The Online Resource for Massachusetts Poverty Law Advocates

SNAP and Photo EBT Cards: Information and Resources


What are Photo EBT cards and who needs to have one?

Massachusetts state law now requires that certain EBT card holders be issued Photo EBT Cards with their picture.  If you receive SNAP or cash benefits, you may need to have a photo EBT card. DTA will either use an available photo from the Massachusetts RMV (driver's license or state ID) or will schedule a time for you to come to DTA for a photo. Many people are exempt. See list of exceptions below. DTA issued guidance in November 2013 implementing the Photo EBT card requirements and updated it in Febuary, and then June, 2014: See Operations Memo 2014-28 and  Operations Memo 2014-29.  (Operations Memos 2013-57A and 58A, and 2014-17 and 18, are obsolete.) The information below summarizes key information you should know.

 Image of EBT card

Applicants and recipients who are not exempt from this law recieve EBT cards with a photo--either from a photo on record with the RMV or from a photo taken in a DTA office (see sample card above).  


Applicants and recipients who are exempt from this law may receive EBT cards that state "VALID WITHOUT PHOTO" (see sample card above). 

Applicants and recipients who are exempt from this law may still have a blue "Bay State Access" card (see sample card above).

Information for Grocers, Retailers and EBT card holders:

There are NO changes to how the EBT card operates at the point of sale (POS) device. The SNAP household can use the same PIN they had for the former blue card, or can change the PIN at any time. Grocers and retailers do not need to do anything different to approve transactions as long as the customer's EBT card is working and the proper PIN is used. Grocers and retailers should not ask to inspect the card nor deny any household member from using it (see below). 

If a SNAP household discovers their EBT card is deactivated or not working, urge them to contact DTA immediately. An EBT household can alwasy check if the card is active and check the card balance by calling the EBT Customer Service Number, located on the back of the EBT card: 1-800-997-2555.

What are the exceptions to the Photo EBT card requirement?

This photo card requirement affects less than half of the current SNAP population in Massachusetts (or about about 220,000 SNAP households out of 490,000 MA households). There are six EXCEPTIONS to the Photo EBT Card requirement. The SNAP household does not need a photo on the card if the card holder (head of SNAP or cash household) is:

a.    Age 60 or older
b.    Disabled
c.    Blind
d.    Under age 19
e.    Victim of domestic violence or
f.     Has a sincerely held religious belief objecting to a photo/facial image.

If you get a DTA letter telling you that you need a photo EBT card, but you meet one of the above categories, you can call your DTA worker to request an exemption from the EBT photo requirement. Note: A victim of domestic violence can self-attest to the domestic violence and is not required to have a “heightened level of security” on his or her case. DTA will refer these individuals to a domestic violence specialist for any additional services needed. Clients with disabilities do not need to receive disability-based benefits in order to claim this exception, and do not need to verify the disability. Any EBT photo cardholder who turns 60, becomes disabled, becomes a victim of domestic violence or meets the other exception can also get a replacement “Valid without Photo” card issued at any time, for no fee. Also, if the client is not eligible for SNAP benefits due to immigration status (but recieves SNAP for eligible household members such as citizen children), they will also receive a "Valid Without Photo" card. 

If an EBT cardholder is not exempt, how do they get a photo EBT card?

For SNAP applicants or recipients whot do not meet one of the six exemptions, one of two things will happen.  1) For persons who have a Mass driver's license or State ID with the Registry of Motor Vehicles (RMV), DTA will use this photo and mail a card to the recipient with the photo, or the client can go in to a DTA office to pick it up. 2) If the RMV does not have a photo, or DTA is not sure it is correct, DTA will schedule an in-office photo appointment. 

Recipients can RESCHEDULE the photo appointments if they cannot make it for any reasonDTA cannot deny or terminate benefits for household failure to show up for a photo appointment. Please let us know if a case is closed because a client could not get to DTA for a photo.  

What are the rights of SNAP households when shopping for food?

1. Every SNAP household member has the right to use the EBT card.* Stores cannot refuse to accept the EBT card from household members, such as spouses or older children. This is true even if their name or photo is not on the card. In addition, caretakers or authorized representatives can also use the EBT card to food shop for the cardholder. Just like a debit card, the PIN is what keeps SNAP benefits safe and works as an electronic signature. If the proper PIN is used, the shopper should be able to use the card.

2. Stores cannot treat SNAP recipients differently from other shoppers.* A store clerk cannot ask to see your EBT photo card unless they routinely ask everyone using credit or debit cards to show a photo ID.  Also, stores that accept EBT cards cannot set up “SNAP-only” checkout lines or discriminate against SNAP households.

At this point in time, DTA is urging SNAP workers to collect detailed information on any incidents and report them to the Policy Hotline. MLRI will also produce materials for you and your clients to track any abuses. In addition, clients can file a 93-A demand letter if they experience issues with retailers when using their EBT card. Click here to visit a web page that has information about the process of filing a 93-A demand letter, along with a sample letter. 

*Federal rules protect the right of all authorized members to use the EBT card and to not be discriminated against, under the following Code of Federal Regulations:  7 CFR 274.7(A), 7 CFR 274.8(b)(5)(iv), 7 CFR. 278.2(b)

When did Massachusetts start issuing Photo EBT cards? 

In November 2013, DTA mailed new EBT photo cards to SNAP card holders required to have a photo on the EBT card. DTA used photos available from the Mass Registry of Motor Vehicles. Note: DTA did NOT mail new cards to the 250,000 SNAP households exempt from the EBT photo card rules (See exceptions agove).  During the initial roll-out, DTA deactived the old blue card midnight before the date the recipient's December benefits were issued (The date SNAP benefits are issued based on the last digit of the SSN of the household). Approximately 12,000 MA EBT households did not get their new cards before their blue cards were deactivated. Most of those households should have since received their photo EBT cards. DTA also mailed photo appointment notices to households that needed a photo but did not have an RMV photo on record. 

We have attached the following documents to this page:

1. 3 Things You Need To Know About Photo EBT Cards flier (English and Spanish). 

2. Religious Exemption Certification Statement: A DTA form for clients who have sincerly held religious beliefs against photos  

3. A copy of the EBT brochure that was sent to clients with the Photo EBT card. 

4.  DTA mailing to recipients on the new photo EBT requirement: This notice explains the upcoming change, highlights that retailers cannot discriminate and that all household members can use the EBT card.  

5. MLRI informational flier for retailers and grocers, including a flier for MA Farmers Markets

For more information about Photo EBT cards, contact Pat Baker, MLRI, 617-357-0700 x 328 or Vicky Negus, x315.