New EBT Replacement Card $5 Fee; New DTA Policy on Verifying SNAP/Cash Recipient Change of Address

FoodSNAP
05/06/13

DTA recently issued a number of policy memos we wish to bring to your attention.  Some of these policy memos will have an impact on your clients. DTA has issued these memos largely in response to recent negative press including a report by the State Inspector General that took issue with DTA’s lack of record keeping, tracking of address changes as well as concerns about the number of EBT cards issued to households. (Unfortunately, the IG report never noted that DTA's caseload surged during the Recession while the number of caseworkers declined and that DTA does not have document imaging - leaving them to fight a forest fire with garden hoses. SEIU is still battling to increase funding for front line case workers to address that shortfall.) 

We are providing DTA with feedback on these policies but want to be sure you are aware of them so that you can advise your clients.

New $5 EBT Card Replacement Fee Policy - Operations Memo 2013-16 : 

In 2012, DTA requested and received permission from USDA to charge households a $5 fee for a replacement EBT card.  The goal of the policy is to both encourage SNAP and cash recipients to hang onto their EBT cards, and discourage illegal trafficking (selling of SNAP EBT cards for cash).  The $5 fee will be collected from the household’s SNAP benefits, or out of their TAFDC or EAEDC benefits if they receive both.  If a household requests 4 or more cards, they must go to their local DTA office to discuss why they need multiple cards.

All DTA clients received a mailing advising them of the new policy and reminding them that the EBT card can last for years, even if the benefits end but start up again. However, the EBT notice did not list the exceptions to the fee and Operations Memo 2013-16 does not reference these either. The exceptions are included in DTA’s initial guidance of December 2012 on the EBT fee included inOperations Memo 2012-56, (this 2012 memo has not been rescinded).  

There is NO $5 fee charged if:

 

  •  The initial EBT card was never received and used for food shopping.  This is very common. For example, DTA offices tend to delay requesting the card be sent timely (an issue we have raised with DTA Central), and the applicant may end up at a local DTA office to get the EBT card even if the initial EBT card is “in the mail.”  There should be NO fees in this case.  
  • The EBT card is defective (e.g. the magnetic strip does not work or it gets twisted or cut).  However, the client needs to bring the defective card to DTA in order to get a replacement. 
  • The client changed his or her name or SSN, or another household member becomes head of household. 
  • The client needs an accommodation due to disability, domestic violence or certain emergency situations. 
  • The SNAP or cash case has been closed for more than 30 days and the client reapplies but does not have his or her old EBT card (clients sometimes throw their EBT cards away if they think their benefits are over.)   

 

If you have clients who believe they were charged the $5 fee incorrectly, please contact the local DTA office to discuss why this happened.

New Policy on Verification of residence when DTA receives returned mail -Operations Memo 2013-13A:  

In 2012, the Inspector General raised concerns about the volume of undelivered mail that came back to DTA. Many of these involve informational mailings about voter registration (DTA had failed to follow federal laws on registering applicants and recipients to vote), and mass mailings involving EITC and child care information. Operations Memo 2013-13A now requires DTA to track all returned mail, and then send the household a form requesting additional information and verification of change of address. 

We appreciate that DTA needs to keep track of where recipients live, but we also know from experience that it is challenging for recipients to reach their case managers to report a change of address, that voice mails are full and that client documents sent to DTA reporting changes get lost or not recorded in the BEACON case file system.  We also find many situations where the Post Office simply does not deliver recipient mail. We have already heard from clients with SNAP "whereabouts unknown" notices who have NOT moved and are tracking those down.  DTA is in the process of revising the recipient form attached to Operations Memo 2013-13A, to which MLRI has provided suggestions. 

Meanwhile, we urge you to monitor and advocate for clients in the following situations: 

 

·         Recipients who have NOT moved but have received notices asking for re-verification of their residence based on returned mail. 

We need to know how widespread this problem is, if it happens as a result of the mass non-essential info mailings, or the essential recipient-specific mail.  Field Operations Memo 2008-22, which is still in effect as far as we know, requires DTA case managers to call the client at the  phone number in the case record to find out why the mail might have been returned, check the spelling of their name and address, and suggest ways to deal with Post Office delivery problems (like getting a PO Box).  If the client received the DTA notice requesting proof of residence at her unchanged address – it would good to know if DTA workers are following this protocol as it would not be off the wall to conclude that the earlier returned mail was an error by the Post Office.  

·         Recipients asked for specific verifications (such as a landlord statement or lease or proof of home ownership), but not allowed to provide other proofs. Remember, the SNAP regulations allow for a range of verifications residence that have an applicant or recipient's current address on it - such as a wage stub, driver license, utility bill, phone bill, school record, doctor’s bill, tax notice, health insurance notice as well as rental or home ownership information.  

 

·         Homeless recipients who may not have any fixed mailing address. These recipients can ask their local DTA office to also collect their mail for pick up.  This may work well if the homeless individual is geographically near the DTA office and is able to get there on a regular basis to pick up mail.

·         Recipients not given sufficient time to provide the required verifications. The federal rules require a household to have at least 10 days from receipt of the request for verification – which should include time for mail delivery of the notice.