Statement of Gloria Guard, Executive Director, People’s Emergency Center, Philadelphia, Pennsylvania

I appreciate the opportunity to submit written testimony as the Executive Director of People’s Emergency Center (PEC), Pennsylvania’s oldest service agency for homeless families founded in 1972.  PEC offers a comprehensive  “continuum of care” to address the housing, employment and social service needs of homeless families in Philadelphia. PEC has served over 6,000 homeless women and children and been remarkably successful in helping these families achieve permanent self-sufficiency.  PEC has understands and addresses the needs of low-income families and communities more broadly.  PEC created the People’s Emergency Center Community Development Corporation in 1992, to serve as its community revitalization agent.  Since its inception, PECCDC has leveraged $14 million of investment into West Philadelphia and converted 70 vacant and blighted properties into 94 units of affordable transitional and permanent housing, 3 social service facilities, a community playground, and green space.  PECCDC has an additional $8 million of important facilities and housing projects in various stages of the development pipeline.

Directly related to welfare, PEC, through its Job Opportunities and Basic Skills Program (JOBS), has provided specialized employment services to homeless women transitioning from welfare to work.  JOBS conducts outreach at 11 of the City’s homeless family shelters and enrolls an average of 125 women per year.  Nearly 50% of those placed in jobs are still working after a year, which is positive compared to industry standards.  In addition, PEC has almost completed the construction of Families First, a one-stop welfare to work center that will house under one roof child care and afterschool for 120 children, a JOBS program assisting 100-120 women annually and a preventive healthcare center.  Finally, PEC has increasingly been recognized as an organization that can speak confidently on welfare reform policy issues, particularly from the perspective of an experienced provider serving women with multiple barriers to employment.  In the past year, PEC was instrumental in calling attention to the expiration of the federal Department of Labor’s welfare-to-work funding and for soliciting other public sector resources to maintain essential components of Philadelphia’s welfare to work program. PEC was selected from among the United Way of Southeastern Pennsylvania’s member agencies to provide the provider perspective on welfare reform at United Way’s welfare reform forum in November.  PEC recently took the lead in organizing a planning group and establishing the Philadelphia Welfare Coalition to address critical welfare issues over the next six months.  The Coalition hosted a forum in January aimed at developing a cohesive and broad-based response to the Pennsylvania Department of Public Welfare’s (DPW) proposed regulations related to the five-year time limits.   The Coalition is now beginning to focus its attention on the federal reauthorization of TANF.

TANF Work Requirements:

Since the purpose of the testimony is ultimately to inform the TANF reauthorization discussions, I want to comment specifically on the Administration’s proposed increase in the work requirement to 40 hours per week. 

The 40-hour per week work requirement is nearly impossible to meet consistently:

The 40-hour per week work requirement is onerous, particularly for single moms with children.  A large part of the difficulty of meeting the 40-hour per week work requirement is the need to meet it consistently every week for as long as the person needs welfare benefits.  The 40 hours is strictly implemented and does not allow for office holidays, vacation days, sick days or personal days.  Welfare recipients are not currently entitled to these critical options the rest of the working population uses to help them balance work and family needs and sustain employment. 

On March 12th, President Bush came to PEC in Philadelphia to announce the USA Freedom Corps.  I had the opportunity to speak with him directly about welfare reform.  I told the President with what I refer to as “the Christmas Story” to illustrate how difficult it is to meet the work requirement.  Each year our JOBS Program has clients placed in paid work experiences with other nonprofits or public sector agencies throughout the City.  Many of these employers close down their offices for the holidays between Christmas and New Years.  Unfortunately, our clients still need to meet their hours-per-week requirement and so we scramble to accommodate with hours at our agency or with other agencies that might be open.  It is always a major challenge to find enough supervised positions in Philadelphia during the holidays to accommodate all of those who must meet their work requirement. 

Another important point that I did not make to the President but would have made given more time is that between Labor Day and the end of January, with national holidays, there is not a single month when offices are actually open 40 hours per week consistently.  Each month, there is at least one observed holiday, which means that one week of every month between September and January welfare recipients are scrambling to make up 8 hours in that same week of the holiday.      

The President responded that clearly no body intended implementation of the work requirement to be so rigid that it created these consequences.  He promised to look into the issue and to think about potential solutions. 

I would like to offer a few points to guide the Administration and Congress’ welfare policy related to work requirements.   

I focused my discussion with the President around this one major implication of the 40-hour work requirement.  However, there are others.  It is the “all or nothing” nature of the 40-hours per week requirement that is most problematic.  A respected colleague articulated the issue well when she said, “I have never before encountered a test when the only passing grade was 100%.” 

We know from experience the past few years that it was extremely difficult for welfare recipients to meet the 30-hours per week requirement.  Obviously, very few welfare recipients will be able to achieve 40-hours per week of activity. 

We also know from experience that states are driven to hit their work participation rate targets and are unlikely to offer programs that are not structured to maximize the number of people meeting work participation rates.   

In the Administration’s proposal, states are only allowed to count families that meet both the 24-hour work requirement and the 40-hour full participation requirement toward their work participation rate.  (States will apparently be able to obtain pro-rata credit for families engaged in activities less than full-time as long as they meet their 24-hour work requirement, but it is not clear what that means).  What is clear is that under the Administration’s proposal, the following would not be considered successful outcomes:

It is also clear that with work requirements so strictly defined, states will end up sanctioning many families—the most vulnerable families--off the caseload. 

Finally, under the Administration’s plan, the stated overarching purpose of TANF would be to improve the well-being of children.  I think that is a critically important goal of TANF.  I want to point out that the 40-hour per week work requirement is not in the best interest of children.  First, it is likely that many families will be sanctioned off of welfare rolls for not meeting the work requirement.  It is definitely not in the best interest of children for their family to have no income.   It is not in the best interest of children for their parents to be penalized for working part-time so they can care for and supervise them.  We know from the research on the first wave of welfare reform that Teens were more likely to be negatively affected with studies suggesting decreases in school achievement and increases in risky behavior.  (Source: Welfare Reform & Beyond, Brief #1).   The increase from 30 hours to 40 hours is likely to increase the negative impacts on teens, particularly since the Administration’s proposal does not allocate additional funds for the afterschool programs that will be necessary for children whose parents are working these additional hours.

We all want welfare reform to be a success.  I am concerned that the Administration’s proposed work requirements set the clients, providers, states and the welfare program up for failure. 

I would also like to take this opportunity to present PEC’s position on TANF Reauthorization more broadly. 

PEC makes the following recommendations in the hope that, when reauthorized this year, the TANF block grant will become an even more powerful asset in helping us to carry out our mission. 

First and foremost, the reauthorization discussions should reflect that (1) the welfare population of today differs from the caseload of five years ago, with a substantially higher percentage of recipients facing multiple barriers to employment; and (2) the economy, though on the mend, is not booming at the rate it was over the past five years.  Nevertheless, we can and must maintain the goal of personal responsibility and high expectations that people still on the rolls can move from welfare to work.  To make these expectations a reality, states continue to need maximum flexibility to support programs that respond to their unique caseload and labor market realities.  They also need sufficient resources-- Congress simply must increase the block grant level at least to account for inflation.  A more substantial increase is required if we wish welfare reform to evolve to the next phase of reaching even the most troubled families and further reducing poverty.  Additionally, to sustain the momentum of welfare reform, we urge the Administration and Congress to:

(1)  Make the rules of the game for families transitioning from welfare to work the same as they are for the rest of us.   We expect welfare recipient to work 40 hours per week like the rest of us.  But most people do not work 40 hours per week every week.  Think of Christmas and Thanksgiving.  Welfare recipients are penalized if they work less than 40 hours in any week, regardless even of national holidays.  This is unfair.  They deserve a reasonable leave policy to enable them to balance work and family needs and retain employment, just like other employees.  Also, people transitioning from welfare to work should not be required to work for less than the minimum wage.  Nor should they have to work off checks and food stamps at artificially low wage rates.  Finally, to the greatest extent possible, welfare recipients should be paid wages that allow them to benefit from the Earned Income Tax Credit and build an employment history for unemployment compensation and social security purposes.  We at PEC find that welfare recipients want to give an honest day’s work; we owe them an honest day’s pay—coupled with time for their family and a chance to build for that family’s future.

(2)  Give providers on the front lines, like PEC, the flexibility we need to provide appropriate services to assist families with multiple barriers to move toward employment and self-sufficiency.  Unfortunately, thecombination of the proposed 40- hour per week requirement, 70% work participation rate and the elimination of the caseload reduction credit incentivizes states to offer a “one-size fits all” program.   We urge the Administration to examine options, including retention of the caseload reduction credit, for allowing states to support the full range of programs they will need.       

(3)  Recognize that affordable housing is essential to the successful transition from welfare to work.  The first purpose of TANF is to “provide assistance to needy families so that children may be cared for in their homes or in the homes of relatives,” yet the TANF program fails adequately to recognize the critical importance of this work support.  Research shows that people leaving welfare that receive housing assistance have significantly higher employment rates and earnings, while housing problems threaten families’ ties to work.  Accordingly, the reauthorized legislation should clearly define housing subsidies as a work support, similar to childcare or transportation, instead of as assistance.  States should also be required to address housing in their TANF plans.  This is just common sense—it is hard for TANF recipients to meet our heightened expectations when, even after going to work, these vulnerable families lack a stable home due to overwhelming housing cost burdens.

Thank you for your time and consideration.