PublicComments

June 15, 2006
Alana Landey
Department of Health and Human Services
Office of the Assistant Secretary for Planning and Evaluation
200 Independence Avenue, S.W.
Washington, D.C. 20201
RE: Comments on Proposed TANF Labor Market Survey
Dear Ms. Landey:
TWA appreciates the opportunity to submit comments on the proposed TANF Labor
Market Survey. We understand that previous research funded by the Office of the
Assistant Secretary for Planning and Evaluation (ASPE) has recommended that the
Department conduct this type of study, specifically a survey of a nationally representative
sample of employers and the labor market intermediaries with which they partner for a
more complete picture of the demand side of the labor market for TANF recipients than
is current available (Long & Ouelette, 2004).
Our main comment is that we question the decision to focus this survey only on one part
of labor market demand, specifically employers seeking to hire workers with a high
school degree or less. This all but ensures that most of the employers who will be
interviewed will be hiring workers for low-skill, low-wage jobs that will not help lift
these families out of poverty. It also is sure to exclude a significant number of employers
that are hiring TANF recipients transitioning off the program, as well as others that the
Department would want to engage to determine whether they would be willing to hire
recipients who had more than a high school degree.
As a result, we believe this survey’s current employer focus will not provide the
Department with information it needs to identify and craft policies to help these families
achieve self-sufficiency, whether through effective employer engagement or through
approaches that help TANF recipients get the education and training they need to
advance beyond low-skill jobs.
Only the last question (E-14), proposes to ask employers whether they would think
differently about TANF candidates if they had better basic or job-specific skills. In
addition, only two other questions (C-57 and E-9) ask about training provided to the most
recently hired employee by an intermediary or by the employer.
1701 K Street, NW, Suite 750 ▪ Washington, DC 20006
Phone 202 223 8991 ▪ Fax 202 223 8354 ▪ info@workforcealliance.org

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While it is true that most TANF recipients have only a high school-degree or less
(Administration for Children and Families, 2004), a significant number are also engaged
in education and training as their TANF work requirement and could be expected to
qualify for jobs beyond the low-wage labor market. In 2004, nearly 53,000 TANF
recipients (nearly 20 percent of the national caseload) were engaged in vocational
education or job skills training as their work requirement on a monthly average basis
(ACF, 2006).
For these reasons, we would recommend:
•

Adding more questions to this survey about the circumstances in which
employers would seek to hire people with some training beyond high school
(although with less than a college degree), or

•

Expanding the population of employers targeted for this survey beyond those
hiring only workers with a high school diploma or less. Comparison of the
answers between the employer groups could be very informative.

We would also encourage the Department to pursue additional research to identify
practices that help TANF recipients transition out of the low-wage/low-skilled labor
market, as recommended to the Department by a recent ASPE-funded report (Andersson,
Lane & McEntarfer, 2004).
Finally, we recommend that the local one-stop center be added to the list of
intermediaries in Questions E-2 and E-4.
Thank you again for the opportunity to comment. If you have any questions, please feel
free to call me at 202-223-8991 ext. 103.
Sincerely,
Gwen Rubinstein
Research Director

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References
Administration for Children and Families, “TANF Sixth Annual Report to Congress”
(Washington, 2004).
Administration for Children and Families, “TANF Families—Work Participation Rates,
FY 2004” (Washington, 2006),
http://www.acf.hhs.gov/programs/ofa/particip/indexparticip.htm#2004
Fredrik Andersson, Julia Lane, and Erika McEntarfer, “Successful Transitions out of
Low-Wage Work for Temporary Assistance for Needy Families (TANF) Recipients: The
Role of Employers, Coworkers, and Location—Final Report” (The Urban Institute,
Washington, 2004).
David A. Long and Tammy Ouellette, “Private Employers and TANF Recipients” (Abt
Associates, Bethesda, MD, 2004)