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INTRODUCTION
This Advocate's Guide was prepared
by the Alameda County Community Food Bank and the West Coast Regional
Office of Consumers Union to provide community-based organizations, advocates,
and recipients throughout California with information they may need to
participate in the transition to the Electronic Benefit Transfer (EBT)
system in their counties. EBT is an electronic delivery system for use
by recipients to access public assistance benefits. California counties
will be transitioning to the EBT system for food stamp benefits over the
next two years. At the same time, a majority of these counties will also
be transitioning to EBT to distribute cash benefits.
For many recipients, EBT represents
a dramatic change in the way they are accustomed to receiving benefits
and managing their finances. Ensuring that recipients have a positive
experience with the new system is a goal of all of those who are involved
in the EBT transition process. The EBT system also requires county welfare
departments to significantly change the way they deliver services to their
clients. Establishing successful new policies and procedures that work
well for recipients and county welfare department staff are essential
for the effective delivery of benefits through EBT.
Two pilot counties in California
have successfully converted to the new EBT system. Their county welfare
departments are reviewing their newly established policies and procedures
for EBT and are making changes where necessary. The majority of recipients
in the pilot counties are successfully using EBT. A large part of this
Guide is based on EBT implementation experiences in Alameda County, one
of the two California pilot counties. We have included many of the successes
and challenges of the transition to EBT in this pilot county, as well
as suggestions for how advocates and recipients can work toward the successful
implementation of EBT in their counties.
This Guide covers the following
areas: a general overview of EBT; advocate and recipient participation
in the EBT transition process; county decisions and considerations for
EBT; training and outreach; and the pilot evaluation process. For convenience
and quick reference, the Guide includes a glossary of EBT-related terms,
an index, and an appendix. A list of helpful websites and contacts is
also included.
It has been the experience
of advocates and county welfare department staff in Alameda County that
collaboration between the community and county welfare department has
resulted in a more successful EBT transition for the majority of recipients.
We hope that this Guide will help to facilitate the process of collaboration
between other communities and county welfare departments to ensure a smooth
and successful transition to the EBT system in their counties.
SECTION
ONE: Overview of Electronic Benefit Transfer (EBT)
What
is EBT?
Electronic Benefit Transfer (EBT) is an electronic system used to deliver
food stamp benefits to recipients. In some California counties, it will
also be used to deliver CalWORKs, General Assistance (GA)/General Relief
(GR), Cash Assistance Program for Immigrants (CAPI), and Refugee Cash
Assistance (RCA). In the future, EBT in California may be expanded to
include such programs as Women, Infants and Children (WIC), foster care,
Workers' Compensation, In-Home Supportive Services, etc.
How Does EBT Work?
People receiving food stamp benefits will no longer receive food stamp
coupons every month. Instead, they will be issued a plastic debit-like
card and a personal identification number (PIN) through which they will
access their benefits. With the EBT system, recipients will pay for their
groceries by swiping the EBT card (also called a Golden State Advantage
card) through Point of Sale (POS) devices in stores. All Food and Nutrition
Service (FNS) authorized retailers should be able to accept the EBT card
after signing up with Citicorp to do so. Citicorp is the State's contractor
hired to deliver EBT services in California.
In those counties that choose
to deliver cash benefits through EBT, these benefits will be accessed
through POS devices and Automated Teller Machines (ATMs). A recipient
can pay for his or her cash purchase by swiping the EBT card through a
POS machine. At many ATMs and stores with POS machines, people receiving
cash benefits will also be able to get cash using their EBT cards.
Why is California Changing
to EBT?
EBT is part of the 1996 federal welfare reform legislation. The federal
government decided that food stamp coupons are too expensive to manufacture,
distribute, and destroy. They also believe that an electronic delivery
system will reduce fraud. All states are required to convert to EBT by
October 2002. California will not have EBT implemented throughout the
state by this deadline. The USDA has granted California a waiver to go
beyond this date.
As of October 2002, 45 states
(plus the District of Columbia and Puerto Rico) are using EBT to distribute
food stamp benefits statewide. Three other states are either piloting
their EBT systems or are in the process of expanding their systems statewide.
Most of these states are using EBT for both food stamp and cash benefits
distribution.
When Does EBT Start in
California?
EBT will be implemented throughout California over the next two years.
The final counties should roll out in December 2004. Alameda and Yolo
Counties are the California EBT pilot counties and rolled out in August
2002. San Diego and San Bernardino Counties entered into contracts for
the implementation of EBT for food stamps benefits in 1997. When their
current contracts for EBT services expire, they are expected to switch
to the statewide EBT system, and could also choose to distribute cash
benefits through EBT. Sacramento County entered into a contract in 1997
to use EBT for General Assistance. When the Sacramento contract expires,
they are also likely to use the statewide EBT system.
Important county decisions
will be made in each individual county during the year prior to that county's
roll-out. A County Implementation Schedule is attached as Appendix A.
Updated schedules can be found on the State EBT Project website at www.ebtproject.ca.gov.
Who Is Responsible for
EBT in California?
In 2001, the State entered into a seven year, $250 million contract with
Citicorp Electronic Financial Services, Inc. (Citicorp or CEFS) to provide
the electronic delivery of Food Stamp Program benefits and cash benefits.
The contract may be extended beyond this period for an additional two
years. Citicorp has the vast majority of state EBT contracts nationwide.
For more information about these contracts, see www.fns.usda.gov/fsp/MENU/ADMIN/EBT/Status/EBT_Status_Report.htm.
The Health and Human Services
Data Center and the California Department of Social Services are responsible
for overseeing the EBT contract with Citicorp. The (California) State
EBT Project consists of staff from these two state agencies.
What Choices Do Counties
Have?
All counties must distribute food stamp benefits through the EBT system,
but each county was given the choice of whether to also use EBT to distribute
cash benefits. It is possible that counties that have not already chosen
to do so, may in the future, choose to issue cash benefits through EBT.
Thirty-seven California counties have, thus far, chosen to distribute
CalWORKs benefits through the EBT system and eleven counties have chosen
to distribute GA/GR through EBT. The list of counties choosing to distribute
cash benefits through EBT is attached as Appendix B. This list of counties
can also be found at the State EBT Project website at www.ebtproject.ca.gov.
In addition to choosing whether
to issue cash benefits through the EBT system, counties will have to make
several other decisions. The decisions include: How to transition recipients
to the new EBT system; how to issue cards for new cases; how to issue
replacement cards; what languages to use for recipient training materials;
whether to apply for a countywide exemption from the three-day stagger
required for cash benefits distribution; and other decisions. These decisions
must be made by each county starting approximately ten months prior to
the county's EBT roll-out. To learn more about the county decisions that
must be made, see Section Three and Appendix C (County EBT Decisions).
SECTION TWO: Advocate Participation in EBT Implementation
At the urging of advocates
across California, the State and some counties have established committees
consisting of State and county decision makers, advocates, and public
assistance recipients. These "formal" committees are a good
way to ensure that recipients and recipient advocates impacted by EBT
are able to discuss with county welfare department staff ways to best
implement the new system throughout the state and in their respective
counties. Other counties and communities are working less formally in
community partnerships. Discussed in this section are some of the committees
or partnerships that have been created thus far and suggestions for what
other advocates in California can do to start the collaborative process
in their counties.
A. Client Advocate Forum-Statewide
The Client Advocate Forum is a statewide quarterly
forum convened by the State EBT Project. Client
advocates and recipients from across the state attend
these meetings to discuss EBT issues and implementation
throughout California with State officials and decision
makers.
B. Alameda County EBT Advisory Committee
This is a committee developed in the pilot county of
Alameda that has been meeting monthly to discuss
EBT issues and implementation in Alameda. The
committee members include advocates, recipients,
county staff, and Board of Supervisors staff.
C. Community Participation in Various Counties
Advocates and community members in other counties
are working with their county welfare departments to
ensure a smooth EBT transition.
D. Suggestions for Advocates Throughout the State
Advocate and community participation is essential for
a successful transition to EBT. This subsection suggests
ways to start working on EBT in your county.
CLIENT ADVOCATE FORUM - STATEWIDE
Background
The Client Advocate Forum started meeting in March 2000 at the request
of statewide advocates to meet quarterly with State officials to discuss
the EBT system and how it would be implemented throughout California and
in individual counties.
The Purpose of the Forum
In Forum meetings, the State EBT Project staff provide information about
EBT policy, decisions, and implementation to community members and groups.
Advocates and recipients have the opportunity to provide feedback to the
State on the issues presented and also to provide feedback in their areas
of expertise about how EBT decisions could or are already impacting recipients.
As EBT rolls out throughout the state, this forum offers advocates an
opportunity to hear from other advocates and recipients about experiences
with EBT in their respective counties and to make suggestions to better
implement the EBT system in the rest of the state.
The Forum Composition
Forum participants include State EBT policy makers, county staff, advocates,
and recipients. "Membership" on this committee is open to any
recipient or community advocate who is interested in making the EBT system
work well. Regular Forum participants include: ACORN, Alameda County Community
Food Bank, California Association of Food Banks, California Reinvestment
Committee, Consumers Union, Eden Information and Referral (Alameda County),
Food Banks of Northern California, Homeless Action Center (Alameda County),
Legal Services for Seniors (Alameda County), Legal Services of Northern
California, San Francisco Food Bank, Strategic Actions for a Just Economy
(Los Angeles), Supportive Parents Information Network (San Diego), Sacramento
Hunger Commission, and the Western Center on Law and Poverty.
Additional advocates and recipients
are invited to participate in these meetings. For more information about
the Forum, please contact State EBT Project Liaison Dave Swift at (916)
263-3621 or dave.swift@sid.hhsdc.ca.gov, or Debra Garcia of Consumers
Union at (415) 431-6747 or dgarcia@consumer.org.
The Forum Has Impacted
EBT Throughout the State
Some of the successes of advocates and recipients on the Forum include:
persuading the State to encourage counties to solicit community feedback
on each county's cash access plan (see page 20); improvement to the State's
training materials through review and feedback of the materials; persuading
the State to include both Cantonese and Mandarin on Citicorp's Customer
Service Helpline; and persuading the State to send four key EBT communications
to recipients in all ten of the languages in which written training materials
are to be provided.
ALAMEDA COUNTY EBT ADVISORY COMMITTEE
Background
Approximately two years in advance of rolling out EBT in Alameda County,
local advocates learned that their county would pilot EBT. A number of
direct service organizations in Alameda County that were familiar with
the county welfare department (CWD) and the Food Stamp and cash aid programs
were concerned that the County and State would implement an EBT system
without community input. In September 2000, a small number of advocates
and recipients requested a meeting with the CWD to discuss how the community
would be involved in the decision-making processes of EBT implementation.
The first meeting between the community and County was in January 2001.
State representatives were also in attendance.
Following the meeting, advocates
and recipients requested that the CWD create a committee to ensure ongoing
community input. They asked the Board of Supervisors to support an EBT
Oversight Committee to consist of advocates, county staff, Board of Supervisors
staff, and recipients and presented a draft charter to the Board. Although
the name was changed to EBT Advisory Committee, advocates were successful
in this request, with the Board endorsing the creation of the committee.
After four negotiating sessions over the next several weeks, advocates
and the CWD agreed upon a charter to govern the Alameda County EBT Advisory
Committee (Appendix D).
The Advisory Committee met
once a month for several months prior to the implementation of EBT in
Alameda County and kept the Board of Supervisors apprised of their progress
on a regular basis. In addition to monthly meetings, Advisory Committee
members and other community members met on a more frequent basis, forming
subcommittees to discuss issues specific to certain processes or recipient
populations. The subcommittees formed include: the Client Conversion Subcommittee,
the Limited English Proficient (LEP) Subcommittee, the Communications
Subcommittee, and the Cash Access Subcommittee.
The committee structure was
formal, following Brown Act public meeting rules, which required that
agendas and minutes be publicly posted. In addition, the committee used
Robert's Rules of Order, allowing for more structured discussion when
controversial topics arose.
It is the broad consensus of
CWD staff, advocates, and recipients involved in the process, and the
Board of Supervisors, that the success of Alameda County's roll-out is,
in part, attributable to the work of the Advisory Committee. Alameda County's
Board of Supervisors sent a letter to the State's EBT Project Director
suggesting that for continued success in the implementation of EBT throughout
the rest of California's counties, other counties should be encouraged
to adopt a similar method for county welfare departments and communities
to work together in implementing EBT. A copy of the letter is attached
as Appendix E.
The Purpose of the Committee
According to the Alameda County EBT Advisory Committee charter, "The
purpose of the Alameda County EBT Advisory Committee is to assist in ensuring
that recipients are presented with the best possible Electronic Benefit
Transfer (EBT) system."
In practice, the purpose of
the Advisory Committee was carried out by:
- Providing a forum for CBOs,
advocates, recipients, Board of Supervisors staff, and county welfare
department (CWD) staff to discuss decisions that had to be made for
the successful implementation of EBT in Alameda County;
- Allowing for community input
into those decisions;
- Bringing to the attention
of the CWD issues of concern to recipients and the community; and
- Working together toward
solutions to actual and/or potential problems with EBT.
The topics discussed in these
meetings, and addressed by hours of work that occurred outside of the
meetings, are covered in this Guide.
Composition of the Committee
The Alameda County EBT Advisory Committee was composed of "Voting
Members" and "Resources." Both advocates and county welfare
department (CWD) staff wanted to assure fairness in the decision-making
process and also did not wish to discourage other members of the community,
or State representatives, from participating in the meetings. The Committee
was co-chaired by one CWD staff person and one advocate. Meeting facilitation
was rotated between the co-chairs.
The voting members included
seven community advocates, two recipients, three CWD staff, and two Board
of Supervisors staff. Alternate members for each category attended and
participated in the meetings. On the rare occasion when a vote was called,
the alternates voted only if they were filling in for a "regular"
voting member.
"Resources" consisted
of State staff, community members, and other guests. If a vote was called,
the resources did not vote. At the beginning of each meeting, the chair
asked the committee's voting members for permission for the resources
to be able to participate in the discussions. Full participation was always
allowed (with the exception of voting).
The community-based organizations
represented on the Advisory Committee and subcommittees include:
Advisory Committee:
Alameda County Community Food Bank, Bananas Child Care Referral Agency,
Bay Area Legal Aid, California Reinvestment Committee, Catholic Charities
of the East Bay, Consumers Union, Davis Street Community Center, East
Bay Community Law Center, Homeless Action Center, Legal Services for
Seniors, and the Women's Economic Agenda Project.
Advisory Subcommittees:
Advisory Committee member organizations, Board of Supervisors staff,
Asian Community Mental Health Services, Lao Family Center, Legal Language
Access Project, National Immigrant Law Center, East Bay Vietnamese Association,
Rescue Committee, Traveler's Aid, Oakland Private Industry Council,
and other immigrant and direct service provider organizations.
How the Advisory Committee Impacted EBT in Alameda County
Because it is impossible to know how EBT would have been implemented in
Alameda County if the Advisory Committee had not been formed, we can only
suggest those things that we are relatively certain resulted from the
participation of the Advisory Committee. Below is a short list of some
of the most important outcomes of the Advisory Committee's involvement.
At the State Level:
- The State required Citicorp
to include Mandarin and Cantonese customer service on the Helpline,
rather than just Mandarin.
- The State requested input
on the format of the cash access plan to make it more accessible for
communities to interpret, and implemented some of the Advisory Committee
suggestions.
- The State improved CBO and
recipient trainings and translated additional training materials partially
as a result of Advisory Committee feedback.
- The Alameda County EBT Advisory
Committee set a precedent and can serve as a model for other counties
to involve CBOs, recipients, and other community members during their
EBT implementation.
- The State agreed to survey
recipients and CBOs during pilot evaluation and the Advisory Committee
advised and assisted the State in collecting recipient and CBO interviews.
At the County Level:
Service to Recipients
- More time and attention
was paid to barriers facing Limited English Proficient (LEP) recipients
- especially with regard to how the county welfare department (CWD)
would provide translated forms, offer interpretation services at community
forums, and make calls to those who had not used their EBT cards in
the first ten days after conversion.
- The CWD sent six notices
(multilingual) to recipients prior to roll-out and the notices were
easier to understand due to Advisory Committee input. See Appendix F
for a copy of the first notice sent to recipients in February 2002.
- The CWD prepared recipient-friendly
forms (e.g., cash EBT exemption and three-day stagger exemption forms)
as a result of Advisory Committee input.
Community Outreach
- The CWD and Board of Supervisors
staff coordinated twelve community forums about EBT, in general, and
one community forum regarding fraud, personal security, and privacy
issues, in particular.
- More CBOs were prepared
for the change because advocates and CWD staff worked together to ensure
that as many CBOs as possible were invited to meetings and received
materials regarding EBT prior to roll-out.
Cash Access
- The Board of Supervisors
staff became involved in helping the State and Citicorp contact local
businesses to sign up to accept EBT.
- The State received additional
encouragement from advocates to ensure that the county's cash access
plan better met the needs of recipients, especially in hard-to-serve
zip codes.
- The State and Citicorp contacted
ethnic retailers, in languages other than English, who were identified
by the LEP Subcommittee as limited English proficient speakers.
- The CWD agreed to develop
and distribute to recipients lists of locations of surcharge and surcharge-free
ATMs throughout the county.
Food Stamp Access
- More attention was brought
to farmers' markets and ethnic retailers as locations that serve food
stamp recipients, and that otherwise might have been left behind in
the EBT transition.
What the Advisory Committee
Did Not Do
In hindsight, there were some things that the Alameda County EBT Advisory
Committee did not accomplish that advocates would have liked. Other recipient
advocates may wish to consider these ideas for their counties. Advocates
on the Advisory Committee were unable to:
- Convince the county welfare
department (CWD) to allow all GA recipients to "opt-in," rather
than "opt-out" of cash EBT (see page 34 for more information);
- Convince the CWD to set
up its own EBT helpline, as was done in Yolo County;
- Improve EBT services and
procedures for homeless and disabled recipients (see page 44 for more
information);
- Encourage greater participation
by farmers and farmers' markets to ensure that they would be able to
continue to accept food stamp benefits for purchases after EBT implementation
and that they would be ready to do so when Alameda County rolled out
EBT (see page 57 for more information).
Advocates in other counties may wish to consider the issues addressed
by the Alameda County EBT Advisory Committee as starting points to improving
the EBT transition process in their communities.
COMMUNITY
PARTICIPATION IN VARIOUS COUNTIES
The success of the pilot county
of Alameda was due, in part, to the county welfare department's willingness
to allow and invite community participation in the EBT development and
implementation process. Implementing EBT is a tremendous undertaking and
recipients will be better served by the involvement of community organizations,
advocates, and recipients. In addition to the statewide Client Advocate
Forum and the EBT Advisory Committee established in the pilot county of
Alameda, advocates and recipients in other counties set to roll out EBT
in the near future have also started dialogues with their county welfare
departments.
Los Angeles County
Similar to Alameda County, Los Angeles County has also established a "formal"
advisory committee. The Los Angeles County EBT Advisory Committee started
meeting monthly in Spring 2002. Voting members include recipients, community
advocates, and county welfare department staff. Los Angeles County has
approximately 40% of the welfare caseload in California and it is crucial
that advocates work to ensure that the EBT system works well for recipients
throughout Los Angeles. If you would like information about participating
on the Committee, contact Debra Garcia of Consumers Union at (415) 431-6747
or dgarcia@consumer.org, or the SAJE EBT Action Committee at (323) 732-9961.
A copy of the Los Angeles County EBT Advisory Committee Charter is attached
as Appendix G.
Solano County
The Solano County EBT Advisory Committee also began meeting monthly in
Spring 2002. Solano County is scheduled to roll out in December 2002.
Community members, recipients, and county welfare department staff have
been working well together to ensure the best possible implementation
of EBT in Solano County. A copy of the Solano County EBT Advisory Committee
Charter is attached as Appendix H. For further information, contact Debra
Garcia of Consumers Union at (415) 431-6747 or dgarcia@consumer.org.
Fresno County
Fresno County is an EBT food stamp-only county and is scheduled to roll
out in February 2003. Fresno will be one of the first food stamp-only
counties to convert to EBT. Community members in Fresno have formed an
EBT Action Team and are trying to work with the county welfare department
to ensure a smooth transition to EBT. For information about the EBT Action
Team, contact Edie Jessup of Fresno Metro Ministries at (559) 485-1416
or edie@fresnometmin.org.
San Francisco
San Francisco County is also an EBT food stamp-only county scheduled to
roll out in February 2003. Advocates and county welfare department staff
started meeting on a semimonthly basis in October 2002. They have decided
to collaborate on the following six specific areas: farmers' markets,
small retailer outreach, group living facilities, homeless conversion,
client notices, and the food stamp stagger gap. For further information,
contact Cindee Billings of the San Francisco Food Bank at (415) 282-1900
or cbillings@sffb.org.
Yolo County
Yolo is a California EBT pilot county in addition to Alameda. Because
the decision to include Yolo County as a pilot county was made just months
prior to EBT roll-out, there was not enough time for many members of the
community to learn about EBT and become fully involved in the transition.
However, a few advocates requested that they be included in the county's
implementation process and were able to provide valuable input.
In response to advocates' requests
to be involved in the EBT transition process, the county welfare department
invited a small number of advocates to participate on the county "workgroups."
County "workgroups" to be established in each county as part
of EBT implementation include the Benefit Access Workgroup, the Conversion
Workgroup, the Communications/Outreach Workgroup, and the Training Workgroup.
The general consensus of the advocates was that this type of community
involvement was not very productive. The county workgroups are made up
of county staff who have a number of specific tasks that they must accomplish
to implement EBT. Much of a typical two hour meeting was spent with county
staff discussing the tasks that they had to carry out. There was seldom
enough time for meaningful community input and some advocates became frustrated
with the process. However, some advocates working inside and outside of
this process were able to contribute toward a successful EBT roll-out
in Yolo.
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