28 March 2015


The Urban Institute has released a report [PDF] by Gregory B. Mills and Christopher Lowenstein on Assessing the Merits of Photo EBT Cards in the Supplemental Nutrition Assistance Program.

The authors comment
In seeking to reduce the trafficking of electronic benefit transfer (EBT) cards in the Supplemental Nutrition Assistance Program (SNAP, formerly the Food Stamp Program), states are considering—and some have implemented—the use of photo EBT cards. These personal identification number (PIN)-protected EBT cards include an imprinted photograph of the SNAP case’s head of household. Massachusetts adopted a statewide photo EBT policy in fall 2013, and Maine has more recently sought to expand a one-county pilot project statewide. Though states are given the authority to implement such policies under the Food and Nutrition Act of 2008, the statute also requires that “the State agency . . . establish procedures to ensure that any other appropriate member of the household or any authorized representative of the household may utilize the card.”
States’ use of photo EBT cards in SNAP has sparked controversy. These policies place in direct conflict two principles: the desires of state government agencies and taxpayers to uphold program integrity, and the statutory rights of SNAP household members and their designated representatives to use program benefits without being subjected to additional scrutiny in the retail marketplace. The US Department of Agriculture’s Food and Nutrition Service (FNS), the federal agency that administers SNAP, has sought through its regional offices to ensure that the photo EBT procedures and practices of state agencies and food retailers adequately protect clients’ rights to full benefit access and equal customer treatment. Client advocacy organizations contend that photo EBT policies undermine program participation by imposing undue procedural burdens upon households legitimately entitled to SNAP benefits and by re-stigmatizing program use by clients in food retail establishments. Representatives of food retailers indicate that checkout clerks typically refrain from checking the photo on the EBT card, relying on the PIN to protect against unauthorized card use.
This brief examines the extent of trafficking of EBT cards in SNAP, the efforts in place to monitor and deter trafficking behavior by clients and retailers, the proposals introduced in state legislatures to implement photo EBT cards, and the photo EBT initiatives implemented since 2008. A case study is presented of the Massachusetts experience with its statewide photo EBT policy, more than one year following rollout. The available information on the costs of the Massachusetts policy is compared to the potential benefits that may result from reductions in trafficking.
What emerges from this review is the absence of a compelling logic model to suggest that photo EBT cards might meaningfully reduce card trafficking, given that such trafficking involves the complicity of individuals and retailers for whom a photo on the card will not act as a deterrent. The cost estimates of operating a photo EBT policy, weighed against the limited expectation of altering the behavior of would-be traffickers, suggest strongly that photo EBT cards are not a cost-effective approach to combat trafficking. This assessment is strengthened by evidence from Massachusetts that retailer clerks generally do not check the photos on the cards. Moreover, it is evident that many participants who are subject to the state’s photo EBT card requirement have encountered difficulty with the state agency’s procedures for obtaining a photo card and with the grocery checkout practices of some food retailers that have prevented participants from accessing their program