EBT Photo Card Update: Status of Deactivated Cards; Issues to Flag, Next Steps

01/07/14
We are continuing to receive calls and emails about the Massachusetts EBT photo policy from community partners and individual recipients. This email is to give you a brief update on the EBT photo card implementation and to ask you to continue to flag EBT card cases, even if resolved. We very much appreciate hearing from SNAP Coalition community partners who have assisted SNAP recipients with emergency food and community meals due to premature deactivation of their blue EBT card before a replacement card was issued. Our goal is to help the Patrick Administration understand the problems with the December EBT roll-out and to quickly identify individuals still without active cards. We have also urged them to NOT deactivate any additional EBT cards in the coming months and have provided EOHHS with detailed recommendations to that effect. If you would like a copy of our recommendations, please contact me.
 
Here's an update on the December EBT deactivated cards: 
  • Before December 25th, over 10,000 EBT photo cards (out of 170,000 EBT photo cards mailed 11/25-12/5 - using RMV-generated photos) were returned to DTA Central. They were returne because the US Postal Service was unable to deliver them for various reasons. Unfortunately, DTA had Xerox (the EBT vendor) deactivate the regular blue EBT cards on midnight before the December benefits were issued. As a result, these 10,000 EBT recipients lost immediate access to their December benefits. At the behest of MLRI, DTA agreed on December 11th to arrange for overnight mail of cards that did not arrive before the December benefits were due, but this did not prevent delays in accessing benefits (and was not a good solution for recipients who could not be reached, nor those who could not wait home all day to sign for the USPS delivery). 
  • As of December 27th, about 5,000 recipients of the 10,000 recipients whose cards were deactivated managed to get new EBT photo cards, some losing work hours and incurring travel costs to wait in congested DTA local offices to get the card while hundreds of other recipients were there to have photos taken. As of December 27th, about 5,000 recipients still did not have activated EBT cards. We do not know the status of these cases at this point, nor why the mailed EBT card was undelivered. Based on the calls we received and reports from the field, a number of the EBT recipients who never got new EBT cards had not moved, had reported a move to DTA or were under the SNAP semi-annual reporting rules (not required to report a change of address until their 6 month reporting period). 
  • In addition to these 10,000 EBT recipients, there is an undetermined number of recipients whose EBT cards may have gotten "lost in the mail" or the cards were delayed in arriving till after the December issuance date due to the December holiday mail. We have requested that EOHHS (Executive Office of Health and Human Services) and the USDA Food and Nutrition Service look into the EBT activity/ usage for all recipients in December 2013 to determine if there are recipients who still have not been able to access their cards.
  • About 700 EBT card recipients had their new EBT photo cards mysteriously deactivated by Xerox, for reasons we still do not know. 
Ongoing EBT photo card issues: 
  • As noted above, DTA continues to schedule in-office photo appointments for the 55,000 EBT households required to have EBT photo cards and for whom they lack RMV photos. We have heard from clients who have hardship situations making it difficult to get to the DTA office including lack of transportation, lack of child care and work/training hours which conflict with DTA hours. Note that DTA cannot terminate the SNAP or cash benefits for failure to come in for a photo EBT appointment. (Unfortunately, DTA has insisted that this photo process continue even though local offices are still handling recipients whose photo cards were lost in the mail. Many SNAP workers are getting behind in recertifications.) 
  • DTA is also scheduling photo-appointments for immigrant heads of households who lack SSNs (e.g. ineligible parents for U.S. citizen children) but DTA is then giving these households a "Valid without photo" EBT card, which is both creepy and confusing for the immigrant clients. Community groups report that DTA office are providing no information as to why these immigrant households do not get a photo EBT card after taking the photo, or are telling them to "come back when they get an SSN" - which could be never. We would like to hear what you are seeing in these cases and if clients are confused or scared off from continuing to get SNAP or cash benefits for their eligible children.  
  • Persons with disabilities are exempt from the EBT photo requirement (as are caseheads age 60+, under age 19, victims of domestic violence and persons with religious exemptions.) However, DTA does not affirmatively screen for and mark SNAP recipients as disabled unless the individual already receives a disability-based benefit such as SSI, Social Security, MassHealth-Disabled or EAEDC benefits. Victims of domestic violence are also exempt, but again, this is not routinely screened.  If you have any clients who have a disability or are victims of domestic violence and who do not wish an EBT photo card, they should be able to self-declare their disability or DV and be excused from the photo EBT card.  
What you can do:  
  • If you have any clients who do NOT have access to their EBT benefits due to a deactivated blue card, there are TWO steps you can take:  a) Ask the recipient if he or she wishes DTA to issue an overnight EBT photo card by mail, or if he or she can get to the local DTA office to pick up a new photo EBT card in person. (Note, the client needs to be home for the USPS overnight mail delivery.)   b) Call the DTA local office director to confirm the overnight request (if that works best for the client) or let the director know that the client will be coming in person.  It is critical that EBT recipients get EBT cards that work ! 
  • Let me or Vicky Negus at MLRI know if you have clients who lost access to their December SNAP or cash benefits for any period of time, even if they now have an activated EBT card. We'd like to know what happened so we can help other SNAP and cash recipients. You can reach Vicky at vnegus@mlri.org or 617-357-0700 x 315 or me at x 328.
  • Notify your local State Rep and State Senator of these and other EBT implementation problems. They need to understand what is happening to low income constituents in their communities as a result of this change in the state law, even if the immediate problem is solved. 
                                                                                                          And PLEASE FLAG any of the following situations:
 
  • Closing of SNAP case due to missing an in-office DTA photo appointment or an in-office SNAP recertification interview:  Let us know if you see clients who cannot get to DTA for a photo appointment or for a SNAP recertification interview. Be sure to tell them they can reschedule the photo appointment or come in on any Friday. For clients who have a hardship reason and are unable to get to a DTA office at all, note that federal SNAP rules require DTA to allow good cause for hardship situations including disability or illness, lack of transportation, work or training hours that conflict, lack of child care. 
  • Immigrant-headed households who were not given a photo EBT card (even if not eligible themselves) and who are confused or scared by the photo EBT process. 
  • Persons with disabilities or victims of domestic violence who are unaware of their right to claim an exemption or for whom going to a DTA office would be a hardship, These recipients can self-declare their disability or DV and should be excused from the in-office photo appointment and their blue cards should remain active. They can also request a new EBT card Valid-without-photo at any point (and without charge)
  • Confusion/inappropriate treatment of SNAP recipients at supermarkets, grocery stores and convenience stores.  REMEMBER - every household member has a right to use the EBT card even if their name or picture is not on the card. Grocers and retailers cannot ask to look at the EBT card photo unless they have a store policy of asking for photo ID of all shoppers who use a debit or credit card. There can be no discrimination against SNAP recipients. Unfortunately the EBT cards do not contain this information, 
  • For copies of MLRI's flier provided to EBT recipients and to retailers, see the attached or go to www.masslegalservices.org/photoEBT    
Attachment Size
Informational Flier Retailers and Grocers from MLRI-12-12-13 FINAL.pdf (259.88 KB) 259.88 KB
MLRI Flier - 3 Things You Need To Know About Photo EBT Cards ENGLISH - Nov 2013 1_1.pdf (113.29 KB) 113.29 KB