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Are your elderly or disabled clients losing access to their SNAP benefits due to DTA's recent "off-line" policy?

At the March SNAP Coalition meeting, community partners reported that some of their elder or disabled SNAP clients received notices that some of their SNAP benefits on their EBT cards were taken away due to DTA's "offline" benefits policy.  We are hearing that more elder and disabled recipients are confused or distressed by these notices and that DTA front line workers are upset with this policy.  This is our second email to flag potential problems.
Since mid-February, DTA has been sending client notices about offline SNAP benefits. These letters state that a portion of the recipient's benefits were "not used for at least 180 days and are no longer available on the EBT card." Clients are instructed to call their SNAP workers to get the benefits back.  See DTA Ops Memo 2014-8.  (This DTA policy also affects cash benefits, but we have heard only of SNAP problems so far).  It appears that DTA is taking the benefits off-line even if the EBT card was used during the past 6 months. The "offline" policy appears to be triggered if the full monthly benefit that was issued to the client 6 months ago was not completely accessed or used. For example, if a SNAP recipient received $50 in October, 2013 and used only $30 of that month, then $20 goes "off line" in April 2014 - even if the SNAP recipient used his EBT card multiple times since but there is still $20 "left-over" in April.  
Federal SNAP law directs states to "expunge" (permanently take away) benefits if the EBT card has not been used at all for 12 months (365 consecutive days). That is done by all states. However, Massachusetts is the only state in the New England region with this "off line" policy.  DTA also requires clients to track down case workers to get the SNAP benefit back vs simply having the SNAP benefits restored if they go food shopping.  
Why is this DTA "off-line" benefits policy a problem? 
  • Most SNAP workers have 900-1,000 SNAP cases.  Many DTA clients complain they cannot easily reach their SNAP workers due to busy phones and/or full voice mails.  Further, many DTA clients do not understand the "off line" notices, or do not have working phones or easy access to transport to get to DTA.  
  • Lack of activity on an EBT card sometimes means an elder or disabled SNAP recipient needs help with food shopping.  Rather than taking a client's benefits "off line" and waiting for a phone call - DTA should be affirmatively contacting clients with high balances and unused benefits to see if they need help finding an "authorized representative" to help with food shopping (someone to receive a second EBT card). For example, a SNAP recipient  from the North Shore recently contacted MLRI.  He is severely disabled and is not able to regularly get to the grocery store. This individual received DTA's offline notice but could not reach his DTA case manager to figure out how to solve the problem. With our intervention, his benefits were restored and his options for getting assistance explained. But not all SNAP recipients find an advocate.  
  • Other SNAP recipients -  especially those that receive the minimum $15 benefit -  often save up their SNAP benefits for a larger supermarket shop (getting the minimum SNAP also gets them a utility discount and LifeLine services).  But the DTA "off-line" notice is causing SNAP clients to believe they must spend the small monthly benefit immediately at the local corner store, rather than saving for a bigger food shop at a supermarket or CostCo where their is less expensive food.  
  • Many front line DTA staff seem unable to explain why a specific EBT amount was taken away even though the client used her EBT card in the past few months. It's indeed very confusing. Further, a number of DTA staff have shared with us that thuis DTA off-line policy requires 3 "check-offs" in BEACON to restore the "off-line" benefits - the case worker, the supervisor and the director - adding to already large case management tasks.
PLEASE continue to let us know if you have clients who got these "off line" SNAP or cash notices and have not been able to reach their case managers and/or get their benefits immediately put back on line. MLRI is monitoring this policy closely and compiling a report with recommendations on how to revise this and other recent policies that may have unintended or harmful consequences.   We will discuss this at next week's Coalition meeting.