Last updated August 2023

Work verification plans provide an underutilized vehicle for exercising state flexibility in implementing TANF work requirements. Below, we first describe what is required of states then discuss how states can use their work verification plan to maximize the flexibility they have in operating their work programs.

States are required to submit a work verification plan to the Office of Family Administration to demonstrate how the state will verify the accuracy of the information that the state gathers and submits to determine its work participation rate (WPR). The work verification plan is a key component of how states are implementing the work requirements as laid out in the regulations promulgated after the passage of the deficit Reduction Act of 2005. A state’s work verification plan lays out how states will: (1) collect data for each of the 12 activities in which recipients must be engaged to count as meeting their required work participation requirement; (2) verify hours engaged in work and address issues such as excused absences, holidays and FLSA deeming; (3) identification of work eligible individuals; (4) implement internal controls to ensure consistent measurement; and (5) verify other data (e.g., characteristics of recipients) used in calculating the work participation rate. States can amend or update their work verification plan at any time.

Meeting the WPR is a requirement of states, not parents. States have total flexibility to decide which parents are subject to work requirements and what they must do to meet those requirements. States often conflate these two things and require all parents to be engaged in work activities that will count towards the WPR, but that is a state choice, not a federal requirement.

Because the majority of states meet their WPR primarily by counting the work hours of working parents, some states have modified their work verification plans to narrow the program activities on which they report data to the federal government. This has the potential to greatly reduce the administrative burden on staff and parents. For example, Texas — the first state to adopt this approach—only reports data on individuals who are working or completing a high school degree. Vermont and Massachusetts submitted a revised work verification plan and received approval to follow Texas’ approach. Kansas and North Dakota have both expressed interest in following this approach.

You can find details on what states are required to include in their work verification guide in this document: Work Verification Plan Guide | The Administration for Children and Families (hhs.gov).

Texas’ work verification guide can be used as a template for other states:  Work Verification Plan Guide (texas.gov). (State work verification plans can be obtained by requesting them from the state agency or through an online search.)

We have uploaded three documents produced by advocates in PA to encourage the state to adopt Texas’ approach to work verification. You can find those documents in the right column.

The Racial Impact and Human Toll of Federal TANF Hours Verification Requirements

How Pennsylvania Could Shift the Focus in its TANF E&T Programs from the Very Strict Verification of Hours Requirements Currently in Place to More Simplified Tracking of Participation and Outcomes, Without Compromising its Ability to Meet the Federal TANF Work Participation Rate

How TANF Employment and Training Activities Would be Tracked and Reported Under EPC’s E&T Participation Tracking Proposal