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CFSM - Citizens for Social Morality

January 23, 2006
TO: Federal Government
RE: TANF Reauthorization

I am the founder and director of the CFSM, “Citizens for Social Morality.” We are an advocacy group, which deals with child abuse and in that grey area, commonly referred to as, “child protection”. Currently, we are taking issue with Canada’s historically deplorable, child protection “business” and thus, have launched Phase III of a “four” phased platform, I designed some “three” years ago when a provincial government of Ontario agency, known as the CAS, decided to apprehend/kidnap my two US born children from my ex-wife, who now resides back in Canada. As a result, I launched the largest offensive of its kind, in opposition and forced withdrawal of the application some “five”months later. So and therefore, I/we, have proceeded to take significant actions against the government and have assisted numerous families, both there and here in the US as well. Therefore, you may consider me an expert, in the field of child abuse/protection. Going forward, our initiatives, involve notification’s to most government’s and media worldwide, exclusive of the US, and specifically, we are taking issue with some “forty-five” violations of non-compliance and Canada’s egregious failures, in the area of child abuse and protection.

As to child abuse and protection concerns here in the US, that shall be dealt with in Phase IV. Although I was in the process of drafting a quite lengthy document, in regards to CAPTA and TANF, I shall forego the joining together of the two issues, in this response. But before I proceed, I find it of necessity, to at least advise you as follows. In the area of child abuse, there exists a certain anomaly, when trying to grapple with the full spectrum of issues. As, there is an absolute correlation, whether direct or otherwise, between child abuse and the underpinnings, of a low income support net, which remains allusively obscured, within this TANF platform. Though I for one, still find it an insurmountable task, in trying to envision the concept. Oh yes, I do see what it was, then-President Clinton had in mind in 1996, but that was then and this is 2006. As what is the case here, is that, once again, the government continues to avoid acknowledging the realties of both the “actual” and “root cause” failures, in this accommodating appeasement, to the disenfranchised less fortunate. Kind of synonymous with, a carrot/assistance and stick/work, social application of legislative intent. In the prior matter, I would have alluded to and at the pinnacle of this conundrum of child abuse v. protective mandates, an introspective look, into what is arguably a much more serious issue, child abuse. Or, media “feeding frenzied”driven “reactionary legislation’s” and the partnering up, of the family court/judicial process, with child protection services. But in lieu of this rolling over, of this act/“campaign”, we’ll just set this issue of a/the “child welfare industry” aside, at least for the time being and get on with the onerous nature of funding. Thereto, let me revert back to TANF. As there is no hyperbole of cause and effect, within the auspices of income and or poverty, in that they have become, inherently intertwined, with all socialized program developments. As is the case here, within the child’s rights issues, addressed in CAPTA on one hand and within TANF, and assistance on the other.

Or, considering the millions of reports of abuse, annually, all of the billions doled out for quick fix legislation and the enormous scrutiny involved, then what begs to question, is. Why has there has been “no” real, dollar for dollar proofs, nor any real, meaningful and positive effects, nor significant departures from the status quo? Why, well because Washington still continues to march lock step, into a world of socialized accommodations, that have failed miserably for years on end and while still ignoring history, by following policies’s, that simply do not work. Suffice it to say, the obligation of the legislation, was or should have been, a forwarding of a “positive” and “opportunistic” mind set. While your research, should have dictated, that you cannot legislatively interject, a “state of mind”, or the “fulfilment and gratification one gets when they finally get a job”. Thus, whereas and if perception was in this instance, about everything, then when or where did reality vacate the building. As this legislation is more so and so invariably superficial, that it merely exists as a social enigma. And who were the people and the families you are trying to help and why? Or was this entitlement word “Temporary”, used purposely and as a misleading introduction of smoke and mirrors, in order to, one, silence its critics and two, in order to placate a side of public opinion, which perceives this act, as just another “hand out” and to “those” second class citizens.

TANF/Opinion & General Information: When one looks at the propensity for attempting to interpolate morality and social norms, there must be a cognizant effort, to avoid these sorts of 21st century, high profile media-driven legislative repair mechanisms. This $16.5 billion block grant was enacted under PRWORA and replaced AFDC. Its mandate, was two pronged, one to “end welfare as we know it” and two, to “foster self-sufficiency” through work. Further, it was by design, an initiative which intended to interject a fresh air alternative, as opposed to, an ideological inference, as so contained, in the “free money” doctrine of AFDC. I submit, the motivating factors behind this change in legislative modus operandi, had more to do with, the “white majority” taking issue, with some “lazy” black/minority, just sittin’ around collecting welfare, stereotype, than it was about, Congress’s concern for the plight of the “disadvantaged minorities”. Maybe there was some consideration given, as to any reasonable taxpayer valuation being attached to this program or its overall benefit to the community or as to the bigger picture, our compassionate expression as a country. Statistically, the TANF caseload may have declined, but to what do we attribute this? Does this or should this imply, that there is a resurgence in inner city business? Now the average monthly number of TANF families was 2,060,300 in FY 02. On average, 168,900 TANF families had their assistance terminated each month. African-American and Hispanics total roughly, 60%+ of the total racial makeup of TANF families. Of which, about 80% receive Food Stamps. In the area of racial distribution, about 40% of the recipients, are African-American children. Ninety-five percent of TANF families received cash or cash equivalent assistance. So getting back to this pesky little issue of assistance and how resilient the economy is or isn’t. For what the statistics do show, is that most recipients tend to live in lower class neighborhoods and generally, within the inner city. They are of the minority, usually black and Hispanic. That they are given this tool, assistance, but in order to be availed this privilege, one must consent to certain predetermined program requirements. This is all well and good, assuming in the first instance, the availability of employment. Two, that if so, there is a reasonable expectation that s/he really wants to work and three, that the recipient is looking for employment out of necessity and hopefully as a principled matter of self-esteem, to better s/he and the family, and not just because s/he has to. As this program was purportedly premised upon, providing assistance to the family, not just the ‘care giver’.

So and bearing in mind this snapshot of statistics, what has this legislated $16.5 billion dollar appropriation really bought us? Certainly, the states have complied with the “spirit and intent”, of most of the rules and have used 40%+ of their Federal TANF and as well, the State’s have adhered to their end of the bargain under the (MOE) and used 75% of the amount it spent on welfare programs FY 1994. FY 2002, 33.4% of non-exempt adults met all-family work participation standards. FY 2002, about 17.2% of case closings were reported as closed due to employment, although an additional 25.8% were closed due to non-compliance. Yes, closed. And they, our representatives, will cite this revelation as some sort of magic pill, this so-called 50% drop off of people receiving welfare, since the onset of this illustrious program. Never mind the fact, that they are still living in poverty. That 50% of those who have left “welfare” and who are working, earn wages “below the federal poverty line”. Granted, many ex-recipients have found work, where often, they are low-wage jobs that provide “no benefits”. Then and to make matters worse, economic factors come into play and they get laid off, are ineligible for unemployment and to add insult to injury, run up against that five-year lifetime limit on benefits. So and again, where is the beef? Were there some valuable suggestions contained in the 300 comments received following the notice on 11/20/97? Whereas, there are 5 versions of bill H.R.3734. ENR, the senate version having been moved forward and passed under EAS, with the EH house version pending. Changes contained in the propositions, follow a wide array of minor to somewhat major variations, but all in all, bring little real change to the table.

There’s some subtle change, as in the MOE’s and its “three” statutory provisions and its penalty base. Under -3- MOE’s 2) W-to-W grant reduction formula and 3) Contingency funding, IE Retain&remitted funds. There’s changes in the caseload reduction credit, a reference to the “fair treatment of State”, and, a reduction of minimal participation rates tied to the MOE. The time limit, correlates a 60 month base point with a 20% extension criteria, etc etc,,,,,,,,,, and so on and so forth.

Issues still in flux: Child care, opportunities for education and job training, access to substance abuse treatment and rehabilitation and health coverage. Are these looked at as benefits or are they mandated, as part of some stick and carrot approach? As it does make me wonder, why were these issues not front and center in the initial legislation? Especially education and substance abuse. For did you have no concept of what you were trying to accomplish? Here you give people “cash”, send em to some b------t work accountability program, represent it as a one size fits all, help the needy program, while at the end of the tunnel, the door’s slammed shut. Real smart and dedicated people, who ain’t got a clue about the stark, real world realities of poverty and hopelessness. But worry not, for if you add another $6 billion of child care funding to the mix, well, that should fix everything. You can add $100 billion and it will matter not. The program is still old school ADC, but with a more palatable name and was design flawed in 1996 and it’s no better for wear today.

But at the end of the day, these changes are as such, insignificant and will prove negligible, in motivating this program forward. There is however a restatement, of the minimum rate for adults in all families and “two” separate work participation rates. In part, FY 1997 it began with 25%, went to 40% FY2002 and was to rise to 50% FY 2002 and thereafter. The degree or percentage increase for penalizing due to non-compliance, rises from 75% to a proposed 90%. Now and as I understand it, the president had sought to increase the numbers of work hours of a participant, as a precursor to qualification. While the official administrative overview, was of the opine, that too many people were not working at all. Secretary Horn, is on record, in stating, “there is really good evidence that when states put their mind to it, they can dramatically increase the work participation rate” and, “The big problem was that 56 percent of TANF recipients are not doing anything, not one hour over the past month in any activities and to get them to be doing 20 or 30 hours of work a week would be an achievement”. Then I would consider, Georgia’s having increased their work participation levels to 65%, as well, a positive. Anyway, as I look over the work participation rates FY 2003, I see “nine” states of +50%, “nine of +40%, leaving “thirty-three” below 40% and with a national average of 31.3%. And again, what are these statistics to show? I can only offer, that the concept of tying funding to a work qualification, in as a practical matter, remains allusive and quite complexing. But what is the final objective? If there is a goal, what is the bottom line and where is the strategy imbedded in this legislation, which points us to an end game? I mean, where is it? Some will argue, a state can simply raise rates by kicking people out of the program. As in the case in Georgia, a state may take heed of the errors in management and reform their policy. After all, I thought “two strikes” had to do with penal codes. That it’s really just plain common sense, to slowly reduce a recipient’s benefit as a least disruptive alternative. Also, some of these benchmarks can be misleading, such as part-time work and or substance abuse counseling. However, I foresee as the Democrats do and I seldom agree with that side of the aisle on anything, that the states may simply pressure their delegated agency, to deny assistance to needy families and without regard, to whether they have secured employment.

Alternative Suggestions/Recommendations: First and foremost, I need advise you as follows. As I for one, had anticipated filing a formal complaint to the DOJ and here in Michigan, to the Attorney General. Why you ask? Because this law appropriates tax dollars and with absolutely “no fiduciary controls” and thus, provides the means, methods and opportunity for both state misuse and recipient abuse of funds. Ergo, a taxpayer places his trust in the federal government and as to TANF, expects that the funding be protected from any or all tendencies for abuse. That the legislative content, must take into consideration a/the propensity for abuse, whereby a state or person cannot willfully be provided assistance and without any compensatory controls or proscribed penalties. Hence, I suggest the law is unconstitutional. But then again, what do I know. As I have no law degree, nor an -4- office on Capitol Hill. Although, what I do have, is a bit of experience in the area of, the less fortunate, peoples of lesser per capita income, illicit and prescription drug abuse, individuals with a depraved indifference to moral and social acceptance, such as the homeless/1000+hours of volunteer work. Child abusers and child protection/1000's of hours of the good with the bad. Domestic violence, bigotry and in general, some of the things we don’t talk about with the neighbors. Mitigation, mediation, litigation, statutory and case law. State, federal and international rights/treaties and conventions and explicably, worldwide human rights research. Politics and the media. All the while and understanding, that since I am an advocate for child and family rights, one can assume, that I cannot nor will not, take up a position, which negatively counter weights helping “our children”. Nor would it involve any posture, which opposes “family” assistance or as we, the CFSM view it, the “family unit”. Bearing in mind the above information, the following paragraph shall begin, in addressing the complaint and remedy.

Issue&Point #1: The federal government and for varying reasons, found it necessary to make changes in the food stamp program. Primarily, the elimination of paper and the introduction of a more suitable media, the “bridge card”. Although there were numerous reasons for this change, one of the primary concerns had to do with “fraud” or the use of “food stamps” for purposes, other than that for which they were so intended. Example, trading stamps for drugs. So now if you all knew this and since the stamps were suppose to be exchanged for food, to feed children, then what were you thinking when you drafted TANF? Let me put it this way and from an abuse perspective. If you are dealing with individuals who live in a downtrodden community, plagued by drugs. If 85% of the food stamp recipients are also TANF beneficiaries and they report to the same worker for both programs. Assuming, the direct correlation between the unfortunate fact, that they usually live in a somewhat impoverished environment and are usually single moms, or there are no parents in the home whatsoever. That unfortunately, “many of these recipients have past or current drug abuse histories”. Then and knowing, that if a person had traded stamps for food and within the old “paper oriented” media, then and going forward. Not only is the paramount issue here, about a child not getting fed. It goes well beyond that or any boundary of and or standard of conduct. As it’s really and moreover, all about the government’s complicity, in its facilitating a/the circumstance(s), which I submit, as extremely problematic. I mean, if you do not implement every possible control in order to avoid facilitating a user, then what you’ve become and within the proper context, is an “enabler”. Like it or not, that was a fundamental flaw in design, prior to the “bridge card”. Now don’t get me wrong, for not all people abuse drugs, gamble the money away or by some other means, simply waste this money, nor do they all try to cheat/circumvent the system. Yet, I’m here to tell you, that my experiences in the real world, or shall I say on the streets, tells me, that caution got thrown to the wind in this legislation. So my friends, it’s not all about books, blogs and the Internet. Further, and back to the issue. TANF has been doling out and at a pretty hefty clip, billions.

So, accordingly and I suggest, you take the running total to date, or $82+billion, divide by 20% or $16+, and you will be pretty close to my guesstimate of a/the, funded abuse rate. But do not embroil yourselves in numbers here. As, if you use just a single-cased example, the average cash assistance and on a monthly basis, is about $355 and that calculates to $70 per month, if you consider the 20% abuse rate theory. Although, I would hope, that more often than not, that the majority of recipients would not abuse the privilege. Whereby, most are not thieves and thus, do value the assistance. But and again, as a taxpayer, I take issue with the fact, that there are no control mechanisms at all, “none”. Not so much and due in part, to an irresponsible few, who abuse and waste funds, but due to the fact, that as a “child” advocate, I resent the children being deprived of its intended benefits. That is my friends, what this all about, isn’t it? Helping the ‘kids’ and helping the ‘family’ help themselves. In that, TANF is not a work program. It only serves, as a facilitator for an alternate strategy, and that certainly does not mean. Rule #1, funds to be used to buy employment and or for training tools. So lets get back to this $355.00 and with regards to, designing legislation to fix a problem. TANF not only hasn’t fixed much, its by my opinion, simply exasperated the problem or made it worse. Oh certainly, all sorts of people will jump up and scream, you this and you that. Political opinions abound, the states two cents, those ‘special interest’ groups, who represent the administrative side of the program and so on. Yet, at the end of the day and using a single minority mom in this example, try and digest the likelihood of this scenario.

I live in the inner city, didn’t finish high school or lets just say I did, have what’s called a “dead beat dad” for an ex, have no transportation, no money, few decent friends, clothes that may or may not be suitable for a job interview,,, let alone, ones I could wear to a job, live in a lousy sh--hole of a neighborhood,,,, surrounded by people with bad intent, the only close to home business is a party store or a Burger King,,,, if you’re lucky and thus, little to no hope for local employment, the house note or rent is 3 months past due, utilities add up to who knows what, with a couple in shutoff, and,,,,,oh well,

Now you take a long hard look at this picture and ask, I mean really ask yourself this. If faced with this dilemma and assuming a prior history of drug abuse, what would you do? So then this being the case, why in the hell would you put cash on a bridge card and without any audit trail capacity? Why does the act not require utility vendoring? Why does the act not require the recipient to submit documented proofs, say every “two” months, showing where the money was spent? Why no random drug testing? Some will argue this as unnecessary, expensive, or as an invasion of ‘privacy’ issue, and so on. But they are wrong! This all about protecting our investments in our children, our kids and I don’t mean by some claim of Parens Patriae. As I submit, you have opened the door to abuse here and I know it full well, I see it reflected in the abuse of children.

At midnight, another $355 goes on the card, “recipient A” goes to 24 hour banker. Drives, gets ride or walks to a dope house. Kids at home or with whomever. Mom returns home. All or some of the money is gone. Get the picture! Kids, we may run out of food and we’ll have to just make do. Little to no money goes towards any bills. But that’s OK, she’ll make it to Work First, maybe or one way or the other.

One way or the other and this what you call a good idea? Just going through the motions. Since this is just merely a sample and whereby, it could have just as easily been, a 20 year old white male, a 30 year old minority or anyone for that matter, in any town and in any state. But here’s the bottom line. In the absence of defining, controlling and tracking these expenditures, there can exist a propensity to consider the worst of the worst. For there is absolutely no way to gauge if and what benefits, are being derived from every dollar spent. Every billion dollars spent! So whether or not and to what varying degree TANF works, cannot be determined. Therefore, this law, is an open invitation to abuse and failure.

Work participation. Oh yes, the sidebar of TANF. Fostering self-sufficiency though work. Might make for great bedtime reading or as sound bites on FOX news, but that’s just about the extent of it. Good idea if it worked. My friends in Washington, now I can’t speak for our administrators here or to how other states have implemented TANF, but as an expert and taxpayer, I can certainly venture an opinion, as to how it’s done here in Michigan. I suggest it acts as a microcosm, into how the rest of the states operate. Here, a person signs up for Work First, shows up so many days per week, as required. Sits in a building with a bunch of others, who don’t wish to be there. Usually and mostly un/under educated and untrained for the most basic positions of employment. You learn how to do a resume. Some basic skill-sets, which relate to presenting yourself to a perspective employer. But that’s just about it. So lets assume, we have “recipient A” participating today, who’s paid $5 dollars, per each day of attendance. S/he learns how to do a resume, which when reviewed by a potential employer, gets s/he no foot in the door.

Not today, tomorrow or even next month. But they show up, participate, go along with “the program”, get no job and in “four” weeks its $355 on the card. There is “no” teaching of courses, just killing time. And why is there no mention of a mandatory requirement by the state to provide courses? You know like math, business, basic computer 101? Since I can recall, when I spent time working on one homeless program, some years back, and as a portion of my voluntary work. I developed and implemented, three basic little courses and Lord forbid, you’d be amazed how receptive the individuals were. They thoroughly enjoyed learning, as opposed to, just sitting around passing time. You do see the parallel here? So if you truly want to accomplish or gain anything from this legislation, these people need to be taught. Given hope and direction. Something, anything,,,,,,,,,,,,. At least, try and level the playing field and then if they fail, its on them, not on you. But as it stands, TANF and in its current state, is doomed to fail. It is and shall always be, only a money pit, full of wasted taxpayer dollars. Or, the same old same old of help, that doesn’t really help. And here we are, back to the realities of just another social program, that offers solutions that don’t work and performs but one function well.

Spending money. Now and lets assume for the sake of argument, that by the grace of God, she, recipient A, gets lucky. Somebody hires her. Now she has to get to work, find somebody to watch the kids, no matter if day care is supplementary, still got to find a babysitter. Get to and from work. Report the income to Work First, where it gets deducted from the $355.00. Try as you may, the job sucks, pay is minimal and through it all, you’re still barely keeping your head above water.

Oh yes, eventually some become self-sufficient. They do become productive members of society. No longer “burdens” to the taxpayer. But more often than not, they just become another one of your statistics. Caseload statistics if you will. Sometimes as one of the 17.2% closed due to employment. Or, just as a little piece of the 25.8%, who and for whatever reason, just couldn’t cut it. Still leaves over 50% of statistical data, which is in need of clarification. Or is this the part, where some state psychotherapist or a DHS director, goes on record and talks about “transparency”. How they are doing their utmost best, how much they truly empathize, with the plight of those less fortunate.

In closing, legislation is most always reactionary. It’s seldom drafted, in response to a problem, before it becomes one. Its not like some politician says, hey lets fix something that ain’t broke yet. Since and in a normal process, laws do not come into existence, other than by way of a necessary reaction. Usually dictated by a moral or social issue. Often by way of significant media coverage and with respect to, a particular issue of concern. So I would hope that you take a close-in look at this legislation and consider this picture. If the crafters of the TANF were painters, and assuming there to have been paint on the brush, I think that they must have been blinded by a greyness of purpose, when they misconstrued the ideological concepts in this document, known as TANF.

“There is no more fundamental test of a society than how it treats its children.” R. Reagan

CFSM, “Citizens for Social Morality”

W. David Dunkelberger, Director
17135 Forest
Eastpointe, MI 48021
PH. & FAX# (586) 445-1695


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