AN EVALUATION OF
IMPLEMENTATION OF
LEARNFARE EXPANSION
WISCONSIN DEPARTMENT OF
WORKFORCE DEVELOPMENT
State of Wisconsin
Legislative Audit Bureau
LEGISLATIVE AUDIT BUREAU
The Bureau is a nonpartisan legislative service agency responsible for conducting financial and program evaluation audits of state agencies. The Bureau's purpose is to provide assurance to the Legislature that financial transactions and management decisions are made effectively, efficiently, and in compliance with state law, and that state agencies carry out the policies of the Legislature and the Governor. Audit Bureau reports typically contain reviews of financial transactions, analyses of agency performance or public policy issues, conclusions regarding the causes of problems found, and recommendations for improvement.
Reports are submitted to the Joint Legislative Audit Committee and made available to other committees of the Legislature and to the public. The Audit Committee may arrange public hearings on the issues identified in the report, and may introduce legislation in response to the audit recommendations. However, the findings, conclusions, and recommendations in the report are those of the Legislative Audit Bureau. For more information, contact the Bureau at 131 W. Wilson Street, Suite 402, Madison, WI 53703, (608)2662818.
State Auditor - Dale Cattanach
Editor of Publications - Jeanne Thieme
Audit Prepared by
Judith Frye, Director - Contact Person
Karen McKim
Emma Caspar
Sandra McKinley
David Varana
TABLE OF CONTENTS
LETTER OF TRANSMITTAL1
SUMMARY3
INTRODUCTION7
Program Requirements7
Responsibilities of Agencies Involved in Program Administration8
Preparation for Learnfare Expansion10
Initiation of Learnfare Expansion13
LEARNFARE EXPANSION PROCEDURES15
Placing a Child on Monthly Attendance Monitoring17
Performing Monthly Attendance Monitoring21
Imposing a Sanction22
LEARNFARE CASE MANAGEMENT25
Position Descriptions of Learnfare Case Managers25
Activities of the Learnfare Case Managers26
KEY ELEMENTS OF IMPLEMENTING LEARNFARE EXPANSION29
Working with the Schools29
AFDC Records and Procedures31
Training AFDC Staff32
The Role of the Learnfare Case Manager33
APPENDIX I - LEARNFARE EXPANSION PROCEDURES RELATED TO POOR
ATTENDANCE
APPENDIX II - LEARNFARE EXPANSION IN BROWN COUNTY
APPENDIX III - LEARNFARE EXPANSION IN FOND DU LAC COUNTY
APPENDIX IV - LEARNFARE EXPANSION IN KENOSHA COUNTY
APPENDIX V - LEARNFARE EXPANSION IN ROCK COUNTY
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September 10, 1996
Mr. Richard Wegner, Acting Secretary
Department of Workforce Development
201 East Washington Avenue
Madison, Wisconsin 53703
Dear Secretary Wegner:
We have completed a process evaluation of the implementation of the Learnfare Expansion program during its first year of operation, as required by the Interagency Agreement between the Legislative Audit Bureau and the Department of Health and Social Services and by the terms and conditions of the federal waiver authorizing the Learnfare program. The program has since come under the direction of the Department of Workforce Development.
Statutory provisions, legal due-process requirements, and administrative requirements make the procedures required of AFDC staff for identifying and responding to children’s attendance problems complicated and time-consuming. In addition, because so few 10- to 12-year-olds have enrollment or attendance problems serious enough to warrant monthly monitoring or imposition of sanctions, AFDC staff in the four pilot counties did not become familiar with the procedures through experience. When a case warranted action, AFDC staff sought direction from state staff in working through the complexities.
However, Learnfare case managers were provided with wider latitude in identifying and working with families of children with apparent or developing attendance problems. These case managers took initiative to establish working relationships with schools and other community agencies and to address truancy problems before they became so serious as to violate minimum Learnfare attendance requirements.
The previous experience that participating schools had with the teenage Learnfare program appears to have made implementation of Learnfare Expansion easier because of familiarity with attendance-reporting requirements. Nevertheless, if other jurisdictions consider implementing the program, they must work with schools to establish workable attendance-reporting procedures.
We appreciate the courtesy and cooperation we received from department and county staff and the various contract agencies working with counties to provide Learnfare services. We have included a profile of each county in the appendices.
Sincerely,
Dale Cattanach
State Auditor
DC/JF/ce
SUMMARY
The Learnfare Program requires 13- to 19-year-old children in families that receive Aid to Families with Dependent Children (AFDC) to enroll in and attend school or face reductions in their families’ AFDC grants. The Learnfare Expansion program extends the requirement to younger children in four pilot counties over three years: children ages 10 through 12 in 1994, ages 8 and 9 in 1995, and ages 6 and 7 in 1996.
As part of the federally required evaluation of the Learnfare Expansion program, we reviewed how the program was implemented during its first year to determine whether administrative or operational problems that limited its potential effectiveness might be avoided by other jurisdictions seeking to implement Learnfare expansion. We reviewed the work of AFDC staff in each of the four participating counties: Brown, Fond du Lac, Kenosha, and Rock. We also reviewed the work of Learnfare case managers in their efforts to address attendance problems with families and schools.
Although early intervention in attendance problems is the goal of Learnfare Expansion, the procedures required for taking action against a family’s AFDC grant are complicated and time-consuming. In addition to the legal and administrative requirements, four tasks, each of which contains several steps, must be accomplished before a Learnfare Expansion sanction can be carried out in response to an attendance problem. Completion of these tasks requires at least three months.
First, to determine whether a child should be placed on monthly attendance monitoring, a child’s enrollment and last semester’s attendance must be verified through school records. Four types of problems prevented children from being placed promptly on monthly attendance monitoring, including:
- the timing of case reviews, which can delay monthly monitoring for up to one year;
- difficulty obtaining accurate and timely information on prior-semester attendance from schools;
- errors by the AFDC staff person handling the family’s case; and
- data-processing errors in the new Client Assistance for Re-employment and Economic Support (CARES) computer system.
Once monthly monitoring is approved, attendance reporting problems involving accuracy and timeliness can delay detection of continued attendance problems and imposition of sanctions. Even when attendance requirements are not met, sanctions may be delayed because the procedures for initiating and imposing a sanction against the family’s grant are complicated and time-consuming. Unlike many other AFDC actions, the sequence and timing of these procedures is critical to their successful completion.
Imposition of a sanction based on poor attendance requires that three conditions be met in sequence:
1.The first time that an individual fails to meet attendance requirements, the county must offer the family an opportunity to work with a Learnfare case manager, who will assist the family in identifying and obtaining services and resources to correct the attendance problem. This offer must be separate from offers contained in routine notices.
2.The family must fail to cooperate with the case manager or with the plan of activities prescribed by the case manager to improve the child’s attendance.
3.The child must continue to fail to meet the attendance requirements.
Meeting these requirements involves at least six administrative steps and requires several months to complete: their actual effect cannot be determined because no sanctions were imposed in the first year of the program. Requirements for imposing a sanction based on lack of enrollment are less complicated, but the incidence of dropouts among this age group is even less frequent than the incidence of attendance problems.
The complexity of these procedures was reflected in their unfamiliarity to AFDC staff, despite training. AFDC staff, who handle all aspects of the family’s AFDC case with regard to eligibility and benefits, indicated that implementation of the centralized case records system, known as CARES, which required them to re-learn all the routines of their jobs, limited their ability to learn the details of a new and relatively small program, such as Learnfare Expansion, during its first year of operation.
While AFDC staff did not know the new program well at the end of its first year, Learnfare case managers proved to be instrumental to the program. While the specific responsibilities assigned to case managers in the design of the program are largely limited to working with families of children who had been identified, by AFDC staff, as having had attendance problems, the Learnfare case managers in each of the four pilot counties have adopted broader, more active roles. These include early identification of children with attendance problems, establishing working relationships between the AFDC agency and the schools, and assisting AFDC staff with gathering accurate information and using CARES.
If Learnfare Expansion is continued under the State’s new welfare system, extended to other counties, or implemented by another state, some difficulties might be avoided with more thorough planning, taking into account the experience of the pilot counties. Other difficulties appear to be inherent in the program and will require work with local schools, workable AFDC records and procedures, adequate AFDC staff training and ongoing assistance, and continued involvement of Learnfare case managers.
In working with schools, it must be recognized that record systems in the schools are generally not designed for uses other than those required by school administration and education, which tend to emphasize individual circumstances rather than seek uniform procedures. Schools’ attendance recording systems devised before the implementation of Learnfare are not likely to be able to meet all the program’s needs for attendance data, especially in elementary schools, where attendance records typically are not detailed. Making Learnfare attendance requirements consistent with existing statutory attendance requirements for truancy purposes may reduce these problems.
Jurisdictions implementing any program similar to Learnfare Expansion must be prepared to provide a sophisticated automated system, capable of such tasks as keeping detailed track of attendance, generating notices, providing case history features, and allowing access to case information by both AFDC staff and Learnfare case managers. In addition, given the complex administration requirements and routines required by Learnfare Expansion and the relative infrequency of severe attendance problems among younger children, it is more important for staff to obtain one-to-one instruction at the time they first perform certain routines than for staff to receive detailed training when the program is introduced.
Finally, some method must be devised to ensure that at least a few staff develop expertise in Learnfare requirements and procedures, either by relying on specifically designated AFDC staff or by including this role for the Learnfare case managers, whose job responsibilities allow them more flexibility to spend large blocks of time with one problem.
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1
INTRODUCTION
Learnfare is a program intended to encourage school attendance and completion among children in families receiving Aid to Families with Dependent Children (AFDC). If the children do not meet the program’s school enrollment and attendance requirements, their families might lose some cash benefits. Learnfare went into effect statewide in 1988 for teenagers. In late 1994, it was expanded to younger children on an experimental basis in Brown, Fond du Lac, Kenosha, and Rock counties. Learnfare Expansion, as the program for younger children is known, is being phased in over three years: for children ages 10 through 12 in 1994, for ages 8and 9 in 1995, and for ages 6 and 7 in 1996. The Department of Health and Social Services had primary responsibilities for administration of the program until June 30, 1996, when the program came under the direction of the Department of Workforce Development.
This report, the first in a planned long-term study of Learnfare Expansion, will evaluate the implementation and operation of the program. The program’s effects on the first group of participants will be reported later. Program participants who were 10to 12 years old when the program was initiated at the beginning of the 1994-95 school year were randomly assigned either to participate in or to be exempt from the program as part of the long-term evaluation of the program required by federal waivers. After the end of their third semester, attendance for the two groups will be compared to determine the effects of the Learnfare Expansion program.
Learnfare was made possible by a series of federal waivers of the regulations that govern the operation of AFDC nationwide, and by a series of enabling state laws. The initial federal waiver was granted in October 1987, and Learnfare was enacted into state law by 1987WisconsinAct 27, which established the basic program for AFDC teenagers. Detailed program requirements were established by state administrative code and subsequent changes to state law.
The Department of Health and Social Services received a second waiver in June 1990, which extended Learnfare through September 1994 and included permission to expand Learnfare to AFDC pre-teenagers from ages 6 through 12. Enabling state legislation, 1993 Wisconsin Act16, scheduled the implementation of Learnfare Expansion in four pilot counties between September 1994 and 1996. Later, additional federal waivers extended the program through September 1998 and imposed specific evaluation requirements.
Program Requirements
In general, Learnfare requires that children who have not graduated from high school and who have no good reason for missing school should be enrolled in school and maintain an acceptable level of attendance. Enrollment is expected to be continuous throughout the school year; if AFDC staff become aware at any time that a child has dropped out and the family cannot show good cause why the child is not in school, the child may be removed from the grant.
AFDC staff are to monitor and enforce two separate attendance requirements. The first, which applies to all children at all times, requires students to have fewer than ten unexcused full-day absences each semester. At the time of the family’s initial application for AFDC and semi-annually thereafter, AFDC staff review attendance using documents provided by the families, such as report cards, by obtaining prior-semester attendance information from the schools, or both.
Students who failed to meet prior-semester attendance requirements are made subject to a monthly attendance requirement. Missing more than two full days in a single month without excuse may result in the family being sanctioned by the child’s temporary removal from the grant.
Learnfare regulations provide for a number of exceptions to the attendance requirements when a child cannot attend school for reasons beyond the control of the family. For example, if a child has been expelled from one school and no other school within a reasonable commuting time is available, the child may be granted a good-cause exemption from Learnfare requirements. Enrollment in non-traditional educational programs, including part-time programs (if authorized by the local school), schooling provided by correctional or therapeutic programs, and home schooling, are also accepted as fulfilling Learnfare requirements. Another essential feature of the Learnfare program is the provision of case management services. Families are offered the opportunity to work with Learnfare case managers, who are staff assigned specifically to assist families in identifying the causes of attendance problems and gaining access to appropriate services.
Learnfare requirements for teenagers and younger children are identical with one exception. Teenagers may be sanctioned whenever they are determined to have failed to meet enrollment or attendance requirements without good cause. Younger children, however, may be sanctioned only after: 1) the child has failed to meet enrollment or attendance requirements; 2) case management has subsequently been offered and refused; and 3) the child continues to have poor attendance. Therefore, families of younger children with poor attendance may avoid sanction either by improving the children’s attendance or by cooperating with the Learnfare case manager.
Responsibilities of Agencies Involved in Program Administration
In each county, administration of the Learnfare program requires the coordinated efforts of the county AFDC staff, the Learnfare case managers, and the local schools. The state AFDC authority also has important coordinating and support responsibilities.
Primary responsibility for the day-to-day administration of Learnfare requirements lies with the county AFDC staff, who handle all basic administrative duties related to each family’s AFDC case. The Learnfare duties of AFDC staff are similar in all four counties and include:
- requesting the necessary information from the families, the schools, and the Learnfare case managers at the appropriate times;
- reviewing the enrollment and attendance information and obtaining additional information as necessary;
- based on that information, determining which Learnfare requirements apply to each child and whether the child is meeting Learnfare requirements;
- taking necessary actions to initiate required Learnfare actions; and
- taking necessary actions to document their determinations and the resulting actions.
In contrast to the relatively consistent responsibilities of AFDC staff, the responsibilities of Learnfare case managers vary among the counties. Commonly, Learnfare case managers are expected to involve the families of children with attendance problems in case management by taking steps in addition to those taken by AFDC staff. Once a family has agreed to cooperate, Learnfare case managers perform assessments and provide guidance and assistance in obtaining services that might include tutoring; the provision of school supplies or clothes; assistance with housing; family therapy; or other services, depending upon the causes of the child’s excess absenteeism. Depending upon local practice, Learnfare case managers may also perform counseling or conduct outreach to families and students who are at risk of having attendance problems but who have not been referred by AFDC staff.