The "Superwaiver" Proposal and Service Integration: A History of Federal Initiatives

The "Superwaiver" Proposal and Service Integration: A History of Federal Initiatives

Order Code RL32859
CRS Report for Congress
Received through the CRS Web
The “Superwaiver” Proposal and Service
Integration: A History of Federal Initiatives
April 13, 2005
(name redacted)
Visiting Research Associate
Domestic Social Policy Division
Congressional Research Service ˜ The Library of Congress

The “Superwaiver” Proposal and Service Integration:
A History of Federal Initiatives
Summary
As part of the continuing debate over welfare reform reauthorization, the Bush
Administration has supported a proposal that would enable states to obtain waivers
from certain federal rules of various welfare-related programs in order to integrate
activities across a wide spectrum of social services. This proposal, often referred to
as the “superwaiver,” would provide broad waiver authority to executive branch
agencies that administer covered programs. The Administration has argued that
giving state and local authorities more flexibility to coordinate workforce and family
support programs can help to promote self-sufficiency among low-income families.
Waiver initiatives like the “superwaiver” are one type of approach to service
integration — a broad and more enduring policy issue that has been raised in
response to criticism that social service programs are fragmented, costly to
administer, and complicated for low-income families to maneuver.
Over the past 30 years, there have been numerous federal-level service
integration initiatives. In addition to waivers, approaches to service integration have
included grant management reform, administrative simplification, demonstration or
pilot projects, and block grants. Past federal efforts reveal that issues related to
potential costs and savings, programs to be covered, administering authority,
evaluations, and accountability are important components that can influence the
success of service integration initiatives. Ironically, the biggest lesson has been that
reform itself can be fragmented, and requires a great deal of effort and strong
leadership to coordinate and implement in its own right.
Lessons from past initiatives have shown that service integration requires
resources to execute in the short-run and it is not clear whether integration is cost-
effective in the long-run, taking these costs into account. Federal programs included
in integration efforts generally are those that provide services to meet “basic needs”
of low-income individuals and families, but the debate over which programs and
types of requirements to include can be highly political and lead to wide variation in
the types of projects undertaken. Designation of an organizational body with
authority to implement an initiative can facilitate federal participation, expedite
approval of projects, provide technical assistance, and act as an oversight entity.
Pilot and demonstration projects require substantive evaluations in order to compare
the effectiveness of varying types of inter-agency linkages and approaches to
integration to inform future efforts. Developing strong performance measures is
critical to enhancing accountability of service integration projects.
This report reviews the history, trends, and outcomes of past federal service
integration initiatives that might be seen as comparable to the current “superwaiver”
proposal. These past attempts are wide ranging, but related in the sense that they
have sought to cut across multiple federal program boundaries in order to give state
and local agencies more flexibility to integrate and coordinate programs that serve
the same or overlapping low-income populations.

Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Service Integration Defined . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Scope of Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Overview (1968-Present) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Service Integration Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Integrated Grants Administration (IGA) Program, 1972 . . . . . . . . . . . . . . . 13
Service Integration Targets of Opportunity (SITO), 1972 . . . . . . . . . . . . . . 15
Joint Funding Simplification Act of 1974 (P.L. 93-510) . . . . . . . . . . . . . . . 16
Allied Services Act 1975 (H.R. 9981/H.R. 10248) . . . . . . . . . . . . . . . . . . . 17
Eligibility Simplification Projects, 1980 . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Omnibus Budget Reconciliation Act of 1981 (OBRA, P.L. 97-35) . . . . . . 20
1984 Deficit Reduction Act (P.L. 98-369) . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Low-Income Opportunity Improvement Act of 1987
(S. 610/H.R. 1288) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Community Opportunity Act of 1991 (S. 1529) . . . . . . . . . . . . . . . . . . . . . 25
Local Empowerment and Flexibility Act of 1996 (S. 88) . . . . . . . . . . . . . . 26
Welfare Reform Reauthorization 2004 (H.R. 240) . . . . . . . . . . . . . . . . . . . 27
Lessons Learned . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Costs and Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Programs Covered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Administering Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Accountability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Issues Facing the “Superwaiver” Proposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Appendix A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Timeline of Federal Service Integration Initiatives (1968-Present) . . . . . . . 37
Illustration of Integrated Grants Administration (IGA) . . . . . . . . . . . . . . . . 37
Appendix B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Examples of Projects Funded through the Integrated Grants
Administration (IGA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Examples of Service Integration Targets of Opportunity (SITO) Projects . 36
Examples of Service Integration Pilot Projects (SIPP) Authorized by
the 1984 Deficit Reduction Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
This report was written by (name redacted), a Presidential Management
Fellow on detail from the U.S. Department of Health and Human
Services, under the supervision of (name redacted), Domestic Social Policy
Division.

The “Superwaiver” Proposal and Service
Integration: A History of Federal Initiatives
Introduction
As part of the continuing debate over welfare reform reauthorization, the Bush
Administration has supported a proposal that would enable states to obtain waivers
from certain federal rules of various welfare-related programs in order to integrate
activities across a wide spectrum of social services.1 This proposal, often referred to
as the “superwaiver,” would provide broad waiver authority to executive branch
agencies that administer covered programs.2 The Administration has argued that
giving state and local authorities more flexibility to coordinate workforce and family
support programs can help to promote self sufficiency among low-income families.
This initiative has rekindled long-standing discussions about service integration, an
issue that has confounded and perplexed policymakers and program administrators
for more than three decades.
This report reviews the history, trends, and outcomes of past federal initiatives
to integrate social services that might be seen as comparable to the current
“superwaiver” proposal. These past attempts are wide ranging and have included
efforts to reform the federal grant management system, implement small-scale pilot
or demonstration projects, as well as simplify administrative regulations across
programs. They are related in the sense that they have sought to cut across multiple
federal program boundaries in order to give state and local agencies more flexibility
to integrate and coordinate programs that serve the same or overlapping low-income
populations. Much of the discussion in this report transcends the “superwaiver”
debate, and can be understood as an analysis of service integration as a long sought
after policy objective.
Reforming the delivery of public assistance programs through service
integration has generally gained support as a way to improve the cost effectiveness
and efficiency of programs, and to more comprehensively meet the needs of the low-
income population. Yet, certain tradeoffs can occur when categorical programs are
integrated. It is argued that some groups may in fact be better protected at the federal
level by prescriptive regulations and mandates, especially if integrated services result
in different constituency groups battling each other for resources at the state and local
levels. This perspective prompts larger disputes about federalism and the role of the
1 For information on the current status of this proposal, see CRS Report RS21219,
“Superwaiver” Proposals in the Current Welfare Reform Debate, by (name redacted).
2 The proposed waiver authority has been referred to as a “superwaiver,” “state flex”
authority, and “Ticket to Independence.” In its current legislative form it is titled, “Program
Coordination Demonstration Projects.”

CRS-2
federal government in establishing national objectives, which is one reason why the
debate about service integration is so enduring.
Apart from these differences, service integration has become a recurring issue
at all levels of government. The sheer number of separate categorical programs and
the amount of money being spent makes it hard to disagree that at least some
integration is desirable. Yet, determining what actions the federal government can
or should take to create a more integrated, coordinated system and how far it should
go, generates ardent disagreement. Past federal efforts reveal that issues related to
potential costs and savings, programs to be covered, administering authority,
evaluations, and accountability are important components that can influence the
success of service integration initiatives.
Context
In FY2002, approximately 85 means-tested federal benefit programs provided
varying forms of cash and non-cash assistance directed towards low-income
individuals and families. These programs, including Medicaid, the Earned Income
Tax Credit (EITC), Temporary Assistance for Needy Families (TANF), Food Stamps,
Section 8 housing assistance, the Child Care and Development Fund (CCDF) and the
Social Services Block Grant (SSBG), cost an estimated $522.2 billion in that year.3
Congress has created these programs at different points in time to meet distinct needs
of various segments of the low-income population. However, when viewed as a
whole, the programs prompt concerns that the federal social assistance system has
become costly to administer and complicated for low-income families to maneuver.
Across programs there exist different funding formulas, eligibility criteria, reporting
procedures, data collection requirements, performance measures, and accountability
standards. State officials contend that federal funding “silos,” and conflicting
regulations make it difficult to serve all the needs of families comprehensively and
efficiently.4 For the most part, federal assistance programs operate in relative
isolation of each other, despite the fact that many of them target similar populations
and have related goals.
Service integration proposals are challenging from the federal level for systemic
reasons, among others. The nature of the legislative process itself provides
incentives to individual lawmakers to sponsor programs that deliver distinct and
identifiable benefits to narrowly drawn constituencies.5 Over time, this has meant the
3 CRS Report RL32233, Cash and Noncash Benefits for Persons with Limited Income:
Eligibility Rules, Recipient and Expenditure Data, FY2000-FY2002, compiled by (na
me redacted).
4 Some have referred to federal executive branch agencies as “silos,” to describe the degree
to which the organizational structure of federal departments inhibits coordination between
agencies operating similar programs.
5 In his book From New Federalism to Devolution: Twenty-Five Years of Intergovernmental
Reform (Washington: Brookings Institution Press, 1998), Timothy Conlan argues, “Narrow
(continued...)

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creation of an assortment of social service programs. Yet, for as long as these
programs have existed Congress has had an interest in coordinating and making them
work better together. During a 1991 hearing, Representative Bill Emerson expressed
a common sentiment that arises in discussions of service integration:
I think we all agree that all of the programs we are talking about have been well
intentioned. The problem is over a period of time, there are so many programs,
and there is so much conflicting jurisdiction, that there has been a lot of
confusion.... The solution may be combining some of these programs, and
addressing the needs of the individual or whole person, rather then a piecemeal
solution. I think everybody wants to solve these problems and I don’t think the
differences are as much philosophical as they are practical, in terms of what
works and gets results.6
The structure of congressional committees also creates a disjuncture of authority
over many closely related social service programs, which can stall momentum for
reform. Committees with related or overlapping jurisdictions may resist proposals
to integrate or consolidate programs, in order to preserve their powers of oversight
and authorization, and to balance conflicting interests. Additionally, many advocacy
and lobbying groups have an established interest in the continuation of existing
programs, and they may object to proposals that would merge them into
comprehensive general service packages. Thus, the heavy power of the “status quo”
can dampen efforts that involve large-scale change. These systemic realities are not
necessarily insurmountable, but they do establish the predispositions of political
players and the preference for particular outcomes.
Institutional power struggles, whether between states and the federal
government or the executive and legislative branches, can also generate challenges
to service integration. State and local grantees that administer federally funded
programs have long sought flexibility and sometimes advocate waivers as a way to
better integrate services. At the same time, Congress seeks to ensure accountability
and the fiscal and programmatic integrity of programs established to meet national
goals. This necessarily involves at least some federally imposed requirements,
guidelines, and procedures. Additionally, some approaches to service integration,
like waivers, give more authority to executive branch agencies to administer and
approve projects.
Several arguments are used to promote integration of public assistance
programs. One is to make more sense of the programs from the perspective of the
individual seeking help. There is the rationale that the causes of poverty are multiple
and inter-related, therefore providing preventative and comprehensive services can
5 (...continued)
categorical programs permit members of Congress to obtain particularized benefits
corresponding to their own constituency needs, and they can do so in such a way that
members can be identified with a program for advertising purposes, announcing grant
awards and so forth,” (p. 41).
6 U.S. Congress, House Select Committee on Hunger, Coordination and Simplification of
Public Assistance Programs: Today’s Efforts, Tomorrow’s Solutions, hearing, 102nd
Congress, 2nd sess., Serial no.102-3, Apr. 23, 1991.

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be a more effective way to help low-income families and individuals. One 1976
document published by the Department of Health, Education, and Welfare (HEW),
used the following statistic on program fragmentation to support its case for service
integration:
Studies indicate that between 85% and 95% of all HEW clients have multiple
problems, and that single services provided independently of one another do not
result in changes in a client’s dependency status or life chances. Frequently, the
failure to receive referred services prevents clients from benefitting from a
service already provided.7
Integrated services can also make programs more compatible so that caseworkers
may face fewer obstacles and be better able to perform their jobs. From the efficiency
perspective, integrated programs could help to reduce administrative costs by taking
advantage of economies of scale, reducing overlap, and utilizing cost-sharing across
programs.
Critics of the current “superwaiver” proposal argue that existing waiver
authority within social service programs, as well as flexibility in block grants such
as TANF and SSBG, have so far been successful at increasing program coordination,
and that broad sweeping waiver authority is not needed. These groups contend that
giving the executive branch new powers would compromise congressional authority,
and is not necessary to achieve better integration of services. The Center on Budget
and Policy Priorities (CBPP) argues
There are, to be sure, areas in which states could use further flexibility to define
certain program parameters or better align programs that serve similar
populations or provide similar services. These matters can be addressed,
however, without the radical shift in governance and risks to low-income families
that the superwaiver poses.8
Others contend that states may have other reasons for promoting flexibility in certain
areas. For example, in many discussions of service integration states bring up rules
related to cost allocation as a barrier to integrating programs. There is concern
among some federal administrators that these issues have more to do with states’
ability to maximize revenue by shifting federal funds between programs, than with
the intent of providing integrated services. Lastly, questions have been raised about
the range of possibilities for service integration under current law.9 While legal and
7 Sidney Gardner, “Roles for General Purpose Governments in Services Integration,” Human
Services Monograph Series, no. 2, Oct. 1976. Project SHARE, A National Clearinghouse
for Improving the Management of Human Services.
8 Robert Greenstein, Shawn Frenstad, and Sharon Parrott, “‘Superwaiver’ Would Grant
Executive Branch and Governors Sweeping Authority to Override Federal Laws,” Center
on Budget and Policy Priorities (CBPP), June 11, 2002.
9 Mark Greenberg (CLASP) and Jennifer Noyes (Hudson Institute), Increasing State and
Local Capacity for Cross-Systems Innovation: Assessing Flexibility and Opportunities
under Current Law: Implications for Policy and Practice, Jan. 2005. A collaborative effort
was undertaken by the National Governors Association, the Hudson Institute, and the Center
(continued...)

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regulatory requirements pose some barriers at the federal level, service integration
also requires a significant amount of resource investment and technical expertise to
execute at the state and local level. Federal barriers may only be one of many
obstacles to implementing a strategy for service integration.
Over the past 30 years, public assistance programs have evolved through various
federal and intergovernmental reform efforts. In the last decade, there has been a
greater tendency to block grant programs in order to devolve more flexibility and
decision-making authority to state and local governments.10 The context has also
changed in response to the transformation of federal priorities related to the welfare
system. There is a strong emphasis on employment and support services to provide
the framework for sustained independence from federal assistance. Lawmakers have
recognized that low-income families moving from welfare to work require services
that address multiple needs. These may include employment and education services,
assistance with child care, access to medical care, and help finding affordable
housing. This rationale has provided renewed vigor for concerns that a family
experiences these needs concurrently and as inter-related, but federal programs
continue to address them as isolated problems. Also, a growing literature on service
integration has provided an academic and political forum for discussions of past
efforts and current policy.11
Service Integration Defined. Service integration is an unwieldy topic in
many respects, but even at the most basic level it is also difficult to define.12 Past
9 (...continued)
for Law and Social Policy (CLASP) to establish a better understanding of flexibility,
opportunities, and barriers that exist under current law with respect to service integration.
10 Block grants are generally understood to be fixed-sum federal grants to states that give
them broad flexibility to design and implement designated programs. In contrast,
categorical grants often include prescriptive federal requirements and must be used for more
narrowly defined purposes.
11 Two past initiatives, funded by the federal government have contributed to this literature
base. In 1974 the Department of Health, Education, and Welfare initiated Project SHARE,
a national clearinghouse to improve the management of human services. Also called the
Human Service Monograph Series, the project produced a collection of papers on service
integration and related topics that were compiled for public access. In 1991, grants from the
Department of Health and Human Services partially funded the establishment of the
National Center for Service Integration. The center’s mission was to actively support
service integration efforts by serving as an information clearinghouse for documents,
programs, and organizations.
12 The most often cited definition of services integration originated with HEW Secretary
Elliot Richardson in a June 1971 departmental memorandum. “Service integration refers
to ways of organizing the delivery of services to people at the local level. Services
integration is not a new program to be superimposed over existing programs; rather, it is a
process aimed at developing an integrated framework within which ongoing programs can
be rationalized and enriched to do a better job of making services available within existing
commitments and resources. Its objectives must include such things as: (a) the coordinated
delivery of services for the greatest benefit to people; (b) a holistic approach to the
individual and family unit; (c) the provision of a comprehensive range of services locally;
(continued...)

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approaches have focused on different goals and outcomes, which have reflected
varying understandings of what service integration means to particular individuals,
groups and programs. In 1986, the General Accounting Office (GAO) issued a report
that provided an inventory of service integration demonstration projects completed
between 1970 and 1985:
We found that there is not a universally agreed-upon definition of service
integration. To some, service integration means co-location of service providers,
combined case management, common application forms, and shared client data.
To others, it means system accountability and accessibility combined with
efficient and effective services provided at the most reasonable cost.13
Organizations that seek to integrate services may differ in administrative structure,
budget, size, target population, geographic boundaries, and staffing, all of which can
affect the scope and impact of reforms. Service integration has also been described
as existing on a continuum ranging from loosely coordinated services, to
collaboration, and finally to integration.14
In general, the literature tends to distinguish between two approaches to service
integration: service-oriented and system-oriented reform. Service-oriented
integration is client and case management focused, with the goal of linking clients
to a broad range of services that address multiple family needs. Examples of these
efforts are co-location of services, joint applications and eligibility determination,
and cross-training of staff. System-oriented reforms would change administrative
and service delivery structures to facilitate integrated management and coordination
of programs across state, county and/or local agencies.15 Examples of system-
oriented reforms are eliminating conflicting eligibility and benefit rules among
service programs, changing how agencies plan and finance services, reorganization
of public agencies around a common population, or offering fiscal and performance
incentives to increase coordination between agencies.
For the most part, service integration must take place at the state and local levels
because that is where services are accessed by recipients. Yet, many public
assistance programs are funded with a mix of federal, state, and local dollars, which
(...continued)
and (d) the rational allocation of resources at the local level so as to be responsive to local
needs.”
13 U.S. General Accounting Office (GAO), Fact Sheet for Congressional Requesters,
Welfare Simplification: Projects to Coordinate Services for Low-Income Families,
GAO/HRD-86-124FS, Aug. 1986. (GAO was renamed the Government Accountability
Office in 2004.)
14 See CRS Report 93-369, Linking Human Services: An Overview of Coordination and
Integration Efforts, by (name redacted). (Archived, available from the author upon
request: 7-.....)
15 It is important to note that some system-oriented efforts, can have substantial implications
for program costs. For example, eligibility requirements limit benefits to a certain
population of low-income recipients. Conforming eligibility rules across programs could
result in many more individuals being eligible for certain services and greatly increase costs.

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means large-scale attempts at integration require an intergovernmental effort.
Conflicting regulations and fragmentation of these programs at the federal level can
impede state and local efforts that would otherwise bring programs together. As a
result, many service integration reforms at the federal level have focused on system-
oriented changes that remove structural obstacles to integration. Federal system-
oriented reforms have included initiatives to reform the management of federal
grants, devolve decision-making power and flexibility to states, incorporate state
options into statutes authorizing programs, and efforts to simplify administrative and
reporting rules across programs. Giving states the opportunity to apply for waivers
of certain federal requirements, as the “superwaiver” proposal would do, is also a
system-oriented reform intended to increase flexibility to integrate services within the
existing federal framework.
Drawing from the experience of past efforts, much more is now understood
about the barriers to integration. Instability, both fiscal and political, can hinder the
capacity of any level of government to follow through with and maintain programs
over the long run. Service integration requires strong leadership and a successful
advocate to bring all the parties into the planning process. Studies have found that
as individual champions of projects retire or move on, support for and cooperation
with initiatives has dissipated.16 There are often differing geographical boundaries
for program service areas. Turf issues such as loss of autonomy, distrust of other
agencies, and differences in philosophy for serving clients can be substantial barriers.
State and local agencies running separate programs have an established “culture” that
often conflicts. Program administrators can be reluctant to merge their program and
change methods of operation. Integration may require co-location, changes to
personnel organization and job responsibilities, and training that requires a high
degree of cooperation and commitment from employees. Issues such as protecting
client confidentiality can be a barrier to sharing data and technical integration of case
management systems. Finally, service integration projects can require significant
resources and technical knowledge of multiple programs to implement.
Scope of Report. This report covers broad, federal-level service integration
efforts inclusive of multiple programs that bridge agency boundaries, like the
“superwaiver” proposal. Distinct from these initiatives, there have been many other
federal attempts to coordinate and integrate services within individual programs that
focus on particular sets of problems or populations. It is worthwhile to give a brief
synopsis of these “within” program efforts to provide some perspective on what can
be an infinitely expansive issue. Targeted programs in which service integration or
coordination is a major feature include those serving children with disabilities, senior
citizens, low-income families with children, and programs that coordinate federal
employment and training services. For example:
16 A 1972 evaluation of service integration projects in the Department of Health, Education,
and Welfare found that a project’s leader was an important predictor of success. It said,
“The study provides support for the ‘great man’ theory that the personality of the project
director is one of the most important factors in services integration. Leadership,
persuasiveness, commitment, and personal contact with political sources ... appeared to be
those attributes which had the greatest positive impact.” Marshall Kaplin, Gans and Kahn,
Integration of Human Services in HEW: An Evaluation of Services Integration Projects,
Volume I (San Francisco, CA 1972).

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! The Individuals with Disabilities Education Act (IDEA) authorizes
funding for special education and related services for children with
disabilities and their families.17 Part C authorizes grants to assist
states in developing coordinated and comprehensive service delivery
programs. The purpose is to have one accessible system that
delivers education and early intervention services to infants and
toddlers with disabilities, as well as their families. Included are
individualized family service plans, interagency participation,
training of personnel on available early intervention services and
referral sources, and a single line of responsibility for
implementation within the state.
! The Older Americans Act provides funding for the delivery of a
wide-range of social and nutrition services for older persons.18 Title
III authorizes grants to states to coordinate six separate service
programs for the elderly. Services are targeted toward low-income
minority seniors, and older persons living in rural areas. The Act
has been amended several times to improve coordination of services
by consolidating the otherwise separate programs for nutrition,
social services, and multi-purpose senior centers into one grant
program.
! The Personal Responsibility and Work Opportunity Reconciliation
Act of 1996 (PRWORA) created the Temporary Assistance for
Needy Families (TANF) block grant. TANF devolved substantial
flexibility to states to create and manage welfare programs, with
some federal time-limits and work requirements. PRWORA also
established the Child Care and Development Fund (CCDF), which
consolidated previously separate child care programs for welfare and
other low-income families in the workforce. To further promote
flexibility states can transfer up to 30% of TANF funds to CCDF or
the Title XX Social Services Block Grant (SSBG)19 in order to
provide additional services to low-income clients.
! The Workforce Investment Act of 1998 (WIA) was enacted to
consolidate, coordinate, and improve employment, training, literacy,
and vocational rehabilitation programs under a single federal
training system.20 Under WIA, local area workforce investment
boards administer a variety of employment and training services for
17 See CRS Report RL32716, Individuals with Disabilities Education Act (IDEA): Analysis
of Changes Made by P.L. 108-446, by (name redacted) and (name redacted).
18 See CRS Report RL31336, Older Americans Act: Programs and Funding, by Carol
O’Shaughnessy.
19 Within the 30% transfer limit, no more than 10% of TANF funds may be transferred to
the SSBG.
20 See CRS Report 97-536, Job Training Under the Workforce Investment Act (WIA): An
Overview, by (name redacted).

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youth, adult and dislocated workers offered through “one-stop”
delivery systems that provide a central location for accessing
multiple services.
Many existing federal assistance programs also allow states and localities to
request waivers from certain requirements within individual programs. These
waivers are authorized by Congress and usually give the secretary of the department
overseeing a program discretion to allow grantees to be exempt from certain statutory
or regulatory provisions, if necessary to meet a particular goal. For example, in
Medicaid and the State Children’s Health Insurance Program (SCHIP), the Secretary
of Health and Human Services (HHS) has authority to grant demonstration waivers
to states to test restructuring of their programs for the delivery of health care services
and to adapt programs to local areas.21 In Medicaid, states have used waivers to
cover non-Medicaid services, to change eligibility criteria to provide coverage to new
groups, and to expand contracts with managed care plans. Congress has also
authorized the U.S. Department of Agriculture (USDA) to approve waivers of certain
food stamp rules to increase access and reduce the reporting burden on families.
Food stamp waivers can be related to program eligibility, reporting requirements, and
other options related to serving TANF recipients. A 2002 GAO study on waivers in
the food stamp program found that almost all states used options or waivers to
change their food stamp eligibility determination process, and more than half used
options or waivers to make TANF families automatically eligible for the program.22
Finally, several state and local level “lighthouse” projects have implemented
service integration reforms. A paper prepared for the Enhancing the Capacity for
Cross-Systems Innovation Project found that “[d]espite the legitimate impediments
to service integration that flow from federal program and regulatory silos, a number
of local sites have been successful in developing and implementing integrated service
systems.”23 A 2003 study conducted by the Rockefeller Institute of Government
highlighted 12 sites that significantly restructured their human service systems,
specifically related to provision of TANF, Medicaid and Food Stamp benefits, as
examples of comprehensive service reform.24 These sites varied in the type and
scope of projects undertaken. Examples included San Mateo County, California,
which created a large Human Services Agency to act as a single administrative unit
for operation of multiple human service programs. The agency regionalized
operations and gave local offices flexibility, offered clients one-stop access to
services, and established common intake processes, family self-sufficiency teams,
21 See CRS Report RS21054, Medicaid and SCHIP Section 1115 Research and
Demonstration Waivers, by Evelyne Baumrucker.
22 U.S. General Accounting Office, Food Stamp Program: States’ Use of Options and
Waivers to Improve Program Administration and Promote Access, GAO-02-409, Feb. 2002.
23 Tom Corbett and Jennifer Noyes, Enhancing the Capacity for Cross-Systems Innovations
Project, “Toward a Framework for Integrating Welfare, Workforce, and Human Service
Systems — Securing the ‘Holy Grail’ of Public Policy at Long Last?” Mar. 2004.
24 Mark Ragan, Casey Strategic Consulting Group, Rockefeller Institute of Government,
Prepared for the Annie E. Casey Foundation, “Building Better Human Service Systems:
Integrating Services for Income Support and Related Programs,” June 2003.

CRS-10
and collaboration with community partners. The state of Nebraska implemented an
automated eligibility determination and case management system, called N-FOCUS,
which integrated 27 human service programs, including child welfare case
management. These and other sites have provided examples of innovative solutions
and best practices for integrating services at the local level.
Overview (1968-Present)
Service integration initiatives undertaken by Congress or executive branch
agencies over the last 30 years can be divided among five major categories. While
these headings are not mutually exclusive, they provide an organizational structure
from which to consider past approaches.
! Grant Management Reform — Initiatives to simplify the federal
process for managing grants-in-aid to states, to devolve more
decision-making authority to state and local governments, and/or to
streamline the process for obtaining grant funds from multiple
federal sources.
! Administrative Simplification — Federal interagency initiatives to
address the complexity of administrative, regulatory or reporting
requirements through which different public assistance programs
were operated.
! Demonstration or Pilot Projects — Congressionally authorized or
supported through discretionary funding from executive branch
agencies to test methods of integrating services, often including the
option of obtaining waivers.
! Block Grants — Initiatives to consolidate federal funding into block
grants that give states broader flexibility to design and implement
designated programs.
! Waivers — Allows states, local grantees or pilot projects to request
waivers from certain federal requirements in covered federal
programs in order to coordinate and integrate social services.
It is difficult to pinpoint the definitive introduction of service integration within
the federal government, yet lawmakers formally began to grapple with this idea
during the 1960s. A surge in interest coincided with exponential increases in federal
expenditures on social assistance programs, many of which emerged isolated and
fragmented from one another. Federal financial assistance to state and local
governments and other organizations increased from $3 billion in FY1955 to an
estimated $52 billion in FY1975.25 As the number of categorical federal programs
increased, shortcomings in the system became evident. According to a 1979 GAO
report, “Studies showed that red tape, delays and vast amounts of paperwork were a
characteristic common to most federal programs. Each program had it own unique
requirements for application and administration. Because most new programs were
25 U.S. General Accounting Office, Report to Congress by the Comptroller General, The
Integrated Grant Administration Program — An Experiment in Joint Funding, GGD-75-90,
Jan. 1976.

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developed without sufficient regard to existing programs, many requirements were
inconsistent among related programs.”26 As a result, Congress sought to simplify and
streamline the federal grants process to promote better coordinated projects and
services at the state and local levels. Grant management reform focused on
decentralization both in the 1960s and again in the 1980s with the Reagan
Administration’s block grant proposals.
In the late 1960s, President Lyndon Johnson established the “War on Poverty,”
which created several programs, including the Community Action and Model Cities
programs that made coordinated planning and comprehensive service delivery a core
feature. The Community Action Program (CAP), part of the Economic Opportunity
Act of 1964 (P. L. 88-452), was administered through non-profit agencies working
at the local level to combine and direct a wide range of federal, state, local and
private resources as a mounted attack on poverty. These local anti-poverty agencies
worked to integrate educational, employment, welfare, health, housing, and other
social services at the grassroots level to meet the dynamic needs of poor families.
The Model Cities program, created in 1966 by the Demonstration Cities and
Metropolitan Development Act (P.L. 89-754), was also designed to coordinate
resources and assistance in impoverished communities. The goal was to unify the
efforts of agencies providing social assistance in designated metropolitan areas.
Evaluations of the Community Action and the Model Cities programs found in
many cases, a lack of political support at both the federal and state level prevented
sufficient resources from being invested to provide comprehensive services.
Planning officials did not have the authority to bring federal agencies and service
providers together, which also limited the success of the programs. While these
efforts centered on supporting the role of non-profits, similar problems related to
leadership and authority structures within different levels of government have
resurfaced in later service integration initiatives, and have proven to be formidable
barriers.
In 1969, the Nixon Administration made integration and responsive government
a key part of its domestic agenda, called “New Federalism.” This policy focused on
the role of general purpose government, moving operational authority over federally
funded social programs to the states, and implementing revenue sharing between the
federal government and states. Nixon launched the Federal Assistance Review
(FAR), a government-wide effort to cut red tape and place greater reliance on state
and local governments.27 Nixon appointed Elliot Richardson, a strong proponent of
service integration, as Secretary of Health, Education and Welfare (HEW) in 1970.
Both HEW and the Office of Management and Budget (OMB) conducted small-scale
pilot projects to test methods and replicable models for achieving a management
system that facilitated integration, paving the way for future legislative proposals.
Following Nixon, under the Ford Administration, two important service integration
bills were introduced in Congress and one was enacted. From 1974 to 1980, the focus
26 U.S. General Accounting Office, Report by the Comptroller General, Perspectives on
Intergovernmental Policy and Fiscal Relations, GGD-79-62, June 28, 1979.
27 Office of Management and Budget, Responsive Federalism: Report to the President on
the Federal Assistance Review, Jan. 1973.

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shifted away from reform of grants management to simplification of funding and
eligibility requirements in public assistance programs.
In 1981, the Reagan Administration introduced its budget reform plan, which
included block grants as a way to reduce the deficit and devolve program
responsibility from the federal to state and local levels. The Administration argued
that through block grants, overlapping programs would become better coordinated
and linked, which would lead to lower administrative costs and overall savings for
the federal government. OMB reported in FY1980, that 75% of grant-in-aid
expenditures were through categorical grants.28 President Reagan proposed to
consolidate 90 categorical program grants providing federal financial assistance to
state and local governments. Again, the debate was framed around alternative
funding mechanisms and devolution of management to states.
In the mid-1980s, state and local governments continued independently to
embark on their own projects working from the bottom-up, many supported by
funding from non-profit organizations and foundations. Throughout the 1990s,
service integration began once again to manifest itself in the form of pilot and
demonstration projects that allowed waivers of certain federal program requirements.
Since the late 1990s, waivers and block grants have become the chief elements of
proposals to promote state flexibility and innovation.
The following section of this report provides an overview of legislative and
executive branch service integration initiatives that have occurred over the last three
decades. While this is not an exhaustive review, it does highlight the major kinds of
approaches employed by the federal government to move toward integration, namely
reform of grant management, administrative simplification, pilot or demonstration
projects, block grants, and waivers.
Service Integration Initiatives
Two initiatives acted as important precursors for subsequent service integration
efforts that occurred throughout the 1970s. These were broad, full-scale efforts to
streamline and integrate grant administration management processes and
intergovernmental activities. The Intergovernmental Cooperation Act in 1968 and
President Nixon’s Federal Assistance Review (FAR) in 1969, set the context for
several significant service integration proposals discussed in this report.
Intergovernmental Cooperation Act of 1968 (P.L. 90-577). The
Intergovernmental Cooperation Act was intended to improve the administration of
federal categorical grants-in-aid to the states to achieve more coordination of
activities among federal, state and local governments. The law was created in
response to concerns raised by states that federal assistance programs providing
grants directly to local agencies (schools, health centers, transportation agencies)
created fragmentation and bypassed consideration of state and local government
priorities. The law authorized OMB to develop a nationwide system for federal grant
28 Sandra Osbourn, Block Grants: An Approach to Restructuring the Federal Aid System,
Congressional Research Service, Feb. 1981. (Archived, available on request.)

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project review and notification across more than 100 programs through
clearinghouses established in each state.
OMB created the Project Notification and Review System (PNRS), a formal
process for applying for federal grant funds.29 PNRS gave state and local
governments the opportunity to review and comment on the consistency of proposed
federally assisted projects with state, regional and local policies. As of 1971, three
years after the law was enacted, a review by the Council of State Governments found,
“State action to date has largely been procedural with many of the vital potential
opportunities of the Act yet to be realized.”30 The process, essentially governed
through two OMB-issued circulars, left much of the impetus to the states to
understand and take advantage of the new system. The clearinghouses and the
framework for the PNRS system lasted about a decade.
Federal Assistance Review (FAR), 1969. The Federal Assistance Review
(FAR) was a government-wide effort spanning from March 1969 to June 1973.
OMB and 14 other federal agencies were brought together to review mechanisms for
placing greater reliance on state and local governments, and to simplify the process
for obtaining funds from multiple federal sources. The review resulted in a 10-point
program that included guidelines for achieving these goals.31 These included
establishment of 10 standardized regions for 75 major federal agencies and bureaus
with field offices. Sharing common jurisdictions and headquarters through co-
location was a way to more easily coordinate programs across traditional agency
boundaries. Concurrently, Federal Regional Councils (FRC) consisting of
representatives from seven major federal grant-making agencies were created to
facilitate large-scale tasks that involved more than one federal department. FAR also
emphasized decentralization of operational authority to regional offices, greater
reliance on state and local governments for administration of programs, and
streamlining of paperwork and procedures in programs. Two initiatives discussed
in this report, the Joint Funding Simplification Act of 1974 and the Integrated Grants
Administration in 1972, were both ideas proposed by the FAR.
With these two preceding efforts in mind, the following section provides a
history of service integration initiatives by Congress or executive branch agencies
with an analysis of the purpose, features, and outcomes for each. (See Appendix A,
Figure 1.)
Integrated Grants Administration (IGA) Program, 1972
Category: Grant Management Reform/Pilot Projects
Purpose. Initiated by OMB, IGA was an experimental program that
authorized pilot projects to test a new method of allowing grantees to draw down
29 Council of State Governments, Coming Together, the Intergovernmental Cooperation Act
of 1968: Survey of Federal and State Implementation, July 1971, p. 17.
30 Ibid., p. iii.
31 Office of Management and Budget, Responsive Federalism: Report to the President on
the Federal Assistance Review, Jan. 1973.

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funding from several different federal assistance programs for use in a single
comprehensive services project.32 This concept was included in FAR, and
encouraged greater financial and technical state involvement in solving local
problems through the development of programs with coordinated activities and
shared staff. IGA was intended to eliminate the need for grantees to use different
forms and follow different administrative procedures for each grant-making agency.
(For examples of IGA projects see Appendix B.)
Features. The IGA program was cost-neutral, and not in itself a source of
federal funds. It acted as a mechanism through which existing appropriated federal
funds could be combined into a single funding stream for use by a grantee. (See
Appendix A, Figure 2.) The primary features of the program were the use of a
single grant application, synchronized funding, and a single audit. Federal Regional
Councils were responsible for administering IGA regionally and acted as the initial
point of contact for processing applications. They also acted as moderators between
grantees and federal agencies throughout the application and grant process. A
detailed system for notification, application processing, and execution of grants was
set-up to manage the IGA program. Projects could be funded by one grant award
notice, rather than several grant awards each with its own funding period. This also
allowed for a single financial reporting system. Funding normally lasted for 12
months, and an annual audit of each project was required within six months after the
project was completed. Considerable flexibility was given to potential grantees in
proposing projects and programs for funding under IGA.
Outcomes. In total, the IGA redirected $33 million in appropriated funds to
24 approved projects. A report submitted by the Comptroller General, “The
Integrated Grant Administration: An Experiment in Joint Funding,” reviewed six
IGA projects in New York, Atlanta, Kansas City, and Seattle. These projects
included a wide variety of initiatives such as coordination of human services at the
city level, comprehensive services for migrant workers, social and health services for
urban Indians, and a regional council established to plan the development of a river
basin area involving two states and six counties. The report found that the projects
only partially achieved their intended benefits. The following difficulties were
identified:
! A lack of coordination and commitment among federal agencies.
While FRCs acted as moderators between federal agencies and
grantees, they lacked the authority to create the collaboration and
commitment that was needed from federal agencies.
! Only one of the six IGA projects reviewed actually received a single
grant award with synchronized funding periods. The other projects
had funds awarded separately due to statutory and administrative
restrictions and delays across agencies.
! Grantees did not always properly allocate costs across each federal
program, resulting in inaccurate accounting of expended funds. This
32 U.S. General Accounting Office, Report to Congress by the Comptroller General, The
Integrated Grant Administration Program — An Experiment in Joint Funding, GGD-75-90,
Jan. 1976.

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jeopardized the ability of agencies to maintain the integrity of
appropriations for individual programs.
! The IGA process was more time consuming for federal agencies and
an expansion of the experimental program would have required
additional staff resources.
Service Integration Targets of Opportunity (SITO), 1972
Category: Pilot Projects/Waivers
Purpose. The Department of Health, Education, and Welfare (HEW) funded
45 SITO demonstration projects to provide replicable information on how to
integrate the delivery of a wide range of human services. Projects were meant to
improve client access to available services and to reduce time spent on referrals,
space, and equipment to increase the long-run efficiency of program operations.
SITO projects were used to test provisions of the Allied Services Act, a proposal
discussed later in this report. (For examples of SITO projects, see Appendix B.)
Features. Each project was intended to be a demonstration of various models
of integrated service delivery. These models included coordinated case management,
client tracking systems, common service sites, and information and referral
services.33 Grants were given directly to state and local governments to help improve
accessibility, convenience and completeness of services. Most were funded for a
period of three years. Projects were supported by discretionary funds from
component HEW agencies, particularly the division of Social and Rehabilitative
Services (SRS).
Outcomes. Of the 45 SITO projects, 10 were technical studies carried out by
consulting firms or public interest groups. The remaining projects were
comprehensive service delivery efforts carried out by state or local governments.
Many of the SITO projects did lead to better service delivery — results of individual
project evaluations showed improved client access to needed services and that
agencies were more responsive to the needs of families being served. Yet, fiscal
problems resulting from pooling funds of different categorical programs and
administrative restrictions limited overall success of these efforts.34 As with the IGA
program, cost allocation and accounting of expenditures across multiple programs
was complex and prohibitive for project administrators. Interagency planning was
difficult because program officials often felt the projects were threats to their
programs, budget, and agency identity. Suggestions were made to provide more
authority to interagency planning councils to enforce participation by agencies.
33 U.S. Department of Heath and Human Services, Office of the Inspector General, Services
Integration: A Twenty-Year Retrospective, OEI-01-91-00580, Jan. 1991.
34 U.S. General Accounting Office, Integrating Human Services: Linking At-Risk Families
with Services More Successful than System Reform Efforts, GAO/HRD-92-108, Sept. 1992.

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Joint Funding Simplification Act of 1974 (P.L. 93-510)
Category: Grant Management Reform/Pilot Projects
Purpose. The Joint Funding Simplification Act was a formal extension of the
Integrated Grants Administration program (IGA). It was enacted in 1974 for five
years, reauthorized in 1980 and repealed in 1982.35 The law did not authorize
appropriations, since projects were required to be cost-neutral. As in the IGA
program, the purpose of the law was to establish procedures for projects to draw
funds from more than one federal assistance program, and to simplify administrative
requirements for management of those funds. Uniform provisions of financial
administration, payments, and accountability, joint management of funds by federal
agencies and prioritizing timely and expeditious processing of applications were
explicit goals of the law. It also encouraged agencies to actively form federal-state
partnerships to more effectively combine federal and state resources in support of
projects with common goals and purposes.
Features. The enacted law was vague regarding what authority would oversee
cooperation across federal agencies, and left many of the details to be determined by
an Executive Order of the President.36 As in the IGA, Federal Regional Councils
were given the responsibility of processing applications. In addition, for each project
a federal lead agency was to be designated to coordinate the participation of all
federal agencies involved, and to act as the applicant’s primary contact for
administrative matters. The regulation allowed transfer of federal funds from grantor
agencies to grantees through a management fund and federal letter of credit.37
Programs eligible to participate in joint funding were to be determined by federal
agencies, limited to financial assistance provided through grants or contracts.
The law allowed (but did not direct) federal agencies to encourage federal-state
partnerships through which non-profits and local governments could combine
funding for joint support of projects. Authority was given to agencies to take the
following actions: identify programs appropriate for joint support for specific
projects; promulgate guidelines, model or illustrative projects, joint application forms
or other guidance to assist in the planning and development of projects; determine
which program requirements may impede joint support of projects; establish common
technical and administrative rules in related programs; and develop a joint procedure
for project supervision, including the designation of lead agencies.38
35 P.L. 96-534 reauthorized the Joint Funding Simplification Act in 1980, and P.L. 97-258
Section 5(b) repealed the law in 1982.
36 Executive Order 11893, dated Dec. 31, 1975, delegated to the Director of the Office of
Management and Budget (OMB) the authority to issue regulations governing jointly funded
assistance to state and local governments and nonprofit organizations, and to perform other
functions specified in P.L. 93-510. OMB issued formal regulations published in the Federal
Register, vol. 41, no. 148, July 30, 1976.
37 Federal Register, vol. 41, no. 148.
38 P.L. 93-510, CRS Summary.

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Outcomes. Two reports by the Comptroller General’s office reviewed
implementation of the Joint Funding Simplification Act. The first report, published
just two years after passage, found a need for federal-level measures to increase
federal agency responsiveness and commitment to the joint funding program.39 The
report also recommended that Congress amend the Act to retain requirements related
to non-federal matching shares within projects to preserve the integrity of individual
programs. A later report by the Comptroller, conducted in the final year of
authorization, found that implementation of the program was a disappointment and
that only seven new projects had been funded.40 At the time of the report in July
1979, there were 17 active projects, 10 of which were carry-overs from the Integrated
Grants Administration. The report cited several reasons for this low level of activity,
such as OMB’s lack of adequate and timely leadership, support and oversight; federal
agencies’ limited commitment; and the Act’s permissive nature, which did not
mandate federal agency participation or include a mechanism for conflict resolution.
Both reports found that joint funding could only be successful at packaging related
programs and simplifying grant administration if given sufficient federal support.
Allied Services Act 1975 (H.R. 9981/H.R. 10248)41
Category: Demonstration Projects/Waivers
Purpose. The Allied Services Act of 1975 was a Ford Administration
proposal introduced in the House and Senate, but no action was taken by Congress.
The bill proposed to authorize demonstration grants to states for the development of
“allied services plans” to coordinate delivery of human services in order to facilitate
access, improve effectiveness of services, and use resources more efficiently with
minimal duplication. The bill would have authorized $20 million each year for
FY1975 and FY1976 for implementation grants to cover initial project and systems
costs. The 1972 SITO projects funded by the Department of Health, Education, and
Welfare (HEW) were developed to test the provisions outlined in the Allied Services
bill.42
Features. The bill would have authorized the Secretary of HEW to make
demonstration grants to states for a maximum of two years to develop plans to
coordinate service delivery, and a maximum of three years for the initial costs of
consolidating administrative support services. At the minimum, projects needed to
include services for low-income families, child welfare services, and services to
39 U.S. General Accounting Office, Report to Congress by the Comptroller General, The
Integrated Grant Administration Program — An Experiment in Joint Funding, GGD-75-90,
Jan. 1976.
40 U.S. General Accounting Office, Report by the Comptroller General, A Study of the Joint
Funding Simplification Act, GGD-79-87, July 1979.
41 H.R. 10248 was an identical bill introduced in the 94th Congress, which included an
additional 20 cosponsors.
42 Legislative Reference Service, Analysis of the Proposed Allied Services Act of 1974, H.R.
12285, by Sharon House, June 26, 1974. (Archived, available on request.)

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Work Incentive Program (WIN)43 recipients and at least three other human services
programs funded through any source.44 The bill would have authorized the transfer
of up to 25% of funds from participating HEW programs provided that the funds
were directed at essentially the same target population. It also would have allowed
waivers of administrative, regulatory, and technical requirements providing the allied
services plan demonstrated that such requirements would prevent coordination of
human services. Finally, the bill would have authorized joint funding across agency
lines to reduce duplication and maximize resources.45 In order to apply for a grant,
states would have been required to designate service areas where a local
demonstration project would be implemented and prepare a statewide allied services
plan laying out the details of the planned demonstration project. At the federal level,
consultation and review by other federal departments would occur when plans
included services outside the jurisdiction of HEW. Projects would have been
required to provide evaluation reports assessing the impact of allied services efforts
on clients.
Legislative History. The Allied Services proposal was introduced multiple
times beginning in 1972. The Nixon Administration, specifically Secretary of HEW
Elliot Richardson, made this issue a priority by using discretionary funding to initiate
the SITO demonstration projects and subsequently by sending the Allied Services
Act to Congress for consideration.46 The Ford Administration continued these
efforts, and under the direction of HEW Secretary David Matthews, the Allied
Services Act was again introduced in 1975, but no further action was taken.
Eligibility Simplification Projects, 1980
Category: Administrative Simplification
Purpose. During the 1980s, more attention was focused on the complexity of
administrative rules and regulations through which different federal assistance
programs were operated. Specifically, two large-scale projects, one at the federal and
the other at the regional level, were undertaken to review eligibility requirements
across human services programs. As part of the Carter Administration’s welfare
reform proposals, the President requested an interdepartmental review of eligibility
policies and procedures among major federal assistance programs called the
Eligibility Simplification Project.47 An interagency team developed and published
recommendations in 1980 for simplifying and standardizing the eligibility
requirements and procedures of seven “basic needs” programs. A separate, but
43 The WIN program provided employment and training services for recipients of Aid to
Families with Dependent Children, the predecessor to TANF.
44 Congressional Research Service, The Proposed Allied Services Act: Summary and
Arguments, Pro and Con, Nov. 1975. (Archived, available upon request.)
45 Department of Health, Education, and Welfare, The Allied Services Act of 1975, Fact
Sheet, Oct. 1975.
46 H.R. 12285 was introduced in the 93rd Congress as the “Allied Services Act of 1974.”
47 Office of Management and Budget, Eligibility Simplification Project: An Interagency
Study with Recommendations for Simplifying Client Eligibility among Major Public
Assistance Programs, Oct. 1980.

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related project funded by HEW48 was completed by the Mountain Plains Federal
Regional Council. The FRC conducted a study in four states — Colorado,
Massachusetts, Michigan, and South Dakota — on the eligibility requirements in six
public assistance programs. A report titled “The Intergovernmental Eligibility
Simplification Project”49 provided a step-by-step approach to establish uniform
definitions of income and resources for human service programs.
Features. The Eligibility Simplification Project was led by the Secretary of
HEW and the Director of OMB. It found that complex requirements for establishing
eligibility in different federal assistance programs contributed to inefficiency and
created difficulties for clients and administrators alike. The seven basic needs
programs selected for analysis were Aid to Families with Dependent Children
(AFDC), Comprehensive Employment and Training Act (CETA) services, Food
Stamps, rental housing assistance (Section 8), Medicaid, Title XX of the Social
Security Act (Social Services), and Supplemental Security Income (SSI). All of these
programs at that time, based eligibility on some form of means-test for income and
some also applied an assets test. The project resulted in the following
recommendations:
! Standardize treatment of income and assets across programs. For
example, programs differed in treatment of income from educational
benefits, valuation of vehicles and household goods, and methods to
calculate net earnings.
! Improve consistency of work requirements across programs, adopt
same definition of student eligibility status, and definition of
disability.
! Create a task force to revise approaches in budgeting, administrative
and cost accounting areas, especially with regard to quality control
systems.
! Implement “one-stop” eligibility determination in local welfare
offices to reduce administrative costs and increase accessibility for
clients.
The Intergovernmental Eligibility Simplification Project conducted by the
Mountain Plains FRC studied six similar programs: Food Stamps, AFDC, SSI, Title
XX of the Social Security Act, CETA, and Section 8 housing assistance. This project
developed a computer simulation model to determine the impact on client enrollment
and benefit levels of proposed uniform definitions.50 The study found that uniform
measures to determine income and resources would not lead to significant changes
48 U.S. Department of Health, Education, and Welfare became the Department of Health and
Human Services through reorganization in May 1980.
49 The Intergovernmental Eligibility Simplification Project, Uniform Measures for Use in
Determining Client Eligibility Among Human Service Programs: An Impact Analysis,
Submitted to the Mountain Plains Federal Regional Council, July 1980.
50 To test proposed changes using uniform financial measures of income, the study designed
a computer model that predicted the effect of the change on eligibility outcome and benefit
levels of sample case populations in Colorado, Massachusetts, Michigan, and South Dakota.

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in the number of individuals eligible for benefits or the level of program benefits
available. The following recommendations resulted:
! Develop a federal policy on the use of uniform standards for
evaluating and treating the personal finances of individuals and
families applying to public assistance programs.
! Design a comprehensive data system for use by federal agencies,
which would provide useful and consistent information regarding the
characteristics of populations enrolled in public assistance programs.
Outcomes. Recommendations of the Eligibility Simplification Project were
never formally addressed by Congress through legislation, yet some of the
recommendations became a part of the Carter Administration’s welfare reform
proposal. In addition, federal agencies overseeing the seven programs studied took
actions including regulatory changes, and joint task forces to promote increased
administrative coordination.51 In 1990, a similar administrative simplification project
called the Welfare Simplification and Coordination Advisory Committee, published
a report with recommendations for simplifying and coordinating four public
assistance programs: AFDC, Food Stamps, Medicaid, and public housing.52 The
1990 committee also identified administrative conflicts in definitions and procedures
among these programs.
Omnibus Budget Reconciliation Act of 1981
(OBRA, P.L. 97-35)53
Category: Block Grants
Purpose. The Omnibus Reconciliation Act of 1981 created nine new block
grants from approximately 57 of the more than 300 categorical programs in effect at
that time.54 One of the major aims of block grant proposals is to transfer decision
making authority to state and local governments by reducing rules and regulations
51 Examples of changes undertaken by federal agencies are: SSI changed treatment of motor
vehicles as assets for SSI purposes to be consistent with the Food Stamp definition; through
policy regulations, applications for Food Stamps were to be taken in Social Security offices
for SSI applicants; valuation of assets in SSI and AFDC were changed to mirror the Food
Stamp program; HHS and USDA coordinated the use of AFDC monthly reporting system
for Food Stamp purposes.
52 Report of the Welfare Simplification and Advisory Committee, Time for a Change:
Remaking the Nation’s Welfare System, June 1993.
53 Congressional Research Service, Block Grants in the Omnibus Budget Reconciliation Act
of 1981 (P.L. 97-35): An Overview of Their Characteristics, Sandra Osbourn, Aug. 1981.
(Archived, available on request.) The following block grants were created by OBRA:
Puerto Rico Food Stamp Block Grant; Elementary and Secondary Education Block Grant;
Community Services Block Grant; Preventative Health and Health Services Block Grant;
Alcohol and Drug Abuse and Mental Health Block Grant; Primary Care Block Grant;
Maternal and Child Health Block Grant; Social Services Block Grant; Low-Income Energy
Assistance Block Grant.
54 George Peterson, Randall Bovbjerg, Barbara Davis, Walter Davis, Eugene Durman, and
Theresa Gullo, The Reagan Block Grants: What Have We Learned? (Washington: Urban
Institute Press, 1986).

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under which categorical programs operate. The Reagan Administration argued that
consolidation through block grants would lower costs by eliminating federal
categorical programs with different matching rates, procurement requirements,
reporting standards, and accounting practices, thus justifying the 25% reduction in
funding that accompanied its block grant proposals. The President’s FY1982 budget
stated “The current system’s administrative requirements have resulted in nearly
insurmountable barriers for states, local governments, communities, and even
individual providers who wish to integrate funds from all grant programs into
comprehensive assistance systems.”55 Block grants were associated with a variety
of goals including lowering administrative costs, decentralizing decision-making,
reducing programmatic overlap, promoting coordination and innovation, and
providing states opportunities to target funding.
Features. For the purposes of this discussion, two of the block grants — the
Social Services Block Grant (SSBG) and Community Services Block Grant (CSBG)
had the most impact on consolidation of social service programs. The final SSBG
combined funding for social services, day care and training under Title XX of the
Social Security Act, giving states increased flexibility in using social service funds
to promote self-sufficiency through employment, training, day care, and counseling.
The changes encompassed in the SSBG were scaled-back from the Administration’s
original proposal, which would have consolidated funding for additional programs
— child welfare services, foster care, adoption assistance, child abuse, runaway
youth, development disabilities, rehabilitation services — along with the Community
Services Administration (CSA) and Title XX activities into a single mega-Social
Services Block Grant.56 The following are provisions included in the final 1981
SSBG block grant:
! Funds are allocated annually based on the ratio of each state’s
population to the total U.S. population.
! States may transfer up to 10% of their allotments to any of the four
other health-related block grants or low-income home energy
assistance programs.
! States were required to make an annual report to HHS, subject to
public comment, outlining types of activities to be funded by SSBG
and characteristics of the population to be served.
! There are no federal eligibility criteria for SSBG participants; states
have discretion to set their own criteria.
CSBG created the Office for Community Services in HHS and consolidated
funding for services and activities to address poverty previously administered by an
55 Office of Management and Budget, America’s New Beginning: A Program for Economic
Recovery, Feb. 18, 1981.
56 CRS Issue Brief IB81102, Social Services Block Grant, by Mary Smith and (name redacted).
(Archived, available upon request.)

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independent federal agency known as the Community Services Administration
(CSA), which was abolished by the 1981 legislation.57
Outcomes. SSBG is often referred to as “glue” money by states because it
gives them flexibility to cover gaps between grants in order to better coordinate
social service programs. CSBG makes federal funds available for a wide variety of
anti-poverty activities, directed toward low-income populations including the
homeless, welfare recipients, and the elderly. As a mechanism for public funding,
block grants are often controversial, yet Congress has continued to consider block
grant proposals and has enacted several since, including the Child Care and
Development Block Grant (CCDBG) and Temporary Assistance for Needy Families
(TANF). Block grants have an inherent tension built into them in that they give
states flexibility and discretion to target funding, but in doing so critics argue they
undermine accountability by minimizing administrative requirements. Critics also
argue that block grants are more susceptible to funding cuts, due to the difficulty of
sustaining broad-based support for general purpose programs.
1984 Deficit Reduction Act (P.L. 98-369)
Category: Demonstration Projects/Waivers
Purpose. The 1984 Deficit Reduction Act added Section 1136 to the Social
Security Act, authorizing federally-assisted pilot projects to demonstrate the use of
integrated service delivery systems to improve the effectiveness and efficiency of
human service programs.58 This program was called the HHS Integrated Service
Delivery Program or Service Integration Pilot Projects (SIPP). SIPP projects were
intended to develop ways to improve the delivery of human services by eliminating
programmatic fragmentation, so that an applicant to one program would also have
access to services provided by other programs. It was argued that strengthening the
ability of states to address social needs through flexibility would bring about better
targeting of resources and increase the ability of individuals to achieve self-
sufficiency. (For examples of SIPP projects see Appendix B.)
Features. This program was implemented through the Office of Human
Development Services (OHDS) within HHS. The law authorized HHS to approve
three to five projects to demonstrate integrated service delivery systems for a period
of up to 42 months. Human service programs to be included in the projects were
AFDC, SSI, Food Stamps, and any other federally assisted program that used means-
testing to determine eligibility for benefits. The law authorized $8 million to fund
the projects, but no money was ever appropriated. OHDS published an
announcement in the Federal Register to solicit proposals for demonstration projects,
and selected five states — Maine, Arizona, South Carolina, Oklahoma, and Florida
— to participate. Section 1136 specified nine requirements that each project had to
address. These were: (1) develop common terminology; (2) create a single
57 The CSBG is the modern-day remnant of the Community Action Program created as part
of the 1964 War on Poverty, described earlier in this report.
58 U.S. Department of Health and Human Services, Office of Human Development Services,
Office of Policy, Planning, and Legislation, Report on Progress and Status of Services
Integration Pilot Projects: First Year Planning Phase, Feb. 1987.

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comprehensive family profile; (3) establish a single resource and referral directory;
(4) develop a unified budget process and auditing procedures; (5) implement unified
planning, needs assessment and evaluation procedures; (6) consolidate agency
locations; (7) standardize procedures for purchasing services; (8) create
communications linkages across agencies; and (9) develop uniform application and
eligibility determination procedures.
Subject to the approval of the agency secretary, a grantee could request a waiver
of any requirement that “would otherwise apply with respect to the proposed project
under any of the laws governing the human services programs to be included in the
project.”59 The five SIPP projects involved a mix of statewide and county
demonstrations that incorporated different combinations of services and targeted
varying elements of the low-income population, including pregnant teens and senior
citizens. A primary focus in most of the programs was integrated case management,
which allowed clients with multiple problems to receive a comprehensive network
of support and assistance.
Outcomes. Implementation of the SIPP projects was initially uncertain
because Congress did not appropriate the funds authorized in the legislation. Instead,
OHDS used discretionary demonstration funds for the first year of planning, and after
a delay, for the following years in the project periods as well. The total amount of
federal funds spent on the program was $4.6 million and states were required to
allocate matching funds to the projects, which totaled $3.2 million.60 The projects
were approved for 3½ years, yet concerns about funding spilled over into the second
year and jeopardized the momentum of several of the projects. A GAO report
reviewing implementation of the SIPP projects said, “One state official told us that
his state was in the tenuous position of having generated substantial local community
support and commitment for the project without assurances that federal funding
would continue.”61 Through additional discretionary funding from the Department
of Labor (DOL) and the Department of Housing and Urban Development (HUD),
HHS was eventually able to fund the projects through to completion.
States encountered administrative difficulties in obtaining waivers from federal
agencies to overcome specific requirements of programs affected by integrated
service projects. Federal procedures for obtaining waivers were time consuming, and
approvals came too late in the project implementation phase to be of value. Waiver
requests were held to a high standard of justification, with processing time frames of
up to one year. Federal officials discouraged, rather than encouraged, waiver
requests, and often told states the prospects for waiver approval were not good.
OHDS formed an interagency workgroup to coordinate waiver requests with other
federal agencies, but cooperation was minimal.
59 P.L. 98-369, Section 1136(d)(1).
60 U.S. Department of Health and Human Services, Office of Human Development Services,
Services Integration Pilot Projects: An Evaluative Report from Arizona, Florida, Maine,
Oklahoma, South Carolina, Sept. 1989.
61 U.S. General Accounting Office, Welfare Simplification: Service Integration
Demonstrations under the 1984 Deficit Reduction Act, GAO/HRD-86-125BR, Aug. 1986.

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In addition to the nine requirements outlined in Section 1136, OHDS directed
states to develop measures for evaluating the impact of service integration on client
economic self-sufficiency. Four of the five states reported problems developing these
types of measures since it was difficult to tie system changes directly to outcomes.
One state official said, “While increased self-sufficiency is the ultimate goal for all
human services programs, I believe that there is a fundamental difference between
improving the existing service delivery system and demonstrating increased self-
sufficiency as a result of the services delivered.”62 In the absence of self-evaluations,
HHS later awarded a contract to an independent organization to conduct a process
evaluation of the SIPP programs.63 The evaluation found that the states faced similar
barriers to integration that included the need for collaborative planning and support
among all the stakeholders at the state level, the need for local level involvement
throughout the planning process, difficulty in establishing new case management
practices that added additional responsibilities for caseworkers, ineffective and
outdated technology, and prohibitive costs of co-location of services.
Low-Income Opportunity Improvement Act of 1987
(S. 610/H.R. 1288)
Category: Demonstration Projects/Waivers
Purpose. The Low-Income Opportunity Improvement Act was introduced in
the 100th Congress, but was never enacted. The proposal was developed in response
to recommendations made to President Reagan by the Domestic Policy Council Low-
Income Opportunity Working Group. It would have authorized state demonstrations
of innovative methods to simplify existing programs of assistance for low-income
families. The bill intended to streamline programs by taking advantage of economies
of scale that would allow states to reduce duplicative and inefficient expenditures.
Demonstration projects were referred to as anti-poverty “experiments” designed
entirely by states.64
Features. This legislation would have formally established an Interagency
Low-Income Opportunity Board to certify demonstrations and to authorize waivers
from existing law needed for projects. Demonstrations could have included any
federally assisted program intended to alleviate poverty that used means-tests to
determine eligibility, or for which funding was allocated based on the size of the low-
income population within the community served by the grantee.65 The demonstration
plan would specify procedures for deciding eligibility and benefits, programs
affected, waivers needed, and an evaluation plan. The bill required that AFDC
recipients be involved in employment-related activities or education/training
programs to ensure that clients were moving toward self-sufficiency. An unspecified
appropriation was authorized for FY1988. The appropriation would have equaled a
62 Ibid.
63 James Bell Associates, Evaluation of HHS Services Integration Pilot Projects, Volume
I: Executive Summary, Nov. 1993.
64 CRS Report 87-309, Welfare Reform: Brief Summaries of Selected Major Proposals, by
(name redacted) and Carmen Solomon, June 1987. (Archived, available upon request.)
65 S. 619, CRS Summary.

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sum based on the estimated amount states would have received in the absence of the
demonstrations, for programs included in the demonstration. The bill also would
have required non-federal funds to be contributed.
Legislative History. In February 1987, President Reagan sent this bill for
consideration to Congress as part of his welfare reform initiative.66 While the bill
was not enacted, Reagan did establish within the executive office the Interagency
Low-Income Opportunity Board (LIOB) to encourage state and local tests of welfare-
to-work innovations. The board promoted the use of waiver authority that already
existed within many federal assistance programs such as AFDC and Medicaid. The
LIOB acted as a technical assistance body that helped states negotiate waivers from
different federal agencies. In 1990, the LIOB was replaced by the Economic
Empowerment Task Force.67
The Low-Income Opportunity Improvement Act was the predecessor to the
Family Support Act of 1988 (FSA, P.L. 100-485). FSA was considered at the time
to be the most sweeping reform of the federal welfare system in the previous 50
years. It also included a provision authorizing a limited number of state
demonstration projects to test specific initiatives aimed at assisting long-term AFDC
recipients, such as early childhood development programs for AFDC families,
financial incentive approaches to reducing school drop-outs, and methods to ensure
long-term family self-sufficiency through community-based support services. These
demonstrations were much more narrowly defined in relation to specific goals, than
the ones originally outlined in the Low-Income Opportunity Improvement Act.
Community Opportunity Act of 1991 (S. 1529)
Category: Waivers
Purpose. This bill was a proposal supported by the George H.W. Bush
Administration and introduced in the Senate, but never enacted. In a May 1991
speech, President Bush announced the Act as “legislation that would enable poor
citizens to tailor federal programs to meet their actual needs.”68 This quote was in
reference to a specific requirement in the bill to incorporate the comments of program
beneficiaries when developing an integrated service system. The bill would have
provided waiver authority to communities to integrate and restructure services and
benefits for low-income families under multiple federal assistance programs. The
purpose was to create economic opportunity at the community or neighborhood level
and to increase the self-sufficiency of low-income individuals and families.
66 Speech by President Reagan to Congress, “Message to Congress Transmitting Proposed
Low-Income Opportunity Legislation,” Feb. 26, 1987, at [http://www.reagan.utexas.edu/
resource/speeches/1987].
67 Theodore Ooms and Todd Owen, “Coordination, Collaboration, Integration: Strategies
for Serving Families More Effectively,” Part One: The Federal Role (The Policy Institute
for Family Impact Seminars, Sept. 1991). This report found that as of mid-1990, 13 state
projects were authorized through LIOB, these included Wisconsin Learnfare and a New
Jersey plan to permit AFDC recipients to become family day care providers.
68 Speech of President George H. W. Bush at the Cochran Gardens Apartments in St. Louis,
Missouri, “Public Housing and Enterprise Zones,” May 4, 1991.

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Features. The legislation expected programs to be operated from the local or
neighborhood level and would have authorized the development of “community
opportunity systems” to restructure the delivery of social services. The bill did not
authorize any appropriation beyond the discretionary funds already authorized for
existing grant programs. The President would have been given authority to designate
a panel of federal officials with responsibility to approve the inclusion of specific
programs and waive any federal statutory or regulatory requirements in that program.
The bill also included technical assistance to help develop and implement an
integrated system. Applications were required to define a particular service area, the
population to be served and how the program would measure performance related to
increasing opportunity and self-sufficiency. The individuals and families to be
served were to be included as participants in the design and implementation of the
comprehensive system. An evaluation component would have required approved
agencies to conduct assessments of the system’s impact on the target population and
community. Extension of waiver approval would be allowed if the agency
demonstrated a superior alternative system for assisting individuals and families.
Legislative History. The Community Opportunity Act originated as a
proposal from the Reagan Administration’s Economic Empowerment Task Force and
became part of the Bush Administration’s welfare reform agenda. While the bill
itself was not re-introduced and saw no further action, the concept of authorizing
waivers for demonstration projects and the inclusion of evaluation requirements
manifested itself throughout later proposals.
Local Empowerment and Flexibility Act of 1996 (S. 88)
Category: Waivers
Purpose. The Local Empowerment and Flexibility Act of 1996 was
introduced and reported by committees in both the House and Senate, but was not
enacted.69 The bill would have established a process by which a federal interagency
board could approve “flexibility plans” proposed by one or more local governments.
A key goal was to enable state, local, and tribal governments and private, non-profit
organizations to adapt federal financial assistance programs to particular
communities. Proponents argued, “Each of the various grant programs tends to treat
the needs it aims to address as if most communities had the precisely identical
problem calling for a single, common solution.”70 Additionally, there was concern
about the budget deficit, and the bill was seen as a way to maximize efficiency in
discretionary grant programs and optimize expenditure of federal resources.
Features. The legislation would have authorized local governments that
received aid under multiple federal assistance programs to propose “flexibility plans”
for the administration of two or more such programs. The legislation was cost
neutral — existing grants from these programs were to be combined with similar
state and local program funds. A key element was that local governments could
request a waiver (for a maximum of five years) of a wide range of federal
69 Also introduced as H.R. 2086.
70 U.S. Congress, Senate Committee on Governmental Affairs, Local Empowerment and
Flexibility Act of 1996, hearings, S. 88, July 1996.

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requirements if it was necessary for implementation of the plan.71 The bill made use
of existing Community Empowerment Boards, established by Presidential directive
through Empowerment Zone and Enterprise Community programs. The board was
intended to foster federal interagency communication, review waiver requests,
provide technical assistance, and monitor performance of the flexibility plans.
Waivers would ultimately be approved by the appropriate federal agency. The bill
gave priority to applicants that were designated as an enterprise community or
empowerment zone. Amendments to the original bill required that plans be
developed with “significant public input,” and submitted to affected local and state
agencies for a comment period. Plans would have been required to include
measurable performance criteria.
Legislative History. There was opposition to this bill in both the House and
Senate. Some critics objected to the bill’s sweeping scope and the indeterminate
impact of the legislation. Among the issues raised were the lack of constraints on the
ability of local governments to shift the use of funds, the potential for waiving
provisions that could compromise a program’s original purpose, and the absence of
congressional oversight and public accountability for Community Empowerment
Boards. Additionally, the mechanism for developing flexibility plans was viewed as
too cumbersome to be effective. This bill was advocated by the U.S. Advisory
Commission on Intergovernmental Relations, which testified before the Senate
Government Affairs Committee.72 During this testimony, both the Integrated Grants
Administration (IGA) and the Joint Funding Simplification Act of 1974 were cited
as examples of past reforms to address grant assistance issues and as a demonstration
of the persistence of service integration problems at the state and local levels.
Welfare Reform Reauthorization 2004 (H.R. 240)
Category: Demonstration Projects/Waivers
Purpose. In response to a George W. Bush Administration proposal, Program
Demonstration Coordination Projects were included in a long-term welfare reform
reauthorization bill that passed the House in both the 107th and 108th Congresses and
is again under consideration in the 109th Congress (H.R. 240). These projects would
allow states to request waivers from federal requirements in order to integrate
activities across a wide spectrum of federal programs to build integrated service
systems, and deliver seamless services to clients. A primary goal of the proposal is
to improve coordination across programs to support working individuals and
families, and to promote independence from welfare. Sponsors argue that the
combined effectiveness of public assistance programs is compromised by differences
in administrative practices and rules.
71 (H.R. 2086) Requirements that could not be waived included Title VI of the Civil Rights
Act of 1964; Section 504 of the Rehabilitation Act of 1973; Title IX of the Education
Amendments of 1972; the Age Discrimination Act of 1975l the Americans with Disabilities
Act of 1990; the Fair Housing Act; or the Individuals with Disabilities Act.
72 Testimony of Charles Griffith, Director of the Intergovernmental Liaison Advisory
Commission on Intergovernmental Relations, On Senate Bill 88, Local Empowerment and
Flexibility Act, Dec. 5, 1995.

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Features. Under the current proposal, states or sub-state entities administering
two or more covered programs could propose a demonstration by submitting an
application to the appropriate federal agency. Each federal agency administering a
program within the project must act on an application within a 90-day deadline, after
which proposals would be considered approved if no action was taken. Proposals
would describe programs to be included, how the project would improve
achievement of quality or cost-effectiveness objectives, the population to be served,
eligibility criteria, and performance objectives. The proposal must justify the need
for any waivers of statutory or regulatory requirements.
The bill requires projects to be cost-neutral and authorizes demonstrations for
up to five years. Ongoing and final evaluations are required of any approved
demonstration projects. Covered programs would include TANF, welfare-to-work,
certain activities under WIA, Wagner-Peyser Act, Child Care and Development
Block Grant (CCDBG), SSBG, Food Stamps, adult education programs under the
Adult Education and Literacy Act, housing assistance programs except Section 8
rental assistance, Titles I-IV of the McKinney-Vento Homeless Assistance Act, and
the Job Opportunities for Low-Income Individuals program (Section 505 of the
Family Support Act). Some limitations are placed on waivers that relate to civil
rights or discrimination, labor standards, and environmental protections.
Additionally, provisions may not be waived if they relate to the purposes or goals of
a program, or impose maintenance-of-effort requirements.73
Legislative History. Largely based on the Bush Administration initiative, a
version of the superwaiver was passed by the House in both the 107th and 108th
Congresses and is pending in the 109th Congress. The Senate Finance Committee
reported a scaled-down version in October 2003, and again in March 2005 (S. 667).
The Senate committee’s version has many of the same elements, but limits the
programs that could be included in demonstration projects, includes stronger
evaluation requirements, and limits the number of states that could participate to 10.
Lessons Learned
Past federal-level service integration initiatives covered in this report provide
some lessons that can help to inform the current “superwaiver” debate, as well as
future federal efforts. Ironically, the biggest lesson has been that reform itself can be
fragmented, and requires a substantial amount of effort to coordinate and execute in
its own right.
Costs and Savings. Most of the service integration initiatives covered in
this report have been designed to be cost-neutral, meaning they did not include a
separate appropriation or authorization for funding, and would not have resulted in
new spending or benefits. Proposals were often created under the perception that
consolidation of existing grant programs would lead to more effective delivery of
services, and save money by lowering administrative costs and reducing overlap
73 For information on the current status of this proposal, see CRS Report RS21219,
“Superwaiver” Proposals in the Current Welfare Reform Debate, by (name redacted).

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across programs. Cost-savings and increased efficiency were used as arguments for
many legislative initiatives, which helped to build political support, but also meant
little or no funding for the project itself. Service integration projects undertaken by
executive branch agencies were more likely to be funded, yet grants were subject to
the impetus of the sponsoring agencies to use discretionary funds, and funding was
often uncertain under these circumstances.
An independent evaluation of the SITO projects, found that they did not
demonstrate long-term savings. “Fieldwork indicated that it may not be possible to
justify services integration strictly in terms of total dollar savings.... Although there
are some cost savings resulting from economies of scale and reduction of duplication,
they do not appear to equal the input costs of administrative and core service staff
required to support integrative efforts.”74 The SITO evaluation did not review all
projects funded, and other initiatives, such as the SIPP projects, did not include a cost
benefit analysis, making it difficult to generalize this finding.
The true costs of integrating services are not entirely clear. Yet, it does seem
to be the case that there are short-run costs involved in initiating projects. Service
integration requires both financial and political resources to implement, whether from
the federal, state or local level. Integrating services may include costs of planning
and building a network of support in the community, training staff, co-locating
agencies, and investments in technology. Sustaining or “institutionalizing” service
integration may require some level of continued resources. In the long-run, it is
anticipated that the economies of scale achieved through integration will outweigh
the costs of implementing the necessary changes. It is also argued that
comprehensive services can better serve clients and lead to increased independence
from assistance. There is little evidence about the cost-effectiveness of service
integration strategies, and the variability and scope of projects undertaken make it
difficult to estimate the amount of additional resources that may be required for a
given project in a particular type of community.
Programs Covered. Many of the federal initiatives covered in this report
allowed states and localities a great deal of discretion in deciding which programs
they would include in a service integration project. For example, in the proposed
Community Opportunity Act of 1991, Congress did not specify the programs eligible
for inclusion in a demonstration project. Instead, a panel of federal officials would
have conferred with the heads of federal agencies operating programs included in a
demonstration project application, and make a recommendation to each agency
regarding inclusion of the program or waiver of statutory or regulatory
requirements.75 Inclusion of programs often was left to the state or local
administrators of a project, and was decided in many cases based simply on what was
the most practical given a community’s socio-political environment.
74 U.S. Department of Health, Education, and Welfare, Social and Rehabilitative Service,
Integration of Human Services in HEW: An Evaluation of Service Integration Projects, SRS
73-02012 (1972), vol. 1, p. 22.
75 S.1529, Community Opportunity Act of 1991, 102nd Congress, July 23, 1991.

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The selection of categorical programs funded to meet the “basic needs” of low-
income individuals is considered a logical baseline for deciding which services
should be included under an integrated system. Welfare-related programs can have
similar goals, missions, and/or populations served. Many existing federal programs
are identified as “income-support” and share the purpose of helping individuals
achieve self-sufficiency by supporting employment. A 2001 GAO report reviewing
eligibility requirements in means-tested programs identified 11 programs that help
meet basic needs such as income, food, medical assistance, and housing.76
Notwithstanding, categorical programs included in past federal service integration
initiatives have been wide-ranging, and loosely defined by Congress or executive
branch agencies under the heading of “public assistance.” This broad definition has
made it difficult to establish generalities and structure across different projects.
Political wrangling often causes the selection of programs included in service
integration efforts to be haphazard depending on political resistance from certain
groups with established interest in current programs. Yet, creating a common
framework for federal-level initiatives that is inclusive of a minimum of basic needs
programs, can lead to better opportunities for evaluation, more consistency in
projects at the local level, target needed cooperation at the federal-level, and ensure
continued provision of primary support services.
Administering Authority. Most federal-level service integration efforts have
included designation of an administrative entity to facilitate implementation of an
initiative. The purpose of this body has been to act as a focal point for carrying out
logistical elements and communicating with different federal agencies. An
administering authority can provide direct oversight of projects and report to
Congress regarding projects and program activities. Some federal administrative
bodies have also been tasked with providing technical assistance to grantees or
projects conducted under the initiative. The Integrated Grants Administration (IGA)
and the Joint Funding Simplification Act of 1974 were administered through Federal
Regional Councils, which were responsible for managing the programs regionally,
processing applications and acting as moderators between grantees and various
federal agencies.
Based on previous initiatives that were enacted, federal administering authorities
streamlined interaction between grantees and federal agencies, but they often lacked
the authority to compel federal agencies to fully participate and cooperate with the
intent of the legislation. This was a problem also found in implementation of the
Community Action and Model Cities programs, in which evaluations found that a
lack of authority by planning officials to bring federal agencies and service providers
together limited the success of the programs. A GAO report on the Joint Funding
Simplification Act found, “One joint funding grantee said the poor attitude toward
76 The 11 programs identified were TANF, Food Stamps, Medicaid, Child Care and
Development Fund (CCDF), State Children’s Health Insurance Program (SCHIP), Low-
Income Home Energy Assistance Program (LIHEAP), Special Supplemental Nutrition
Program for Women, Infants, and Children (WIC), School Meals, Housing Choice Voucher;
Low Rent Public Housing, and Supplemental Security Income (SSI). U.S. General
Accounting Office, Means-Tested Programs: Determining Financial Eligibility is
Cumbersome and Can Be Simplified, GAO-02-58, Nov. 2001.

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joint funding by regional staffs and federal agencies is a major stumbling block.”77
Pilot and demonstration projects administered through a single federal agency had
problems obtaining waivers in many cases due to the lack of coordination with other
agencies. The SIPP pilot projects were administered by a single division within
HHS. Yet, grantees found it difficult to obtain waivers from other federal agencies,
and an interagency workgroup did not have the commitment and participation from
representatives to overcome this problem. The limited ability of the administering
body to induce the cooperation of federal agencies in these projects, was a critical
element that hindered the success of these reforms.
Service integration requires momentum and leadership to carry out the activities
included in an initiative, and to promote coordination and collaboration among
participants. At the federal level, facilitating service integration is at least partly
reliant on the designation of some kind of organizational body that has appropriate
authority, sufficient expertise across program areas, and the ability to provide
ongoing technical assistance to overcome barriers and make recommendations for
future proposals. Establishing an “administering authority” without the proper
backing and resources can undermine its capacity to achieve given objectives.
Evaluations. Evaluations of service integration projects can be an important
tool for making assessments relative to the cost-effectiveness of changes, measuring
impact on organizations and clients, and providing insight about pragmatic and
workable approaches to service integration. Despite the implication of the name
“pilot or demonstration,” many of the previous federally-funded projects were
developed without any clear articulation of how best practices or “models” of service
integration could be demonstrated to inform future efforts in other areas. This was
overshadowed by the diversity in objectives, needs, political and organizational
structures across projects. “Pilot programs simply ended when the demonstration
funds ran out. Beginning in the mid-1970s, the public money for ‘taking to scale’
what had been learned from successful demonstrations dried up.”78
An independent evaluation was conducted for both SITO and SIPP projects, but
the evaluations were limited by measurement difficulties and the fact that they were
not initiated until after projects had been implemented. One reviewer found that
evidence from SITO projects was fragmentary and difficult to assess largely because
of inconsistent definitions and limited qualitative measures of impact.79 From the
start, projects were not managed as “demonstrations” by HEW. Research funding
was granted to projects that represented many different approaches to service
integration, which made it difficult to assess them as a social experiment.
77 U.S. General Accounting Office, Report by the Comptroller General, A Study of the Joint
Funding Simplification Act, GGD-79-87, July 1979.
78 Lisbeth Schorr, Kathleen Sylvester, and Margaret Dunkle “Strategies to Achieve a
Common Purpose: Tools for Turning Good Ideas into Good Policies,” The Policy Exchange,
Institute for Educational Leadership, 1999.
79 John DeWitt, Managing the Human Service “System”: What Have We Learned from
Service Integration?, Human Services Monograph, Series no. 4, Project SHARE, Aug. 1977.

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Critics contend that pilot projects are so small in scope that they cannot be
expected to have any measurable impact. Some have also argued that expectations
that pilot projects could help lead to service integration “models” is unrealistic due
to the severity of differences not only in the problems of particular communities
(rural versus urban), but also in particular social and political environments. “Human
Services organizational networks must be adapted to local environments and no one
structure can be implemented in every environment.”80
Evaluations are most effective when they are undertaken from a project’s
conception to establish baselines and an appropriate evaluation methodology. One
type of evaluation might primarily assess whether integration has been achieved, by
examining changes to agency structure, operations, provision of services, and cost-
effectiveness. Another evaluation may look at whether integrated services impacted
client outcomes. Federal provisions that clarify expectations for pilot or
demonstration projects can provide a framework to guide evaluations, so that any
common strategies or similarities across diverse projects might be identified.
Evaluating service integration initiatives raises questions about how to deal with
small sample sizes and changes that may take an extended period of time to produce
significant impacts. Finally, evaluations can be costly to administer and may require
that additional resources be devoted to a project.
Accountability. Federal-level service integration initiatives usually devolve
some authority for decision-making to the states, in order to allow flexibility across
programs. This invariably raises the question of how to ensure accountability.
Developing appropriate and effective outcome measures to assess the performance
and enhance accountability of federally-funded public assistance programs is a
challenge that is not unique to service integration. In retrospect, most of the service
integration projects covered in this report focused primarily on planning and
development of programs, rather than on measuring and tracking performance. This
may be part of the reason why support for projects waned, since there were no
quantitative measures from which to judge a program’s success. Requiring strong
performance measures has many potential benefits to enhance accountability,
including providing information on the effects of integrated services and allowing
better opportunity for oversight.
Issues Facing the “Superwaiver” Proposal
The starting point today is vastly different from what it was in the 1960s and
1970s. For many years, state and local governments, sometimes with federal support,
have experimented with new forms of service delivery strategies and organization.
Now that many programs have aged, some consolidation has occurred, and flexibility
within programs has been created, states have been better able to take advantage of
opportunities to integrate services than in the past. Technology has led to
advancements in information systems and the management and sharing of data
between programs, which has in some places greatly streamlined administrative
80 Douglas Henton, The Feasibility of Services Integration: An Evaluation Prepared for the
HEW Interagency Services Integration R&D Task Force, Mar. 1975.

CRS-33
processes. There is also much more knowledge and literature that has given depth
to this topic. The problem of fragmentation continues to be daunting, but there has
been more national attention and intergovernmental momentum to make better sense
of social service programs as a “system” of support for low-income individuals.
The superwaiver proposal is a service integration initiative that would allow
demonstration projects and waivers. Key issues in the superwaiver debate are similar
to those that have been raised in previous federal efforts.
! Legislation that would authorize the superwaiver or Program
Coordination Demonstration Projects, requires projects to be cost-
neutral. States would have access only to the existing funds
available in each of the programs covered by their superwaiver. This
means that any additional costs that a project may incur, must be
paid for by non-federal resources. Depending on support from a
project’s sponsoring community or state, projects may face resource
constraints that limit the extent of integration that can be achieved.
! The legislation does not designate an administering authority to
approve waivers. Instead, approval (within 90 days) would be
required of each federal agency responsible for a program covered
by the demonstration/waiver request. The Bush Administration’s
original superwaiver proposal included establishment of a federal
inter-agency waiver board to “facilitate the process of processing
waivers,”81 but this was not incorporated into legislation. Applying
for and gaining approval of waivers has the potential to be timely
and cumbersome, even with the inclusion of a 90-day deadline for
federal agency approval, especially if agencies could easily obtain
extensions by requesting more information from the applicant.
! In considering the superwaiver, there has been sharp disagreement
over what programs should be included, and what requirements
could be waived as part of demonstration projects. As they have
moved through Congress, superwaiver proposals have included
different visions of what programs would be eligible for approval
under a demonstration project. There has been strong resistance to
the inclusion of the food stamp and homeless assistance programs.
Within this framework, projects could be expected to vary widely in
type and scope of activities undertaken to integrate services.
! As passed in the 108th Congress and re-introduced in the 109th
Congress, the House bill would require assurance that an applicant
conduct ongoing and final evaluations of the project. The Senate
Finance Committee version would require evaluations be conducted
by an independent contractor, and includes language that random
assignment be used as a methodology if feasible. If projects are truly
81 An informal document circulated by Bush Administration officials included a Federal
Interagency Waiver Board to be established through executive order.

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intended to be “demonstrations,” more structure and detail regarding
evaluations may be necessary. Research and development projects
require careful consideration and action to develop similar
definitions, and collection of baseline data across projects in order
to adequately compare the effectiveness of inter-agency linkages and
different approaches undertaken.
! Finally, the superwaiver includes requirements that project
applications provide a description of the performance objectives for
the project and that each administering Secretary report annually to
Congress regarding how well each project is meeting these
objectives. Strong performance measures can help to increase
accountability of projects, if they are successful at capturing true
impacts and outcomes of integration projects.
The superwaiver proposal is the latest manifestation of an ongoing federal
interest in promoting service integration and cross-program coordination. The
longevity of this movement is telling and suggests that pressure to integrate services
will not subside, but continue to build as the emphasis on setting budgetary priorities
and making services more effective increases, as technology becomes more
sophisticated, and as individual federal programs are modified to allow more
flexibility and collaboration with other services. Most agree that the existing
fragmentation of social service programs is a real problem that must be addressed in
order to better serve families and increase the efficiency of publicly-funded assistance
programs. The intergovernmental nature of social service programs, which often
combine federal, state and local resources, also implies that the federal government
must play some role in helping to address these issues.

CRS-35
Appendix A
Figure 1. Timeline of Federal Service Integration Initiatives
(1968-Present)
Integrated Grants
Administration (IGA)
Local
Program 1972
Deficit Reduction
Eligibility
Act of 1984 (SIPP)
Empowerment
Intergovernmental
Joint Funding
Simplification
and Flexibility Act
Cooperation Act
Simplification Act
Projects,1980
1996
1968
1974
Allied Services Act
Low-Income
Federal Assistance
1975
Omnibus
Opportunity
H.R. 4
Review (FAR)
Reconciliation Act
"superwaiver"
Service Integration
Improvement Act
1969
of 1981 (Block
Proposal, 2003
Targets of
1987
Grants)
Opportunity (SITO)
1972
Community Opportunity
Improvement Act of
1991
Figure 2. Illustration of Integrated Grants Administration

Appendix B
Examples of Projects Funded through the Integrated Grants
Administration (IGA)82
Chattanooga Human Services Delivery Project
Chattanooga, GA (July 1, 1973-June 30, 1974)
Used the IGA mechanism to apply for federal funds to be used for human
services activities in the city. The project consolidated three city departments into
a new Department of Human Services. Funds from several federal assistance
programs were provided through a single channel to this one city department.
Activities administered by the department included a Parent-Child center, a Head
Start program, a Model Cities program, and elements of the Neighborhood Youth
Corps Program.
New York City Neighborhood Government Project
New York City, NY (July 1, 1973 - June 30, 1974)
Used IGA to obtain federal funds for a project to improve the delivery of
community services. Under the project, responsibility for administering and
coordinating services, such as housing inspection, school health programs, and
recreational activities, was decentralized from the citywide to the neighborhood level.
Examples of Service Integration Targets of Opportunity
(SITO) Projects83
Comprehensive Services Delivery System Service Integration
Palm Beach County, FL (Late 1971-December 1973)
The project aimed to provide an administrative structure that maximized the
integration of local, state, and federal resources. Service providers were either co-
located in multi-service centers or received purchased service agreements. Three
multi-service centers were established in the county. Each incorporated service
linkages such as joint staff training, joint planning, evaluation and information
sharing, and central support services and record keeping. Outreach, intake and case
coordination were also direct service linkages provided by the centers.
Integrated Services Program
Polk and Des Moines County, Iowa (July 1972-June 1975)
An experimental county-wide project to promote linkages among public and
private service agencies by demonstrating the utility of case management. The
project completed a community needs assessment, implementation of an automated
client file and information management system, and service scheduling and cost
82 U.S. General Accounting Office, Report to Congress by the Comptroller General, The
Integrated Grant Administration Program — An Experiment in Joint Funding, GGD-75-90,
Jan. 1976.
83 U.S. General Accounting Office, Fact Sheet for Congressional Requesters, Welfare
Simplification: Projects to Coordinate Services for Low-Income Families, GAO/HRD-86-
124FS, Aug. 1986.

CRS-37
management systems. These systems provided data on service providers and
resources available, and was used for eligibility determination and service planning.
East Cleveland Community Human Services Center
East Cleveland, OH (July 1971-June 1974)
Considered a systems development SITO project, its purpose was to develop a
community-based, tax supported, comprehensive social service delivery system
targeted at residents on welfare. The project attempted to develop a model
neighborhood center to act as an integrator to provide information, referrals, and
follow-up services to clients. Linkages were created among service providers
through the use of purchase contracts, technical assistance, joint planning, and
integrated case management. The project was considered a success because it
continued operation of the human service center once SITO funding stopped.
Examples of Service Integration Pilot Projects (SIPP)
Authorized by the 1984 Deficit Reduction Act84
Arizona’s Community Services Integration Project
Flagstaff, Arizona (May 1987-March 1989)
A state-initiated project targeted at families whose income fell below the federal
poverty line, especially those receiving AFDC. The goal of the project was to
increase self-sufficiency of the individuals served. Flagstaff was chosen as the test
site for the project. The central mechanism for services integration was case
management. A new unit with five case managers served 288 clients that had
multiple problems that required collaboration with other programs. Initially, the
demonstration encountered problems with the City of Flagstaff because the site was
selected without consultation with local agencies and community leaders. The
project produced a unified assessment form, a resource directory, and cross-program
staffing procedures. An evaluation of the program tracked some positive client
outcomes, but findings were not statistically significant. The project was
discontinued after the SIPP grant ended, partly because political issues in the state
caused it to lose sponsorship of executive officials in the agency. The experience
demonstrated the need for local input and ownership of programs, and the need for
high-level support.
Maine’s Family Services Integration Demonstration Program
Maine (May 1987-March 1989)
This project sought to improve services for pregnant and parenting teens through
the integration of income maintenance, social services, employment and nutrition
programs for this target group. The goal was to strengthen the family and reduce
dependence on public assistance. Maine established a case management system by
training public health and community service workers. A comprehensive needs
assessment tool and other forms were developed. The demonstration also instituted
a voucher system to pay for transportation, child care, and other client needs. It
developed an automatic referral system and electronic resource directory. The project
experienced difficulties stemming from a change in political leadership that prompted
84 James Bell Associates, Evaluation of HHS Services Integration Pilot Projects, Volume
I: Executive Summary, Nov. 1993.

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an organizational re-structuring and stopped further progress. The project’s case
management services did eventually merge with the state’s welfare reform initiatives
and laid the foundation for a management information system subsequently
developed.

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