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Report
Acknowledgements
Glossary
List of Website & Contacts
List of Appendices
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REVIEWING
THE CASH ACCESS PLAN
Statewide
The State's contractor, Citicorp, will prepare a "cash access plan"
for each county that has chosen to distribute cash benefits through the
EBT system. The cash access plan will be broken down by zip codes within
a county and should list every location in the county where recipients
can use their EBT cards to access their cash benefits, whether there will
be a surcharge, and if so, how much, and the maximum (or estimated) amount
that can be withdrawn in one transaction from that location. (A sample
matrix for one zip code from Alameda County's cash access plan is attached
as Appendix J.)
Citicorp is required by contract
to work with the State and with each cash EBT county in developing a cash
access plan that meets a "minimum access" standard as outlined
in the State's contract with Citicorp. State law requires that recipients
have "reasonable access" to their cash benefits. The State encourages,
but does not require, counties to involve the community in developing
and reviewing their cash access plans.
Each cash EBT county will receive
three versions of the cash access plan for the county. The first version
is called a "template," the second version is called the "draft"
or "first draft," and the third version is called the "final"
cash access plan. The template should be delivered to each county five
months prior to the county's scheduled roll-out date. A number of weeks
will then be given to the county to review the template and provide input.
The same process will then occur for the first draft. The final cash access
plan is the version the State will use to determine if a county's cash
access plan meets the contractual "minimum access" requirements,
and the county and State will then use the final plan to determine if
the statutory requirement of "reasonable access" has been met.
This three-phase process provides opportunities for the county to seek
public input on the plan.
Acceptance of a County's
Cash Access Plan
As previously mentioned, Citicorp is required by contract to work with
the State and with each county in developing a cash access plan that meets
the "minimum access" standard as outlined in the State's contract
with Citicorp. State law requires that recipients have "reasonable
access" to their cash benefits. However, it is the State, and not
the county, that has the final say as to whether a cash access plan for
a particular county is acceptable.
Although the State has final
authority to accept a cash access plan for a county, the Los Angeles County
Board of Supervisors has made its decision of whether or not to be a cash
EBT county contingent upon its final review of the cash access plan developed
for Los Angeles. At the time of publication of this Guide, advocates were
working with the county welfare department to establish the Los Angeles
criteria for the County's "acceptance" of its plan.
State Measurements of
"Reasonable Access"
The State has chosen three measurements to be used in determining if Citicorp
has met the contractual "minimum access" standard, and ultimately,
the statutory "reasonable access" standard. The measurements
are: capacity, proximity, and distribution. In the event that these three
measurements are not met, the State will look at "alternatives"
to meet the cash access needs in a particular zip code. Unfortunately,
the State is not requiring that any of the cash access locations be surcharge-free
for recipients.
Provided below is a summary
of the measurements of "minimum access." For a more detailed
description of the "minimum access" standard and measurements,
see section 5.10 of the State's "Invitation to Partner" located
on the State EBT Project website at www.ebtproject.ca.gov.
- Capacity is the measurement
that requires that there be enough cash available on benefit issuance
days (the first three calendar days of the month) to enable recipients
to withdraw the full amount of their benefits.
- Distribution looks at whether
the cash access locations are adequately dispersed.
- Proximity requires that
cash access locations be in zip codes where recipients live, or in neighboring
zip codes.
- Alternative Solutions may
be used to meet "minimum access" if the measurements of capacity,
distribution, and proximity cannot be met. These might include using
"excess cash access" in neighboring zip codes or counting
places where recipients can use their EBT cards to purchase money orders
or pay bills.
In
Alameda County
The Alameda County EBT Advisory Committee spent a significant amount of
time reviewing and debating the template and draft cash access plans.
It was clear from the very beginning that there were certain zip codes
where meeting "minimum access" would be problematic. Some of
the challenges were:
- In some zip codes, it was
agreed that there were enough ATMs and POS machines to meet the "capacity"
measurement. However, there was disagreement about whether the "distribution"
measurement was met, and advocates were concerned that the cash access
locations were not in adequate proximity to recipients, as the machines
were located far from where large numbers of recipients lived and were
sometimes divided from recipients by railroads, freeways, metro rails,
etc.;
- Zip codes having little
or no commercial infrastructure (e.g., few banks or grocery stores)
made it very difficult to find places to enlist for recipients to use
their EBT cards.
- Some zip codes did not have
any ATM or POS machines at all, requiring the State and Citicorp to
develop "Alternative Solutions" by using ATM or POS locations
in a neighboring zip code; and
- Some ATM locations were
expected to absorb significant EBT use in areas where banks and ATM
machines were limited, which increases the likelihood of ATM malfunctions
(e.g., running out of money, running out of receipt paper, breaking
down, etc.).
In addition to not meeting
the "minimum access" standard in a few zip codes, the advocates
on the committee were very concerned about the lack of free access in
many zip codes. Advocates also found several errors in the draft plan
including incorrect addresses and listings of stores or ATMs that no longer
existed, which made it difficult to determine if "minimum access"
was met.
Community Input Regarding
the Plan
Getting community input on the cash access plan proved more difficult
than anticipated. One of the first requests that advocates made of county
welfare department (CWD) staff was for them to track where recipients
cashed their paper checks. That way, it would be known where people were
obtaining their cash benefits prior to EBT roll-out, and an effort could
be made to ensure that those areas were well-served by the plan. This
request was considered to be too time consuming and was denied by the
CWD.
Without having the paper checks
traced, it was more difficult to determine where recipients would need
to have cash access locations. Advocates and the CWD conducted some surveys
and found some locations that stood out as locations that would need to
be included in the cash access plan (see Appendix K for a copy of the
survey). There were also a few surprises about where people cashed their
checks (e.g., meat markets and furniture rental stores). Many people cashed
their checks for free through friends or relatives.
Another way that the CWD and
advocates had hoped to get community input was through community forums.
In Alameda County, the Board of Supervisors worked with the CWD to offer
twelve community forums throughout the county. The main purpose of the
forums was to present and discuss the cash access plan and to solicit
community input. All recipients were mailed a multilingual invitation
to the forums one to two weeks prior to the forum dates. The turnout for
the forums was very good, with the majority of the attendees being recipients.
The CWD offered a presentation about EBT, showed the training video (both
with interpretation services) and surveyed recipients about their pre-EBT
cash access habits. With over 800 surveys collected, the CWD learned where
many recipients cashed their checks, how many paid fees, and how much
in fees were paid.
However, since this was the
first series of forums for recipients about EBT, forum attendees were
more interested in learning about EBT, in general, than in providing input
into the cash access plan. Although the community forums might not have
been as successful at soliciting feedback on the cash access plan as intended,
they were successful at educating the community, and recipients in particular,
about EBT. In addition, they helped to educate the CWD staff about the
many questions that recipients had with regard to EBT. (See page 62 of
the PDF version for this report to learn more about community forums.)
Accepting the Cash Access
Plan
While it was only a formality, as the State has the ultimate authority
about whether to accept or reject a county's cash access plan, the Advisory
Committee was unable to reach a consensus about whether or not to recommend
the acceptance of the cash access plan for Alameda County. This was one
of the rare occasions when consensus could not be reached and a vote was
called. The majority voted to recommend rejection of the cash access plan.
At a one-and-a half hour session,
the Board of Supervisors heard from advocates about their concerns, from
the State EBT Team about their commitment to continue working to improve
cash access in Alameda County, and from the county welfare department
(CWD) staff about their confidence that the plan would improve over time.
In the end, and against the recommendation of the advocates, the Board
and the CWD recommended to the State that it accept the cash access plan
for Alameda County.
The Cash Access Plan
in Action
The cash access plan did get better over time, but advocates still feel
that there is room for additional improvement. During the cash access
plan debate in Alameda County, advocates had estimated that under the
plan presented, recipients would pay approximately $70,000 per month in
ATM transaction fees and surcharges. The actual amount paid by recipients
at ATMs to access their cash benefits has been roughly $35,500 for each
of the first two months of EBT. (For further discussion, see pages 17-18
of the PDF version for this report, "ATM Fees Paid by Recipients
in Alameda County.")
Although the cost to recipients
to access their cash benefits has been about half of what advocates had
estimated, it is still substantial. It is unknown whether combined transaction
fees and surcharges paid by recipients in Alameda County are less than
they paid to cash their benefits checks prior to EBT, however, the goal
to minimize the cost to recipients should still be pursued.
Suggestions for Advocates
- Ask to be involved in the
review of the template and draft cash access plans for your county.
- See "Suggestions for
Advocates" under "CASH EBT" for additional suggestions
(pages 18-19 of the PDF version for this report.)
CONVERSION
PROCESS: "MAIL-BASED" or "OVER-THE-COUNTER"
Statewide
"Conversion" refers to the process whereby a county's recipient
caseload will initially be transitioned to the EBT system. All current
recipients at the time of a county's conversion must receive their EBT
cards, PINs, and training materials. Each county must choose a "mail-based"
conversion or an "over-the-counter" conversion methodology.
While one primary method must be chosen, a county could choose to have
some groups (e.g., CalWORKs cases) converted by one method and another
group or subgroup (e.g., GA homeless cases) converted by another method.
Citicorp is required by State
contract to convert each county's caseload. If a county chooses to distribute
EBT cards, PINs, and training materials in the county office(s), the Quest
Group (a Citicorp subcontractor) must provide staff to assist the county
with the over-the-counter conversion. If a county chooses mail-based conversion,
Citicorp will mail EBT cards and training materials to recipients within
the month prior to the county's scheduled roll-out date. Citicorp will
send PINs in a separate mailing approximately two to three days after
sending out the cards and training materials. If a county chooses to do
so, it may send a follow-up notice letting recipients know that they should
have received their EBT cards and PINs, and what to do if they have not.
The Quest Group will also staff walk-in training centers in mail-based
conversion counties. See Section Five of the PDF version for this report
for a discussion on recipient training based on the method of conversion
chosen.
In Alameda County
The Alameda County EBT Advisory Committee voted, nearly unanimously, to
mail EBT cards, PINs, and training materials. This meant that cards would
be mailed out within the month prior to roll-out with two pieces of training
materials: a twelve page pamphlet and a wallet card. Approximately two
to three days later, recipients were mailed their PINs.
The mail-based conversion got
off to a rocky start in Alameda because of a miscommunication about when
the cards and PINs would be sent to recipients. The County sent out a
notice to recipients to let them know that if they had not yet received
their cards, they should call or come into a benefits office. Unfortunately,
since recipients were sent this notice prior to receiving their cards,
many recipients came into the county offices or called to get additional
cards. This resulted in many people getting duplicate cards and not knowing
which card to use during the first week of roll-out.
In addition to the miscommunication
between the State, Citicorp and the County about when EBT cards would
be distributed, there was also concern that the out-of-state return address
on the envelopes containing the cards, PINs, and training materials was
confusing to recipients. Additionally, some recipients reported destroying
their first EBT card because they did not "want a credit card."
The biggest concern regarding
mail-based conversion was theft of the EBT cards and/or PINs, as mail
theft is not uncommon in Alameda County. While mail theft appeared to
be a minimal problem, the process for replacing a card and/or PIN was
sometimes complicated for those who were victims of mail theft.
Although the County EBT Team
had established a convenient system of card replacement, which was supposed
to allow recipients to receive a same-day replacement card at benefits
offices, this was not the experience that many recipients reported. Some
County staff did not understand this policy and instead made recipients
wait to receive their replacement cards in the mail. During the pilot,
while replacement cards were supposed to be received within three business
days, some cards took up to seven to ten days to arrive. In addition,
for those who reported multiple card thefts or losses, the policies regarding
multiple card replacement were not clear.
Most of the county's 30,000-plus
recipients received their cards through the mail. However, exceptions
were made for homeless recipients and some disabled GA recipients, who
were asked to come into benefits offices for training and for EBT card
and PIN issuance. Notices of appointments were put in the envelopes with
benefits checks one month prior to the roll-out date. For the 2,389 Alameda
County recipients who were scheduled to come into a benefits office to
convert to EBT, only 43.2% had attended their appointments by roll-out.
This left 1,356 recipients without their EBT cards, PINs, or training
materials. The majority of these "no-shows" were homeless. Follow-up
with this population was difficult.
Regardless of the problems
during the mail-based conversion, both advocates and County staff agree
that mail-based conversion was the right decision for a county the size
of Alameda, with 19,789 people receiving cash assistance benefits and
20,738 people receiving food stamp benefits (with substantial overlap
in the numbers of people receiving both cash and food stamp benefits).
Over-the-counter conversion would have been a very difficult feat, considering
that County staff struggled to assist those 10% to 20% of the caseload
that had problems during the first week of conversion.
In Yolo County
Yolo County chose an over-the-counter conversion for their 3,000-plus
caseload. Recipients were sent an appointment letter telling them when
and where to pick up their EBT cards, select their PINs, and view a training
video, if they desired. Appointments were scheduled over several days
in the month prior to the roll-out date. The majority of recipients made
it to their scheduled appointments; however, after all appointment days
were over, approximately 30% of recipients still had not picked up their
cards and PINs. County staff made it a priority to contact these recipients
and were able to ensure that the vast majority of recipients had received
their EBT materials prior to the "go-live" date of August 1,
2002.
Yolo County staff provided
a county helpline and help desk throughout the first month of conversion
and scheduled staff lunches to avoid closing services during the day.
Yolo County advocates and County staff agree that over-the-counter conversion
worked best for this county.
Suggestions for Advocates
- Make sure that advocates
and recipients are included in the decision about mail-based versus
over-the-counter conversion.
- Based on the limited experiences
of the pilot counties, generally, over-the-counter conversion works
better for smaller counties and mail-based conversion works better for
larger counties.
- Encourage your county to
work with the State and Citicorp to develop a calendar of when mailings
will be sent to recipients in the month prior to the roll-out date.
- Ask your county to produce
an updated list of cases by language preference to help determine necessary
translation and interpretation services.
- Ask your county to develop
a special conversion plan for homeless, disabled, LEP, and other special
needs populations.
- If your county chooses mail-based
conversion, ask the county to work with advocates to develop a list
of recipient populations who may need to be "excepted" from
mail-based conversion and develop a plan to ensure high turn-out for
scheduled over-the-counter conversion appointments.
- For mail-based conversion
counties, ask your county to send a follow-up notice to let recipients
know that they should have received their EBT cards and PINs in the
mail, and if they have not, to contact the county welfare department.
- Encourage your county to
develop a plan ensuring that the extra flow of recipients in benefits
offices can be accommodated during the first week of roll-out that includes
special considerations for the disabled, limited English proficient
(LEP) speakers, the working, etc.
- Ask your county to keep
track of what percentage of recipients keep their conversion appointments,
and have a follow-up plan for those who do not.
- Work with your county to
develop a plan for following up with recipients who appear on the 10-
and 30-day non-use reports after conversion.
- Request that your county
establish a county helpline and help desk no matter what conversion
method they choose.
ONGOING
CARD ISSUANCE
Statewide
Each county must decide how it will distribute EBT cards and PINs to people
who re-apply, are newly eligible for benefits, or need replacement cards
after the county's initial conversion to EBT. Counties can choose to issue
cards over-the-counter in their benefits offices or have them issued through
the mail by Citicorp. Counties may also choose to use some combination
of the two issuance methods. The county does not have to choose the same
issuance method as was used during the initial county conversion.
According to the County Readiness
Guide (May 15, 2002), when Citicorp receives a request for a new card,
the card "must be delivered to the postal facility no later than
the next business day following the receipt of the card issuance request
by the county." This means that it will take at least two business
days for the recipient to receive the card after Citicorp has received
the request from the county. Then, it will take an additional day or two
for the recipient to receive the PIN for the card. (p. 77) While these
are the timelines that Citicorp must follow in mailing out a card and
PIN, they do not take into consideration possible delays in postal delivery.
Additionally, during the first months of roll-out in the pilot counties,
Citicorp has not been able to meet the contractual guidelines for card
delivery. The State EBT Project Team is working with Citicorp to correct
this problem.
New EBT cards issued by the
county in a county benefits office may be issued as soon as eligibility
is determined and the account has been entered into the EBT system. This
is especially important for the timely distribution of expedited (emergency)
food stamp benefits.
Replacement cards issued through
the mail by Citicorp are supposed to be received by the recipient within
three business days of a card being reported lost, stolen, or damaged.
Counties may choose to issue replacement cards over-the-counter so that
the recipient may get a replacement card sooner than if replaced by mail.
There is no cost to the recipient for a replacement card.
In Alameda County
Alameda County chose to continue issuing new cards by mail. However, they
equipped all of their seven benefits offices with the equipment to issue
replacement cards and cards for recipients of emergency assistance (e.g.,
expedited food stamps).
At the time this Guide was
prepared, the pilot evaluation process was still underway, and we cannot
say how the ongoing issuance via mail is working. In general, however,
there have been reports of the cards taking as long as ten days to be
received. Additionally, some people applying for emergency food stamp
benefits have reported that they have had to return to the office on several
occasions to receive an EBT card.
During the EBT conversion in
Alameda County, it became very apparent that there are many day-to-day
processes performed by county workers that are affected by the new EBT
system, including ongoing benefits issuance. In the attempt to have a
successful and timely conversion to the new system, preparing protocols
for these processes and ensuring that staff are well trained may take
a back seat. Yet, in the long run, it will be these processes and creating
a successful ongoing issuance protocol that will be most important to
the Food Stamp and cash aid programs and recipients.
Suggestions for Advocates
- Participate in your county's
decision to have mail-based or over-the-counter ongoing issuance.
- Advocate for all of your
county benefits offices to be equipped to offer EBT card and PIN replacement
on-site during all hours of operation.
- Ask your county to prepare
a plan, not just choose a method, for ongoing issuance. The plan should
include issuing replacement cards, cards for emergency benefits, cards
for the homebound, cards for the homeless, and additional cardholders.
Additionally, the plan should include strategies for training new enrollees,
especially those with special needs (e.g., LEP, homeless, disabled,
homebound, etc.).
LANGUAGES
OF TRAINING MATERIALS
Statewide
Written EBT training materials available from the State are a brochure,
a wallet card, and a poster for county benefits offices. The written materials
are provided in ten languages: English, Spanish, Chinese (Cantonese/Mandarin),
Vietnamese, Cambodian, Russian, Hmong, Lao, Farsi, and Eastern Armenian.
The EBT training video is available in these languages, including both
Mandarin and Cantonese. These languages were chosen because they are spoken
by a significant percentage of the statewide caseload. Each county must
decide in which of the available languages they would like to have training
materials for their clients.
In Alameda County
Alameda County chose to have all training materials in all available languages.
The County is still in the process of developing a plan to ensure translation
and interpretation for EBT services and materials not provided by the
State and is committed to ensuring that no one is underserved due to language
barriers. The County is currently developing a plan to serve limited English
proficient (LEP) recipients, especially those whose languages are not
supported by Citicorp.
Suggestions for Advocates
- Ask your county to update
its list of cases by language preference.
- Make sure your county chooses
as many translated training materials as is necessary for your county's
recipient population.
- Ask your county to translate
the materials in additional languages, if necessary.
- Help your county to distribute
these materials, especially if your organization serves low-income immigrants.
OTHER COUNTY CONCERNS
Potential Problem Areas
In addition to the decisions that the State requires each county to make,
counties should also be encouraged to consider and plan for potential
problem areas. Some of these areas include:
- What to do for recipients
who will be affected by the change to a uniform food stamp stagger (see
page 38 of the PDF version for this report);
- Training for recipients
with special needs (see page 45 of the PDF version for this report);
- Additional outreach to ethnic
retailers to ensure that they learn about and sign up for EBT;
- Getting cards and PINs to
homeless recipients (see pages 44 and 70 of the PDF version for this
report ); and
- Helping drug rehabilitation
facilities, transitional shelters, and other group living facilities
transition to EBT (see page 55 of the PDF version for this report).
Process-Related Issues
Counties will also have to answer a number of process-related questions,
such as:
- How many notices should
be sent to recipients in advance of EBT roll-out and what should they
say?
- What materials (e.g., direct
deposit applications, cash exemption forms, etc.) should be made available
to recipients through the mail and/or at trainings?
- What additional training
materials may be needed?
- Into which languages should
additional training materials be translated?
- How can (additional) training
materials best be distributed?
- How will recipients be educated
about avoiding transaction fees and surcharges?
- What additional training
should be provided to county staff (e.g., on which types of inquiries
to handle and which to refer to Citicorp, being familiar with and understanding
all client EBT forms, etc.)?
- How will the CWD handle
additional calls resulting from EBT?
- How will additional traffic
in benefits offices after EBT roll-out be handled? and
- Which county staff will
have access to EBT-specific information?
Food Stamp Coupons Can Still
Be Used
An additional important note for all counties to consider is that all
FNS certified retailers must continue to accept paper food stamp coupons,
even after a county has transitioned to EBT, until notice is given by
the USDA that permits retailers to stop accepting paper coupons. This
notice will probably be issued several years after 2002. In Alameda County,
advocates have heard reports of some FNS certified retailers already refusing
to accept paper food stamp coupons.
After learning of this, the
State EBT Project Director sent a letter to Authorized Food Stamp Retailers
reminding them of the requirement to continue to accept paper food stamp
coupons. Counties will need to decide how they will educate retailers
about this policy. (See Appendix L for a copy of this letter.)
SECTION
FOUR: Additional Considerations
In addition to the county decisions
and concerns discussed in Section Three, each county will have several
issues to consider before and during conversion to the EBT system, which
will greatly affect services to recipients. Advocates should be aware
of these issues so that they can work with their county welfare departments
to offer the best EBT system possible to all recipients.
A. Exemptions to Cash EBT
Counties can offer recipients exemptions to cash EBT
on a case-by-case basis for hardship.
B. Three-Day Cash Benefits
Stagger
Cash benefits will become available to recipients
in the first three days of each month. As a result,
some recipients will not receive their cash benefits
until the second or third day of the month.
C. Ten-Day Food Stamp Benefits
Stagger
Food stamp benefits will become available to recipients
in the first 10 days of each month. In some counties,
the food stamp stagger will be different and may result
in a substantial disruption in food stamp benefits for
some recipients during roll-out.
D. Additional Cardholders
Some recipients may need assistance using the EBT
system. One solution for these recipients will include
designating another individual to receive an EBT card
and PIN, with authority to access the recipient's benefits.
E. Recipients with Special
Needs
Homeless, elderly, homebound, and disabled recipients
will have challenges with regard to the EBT system that
need to be addressed prior to roll-out in each county.
F. Limited English Proficient
(LEP) Recipients
LEP recipients have unique challenges with regard to
the EBT system that need to be addressed prior to roll-out.
G. Cash Assistance Program
for Immigrants (CAPI)
The CAPI program in your county may be administered
by another county and, therefore, recipients may receive
their cash benefits by EBT even if yours is a food stamp
-only county.
H. Citicorp Helpline
The Citicorp Helpline is a 24-hour toll-free service
that uses an Automated Response Unit (ARU) and
Customer Service Representatives (CSRs) to assist
recipients with EBT-related issues. The Helpline
"supports" eleven languages, but it has limitations.
I. Group Living Facilities
EBT will mean a change in the way many group
living facilities use food stamp benefits.
J. Farmers' Markets
EBT presents additional challenges for farmers and
farmers' markets, that have yet to be successfully
resolved in California.
K. Personal Security, Privacy,
and Fraud
Using the EBT card exposes recipients to a different
set of personal security issues. Recipients and
advocates have also expressed concerns about
privacy issues and fraud investigations.
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