The passage of PRWORA in 1996 gave states the opportunity to engage in secondorder devolution (SOD), which allows local governments to exercise more discretionary power in the implementation of welfare policies. Currently 14 states have engaged in significant SOD, with a number of other states practicing SOD to a lesser degree. Given this trend in TANF administration, it is important to explore if and how SOD affects the implementation of TANF work sanctions and work-related policies. Opponents of welfare decentralization insist SOD may lead to a ‘race to the bottom’ in welfare generosity to avoid the immigration of the poor, the loss of business revenue, and financial burden due to fiscal relationship, while proponents of welfare decentralization insist that local governments better understand the needs of the poor and are therefore better able to provide more appropriate services to their welfare clients, thus improving program performance. Existing scholarship on SOD under TANF has focused on the increase in discretion to local government, and how this may enhance variation in policy outcomes or contribute to policy success or stringency across local jurisdictions (Cho et al. 2005 ; Fording, Soss and Schram 2007). However, these studies are limited by the fact that they examine a single state. To date there has been no systematic analysis of the impact of administrative structure on the implementation of welfare policy which compares centralized states with SOD states. In this dissertation, I conduct an analysis of the effects of SOD across the states by exploring how differences in administrative structure due to SOD affect different implementation outcomes. First, I examine the impact of SOD on the implementation of TANF work sanctions, using individual-level administrative data combined with county level data. Second, I examine the impact of SOD on TANF work sanctions, caseload decline, and several work-related TANF outcomes with state-level data. Multilevel analysis and OLS with panel corrected errors are applied for the analyses. Specifically, I test the conventional wisdom that success and punitiveness in policy implementation is enhanced in second-order devolution states, compared to centralized states, due to increased discretion granted to local governments in SOD states.