February 19, 2002

Office for Civil Rights
U.S. Dept. of Health & Human Services
233 N Michigan Ave
Ste. 240
Chicago IL 60601

ATTN: Patricia Lucas

Dear Ms. Lucas:

Yesterday we sent you a complaint regarding disability discrimination and possible racial discrimination in Wisconsin's W-2 (TANF) program. Among our concerns was "the extent to which such [racial] disparities may permeate the entire [W-2] program."

After that complaint was sent to you, we received information from Wisconsin State Sen. Gwendolynne Moore regarding racial disparities in sanctioning W-2 recipients. According to the attached data, which Sen. Moore recently received from Wisconsin's Legislative Audit Bureau, in Milwaukee African-American W-2 participants comprised 63.6% of W-2 participants but 65.5% of the persons sanctioned. In the "Balance of State" (outside Milwaukee) the problem is particularly stark: African -Americans comprised only 20.2% of the W-2 participants but 35% of the participants sanctioned. At the same time, in the Balance of State whites comprised 59.1% of W-2 participants but only 45% of the participants sanctioned.

These disparities highlight the need for a neutral, independent evaluation of the extent to which racial disparities permeate the W-2 program, as noted in the complaint filed yesterday.

Please contact me should you have any questions or require additional information.

Sincerely,

Karyn L. Rotker
Staff Attorney
Poverty, Race & Civil Liberties Project
American Civil Liberties Union of Wisconsin