 percent of the women had been
severely abused at some time in their life, and about 15 percent had been
severely abused by a partner at least once in the preceding year.5
Further, 61 percent reported being threatened with violence or other
retribution at some point in their lifetime, and 24 percent reported such
an experience had occurred in the preceding 12 months.

Past research has also revealed that domestic violence can, in some cases,
be a barrier to work and financial independence. In our 1998 report, we

2States that have not adopted the Family Violence Option may also screen
for domestic violence and offer waivers to program requirements. However,
these states are not eligible to avoid financial penalties related to the
work requirement and 5-year time limit.

3GAO, Domestic Violence: Prevalence and Implications for Employment among
Welfare Recipients, GAO/HEHS-99-12 (Washington, D.C.: November 1998).

4Richard M. Tolman and Daniel Rosen, Domestic Violence in the Lives of
Women Receiving Welfare: Mental Health, Substance Dependence, and Economic
Well Being in Violence Against Women, Vol. 7, No. 2 (February 2001).

5Severe abuse is defined as including experiences such as being beaten,
being hit with a fist or an object that could cause harm, and being
threatened with a weapon.

reported that various studies found that women who were or had been
victims of domestic violence were employed at about the same rates as
women who reported never having been abused. However, we also cited one
study that found abused women experienced higher job turnover and more
spells of unemployment than women who had never been abused. Further, our
1998 report, as well as other research, has outlined how domestic violence
can impede successful employment for some women. For example, several
studies have shown that abusers may be threatened by any steps a woman
takes toward financial independence, and may thwart a job search or
employment by interfering with transportation to work, or by making
harassing phone calls to a woman while she is in the workplace.

Prompting Disclosure of Domestic Violence Can Be Difficult

State TANF programs face significant challenges addressing domestic
violence, in part because it can be especially difficult to detect. Many
victims of domestic violence may be reluctant to disclose such a personal
and potentially humiliating aspect of their life. Researchers in the field
of domestic violence and state officials stated that domestic violence
victims may be unwilling to disclose domestic violence out of shame and
embarrassment. Victims may also fear retribution by the abuser.

TANF clients may be particularly reluctant to disclose abuse in the TANF
program setting. Advocates for victims of domestic violence explained that
TANF clients often see TANF staff as government officials who cannot be
trusted to keep the disclosure of domestic violence confidential. Further,
some clients may fear that any disclosure of domestic violence to
government officials could result in the loss of custody over their
children. As a result, disclosure may be thwarted, at least until a
trusting working relationship can be developed. Caseworkers may also lack
specific skills that facilitate disclosure. For example, according to some
experts, caseworkers may lack empathy for domestic violence victims.
Additionally, given the heavy workload that some caseworkers face-in busy
urban areas, some have over 100 clients-they may not effectively screen
for domestic violence. According to some researchers, some caseworkers may
see addressing domestic violence as conflicting with the overall goal of
ensuring that clients become employed. Finally, HHS officials told us that
the physical setting of domestic violence screening- which in many offices
can occur in open cubicles or public spaces-may not facilitate disclosure
of domestic violence, as clients may fear being overheard.

The difficulty of identifying domestic violence is compounded by a lack of
consensus about the best techniques for screening clients. Some state
officials and researchers reported the benefit of screening tools composed
of multiple questions asking about various aspects of domestic violence-
such as physical abuse, verbal abuse, or stalking. They believe such an
approach helps clients who may not think of themselves as domestic
violence victims and yet may respond affirmatively to a question about a
specific behavior. On the other hand, some research has found that
detailed questions about specific aspects of domestic violence may be
considered overly intrusive, which can put clients on the defensive and
make disclosure less likely. A 1999 study on the state TANF programs'
efforts to assist victims of domestic violence found that screening
instruments should avoid intrusive questions about the specific actions of
an abuser, as such questions can be too personal or shaming.6

Federal TANF Funds May Be Used to Fund Marriage and Responsible Fatherhood
Programs

Because the TANF program includes a variety of goals, federal TANF funds
can be used for purposes other than cash assistance to needy families.
Because one of the purposes of the TANF program is to encourage the
formation and maintenance of two-parent families, some states have opted
to use TANF funds for marriage programs. Such programs attempt to achieve
these goals through various measures, such as education. Similarly, some
states have opted to use TANF funds for responsible fatherhood programs.
These programs are designed to encourage the active and responsible
involvement of non-custodial fathers in the lives of their children.

State officials, practitioners, and the domestic violence services
community have stressed the importance of involving the domestic violence
services community in development and implementation of marriage and
responsible fatherhood programs. States that have used this approach have
indicated that the involvement of the domestic violence services community
was necessary to ensure that marriage and responsible fatherhood programs
address individual safety. HHS Administration for Children and Families
has echoed this sentiment in an information memorandum that strongly
recommends that states consult with experts in domestic violence or with
relevant community domestic violence coalitions as they design marriage
initiatives. Further, HHS has

6Jody Raphael and Sheila Haennicke, Keeping Battered Women Safe through
the Welfare to Work Journey: How Are We Doing? Taylor Institute (September
1999).

  Most States Have Adopted the Family Violence Option, and States' TANF Programs
  Take Differing Approaches to Screening for Domestic Violence

stated that its Healthy Marriage Initiative--which seeks to promote
healthy marriages though activities such as marriage and pre-marriage
education-requires grantees to develop domestic violence protocols that
address screening for domestic violence and referrals to local domestic
violence services.

While the large majority of states have adopted the Family Violence Option
or a comparable policy, states take a broad range of approaches to
identifying domestic violence. Most states require that clients be
formally screened for domestic violence, though techniques can vary
significantly from state to state. A few states do not actively screen,
but require that clients be notified of available domestic violence
waivers. Comparatively few states have policies regarding the privacy of
screening, although officials in most states we contacted acknowledged its
importance. Finally, most states reported that domestic violence screening
is performed by staff that may have little or no training in recognizing
and discussing domestic violence. To address this issue, some states have
employed domestic violence specialists.

Most States Have Adopted Forty states have certified adoption of the
Family Violence Option (see the Family Violence Option fig. 2). Eight
states reported that they had not certified the Family Violence or an
Equivalent Policy Option, but had adopted similar policies. Each of these
states reported

that they make some effort to screen clients for domestic violence, refer

clients to domestic violence services, and offer waivers of certain TANF

program requirements.

Figure 2: States' Status Regarding Adoption of the Family Violence Option
or a Comparable Policy

Source: GAO survey.

Officials in only three states-Maine, Oklahoma, and Ohio-reported that
they had not adopted the Family Violence Option or a comparable policy.
According to Oklahoma officials, adoption of the Family Violence Option
was not seen as necessary because the state already required some of the
actions called for by the Family Violence Option, though the provisions
may not be precisely comparable.

States Take a Broad Range of Approaches to Screening for Domestic Violence

Formal Screening at Specified Times

States screen for domestic violence using a broad range of strategies and
techniques.7 Some require that staff use formal screening tools at
specific points in the TANF process. Such tools vary in detail and depth
of inquiry. Five states notify clients of domestic violence waivers, but
do not require that staff specifically inquire about domestic violence. In
addition, state TANF program staff can at any time also use informal
domestic violence screening techniques, such as observing a client's
demeanor or interaction with their partner.

Officials in the large majority of states (43) reported that their state
actively inquires about domestic violence, and most of these states rely
on a mandatory screening tool. Specifically, 26 states responding to our
survey reported that they provide local offices with a specific screening
tool that must be used, while another 4 said the tool they provide is
optional. Eight states reported that they provide staff with guidance such
as regulations, staff manuals, or memoranda, in lieu of a specific
screening tool.

We learned during our visits to states that the breadth and technique of
the screening tools vary considerably. For example, the state of
Washington uses a nine-question, electronic screening tool that prompts
TANF staff to inquire about various aspects of domestic violence,
including queries about threats, angry outbursts or controlling behavior
by the client's partner. This screening tool is administered by case
managers, who generally go through these questions verbatim, and record
the client's responses in a data base. In contrast, the state of Iowa uses
a tool designed to be self-administered by the client that makes a single
query about sexual or physical violence in a table that covers a variety
of health related issues. This tool does not ask specific or probing
questions about domestic violence, but prompts the client to enter a
checkmark if physical or sexual violence is an issue for any member of the
client's family.

The large majority of states that require formal screening require it
early in the TANF process, with follow-up screenings at certain points. As
figure 3 indicates, subsequent screenings occur either at regular
intervals, or when it becomes apparent that a client is having difficulty
meeting program requirements. For example, our survey data show that 24
states screen

7In our survey of the states, we defined "screening" as a technique used
by local TANF office staff to identify domestic violence victims.
Techniques may include a single question, investigative interviewing, or
use of a detailed questionnaire.

during a TANF eligibility review that in some states, such as New York,
can take place every 6 months. Many states also screen when the client
exhibits difficulty in meeting TANF program goals or requirements. For
example, 20 states screen when a client fails to meet the conditions of
cash assistance. State officials told us that such follow-up screenings
are important because the client may be reluctant to disclose domestic
violence initially or because it may emerge as a problem after entry into
the TANF program.

Figure 3: Number of States Requiring Follow-up Domestic Violence Screening
at Specific Points in the TANF Process

                              Number of states 50

                                       45

                                       40

                                       35

                                       33

                                       30

                                       25

                                       20

                                       15

                                      10 5

                                       0

Eligibility reveiwviolence suspected

                                    Domestic

Time limitapproachesof cash assistance

                                     Other

Source: GAO survey.

Note: States could report more than one point in the process; therefore,
numbers do not total to 48.

Notification Only	Five states that have adopted the Family Violence Option
or a comparable policy reported that they do not actively screen TANF
clients for domestic violence. These states indicated that they have no
screening requirements beyond informing clients about available domestic
violence waivers. An official of one such state-Pennsylvania-referred to
this process as "universal notification" and explained that the policy was
developed in

Informal Screening throughout TANF Process

consultation with the state coalition that advocates for domestic violence
victims. The policy was developed in the belief that it is best not to
probe clients about domestic violence and risk putting them in an
uncomfortable situation, but to spell out the program flexibilities that
exist for domestic violence victims. This policy allows domestic violence
victims to disclose, if necessary, at a time of their choosing.

Staff in local TANF offices can also conduct "informal" screening through
casually conversing with or observing clients. For example, a client's
demeanor or physical appearance may provide evidence of domestic violence.
Several officials told us that such informal screening can occur at any
time in the TANF process and is especially important because a client may
not be ready to disclose a domestic violence situation at the time of
formal screening, and because a domestic violence situation may arise
after the formal screening. For example, caseworkers and other officials
in Wisconsin told us that disclosure of domestic violence often occurred
in the course of informal discussions and consultations between clients
and staff.

Fewer Than Half of States Reported Having Policies Regarding Privacy for
Screening

Sixteen states reported that they have established policies regarding the
physical setting in which screenings occur. For example, Colorado
officials explained that, while screening will often begin in open
cubicles, the state's policy is that the meeting will be moved to a
private office if a situation of domestic violence has been identified.

In our visits to TANF offices in seven other states, we learned that
screening often occurs in the course of much broader discussions that
occur in open cubicles near staff and other clients.8 During our site
visits, several state officials told us that although private,
confidential settings are important, many local offices would face
constraints in providing such settings. For example, an official in one
state said that the degree of privacy available varies considerably from
office to office, and the setting in some offices dictates that screening
take place at desks near a lobby full of clients. While this is not ideal,
the local offices must work within the constraints of the facilities in
which they are located.

8In some states we visited, domestic violence screening takes place in the
course of a much broader conversation that can cover issues such as the
clients educational and employment history, the client's family situation,
and TANF rules and regulations.

Ten states said that they have policies regarding individuals who may be
present during screening. For example, officials in the state of
Washington told us that, if a couple comes in to the TANF office to apply
for benefits together, it is state policy that they be separated before
domestic violence will be discussed. According to the Washington "Work
First" handbook, which provides written guidance for caseworkers and other
staff in the state's TANF program, caseworkers are not to ask about family
violence in the presence of the partner, because this may endanger the
client. Similarly, the screening tool used in Illinois advises caseworkers
to ask questions regarding domestic violence at a later time if the
client's partner is present. We also found that, although some states do
not have policies in this regard, some caseworkers in these states
nonetheless ensure a client is alone for domestic violence screening. A
local office official in New York, which does not have a privacy policy,
said that before questions about domestic violence are asked, they will
separate couples with a contrived reason, if necessary. For example, they
may tell the partner that he must meet with another staff member about
another topic, such as his job history.

In contrast, most states have no explicit policy about who can be present
during a client's domestic violence screening. For example, an official at
a local office in Iowa said that the initial meeting with the caseworker
takes place with both partners present because it is important to see how
a couple interacts. If the caseworker suspects domestic violence, they may
try to separate the couple for a subsequent discussion. Other states
explained that they encourage a middle approach, explicitly relying on the
judgment of the caseworker. Similarly, in New York, state policy directs
that the domestic violence screening form can be mentioned with both
partners present, but that it not be addressed further if the clients are
not interested. However, the policy also advises that caseworkers may need
to be creative in finding a way to mention the domestic violence screening
form again in a private setting.

Screening Is Typically
Performed by
Caseworkers,
but Some States also Use
Domestic Violence
Specialists

Forty-five states reported that caseworkers or intake workers are the
staff that typically conduct domestic violence screening, a fact
acknowledged by officials during our site visits.9 As figure 4 indicates,
most state policies require little training for these staff. Twenty states
indicated that the state either had no policy regarding domestic
violence-related training, or may provide training only once in
caseworker's career. Another 25 states require training once in a staff
members' career and make additional training optional.

Figure 4: Number of States with Particular Policies Regarding Frequency of
Domestic Violence Training

At special intervals

Once in career

No state requirement

Once in careeradditional optional Source: GAO survey.

Officials in each state we visited told us that the skills, abilities, and
inclinations of staff to conduct domestic violence screening vary
considerably. For example, one state official told us that the
personalities and style of caseworkers range across the board. This
official said that many staff are technical people who have spent their
careers stressing program qualifications, and addressing domestic violence
and other "soft" issues is difficult adjustment. An official of another
state TANF program

9In our survey, states were able to indicate more than one type of staff
"typically" conducts domestic violence screening.

said that even with the best of best training and screening policies,
screening effectiveness is dependent on the effectiveness of individual
caseworkers, and some caseworkers may simply skim the screening questions
and not ask the full range. These comments were reinforced during our
observations of domestic violence screening in several local TANF offices.
At one office, we observed one caseworker who stressed certain aspects of
the TANF experience, such as the need to obtain employment or attend
training services, but gave very peremptory attention to other issues,
such as domestic violence and mental health. At another office, we
witnessed screening performed by a social worker, who paused at length
over these issues, and sensitively asked follow-up questions regarding the
client's home life, and took the initiative to gently and patiently
describe a local organization that could provide alternative living
arrangements, if this were necessary.

In order to supplement the skills of the caseworkers, three of the states
we visited-Georgia, New York, and Washington-employed domestic violence
specialists to conduct in-depth screening and assessment after a client
disclosed that domestic violence was an issue.10 This practice is
implemented statewide in Georgia and New York, and has been established
for almost all of the TANF offices in Washington state. In all three
states, the domestic violence specialist serves to "backup" the screening
conducted by the regular caseworker. For example, New York's policy
requires that a client be referred to a specialist-known as a domestic
violence liaison-as soon as a client discloses that domestic violence is
an issue. State officials told us that the meeting with the specialist is
scheduled as soon as possible and all further inquiry regarding domestic
violence is left to the domestic violence liaison. The specialist then
conducts a more in-depth inquiry and informs clients about options for
protective services and other assistance.

State officials told us that domestic violence specialists can play an
important role in addressing the needs of domestic violence victims and
are important given the limited skills of many caseworkers in dealing with
domestic violence. Officials in Washington, for example, said that the
presence of a domestic violence specialist increases the likelihood that a
domestic violence victim will attend counseling or other services to

10Because our survey did not include questions about domestic violence
specialists, we do not know how many states employ such specialists in
TANF offices. However, a 1999 report on domestic violence and the TANF
program-Raphael and Haennicke-indicates that this practice is used by
other states as well.

address the problem. A caseworker can immediately walk a client over to
the desk of the domestic violence specialist, who then conducts an indepth
assessment, provides some degree of counseling, and makes referrals to
other agencies for ongoing services. They explained that if the domestic
violence specialist were not there, they believe that many clients would
ignore the referrals to outside agencies, and the domestic violence issue
festers. During one of our site visits, we learned firsthand of the
importance of effective interpersonal skills in domestic violence
screening. We interviewed an employee of a local TANF office who was a
former TANF recipient and a domestic violence victim. She explained that,
when she was screened for domestic violence, she was in a desperate
situation fleeing from her abuser and needed assistance right away.
Nonetheless, the attitude of the screening staff was so perfunctory and
indifferent that, had she not immediately been routed to a domestic
violence specialist, she said she probably would not have returned to that
office. The former victim further noted that many caseworkers are
overwhelmed by other demands, and felt that the caseworker she dealt with
was not equipped to handle domestic violence issues.

State officials also told us that domestic violence specialists can
enhance the ability of other office staff in dealing with clients'
domestic violence issues. In Washington, caseworkers at a local TANF
office stated that an onsite domestic violence specialist serves as an
important source of technical assistance for caseworkers. For example, the
specialist has provided training for staff, and made them aware of the
"red flags" that may indicate domestic violence is an issue. The officials
repeatedly praised the domestic violence specialist for this "cultural"
impact on this TANF office.

HHS Has Taken Some Steps to Provide States with Guidance on Domestic
Violence Screening

HHS has, since the establishment of the TANF program, taken a number of
measures to identify and disseminate information on what states are doing
to screen for domestic violence. For example, HHS funded a 1999 report
that summarized how states had implemented the Family Violence Option,
including the basic techniques each state used to screen for domestic
violence, and a number of detailed examples of how domestic violence
screening was conducted at specific locations. 11 Further, an HHS-funded
report published in 2000 provided in-depth descriptions how 7 counties in
different states identified domestic violence victims and assisted those

11Raphael and Haennicke.

who disclosed.12 These reports also made observations regarding the
benefits and drawbacks of various screening practices. For example, the
report published in 2000 noted the usefulness of a more extensive domestic
violence screening tool-covering verbal, emotional, and sexual abuse-that
could be used once a worker has some indication that a client may have
domestic violence issues.

Although HHS has funded research on state TANF program approaches to
domestic violence screening, HHS officials also told us that the agency
has not provided state TANF programs with specific advice in the form of
policy guidance or memoranda regarding best practices in domestic violence
screening. Further, it has not specified minimal acceptable standards for
domestic violence screening. Agency officials explained that the
legislation establishing the TANF program gives states considerable
flexibility in implementing the Family Violence Option, and does not
provide HHS with authority to require particular approaches to screening.

State TANF programs play an important role by offering victims of domestic
violence waivers from TANF program requirements and helping them obtain
needed services. Although most states will waive certain TANF
requirements, the provisions of these waivers vary from state to state.
Further, limited data from two states that we visited indicates that a
comparatively small portion of all TANF recipients obtain domestic
violence waivers. Although all state TANF offices rely on local service
agencies to provide domestic violence services, some also provide inhouse
domestic violence services and most actively monitor clients for
participation in services. While the full range of services is generally
available to victims in urban areas, services in rural areas are generally
less available.

  To Address the Needs of Victims of Domestic Violence, Most States Use Waivers
  and Refer Clients to Local Service Providers

Most States Waive Requirements for Work, Time Limits, and Child Support

Of the 48 states that adopted the Family Violence Option or an equivalent
policy, the majority will waive the requirement that TANF clients work or
engage in work-related activities, the 5-year federal lifetime limit on
TANF benefits, and cooperation with the child support authorities to
collect child support, as shown in table 1.

12Martha R. Burt, Janine M. Sweig, and Kathryn A. Schlichter, Strategies
for Addressing the Needs of Domestic Violence Victims within the TANF
Program (Urban Institute, June 2000).

                Table 1: Number of States That Grant FVO Waivers

Number of states Federal or state TANF requirement granting waivers

                                Work requirement

Time limit for cash assistance

Cooperation with child support authorities

Required aspects of individual personal plan

Other

Source: GAO survey.

Some states will waive other requirements as well. Thirty-eight states
indicated that they will waive specific requirements included in a
client's individual responsibility plan, which is intended to lead to work
and financial independence. For example, an Illinois official told us that
the individual plan of many clients requires them to meet with their
caseworker in order to continue receiving benefits. If a client misses a
meeting and can demonstrate that the failure to make the appointment was
due to domestic violence, the requirement can be temporarily waived and
cash benefits will not be interrupted. Another six states reported that
they will, if necessary, waive other program requirements in the event
that domestic violence makes them difficult to meet. For example, an
Oregon official reported that they will waive certain financial
eligibility requirements in the event of domestic violence. For example,
if a domestic violence victim must use part of her income to flee an
abuser and pay for temporary housing, this portion of the income will be
temporarily excluded from eligibility and benefit calculations.

Conditions for Receiving Waivers Varied by State

Federal TANF regulations allow states considerable flexibility regarding
the conditions for clients to obtain good cause domestic violence waivers.
For example, some states reported that they required recipients to provide
evidence of domestic violence before granting a waiver, while others
reported that the client's word was sufficient. As table 2 indicates, 25
states do not require evidence beyond a client's statement in order to
grant a waiver from work requirements. For example, a Washington official
said that additional evidence before granting a waiver was not needed
because officials expect clients to participate in domestic violence
services, which clients would not want to do unless such services are
needed. In contrast, Illinois requires that recipients provide additional
documentation such as a written statement from a third party, a police
report, or documentation from a domestic or sexual violence program.

Table 2: Number of States and Evidence Required for a Waiver to Be Granted

                                    Requests but does                  
                                          not require         Requires 
                            Requires documentation in documentation in 
                  Domestic only a client addition to  addition to the   Total 
                           the                                         
           violence waiver statement client statement client statement states 
                      Work                      10 15               18 
               requirement                                             
            Time limit for                                             
           cash assistance                       8 11               24 
          Cooperation with                                             
             child support                                             
               authorities                       5 18               23 

Source: GAO survey.

Twenty-seven states reported that they also require domestic violence
victims to participate in domestic violence services in order to waive
program requirements. For example, officials in Iowa and Washington said
that clients must demonstrate that they are making an effort to address
the domestic violence by attending counseling or other services. In
contrast, an Illinois official explained that the state also requires that
caseworkers provide waiver recipients with information about available
domestic violence services and encourage them to attend; however, they
cannot require their participation. Officials said that some clients do
not want to participate in services provided through an agency but prefer
to use an informal network for support and assistance such as family,
friends, or church ministers.

Some states may also tailor waivers to fit a client's particular
circumstances and will help clients maximize compliance with program
requirements. For example, New York offers "partial waivers," which state
officials believe help to ensure a victim's safety while still
participating in program activities. For example, a partial waiver could
be granted to a client who is taking job readiness classes but not
actively searching for a job because of safety concerns. In such a case,
the partial waiver would allow the client to fulfill part of the work
requirement without interrupting cash benefits. Similarly, a partial child
support waiver would be granted if it would put the client in danger to
appear in court to pursue child support (this is in contrast to a full
child support waiver in which a client would not be required to pursue
child support at all if doing so would threaten their safety).

Limited Data Indicates That a Small Portion of the TANF Population Use
Domestic Violence Waivers

Reliable national data on the number of domestic violence waivers issued
by the states does not exist, according to an HHS official responsible for
tracking state data reporting.13 During our site visits, some of the eight
states were able to provide data on domestic violence waivers from the
work requirement. For example, Georgia officials reported that from July
2003 through June 2004, local TANF offices in Georgia granted 925 waivers
from the work requirement, which was less than 2 percent of the 52,515
clients who were receiving TANF benefits during that time. In contrast,
Washington officials reported that from October 2003 through September
2004, local TANF offices in Washington granted 5,162 waivers from the work
requirement, more than 9 percent of the 52,515 clients receiving TANF
benefits.

The number of waivers granted in some states may be relatively small
because clients may opt out of TANF requirements in other ways or because
domestic violence victims can comply despite their situation. For example,
some domestic violence victims may face multiple barriers and could obtain
a state "hardship" waiver that will extend the 5-year time limit without
coding it as a domestic violence waiver. Officials in most states that we
visited said that many victims prefer to work because they consider
financial independence as the best way out of an abusive situation. For
example, a caseworker in Colorado who works exclusively with domestic
violence victims said that she rarely grants a waiver for the work
requirement because most clients want to work, and even if they only work
part-time, the participation in domestic violence services is included in
the work plan as a work activity. She said that she only grants a waiver
from work requirements to individuals that are in such a critical
situation that they can only deal with their domestic violence issues.
Officials in New York also said that most domestic violence victims prefer
to work but that many also participate in the domestic violence services
that are offered.

13Federal regulations applicable to the TANF program do not require states
to report the number of domestic violence waivers granted, unless a state
is seeking penalty relief.

Clients May Be Referred to Outside Service Providers or in Some Cases
Obtain In-House Services, but Degree of Monitoring and Service
Availability Varies

While all states reported that clients are referred to separate local
agencies for domestic violence services such as counseling, some offices
also offer such services in-house. During our site visits, some states
reported that the availability of services varied, with some states
reporting that domestic violence services were less available in rural
areas. Further, some states appear to be more active than others in
monitoring the progress of clients who obtain domestic violence services.

Thirty-eight states reported that their local TANF offices relied
exclusively on separate local agencies to provide services to their
domestic violence clients. These services generally include counseling,
crisis intervention, safety planning, support groups, legal and court
advocacy, and emergency shelter. In contrast, 13 states reported that they
provided some domestic violence services on-site in the local TANF office
in addition to using separate local agencies. For example, officials in
Washington said that most of the state's local TANF offices have a
Domestic Violence Advocate (DVA) on-site who works exclusively with
domestic violence victims providing services such as safety planning and
counseling. The benefit of having this service located on-site is that it
gives the victim immediate access to services, and increases the chances
that the clients will follow through with services. Also, because the DVA
is located at the TANF office, the client may receive services without the
knowledge of the abuser. For other domestic violence services, such as
shelter and legal advocacy, clients were referred to a separate local
service provider.

The kind of services offered to domestic violence victims is determined by
their need and the availability of such services in the community.
However, among the states that we visited, we found that the kinds of
services available varied-urban areas generally provided a full range of
services, while services in rural areas were less available. For example,
a Colorado official cited one area of the state that had only one shelter
serving five counties and officials in one rural county expressed a need
for more counseling services. New York officials also said that services
were less available in rural areas, but that it was simply not
cost-effective to have a full range of services in sparsely populated
areas. In addition, officials in several states that we visited said that
transportation is less available in the rural areas and access to services
can be difficult for victims living many miles from the nearest provider.
For example, officials in a rural office in Oklahoma said that the shelter
serving their clients was 26 miles away and that caseworkers often have to
call the local police to transport domestic violence victims that are
unable to transport themselves.

  Most States Used Federal TANF Funds for Marriage or Responsible Fatherhood
  Programs, but Take Differing Approaches to Addressing Domestic Violence

While most states required that local TANF offices monitor client
participation and progress when referred for these services, some states
more actively monitor a client's progress. In responding to our survey, 29
states reported that, in some or all cases, clients referred to a domestic
violence service provider must be monitored for progress. For example,
Washington officials said that communication with providers is required
monthly to monitor clients' progress so that they can determine when they
are able to move into work activities that will allow them to become
selfsufficient. In contrast, 16 states indicated that they had no such
policy. For example, New York officials said that they discourage
communication between the TANF office and the domestic violence service
agency. An official explained that the providers, who operate
independently, want to maintain confidentiality to ensure the victim's
safety.

Thirty-one states reported using federal TANF funds for marriage or
responsible fatherhood programs, and limited research indicates that such
programs generally do not specifically address domestic violence. States
that reported funding marriage programs most frequently supported adult
and youth marriage and education programs. States that reported funding
responsible fatherhood programs most frequently supported programs that
deliver services to non-custodial fathers to enhance ability to meet
parental obligations. Data show that a relatively small portion of TANF
funds were used for marriage programs in 7 states and responsible
fatherhood programs in 21 states. While research indicates that these
programs do not explicitly address the issue of domestic violence, they
may nonetheless do so by emphasizing better communications and healthy
relationships, and constructive techniques for dispute resolution. Debate
exists as to the best approaches for marriage and responsible fatherhood
programs to address domestic violence.

Most States Used Federal Thirty-one states reported using TANF funds for
marriage programs, TANF Dollars to Fund responsible fatherhood programs,
or both in the last 3 years. Specifically, Marriage or Responsible 15
states reported funding marriage programs, and 28 states reported

funding responsible fatherhood programs from 2002 to 2004. Of these,
12Fatherhood Programs in states reported funding both marriage and
responsible fatherhoodthe Last 3 Years programs. See figure 5.

Figure 5: States Using Federal TANF Dollars to Fund Marriage and
Responsible Fatherhood Programs

Source: GAO survey.

States that funded marriage and responsible fatherhood programs with TANF
dollars in the last 3 years reported supporting various types of efforts.
Most frequently, states that funded marriage programs with TANF dollars in
the last 3 years reported funding adult and youth relationship

and marriage education programs. Such programs are generally based on a
standard curriculum, presented in a classroom-style format, and attempt to
change attitudes and dispel myths about marriage and to teach relationship
skills. For example, the Oklahoma Marriage Initiative works to improve
relationships through services that provide skill-based relationship
training. Workshop leaders are trained to teach Prevention and
Relationship Enhancement Program (PREP) courses, which are designed to
prevent divorce and enhance marriage, in their communities and
organizations across the states. Most workshops are voluntary and
participants learn about the program through the Internet, referrals, word
of mouth, local advertising, and churches. One local TANF office required
participants to attend PREP or PREP-like courses. Similarly, youth
marriage education programs can be taught using one of several nationally
recognized curricula for building successful relationships and marriages.
Several states also reported funding activities such as media campaigns
and conferences relating to marriage.

States that supported responsible fatherhood programs using TANF dollars
in the last 3 years typically funded collaborative fatherhood programs
between government and private agencies or funded direct services to
non-custodial fathers to enhance their ability to meet parental
obligations. We visited one state-Georgia-that has fatherhood programs in
both these categories. These programs were initiated by the Director of
the Division of Family and Children Services, who believed some fathers
were not "deadbeats but dead broke" and appointed a special consultant to
develop fatherhood programs. Georgia's Fatherhood Program is a partnership
with several state agencies and other organizations. The program's mission
is to assist non-custodial parents in training and educational
opportunities leading to employment paying above minimum wage and
encouraging increased involvement in the lives of their children. The
program contracts with the Georgia Department of Technical and Adult
Education to provide job skills and placements for unemployed or
underemployed non-custodial parents. Georgia's other responsible
fatherhood program, the Child Access and Visitation Program, is designed
to assist non-custodial parents with improving visitation with their
children and addressing the children's relationship with the custodial
parent. This program is run through a contract with an outside service
provider and funded through a grant from HHS' Administration for Children
and Families.

Two states that reported not using federal TANF funds for marriage
programs told us that they address factors that cause stress in marriages
without implementing marriage programs. For example, Illinois chose to

emphasize direct support for low-income families by providing material
support, such as childcare, transportation, and cash assistance rather
than implementing marriage programs. An Illinois official also noted that
a key variable in successfully promoting marriage was increasing the
economic status of the couple so that they feel marriage is a viable
alternative. New Jersey also reported in its survey that the state funded
programs that address factors that can cause stress in marriages, as well
as efforts that indirectly promote and preserve marriage.

Limited Data Suggest States Use Small Amounts of Federal TANF Funds for
Marriage and Responsible Fatherhood Programs and Some Rely on Other
Funding Sources

States that reported using federal TANF funds for marriage or responsible
fatherhood programs did not report using a large proportion of their total
federal TANF budget for this purpose. Specifically, no state providing
usable data reported spending more than about 5 percent of its total
federal TANF expenditures on marriage or responsible fatherhood programs
for 2002 or 2003.14 While according to HHS officials more complete
national data does not exist, a Congressional Research Service report also
found that states were not spending large portions of TANF funds on
marriage programs.15 Similarly, according to another report, states spend
relatively small amounts of TANF funds on responsible fatherhood
programs.16

Some states reported that they fund marriage and responsible fatherhood
programs with funding sources other than federal TANF dollars. Five states
in survey commentary17 and one state in a site visit indicated that that
they fund marriage programs with monies other than federal TANF

14States were asked in the survey to provide data for a 3-year period,
2002-2004. However, 2004 data was determined to be unusable because there
were numerous notes indicating that data were not available or states
supplied obligated figures rather than expenditures. State data were
determined usable if no participant notes accompanied the survey response
explaining why data did not conform to our question parameters and if data
were not the same dollar amount for all 3 years except in cases where a
follow-up call confirmed that the expenditures were accurate. Five states
reported usable marriage program data for 2002 and six states for 2003.
Seventeen states reported usable fatherhood program data for 2002 and 20
states for 2003.

15Welfare Reform: How TANF Addressed Family Structure (Washington, D.C.:
Congressional Research Service, Apr. 15, 2003).

16Kathleen Sylvester and Kathleen Reich, Making Fathers Count: Assessing
the Progress of Responsible Fatherhood Efforts (Washington, D.C.: Social
Policy Network, 2002).

17These are additional, voluntary survey comments.

funds. 18 Two additional states indicated that they currently fund
programs with distinct marriage components, but they did not consider them
marriage programs per se.19 A Georgia official told us that the state will
soon be implementing a marriage program similar to the Oklahoma Marriage
Initiative. The program will use an ACF grant under the authority of
section 1115 of the Social Security Act and private funding rather than
federal TANF funds. Furthermore, since state fiscal year 2004, eight
states indicated in survey responses or during our site visit that they
are implementing or developing new marriage programs that may or may not
use federal TANF funds.20

Similarly, some states are supporting responsible fatherhood programs
through other means. For example, some states also support responsible
fatherhood programs with monies other than federal TANF funds.21 The state
of Washington collaborated with Alaska and Oregon using non-TANF funds to
create public service videos to encourage fathers to be involved with
their children. One national fatherhood report also indicated that
responsible fatherhood programs remain largely funded through foundations.

18Colorado, Florida, Idaho, North Carolina, and Utah reported in survey
comments and Georgia in a site visit using other funding sources for
marriage programs. Examples of funding sources reported included non-TANF
grants, Title IV-B of the Social Security Act funds, private funds, and
child support funds.

19Two states, South Carolina and Virginia, indicated in survey comments
that they funded programs that they do not consider marriage programs per
se. For example, Virginia funded an initiative to reduce the number of
out-of-wedlock births among young adults. Programs focused on
relationships and marriage, discouraging risky sexual behavior, and
promoting waiting until marriage to have children.

20These states are Alaska, Delaware, Georgia, Kansas, Kentucky,
Mississippi, Texas, and West Virginia. Seven of these states that did not
previously fund marriage programs and one, Mississippi, is implementing a
new marriage program, but was already funding existing programs.

21Six states-Colorado, Florida, Georgia, Massachusetts, North Carolina,
and Washington- stated in survey comments or an interview that they funded
responsible fatherhood programs with other sources such as Social Services
Block Grant funds, Title IV-B and D of the Social Security Act funds,
child support collection incentive funds, and state general fund monies.

Generally, Marriage and Fatherhood Programs Do Not Explicitly Address
Domestic Violence

According to research and practitioners in the field of marriage and
responsible fatherhood, domestic violence is generally not explicitly
included as a component of marriage and responsible fatherhood programs.
Recent research funded by HHS found that many of the widely available
marriage education programs were designed and tested with middle income,
college-educated couples, and do not assess for or address a variety of
issues-including domestic violence-that place considerable stress on
couple relationships.22 A researcher in the field of marriage programs
stated that such programs do not address domestic violence because
marriage education is an emerging field and developers did not initially
see the need for discussion of domestic violence within these programs.
Similarly, two representatives of national fatherhood advocacy
organizations indicated that most responsible fatherhood programs have not
addressed domestic violence or lack the resources to deal with domestic
violence. Furthermore, one found that this was because practitioners in
responsible fatherhood programs usually do not have expertise in domestic
violence issues.

Nonetheless, some marriage and responsible fatherhood programs do address
domestic violence implicitly through an emphasis on healthy, egalitarian
relationships and constructive conflict resolution. For example, the
Oklahoma Marriage Initiative program focuses on communication and conflict
resolution between couples without an explicit discussion of domestic
violence. The Oklahoma program covers danger signs of marital problems,
such as negative communication habits that can escalate into anger and
frustration, a pattern of constantly putting down or disregarding the
thoughts and feelings of a partner, or a habit of negative interpretations
of the actions and comments of a partner.

There is a range of opinions on how marriage and responsible fatherhood
programs should address domestic violence. Some state officials indicated
that marriage programs that address domestic violence through an emphasis
on healthy relationships and conflict resolution alone can reduce and help
prevent violence in marriages by reducing the stress that often leads to
violence. For example, New York indicated that programs designed to
encourage healthy relationships will have the positive benefit of reducing
the likelihood of physical violence and emotional abuse. Some
practitioners have noted the need to address domestic violence explicitly

22M. Robin Dion and Barbara Devaney, Strengthening Relationships and
Supporting Healthy Marriages among Unwed Parents (Mathematica Policy
Research, Inc.; Apr. 2003).

and have begun to take steps toward explicitly including domestic violence
in marriage programs and have sought program advice from local domestic
violence coalitions. For example, while the Oklahoma Marriage Initiative
does not explicitly cover domestic violence in its marriage curriculum, it
recently created a handout to assist clients in identifying domestic
violence and where to obtain help.

Nonetheless, other evidence suggests that domestic violence should be
explicitly addressed in marriage and responsible fatherhood programs. The
HHS-funded research on marriage and responsible fatherhood programs found,
for example, that many unmarried parents face a variety of challenges that
may impede their ability to form a stable marriage. It further states that
assessment of barriers-in particular domestic violence-could point out the
need for referral to other kinds of appropriate help. State officials and
advocates told us that addressing domestic violence specifically is
important to ensuring that programs address the dangers of domestic
violence. Further, HHS has stated that all future projects funded by its
Healthy Marriage Initiative--which seeks to promote healthy marriages
through activities such as marriage and premarriage education-are to fully
incorporate domestic violence protections, including project specific
policies regarding screening for domestic violence.

Conclusions 	The TANF program emphasizes that recipients move toward
economic self-sufficiency, but also recognizes that some recipients may
face barriers that may make it difficult or impossible for them to work
immediately, or meet specific timelines for attaining self-sufficiency.
One of these provisions-the Family Violence Option-requires states that
adopt it to screen clients for domestic violence, and offer other
assistance to those who need it in overcoming this potential barrier to
self-sufficiency. The Family Violence Option offers states considerable
flexibility in how they screen for domestic violence, and states have
taken a range of approaches to doing so. While this flexibility is
consistent with the overall TANF emphasis on allowing states latitude in
designing and administering their programs, guidance on effective
approaches to domestic violence screening could provide states with
additional information on promising screening practices.

Specifically, there may be certain practices that could benefit all state
programs, assuming they are affordable and practicable. For example, in
the states we visited, domestic violence specialists appear to offer
multiple benefits to local TANF offices, including offering greater
expertise and

more refined skills in dealing with extremely personal issues than is
typical of many caseworkers. This is especially important, given the
limited domestic violence training and varying levels of skills and
abilities among the caseworkers. Some states also appear, more than
others, to stress privacy in conducting domestic violence screening.
Although HHS has taken a number of actions to provide states with
information about approaches to screening, it has not identified and
encouraged the adoption of certain best practices through official
guidance or memoranda.

We recommend that the Secretary of the Department of Health and Human
Services:

o  	examine current domestic violence screening practices of states, and
determine whether certain practices-such as employing and training, where
possible, domestic violence specialists-are particularly promising
approaches to screening for domestic violence, and

o  	provide states with information on these practices, and, through
agency guidance or memoranda, encourage their adoption.

  Recommendations for Executive Action

                                Agency Comments
                               and Our Evaluation

We provided a draft of this report to HHS for its review. Overall, HHS
agreed with the report's findings and provided some comments on the
report's conclusions and recommendations. Regarding the report's
conclusions, HHS correctly states that there is a lack of consensus among
domestic violence services professionals about the best techniques for
screening clients and that it would be reluctant to advocate particular
screening approaches over others. It further states that its regulatory
authority is limited in this and many other areas of the program. We agree
that there is no documented consensus about which screening practices are
the most effective and, consistent with current TANF regulations, state
programs should retain flexibility in designing the approaches they
believe are most effective. However, we believe that there may be some
practices that are sufficiently promising that all states should be made
fully aware of their merits, so that they can choose to adopt them if
practicable. While some of these promising practices might not be
applicable in each and every situation, we continue to believe that state
TANF programs would benefit from HHS guidance on the advantages and
limitations associated with particular promising practices. Further, HHS'
advocacy of these practices would continue to allow state TANF programs
and local TANF offices to retain the flexibility and latitude to select
approaches that best meet the needs of their programs. We have revised our
conclusions and recommendations to more clearly suggest that HHS should
make

information on promising screening approaches available to states and to
encourage their adoption.

HHS also provided technical comments on the draft report, which we have
incorporated where appropriate. HHS' entire comments are reproduced in
appendix II.

As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the
date of this letter. At that time, we will send copies to interested
congressional committees and Members, and the Secretary of Health and
Human Services. We will also make copies available to others upon
request. In addition, our report will be available at no charge on GAO's
Web site at http://www.gao.gov.

Contact points for our Office of Congressional Relations and Office Pubic
Affairs may be found on the last page of this report. GAO staff who made
major contributions to this report are listed in appendix III.

David Bellis, Director
Education, Workforce, and Income Security Issues

Appendix I: Objectives, Scope, and Methodology

The objectives of this report were to determine (1) what states are doing
to identify victims of domestic violence among Temporary Assistance for
Needy Families (TANF) recipients, (2) what states are doing to address
domestic violence among TANF recipients once they have been identified,
and (3) the extent to which states are spending TANF funds on marriage and
responsible fatherhood programs, and how, if at all, these programs are
addressing domestic violence.

To address each of these objectives, we:

o  	conducted a survey of the TANF agencies in all 50 states and the
District of Columbia;1

o  	conducted site visits to state TANF agencies and local TANF service
delivery offices in 8 states; and

o  	interviewed researchers and representatives of national organizations
with expertise in the issues of TANF and domestic violence, as well as
marriage and fatherhood programs.

More detailed information on each of these aspects of our research is
presented below. We conducted our work in accordance with generally
accepted government auditing standards between May 2004 and May 2005.

Survey development and implementation

The survey addressed all three objectives, and included questions about
states' adoption of the family violence option or similar state policies,
screening for domestic violence, and the use of waivers and domestic
violence services to address victim's needs. In addition, we asked states
about their use of TANF funds to support marriage and responsible
fatherhood programs.

The survey was developed based on knowledge obtained during our
preliminary research. This included a review of pertinent literature and
interviews with members of academia and representatives of organizations
that conduct research and policy analysis on TANF, domestic violence, and
marriage and fatherhood programs. We also conducted visits to TANF offices
in Illinois, Iowa, and Wisconsin to obtain an understanding of their state
TANF programs, how they identify domestic violence victims and

1Consistent with the report, we refer to all respondents to the survey as
"states."

Appendix I: Objectives, Scope, and Methodology

address their needs, and the use of TANF funds for marriage and
responsible fatherhood programs. The survey was pre-tested with state TANF
officials in Maryland, Michigan, and Pennsylvania to determine whether
respondents would understand the questions the way we intended. These
states were selected to ensure that we pre-tested with at least one state
that (1) had adopted the Family Violence Option (FVO)- (Maryland and
Pennsylvania); (2) had not adopted the FVO, but was reputed to have
adopted a similar state policy (Michigan); (3) administered the TANF
program through state offices (Pennsylvania and Michigan); and (4)
administered the TANF program through county offices (Maryland). In
addition, Maryland was known to have developed a responsible fatherhood
program and Michigan had both responsible fatherhood and marriage
programs. Revisions to the survey were made based on comments received
during the pretests.

We sent the first mailing of the survey in November 2004 followed by a
second mailing in January 2005; telephone call reminders followed each
mailing. The collection of survey data ended in February 2005 with a 100
percent response rate. We did not independently verify the information
obtained through the survey. We did not attempt to verify the respondents'
answers against an independent source of information; however,
questionnaire items were tested by probing pretest participants about
their answers using in-depth interviewing techniques. Interviewers judged
that all the respondents' answers to the questions were correct. Answers
to the final questionnaire items on expenditures were compared to HHS ACF
data (form 196) for 2002-2003 and information we received from other
researchers in this area. These data are not directly comparable to data
obtained in our survey, but do indicate whether survey respondents'
answers were reasonable. We conducted follow-up phone calls to clarify
responses where there appeared to be discrepancies.

Although no sampling errors were associated with our survey results, the
practical difficulties of conducting any survey may introduce certain
types of errors, commonly referred to as non-sampling errors. For example,
differences in how a particular question is interpreted or differences in
the sources of information that participants use to respond can introduce
unwanted variability into the survey results. We included steps in both
the data collection and data analysis stages to reduce such non-sampling
errors. Specifically, we pre-tested three versions of the questionnaire,
social science survey specialists designed draft questionnaires, and edits
were performed to identify inconsistencies and other indications of error
prior to analysis of data. Data from the mail survey were double-keyed and
verified during data entry and we performed computer analyses to identify

                 Appendix I: Objectives, Scope, and Methodology

inconsistencies and other indications or error. Finally, a second,
independent analyst checked all computer analyses. We conducted our survey
work from July 2004 to February 2005.

                               State site visits

To obtain a detailed understanding of states' TANF programs' efforts to
screen for and address domestic violence, we conducted visits to eight
states. We visited three states-Illinois, Iowa, and Wisconsin- during a
preliminary phase of our work, and another five states-Colorado, Georgia,
New York, Oklahoma, and Washington in a later phase. We selected these
five states in order to ensure we covered (1) states in different regions
of the United States; (2) states that had adopted the FVO recently and a
state that had not adopted the FVO; (3) a state in which the TANF program
is state administered, and a state in which TANF is county administered;
and (4) a state that had used TANF funds to support a marriage program,
and a state that had used TANF funds to support a fatherhood program.

In each state, we interviewed officials at both the state-level policy
setting office, as well as officials in two local service delivery
offices. During both the state level, and local office interviews, we used
a standard interview protocol that enabled us to obtain more detailed-yet
comparable- information than states were able to provide in the survey. In
all five statelevel interviews, we discussed state policies for domestic
violence screening, and policies regarding how victim's needs are met once
identified. In addition, we asked officials about marriage and responsible
fatherhood programs, how these programs were implemented, and the sources
of funding. During the interviews in local TANF offices, we discussed the
implementation of state policies, and toured the offices. In addition, in
seven local TANF offices in five states, we were able to observe
caseworkers interviewing a client applying for TANF benefits, which
included questions about domestic violence. In Georgia, New York, and
Washington we also interviewed domestic violence specialists who were
located at the local TANF offices specifically to identify and address the
needs of domestic violence victims. Finally, we interviewed officials from
each state's coalition against domestic violence to obtain their views
about their state's program for identifying domestic violence victims,
meeting victim's needs, and the existence of marriage and/or responsible
fatherhood programs. Our site visit work was conducted between December
2004 and February 2005.

Other

As part of our work, we reviewed pertinent literature and interviewed
representatives of the following organizations:

Appendix I: Objectives, Scope, and Methodology

o  The Center for Law and Social Policy;

o  The Urban Institute;

o  The Center for Impact Research;

o  The Center on Budget and Policy Priorities;

o  The American Enterprise Institute;

o  The American Public Human Services Association;

o  The Brookings Institution;

o  MDRC;

o  The National Governors Association;

o  Public Strategies;

o  The National Fatherhood Initiative; and

o  The Center for Fathers, Families, and Workforce Development.

Appendix II: Comments from the Department of Health and Human Services

Appendix II: Comments from the Department of Health and Human Services

Appendix II: Comments from the Department of Health and Human Services

Appendix II: Comments from the Department of Health and Human Services

Appendix III: GAO Contact and Staff Acknowledgments

  GAO Contact Acknowledgments

(130380)

David Bellis, Director, (415) 904-2272

David Lehrer, Assistant Director, Michael Hartnett, Analyst-in-Charge,
Deirdre Gleeson-Brown, Gale Harris, Alison Martin, Nancy Purvine, and
Amber Yancey-Carroll also made significant contributions to this report.

Important contributions were also made by Jen Popovic, Corinna Nicolaou,
and Daniel Schwimer.

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