VII. Sanctions

Unfortunately, some clients fail to fulfill the obligations they agreed to and only reconsider when their benefits are affected. TANF sanctions, i.e., the reduction of benefits, will be consistent regardless of the reason, and the policy will guarantee fairness with a right to correct the problem. Exempt clients who volunteer to participate in work, education and training activities are not subject to sanctions for not complying with those outlined activities.

A sanction is the tool of last resort and represents a failure of the family to be properly engaged in the self-support process. It is an undesirable outcome, and is to be applied only when the following conditions are met: The client has failed to perform a work, education or training activity in the number of hours required under the Responsibility and Services Plan; or The client has failed to perform a self-sufficiency activity required under the RSP; or The client has failed to cooperate with the Child Support Services Program; or The client has failed to cooperate with the School Attendance Initiative.

AND There is not a valid good cause for failing to perform the activity or cooperating with the Child Support Services Program; and The client has been given the opportunity by a pre-sanction meeting to correct the issue before the sanction is applied; and Any supportive services agreed to and identified in the RSP as necessary to perform the activity have been made available; and For failure to take action in accordance with a work, education, training or self- sufficiency activity, a clear distinction has been made that the action leading to sanction is a failure to take a step and not a failure to achieve a goal of the RSP. E.g., failure to attend a GED program is a sanctionable issue if the client has not used the opportunity to correct the failure. However, failure to pass the GED test as specified in the RSP is not sanctionable.

Good cause for failing to take indicated actions will be defined in the Illinois Administrative Code.

Sanctions for failing to comply with work, education, training, or self-sufficiency activities will not be applied to a single custodial parent of a child if: appropriate child care is not available because none is located within reasonable distance of the family's home or work site; or informal child care from a relative or elsewhere is not available or suitable; or appropriate and affordable formal child care arrangements are not available.

"Appropriate child care" meets the child's needs and complies with all applicable State and local laws and regulations. "Reasonable distance" means the client's total travel time (from home to child care provider to job/activity, plus return trip) is not more than 25% of the client's total time on the job/activity, e.g., no more than two hours commuting for an 8-hour work day. "Unsuitability of informal child care" means arrangements with family or friends to provide child care do not meet the child's needs, are unreliable and/or violate applicable State or local laws and regulations. "Affordable child care arrangements" are free or eligible for payment by IDHS and do not exceed IDHS' maximum rate for the type of care.

Sanctions for failure to cooperate will be applied to families participating in the Illinois TANF Program. When a sanction is imposed, the TANF grant will be reduced by 30% of the 25% TANF grant designated for the adult member(s) for a TANF adult(s)/child(ren) case. This will result in a 7.5% reduction of the grant amount. When a TANF case is an adult(s) only case, the TANF grant will be reduced by 30%.

When a TANF case is sanctioned Illinois will seek to engage the individual in the required activity. A pre-sanction meeting will be offered to the client prior to the imposition of any sanction. This meeting will provide the client the opportunity to show good cause or to remedy the situation by immediately complying with the requirement. The full TANF grant will be restored from the date the customer complies or cooperates.

A client who participates in Work Experience or Community Service will be sanctioned if he/she fail to participate in the activity for the maximum hours assigned based on the calculation of his/her TANF grant plus his/her SNAP allotment divided by the higher of the State or Federal minimum wage. When the hours assigned based on this calculation are fewer than 20, the client is deemed to have participated in the 20 core hours needed to meet the Federal participation rate as long as the client completes the maximum number of hours assigned. In order to count a family as having satisfied the 20-hour core activity requirement when it participates, the maximum number hours allowed by dividing TANF and SNAP benefits by the minimum wage, Illinois adopted a mini-simplified SNAP program. Under the mini-simplified SNAP program, when a family fails to cooperate with the TANF work activity requirement, both TANF and SNAP benefits are sanctioned with one exception. If the TANF adult has a child under age 6, the SNAP benefits are not sanctioned.

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