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Objectives. Financial penalties, or sanctions, are a core mechanism for enforcing the work requirements of the Temporary Assistance for Needy Families program and helping clients achieve self-sufficiency. This study's objective is to examine whether sanctions are being administered consistent with policy goals of encouraging work.

Methods. This study uses administrative fair hearing decisions, which are the product of an adversarial-style procedure triggered when a client appeals an adverse decision by the agency, including work sanctions. Qualitative content analysis is used to analyze the decisions.

Results. The study found that despite organizational reforms, local offices had created the welfare-to-work version of an eligibility-compliance culture, where sanctions were based primarily on attendance records and became a paper-processing function. Transactions between clients and workers were often routinized and mechanical, resulting in improper and arbitrary sanctions that were reversed by the hearing officers nearly 50 percent of the time.

Conclusion. This study underscores the importance of scrutinizing and correcting agency errors that may undercut clients' engagement in work activities.