Executive Summary
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This report explores one key dimension of access to public benefits —
the application and eligibility determination process. Of particular interest
is how local-level administrative procedures and operations may generally
affect eligible families’ access to benefits. Special consideration
is given to exploring these issues as they relate to immigrants and limited
English speakers.
The four major public benefits programs examined in this study are Temporary
Assistance for Needy Families (TANF), food stamps, Medicaid, and the State
Children’s Health Insurance Program (SCHIP). The findings presented
are primarily based on site visits conducted between June 2001 and December
2001 in six different localities: New York City (five counties/NY), Dallas
(Dallas and Tarrant Counties/TX), Seattle (King County/WA), Raleigh (Wake
County/NC), Arlington (Arlington County/VA), and Sedalia (Pettis County/MO).
The sites vary in terms of the overall size of their client base and the
diversity of the immigrant population, and the way in which application and
eligibility determination processes are structured and implemented.
Background Context
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High levels of immigration over the past decade and increasing dispersal
of non-citizens across the country means that more non-citizens now live
in areas without an established infrastructure to deliver services in languages
other than English, or where such infrastructure is in early stages of
development. Even urban centers accustomed to receiving large numbers of
immigrants, such as New York City, are faced with the challenge of dealing
with an increasingly diverse number of immigrant groups who speak dozens
of different languages.
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The Personal Responsibility and Work Opportunity Reconciliation Act of 1996
(PRWORA) and subsequent legislative changes include eligibility rules for
federally funded public benefits that affect certain classes of legal
non-citizens. Further, "mixed-status" immigrant families have to deal with
eligibility determination that sometimes may be unclear. According to 1998
figures from the U.S. Current Population Survey (CPS), 85 percent of families
with at least one non-citizen parent have at least one citizen child. The
vast majority of immigrant families who apply for benefits have both citizens
and non-citizens in them and while non-citizen adults are often ineligible
for benefits, their children — who are usually citizens —
are generally eligible. The mixed-status of many immigrant families and the
complicated eligibility rules concerning non-citizens presents challenges
for human service agencies as well as immigrant families who may not understand
if and how they are affected by the eligibility restrictions.
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In the years following the enactment of PRWORA, human service agencies have
been engaged, to varying degrees, in creating new organizational structures,
administrative practices and service delivery systems that include undertaking
a significant expansion in medical assistance to children and creating a
devolved, work-oriented welfare system that provides a variety of supports
for working families as well those receiving cash assistance. In particular,
the enactment of SCHIP has served as a catalyst for developing simplified
and streamlined up-front intake procedures in order to expand health insurance
for uninsured children. In addition, efforts to reduce dependency on cash
assistance and promote work have increased awareness of the work support
role of food stamps and medical assistance.
Key Findings
The following are key findings about the application process encountered
by all potential applicants and, in particular, by immigrants and limited
English speakers. There are important variations — across programs
and sites — in the application process:
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It is generally easier to apply for children’s medical assistance
(i.e., SCHIP and Medicaid) than for cash assistance or food stamps.
Overall, across all sites, there is a striking difference between the relative
simplicity of the application process for SCHIP (and often Medicaid-only)
compared to the complexity of the application process required for obtaining
the full traditional welfare package — cash assistance, food stamps,
and Medicaid. For example, SCHIP application forms tend to be simplified
and user-friendly for applicants and often include features that make them
more accessible to immigrants. They are typically shorter, require less
information about non-applicants in the household, and are more likely to
be translated into Spanish (and sometimes other languages) than integrated
applications for the TANF, the Food Stamp Program (FSP) and Medicaid.
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Families can gain access to medical assistance benefits through different
points of entry whereas families in need of the traditional package of welfare
benefits typically have a single physical point of entry — the
welfare agency. Efforts to improve enrollment in Medicaid and SCHIP
have led to a variety of strategies to increase the points of program entry.
These typically involve moving various aspects of program enrollment (e.g.,
applications, eligibility screenings, and eligibility determinations) away
from the traditional welfare agency setting and making these services available
in locations that are more convenient and accessible to eligible families
(e.g., health clinics, hospitals, schools, community-based organizations,
and through phone or mail).
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The application process for the full welfare package of benefits is
more rigorous in some places than others. Among the study sites,
the TANF/FSP/Medicaid application process is the simplest in Seattle and
the most complicated in New York City. Seattle’s application process
has no up-front requirements whereas applying for TANF/FSP/Medicaid in other
sites includes additional steps, such as up-front job search, application
screenings, and work program orientations. Among the sites, New York City’s
TANF application is the most complex and includes requiring applicants to:
attend two eligibility interviews in two different locations, undergo
fingerprinting and photographing for fraud prevention purposes, receive a
home visit from an eligibility verification investigator, attend a mandatory
workforce orientation and attend daily job search classes (five days per
week) for the duration of the 30-day eligibility determination period.
Special eligibility and language issues presented by immigrants and limited
English speakers are addressed in different ways and to varying degrees at
the local-level. Looking across the six sites included in this study, the
following key points emerge:
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There is no one-size-fits-all approach for providing language services
and there are trade-offs associated with each approach. Because
there is no single language-access strategy that is appropriate for every
program or each stage in the application process, let alone for all language
groups, human service agencies tend to employ more than one (and sometimes
several) language assistance strategies simultaneously. The design and
implementation of these multiple local language access strategies are driven
by a complex interplay of factors related to the size of the total local
limited English proficient population, client caseload characteristics (e.g.,
the number and types of languages spoken by limited English proficient
applicants), and agency and community language resources. Developing strategies
that take into account these factors is all the more challenging because
the size, composition, and distribution of immigrant populations are often
moving targets.
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For the most dominant non-English speaking language group, it is often considered
optimal to use in-house bilingual staff who can provide interpretation assistance
in conjunction with their other job duties (e.g., a bilingual eligibility
worker conducts an eligibility interview in the primary language of the
applicant). In sites with significant staffing capacity, this approach can
include specialized units or offices targeted to immigrants and limited English
speakers. However, reliance on in-house bilingual staff may prove inefficient
and unmanageable, particularly with respect to less common language groups,
when the need for language interpretation for a particular language is relatively
infrequent and sporadic. And, because of the continually changing composition
of the immigrant population across our sites, simply adding new bilingual
staff to match each new immigrant wave may be neither possible nor prudent.
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Providing language services on a contract basis provides a more flexible
approach that allows local human service agencies to adjust to the different
language needs of applicants on a daily operational basis as well as over
time. At the same time, relying on contracted staff for interpretation assistance
instead of in-house staff also necessitates additional oversight effort on
the part of human service agencies to monitor the overall quality of the
language services provided to LEP applicants.
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Relying on friends and family for translation is considered a far less desirable
language service strategy but many sites still relied on this alternative,
particularly for less common languages and in agencies where there were no,
or only few, in-house or contracted bilingual staff available to bridge the
language gap. Telephone "language lines" offer extensive language coverage
but they are expensive to use and staff tend to use this alternative only
as a last resort.
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Language access strategies used in the administration of public benefit
programs must be considered within the context of the application processes
for these programs. The more complex and involved the application
process, the greater the challenge for providing language assistance at each
stage in the process and the greater the likelihood that language difficulties
may impede access. Less visible but still critical aspects of the application
process, including the provision of translated written material and
interpretation services for telephone communication, are often overlooked
or inadequately addressed components of language access strategies.
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Within welfare offices, strategies used to address complexities presented
by non-citizen eligibility rules — and all eligibility determination
rules — may include some combination of specialized front-line
workers, automated eligibility determination systems that prompt for all
the required eligibility information, and reliance on immigration
documents. Some agencies rely on more experienced workers or specialized
units to handle non-citizen eligibility or have specialized offices located
in areas with large immigrant communities. Workers in these settings typically
have more experience and familiarity with non-citizen eligibility rules and
immigration documents. The automated eligibility interview programs provide
a means to further standardize the eligibility determination process, making
it possible for all workers to systematically gather all the information
needed to correctly apply eligibility rules, including the complex rules
pertaining to non-citizen eligibility. In addition, workers typically rely
on checking immigration documents in conjunction with charts that crosswalk
program eligibility with these documents. If all these methods are used,
the risk for error decreases. The risk for error is greatest when non-citizen
applicants present rare or unusual immigration documents or more detailed
aspects of non-citizen eligibility rule changes are not accounted for by
workers and/or automated eligibility interview programs.
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The combination of providing a simplified application process in a
non-welfare setting, supplemented with additional application assistance
and language accommodations, appears to increase access to benefits by limited
English speakers and/or immigrant families. Participants in this
study across the six study sites commonly noted that immigrant families (many
of which are mixed status families with citizen children) are more likely
to apply for benefits at community health clinics, hospitals, and other
non-welfare settings than initiating an application process for benefits
at the welfare office. This may be because the application process for
childrens’ medical assistance benefits in these community- and health-based
settings requires less information and documentation and is typically much
easier to complete than the integrated TANF/FSP/Medicaid application process.
Also, there are more likely to be bilingual staff available in these settings
to help bridge any language gaps, and there is less concern among immigrants
that the application will cause immigration-related problems for themselves
or their children. In addition, some application procedures used by welfare
offices for TANF and/or food stamps may be perceived differently by non-citizens
than their citizen counterparts. For example, finger imaging, home visits
and rigorous eligibility verification — procedures used routinely
in the TANF and/or food stamps application in some study sites —
can be particularly daunting for families who closely associate many of these
procedures with the Immigration and Naturalization Service.
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