[PEN-L:4883] Massachusetts welfare waiver request

[albelda@xxxxxxxxxxxxxxxxx]

The following appeal is directed to those who live or work in Massachusetts.

In February, Massachusetts passed the most punative welfare reform measures in
the country to date.  Some of you may recall a letter Mike Meeropol posted
outlining why it is so hateful.  Workfare, learnfare, time limits, shotfare,
fingerprinting, and family caps are all included--not to mention a benefit
cut of 2.75% (presumably just for the hell of it).

The state has submitted a waiver request to the Dept of HHS arguing why this
reform will encourage economic independence and reduce out-of-wedlock births.
The SSA of 1935 requires any "experimentation" with welfare be approved by
waiver with the Feds.  The Clinton admiistration has been giving out waiver
approvals with vitually no questions asked -- and have approved all these
measures (although not as one big package) in other states.  Nonetheless,
a group of academics in the Boston area have been writing expert declarations
about the potential harmful effects of the waivers.  In additions, two people
(neither are economists) also wanted to submit the following letter concerning
the waivers in Massachusetts.

If you live or work in Massachusetts, I urge you to sign on.
If you do not, but know people who do, please forward.  Thanks.

Randy Albelda
albelda@xxxxxxxxxxxxxxxxx

-------------------------------------------------------

     URGENT: Please forward and/or circulate this letter to
     colleagues at your own or other universities who may be
     interested in joining us.
****************************************

April 25, 1995

To:  Academic Working Group on Poverty and other interested
educators and researchers

Re:  Opposition to state's welfare plan

From:  Vicky Steinitz, U Mass/Boston and
       Elliot Mishler, Harvard Medical School


The Mass Law Reform Institute is preparing a response to the
state's request for a waiver from federal AFDC regulations. This
waiver is required before the state can implement recently passed
welfare legislation.  As part of that response we have drafted
the attached statement that documents how the state's
demonstration and evaluation plan violates ethical and scientific
research standards.  In our view the state's proposal is so
egregious that the academic research community should rise up and
register a protest.  Donna Shalala and Mary Jo Bane, the Health
and Human Service administrators responsible for approving the
request are themselves academics. This strengthens our view that
a strong collective statement from their colleagues might have an
impact.

Time is short.   Mass Law Reform must send their response to
Washington by May 10.  If you choose to support this initiative,
please send us your endorsement by May 5.  Include your name,
department/program and college in your message and send it in
whichever of the following ways is most convenient and quickest
for you.

        E-mail to: Elliot@xxxxxxxxxxxxxxxxxxxx
     or send a FAX to Vicky Steinitz at CPCS, U Mass: 287-7099
     or write to: Vicky Steinitz, CPCS, U Mass/Boston,
          Boston, MA 02125
     or call Vicky @ 287-7362 (If you phone, please send
          a note afterwards with your signature)

We will prepare a list of names for Mass Law Reform for inclusion
with their response.  We are preparing a press release that will
include circulation of this statement with signatures, and hope
to hold a press conference the week of May 8.

Please circulate the statement to other colleagues who might be
interested. We're aiming for at least 100 endorsements but hope
to receive many more.
****************************************************
                              AN OPEN LETTER

April 25, 1995

Donna Shalala, Secretary
     Department of Health and Human Services
Mary Jo Bane, Assistant Secretary
     Administration for Children and Families (DHHS)

Dear Drs. Shalala and Bane:

As educators and researchers, we wish to register our strong
objections to the Commonwealth of Massachusetts' waiver request
for a "welfare reform demonstration."  The project is punitive,
applying policies of deprivation, threat and coercion to a
vulnerable population of poor families and children.  Intended
solely for the purpose of reducing numbers of recipients and the
monetary costs of the AFDC program, it totally disregards the
severe harmful effects of the proposed policies.  We are appalled
by the clear violation of prevailing ethical and scientific
standards in the proposal and evaluation plan.  Our judgment is
based on key features of the project, listed briefly below:

     1. The "demonstration" and evaluation plan do not satisfy
ethical standards for research, codified in U.S. and state laws
and regulations for the protection of human subjects.  Public
outrage in the 1970s over unethical "scientific" experiments on
vulnerable populations - poor children, minorities, the mentally
retarded and mentally ill - led Congress to mandate regulations
to assure compliance of researchers with the fundamental ethical
principle: do no unnecessary harm.  Rigorous standards are
specified for pregnant women and children, particular targets of
the state's "welfare reform" proposals.  Subjects' rights for
informed consent, voluntary participation, and noncoercion are
fundamental features of these regulations.  Human studies
committees are instructed to assess the "risk-benefit ratio" of
research interventions.  The waiver request does not document any
precautions that will be taken to assure that subjects' rights
will be protected nor any procedures for assessing risks.  In all
these respects it is in violation of ethical research standards.

     2. The Massachusetts request violates the intent of the
waiver provision which is to provide opportunities for states to
carry out small-scale demonstration projects to test the efficacy
of program changes.  Careful assessment of both positive and
negative effects through well-designed pilot or experimental
studies is mandated before any changes are applied to the full
population. The Massachusetts "demonstration" applies its
"experimental" treatments to all recipients, save for a small
unspecified control group, prior to any information on their
effects.  Findings from the state's "evaluation" will not be
available until long after implementation of the proposals.
Meanwhile, the entire population is placed at risk.  Poor
children, already at high risk, will suffer the full force of
the added stress on families of scarcer resources and punitive
sanctions.  The impacts on their health, development and well-
being are incalculable and may well be irreversible.  The state
takes no account of these harmful effects and has no plan to
monitor or study them.  This is unconscionable and subverts the
ethical imperative and primary aim of Social Security and AFDC
statutes: to support and protect needy children.

     3. The scientific adequacy of the state's "evaluation plan"
is seriously flawed.  It is vague and lacks relevant details.
DHHS will not be able to make a reasonable determination of the
scientific quality of the study since critical features of the
research design are not specified.  Further, they cannot be
specified because the state will not issue an RFP (Request for
Proposals) until after approval of a waiver.  The state is
putting the cart before the horse - requesting a waiver before
DHHS has sufficient grounds for assessing whether the evaluation
study meets acceptable scientific criteria.

     4. The design of the current "evaluation plan," which will
serve as the basis for the RFP, does not ensure the relevance of
its findings to the complexities of the "demonstration."  Among
its serious limitations are the following: (a) Although the
demonstration includes more than fifteen different programmatic
changes - each a different experimental intervention - there is
no specification of how their relative impact will be assessed.
(b) Ritual reference is made to "randomly selected experimental
and control groups," but the plan shows no awareness of the
enormous difficulties of doing randomized field trials and
ignores well-recognized problems of variability among subjects on
dimensions that significantly influence effects of the
"experiment."  (c) By restricting outcome measures to reductions
in numbers of recipients and cost savings, i.e., the state's
political agenda, the plan fails to measure potential negative
outcomes, e.g., homelessness, health problems, malnutrition.
There will be no way to determine whether these potential
"costs," the harmful effects on subjects' lives, outweigh alleged
benefits, the state's overall cost savings in AFDC benefits.

Given the grave shortcomings of this waiver request, we urge you
to reject it and send a clear signal to our state government that
you will not allow the standards that guide the work of DHHS to
be compromised.




[This letter has been endorsed by (Number) members of the
Massachusetts academic community, whose names and affiliations
are listed on the attached pages.]