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DTA starts implementation of new EBT photo requirement - will affect half of SNAP caseload

In August of 2013, the Massachusetts Legislature passed Chapter 65 of the Acts of 2013 which requires that certain EBT cardholders be issued EBT cards with photographic images. DTA Operations Memo 2013-55 is the initial memo announcing this change and includes sample notices to current SNAP and and cash assistance (TAFDC) recipients. DTA has elected to implement this policy quickly. Notices to SNAP and cash recipients affected by the new requirement have been mailed (see Attachments A and B in Ops Memo 2013-55). EBT recipients are starting to contact us with questions. The actual EBT photo cards will be issued in November and/or December. 

Here's important information you should know about the new EBT photo requirement in Massachusetts.

1. The following cardholders/case heads are exempt under the state law and will not have a photo place on their EBT card: Cardholders who are - 

  • age 60 or older,
  • blind,
  • persons with disabilities (e.g. receiving SSI, RSDI, MassHealth Disabled, EAEDC or other disability-based benefit),
  • under age 19 years, and
  • victims of domestic violence.  
Note that close to half of the current SNAP and DTA cash caseload is exempt from the EBT photo requirement. They are exempt based on age, disability, DV status, even if other household members do not meet these exemptions. (MA currently has 500K SNAP cases and 75K cash TAFDC or EAEDC cases). 
It is unclear right now how DTA will determine if a cardholder is a victim of domestic violence since this is not a question on the SNAP application or recert form. We are also concerned about persons with disabilities who are not identified in BEACON as receiving a listed disability-based benefit.  If you are aware of SNAP recipients who are victims of DV or have disabilities but have been told they must have a photo EBT card, please contact your local Legal Services office or MLRI.

2. DTA will use existing RMV photos for EBT card where available. DTA has been working with the Registry of Motor Vehicles to use existing driver license or state ID photos to the extent these photos match up with DTA data on name, DOB, SSN, etc. Households for whom there is no available RMV photo will be asked to come to a local DTA office for a photo appointment. Some households may be able to go to a nearby RMV for a snap shot. A household that has a hardship reason  (lack of transport, work hour conflict, lack of child care) should notify DTA either to reschedule, or to request a waiver. We do not yet have information on how DTA will be handling persons who request a waiver or such requests will be honored. Please contact a local Legal Services if DTA does not grant a waiver. 

3. Federal USDA rules include THREE important legal requirements that SNAP recipients and community partners need to know about:

  • All appropriate members of the SNAP household or authorized representatives are allowed to use the EBT card - whether or not their name or photo is on the EBT card. This includes spouses, older children, unrelated persons who participate in the SNAP grant, as well as caregivers of SNAP recipients who do their shopping (as determined by the household). The PIN is what protects the card, not the photo!  
  • Retailers who participate in the EBT program cannot selectively ask to see a SNAP EBT card or otherwise discriminate against SNAP recipients, such as set up "SNAP-only" lines. Stores may card ALL customers who use a debit or credit or EBT card, or none. Discriminatory practices should get reported to USDA. 
  • SNAP benefits are inter-operable between states. This means that SNAP recipients from from out-of-state can shop in Massachusetts, and all MA EBT residents can shop out of state. (Most EBT out-of-state shopping occurs in boarder communities.) Note: no other state in the US has a photo EBT card. 
Please let us know what you are hearing from SNAP recipients about the new EBT photo requirement, if recipients who should be exempt are told they must get a photo, and if you hear that any retailers are hassling SNAP or cash recipients at the check out counter.