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Report
Acknowledgements
Glossary
List of Website & Contacts
List of Appendices
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ADDITIONAL
CARDHOLDERS
Statewide
State regulations permit the primary cardholder/recipient to allow other
adult household members to receive their own EBT cards and PINs and to
access the primary cardholder's account. A recipient who is unable to
maneuver the EBT system is also permitted to designate a person(s) outside
of the household to receive his or her own EBT card and PIN and to access
the recipient's benefits. The primary cardholder/ recipient will have
the option to allow access to food stamp benefits, cash benefits, or both
types of aid; however, he or she will be unable to limit access to a specific
dollar amount.
Other
Adults in the Household
State regulations allow for additional household members, at the option
of the primary cardholder, to have their own EBT cards and PINs to access
the primary cardholder's benefits. (See MPP 16-505.) State policy says
that the additional household member must be an adult. (See Appendix Y.)
The additional cardholder will have full access to the household's food
stamp benefits, cash benefits, or both, depending upon the authorization
given. Access to a limited dollar amount is not permitted.
Cardholders
Outside of the Household
For some instances in which a recipient will not be able to maneuver the
EBT system, he or she may need to designate a person outside of his or
her household to receive an EBT card and PIN and to act on his or her
behalf. State regulations say that this other person must be a responsible
adult, but that if the county welfare department determines that there
is no responsible adult available, the recipient may designate a minor.
(See MPP 16-505.22.) This person is referred to as an "Authorized
Representative (AR)" for food stamp benefits or a "Designated
Alternate Cardholder (DAC)" for cash benefits.
An AR receives an EBT card
and PIN and is authorized to make food stamp purchases on behalf of the
recipient. ARs have complete access to all of the recipient's food stamp
benefits. ARs may also be used as an alternative for group living facilities,
such as shelters or drug rehabilitation facilities, enabling staff to
make food stamp purchases for the residents of the facility. (See page
55 of the PDF version for this report for a discussion of group living
facilities.)
A DAC receives an EBT card
and PIN and is authorized to access the recipient's cash benefits. DACs
have complete access to all of the recipient's cash benefits.
A recipient could choose to
designate one person to act as both AR and DAC, or could choose one person
as his or her AR and another as his or her DAC. ARs and DACs will be issued
their own cards with their own primary account numbers (PANs) and PINs.
If a designated person acts as both AR and DAC, that person will receive
one card and PIN with both types of benefits accessible through the card.
The EBT system currently will
not limit access to a dollar amount for either type of benefit. In the
case of a person who is acting as both a recipient's AR and DAC, that
AR/DAC will have total access to all of the recipient's food stamp and
cash benefits.
Such complete access to a recipient's
account is a change from the pre-EBT process in which, for example, an
AR could be given a $20 food stamp coupon to purchase items on behalf
of the recipient, or limited cash could be given to a neighbor or child
to make a purchase. If ARs or DACs misuse any or all of the benefits,
benefits will not be replaced.
Because EBT implementation
increases the vulnerability of recipients dependent upon ARs and DACs,
many advocates around the state have been asking the State to consider
a concept called, the "kiddie card" or "kid card."
A kid card could be given to a child or a neighbor, who would have access
to a limited dollar amount of the recipient's benefits. This request has
been denied by the State, but advocates hope that with enough evidence
of how harmful not having the option of a kid card could be to recipients,
the State may reconsider.
The State has, however, encouraged
counties to incorporate training regarding an AR's unlimited access to
benefits through the EBT system and to develop a procedure for confirming
the AR designation of each recipient. Presumably, this recommendation
also applies to DACs.
In Alameda County
Alameda County's welfare department staff thought it very important that
recipients who had an AR fully understand how the new EBT system would
impact them. They made an effort to contact each case with an AR and cleaned
up many of the case files. They found that some of the AR information
was outdated. This was important because the EBT system would require
full training of the recipient and the AR. This project was larger than
first anticipated, with over 3,000 AR cases to review.
In addition to addressing the
situation of recipients with ARs prior to EBT roll-out, the County had
to consider recipients that might now need to designate ARs or DACs because
they are unable to use the new EBT system. As mentioned above, homebound,
LEP, and disabled recipients have benefit access barriers that are enhanced
by EBT. For recipients unable to access benefits due to language barriers
or disability, State and County officials have recommended that recipients
designate an AR and/or DAC. It should be noted, however, that designating
ARs or DACs could make these recipients more susceptible to abuse.
One problem that the County
had in designing a system for recipients to sign up for ARs prior to EBT
roll-out was that the County had to develop a new form for designating
an AR that related to the new EBT process. Unfortunately, with all that
the County had to accomplish during roll-out, the translations of the
forms were not completed prior to EBT roll-out.
Suggestions for Advocates
- Ask your county if they
will be reviewing their database for ARs and Protective Payees and recommend
that they get an early start.
- Ask your county whether
they will be creating a form (with necessary translations) that informs
recipients of the complete access that ARs/DACs will have to benefits
with the EBT system.
- Ask your county if they
have prepared an Additional Cardholder designation form or if they plan
to use the State-developed form. You may wish to review the Alameda
County form and offer it to your county as a starting point.
- Ask your county whether
the Additional Cardholder form will be available in all necessary translations
well in advance of roll-out. Make sure that these forms are available
at all recipient trainings.
- Document stories of those
in your county that could benefit from a "kid card" and share
them with county and State officials.
RECIPIENTS
WITH SPECIAL NEEDS
Statewide
Special needs populations include any recipient group that might need
special consideration with regard to EBT, including: the homeless, limited
English proficient (LEP) recipients, recipients with low-literacy skills,
the elderly, the physically disabled, the mentally disabled, homebound
recipients, and survivors of domestic violence. In general, it is these
recipient populations who will need the most attention to ensure that
EBT works well for everyone. As the State has developed very few processes
to address the special needs of these populations, it is up to the counties
to develop plans to meet the needs of their most vulnerable clients.
In Alameda County
There were several lessons learned from the experience of rolling out
EBT to people with special needs in Alameda County.
First, a major concern with
regard to special needs populations is that the process for cash EBT exemption
(or "opt-out") for hardship was not well-publicized or easy
to access. While we believe the Alameda County form (see Appendix M) is
more client-friendly than the State form, due to the collaboration between
the County and community in developing this form, it is still not readily
available at county offices and two months after roll-out, some staff
were still not familiar with the exemption process. One thing Alameda
County did do was to include notice of the exemption option in the client
mailings. This notice inclusion was in response to a request made by advocates.
A second concern with regard
to special needs populations was that those who may be least able to request
an exemption from cash EBT would also be those who needed it the most.
Alameda County advocates requested a categorical exemption for certain
special needs populations (e.g., homeless, GA with SSI pending, elderly
LEP); however, neither the County nor the State supported this option.
Based on non-use reports, it appears that this might have been a more
successful strategy to take with the homeless population. (See page 34
of the PDF version for this report for further discussion of the "opt-in"
approach.)
Other significant concerns
are about access issues that affect all recipients, but that have an added
impact for people with special needs. These include:
- County staff, especially
frontline staff, were not trained on how to assist people with special
needs issues to access EBT and to identify good cases for exemptions
from cash EBT or the three-day cash stagger.
- The overwhelming number
of recipients going into benefits offices needing help with EBT, and
insufficient frontline staff during the first weeks of roll-out, caused
recipients to wait for several hours - sometimes requiring them to return
on subsequent days. During these first hectic days, seats were not available
to serve all those who needed them, LEP recipients stood in long lines
before they knew which were the correct lines to stand in, and the mentally
disabled were not given the time that they needed for special training
or considerations.
- Not all retail personnel,
even at large retailers, were adequately trained on EBT in general,
and on assisting people with special needs, in particular.
- Advocates had anticipated
that the Citicorp Helpline would be able to assist callers with most
of their questions. During the first few weeks of roll-out, however,
this was not the case. The Helpline could not answer many of the questions
recipients had with regard to the availability of their benefits and
referred them to the county welfare department. Because Alameda County
did not have its own EBT assistance helpline (as Yolo County did), homebound
recipients and those with limited travel ability (due to small children,
work, or transportation difficulties) were especially vulnerable.
- With EBT, tracing missing
funds now takes 15 business days, rather than the seven days it used
to take with the old system. This represents a significant and unacceptable
delay for any low-income person, but especially for those who, because
of mental disabilities, more often find themselves in the situation
of having to request a "tracer."
- While it was the County's
written policy to replace EBT cards in the benefits offices, frontline
workers (and managers) were not always clear about this policy and would
tell recipients that their replacement cards would be mailed to them.
This caused unnecessary delay and hardship for recipients.
Suggestions for Advocates
- Request that your county
designate a key person on its EBT team to be responsible for serving
people with special needs.
- Request that your county
have an EBT helpline and a help desk at each site during at least the
first two months of roll-out.
- Request that your county
be equipped with machines to replace cards and PINs at each benefits
office open to the public and that frontline staff offer recipients
the opportunity to receive a same-day replacement card.
- Request that the State provide
a plan for training retailers in your county about EBT transactions
and special needs that some recipients may have.
- Ask your county to create
a service plan for the first two weeks of roll-out for each benefits
office. Yolo County offers a good example with an EBT helpline, a help
desk, rotating lunch hours, etc.
- Ask your county to adopt
Alameda County's version of the Request for Exemption from Cash EBT
form (Appendix M), which is more client-friendly than the State's model.
Make sure your county has translated copies of this form available before
roll-out.
- Ask your county to mail
an announcement to recipients about their right to request to "opt-out"
of cash EBT or the cash stagger for hardship, well in advance of roll-out,
and to provide this information at all recipient trainings.
- Ask the State to reconsider
categorical exemptions for CalWORKs recipients with special needs or
your county to consider categorical exemptions for GA populations with
special needs (particularly the homeless).
LIMITED
ENGLISH PROFICIENT (LEP) RECIPIENTS
Statewide
Citicorp is contracted to support EBT services in eleven languages: English,
Spanish, Cantonese, Vietnamese, Cambodian, Russian, Hmong, Lao, Farsi,
Mandarin, and Eastern Armenian. These languages were chosen because they
are spoken by a significant percentage of the statewide caseload.
Written training materials
provided by the State are in ten languages. (Only one version is necessary
for the supported Chinese dialects.) The written materials are an EBT
training pamphlet, a wallet card, and a poster for county offices. The
training videos and audio tapes are in all eleven languages. For information
about these materials, see pages 66-69 of the PDF version for this report.
Citicorp also offers a toll-free
Customer Service Helpline; however, service for LEP recipients is limited.
For more information about the Helpline, please see page 51 of the PDF
version for this report, "Citicorp Helpline."
Advocates also have concerns
about limited service to LEP merchants. This is particularly important
due to the fact that many LEP recipients shop at ethnic grocery stores,
many of which are owned and operated by people with limited English skills.
In Alameda County
Alameda County welfare department staff and advocates realized early that
translation and interpretation services were key to a successful EBT transition.
One of the first things that the County did was to run statistics on how
many recipients there were in each language group in Alameda County. In
most cases, the County translated printed materials and offered interpretation
services in the five languages that each represent 5% or more of the county's
caseload. The following are some of the areas in which the County provided
translation and/or interpretation services:
- Notices sent to recipients
each month during the five months prior to implementation;
- At all thirteen public forums
held by the county in advance of conversion;
- All related forms and handouts;
- The walk-in trainings;
- The calls to recipients
who appeared on the non-use reports showing that they
had not accessed their benefits within the first ten days after conversion;
and
- Outreach to LEP merchants.
The county welfare department
also realized the importance of having certain forms or materials translated
in as many languages as were represented in the total caseload. These
forms and materials include:
- The Additional Cardholder
form allowing others to have access to the recipient's benefits (Appendix
O);
- The Request for Exemption
from Cash EBT form (or "opt-out" form) allowing recipients
to request to continue receiving cash assistance by means of a paper
check (Appendix M );
- The EBT Card and PIN Responsibility
Statement form (Appendix P); and
- The Exemption from Cash
EBT Stagger form (Appendix N).
In addition to providing translation
and interpretation services, the county welfare department staff helped
to convene an LEP subcommittee that met twice monthly to address issues
regarding LEP recipients and merchants. At the request of the subcommittee,
the county welfare department committed to publish an LEP plan that detailed
how LEP recipients would be transitioned to EBT. Particular concerns that
the LEP subcommittee had regarding the transition to EBT included the
following:
· ATM and POS machines
usually only use English and Spanish to communicate with customers;
· Lack of training materials available for LEP recipients speaking
languages other than the ten for which written material was printed by
the State;
· Limitations of the Citicorp Helpline for LEP recipients;
· The need for the County to have interpreters available at all
training sites and to be prepared to interpret incoming calls during the
first months of implementation; and
· Despite the obvious need to evaluate how this population is affected
by EBT, neither the State nor the County plans to evaluate the success
of EBT specifically for LEP recipients. The quality of translation and
interpretation services may continue to be an issue of concern resulting
in confusion for a recipient population that may already be challenged
by the new system.
Some of these concerns are
highlighted in a Q&A handout developed during the Alameda County pilot
to help educate the community about these issues. See Appendix Z for a
copy of this LEP Q&A handout.
In addition to the concerns
related to EBT specifically, the LEP subcommittee was concerned that some
of the general problems that LEP recipients had with accessing benefits
prior to EBT would only be exacerbated during and after EBT roll-out.
For example, many of the County's recipients had their language incorrectly
coded in the County's database, which meant that they would not receive
information or follow-up phone calls in a language that they could understand.
In some cases, this occurred because the county computers did not have
codes for some languages even though many recipients in the county speak
this language (e.g., Bosnian). Another example is that even when the county
welfare department does have a person on staff who can interpret, they
are often not well enough informed to answer specific questions that have
a technical nature, as is the case with EBT, so recipients could get incorrect
or incomplete answers when depending on county welfare department interpreters.
Because of the numerous concerns
regarding the LEP recipient population, a group of advocates participating
in the LEP subcommittee requested that the County exempt all LEP General
Assistance (GA) recipients and give them the option to "opt-in"
to the EBT system should they wish to participate in cash EBT. This request
was made because it was learned that a large majority of GA recipients
who were LEP were also either elderly or disabled or both. The GA program
is a county administered program and, therefore, the Alameda County welfare
department had the authority to agree to this request; however, the request
was denied. (See page 34 of the PDF version for this report for more information
about the request made by advocates.)
Suggestions for Advocates
- Establish an LEP committee
or subcommittee for the EBT transition.
- Request that your county
develop a plan for EBT conversion specific to LEP recipients.
- Request that your county
update and supply data regarding the number of LEP recipients (broken
down by language) in your county.
- Ask your county what translation
and interpretation services will be available to recipients during trainings
and walk-in days and for all forms, mailings, and follow-up calls. This
could be part of the county's implementation plan.
- Ask the State to explain
how they plan outreach to, and support for the needs of, ethnic grocers
- especially those with limited English skills.
- Request that the State expand
the Citicorp Helpline services for LEP recipients.
- Request that your county
exempt from cash EBT all LEP General Assistance recipients who are either
elderly or disabled from cash EBT - allowing them to "opt-in"
should they choose to do so.
CASH
ASSISTANCE PROGRAM FOR IMMIGRANTS (CAPI)
Statewide
The Cash Assistance Program for Immigrants (CAPI) is a state-funded program
for immigrants who are not eligible for SSI or Social Security. It is
administered by counties. CAPI recipients are low-income immigrants who
are disabled or elderly and are not U.S. citizens.
Each county that administers
the program will have the opportunity to choose whether or not CAPI payments
will be delivered by the EBT system. It is important to note, however,
that some counties do not administer CAPI for recipients in their own
county. For example, San Mateo County administers CAPI for Alameda and
other counties. As a result, the decision to use EBT for cash benefits
in Alameda County may not apply to CAPI recipients in Alameda County,
unless San Mateo County decides to use EBT for CAPI. All county decisions,
forms, timelines and procedures that apply to EBT transition in San Mateo
County will affect CAPI recipients in Alameda County. It is unclear how
many other counties across the state are in a similar situation.
The State EBT Team is currently
considering how to deal with this issue and could possibly request that
CAPI recipients with a county administrator other than their county of
residence should continue to receive cash warrants. However, due to the
way CAPI is administered, it is also possible that even if a county is
a food stamp-only county, CAPI recipients in that county may be converted
to cash EBT.
In Alameda County
In Alameda County, CAPI recipients have not yet transitioned to EBT because
the CAPI caseload for Alameda County is administered by San Mateo County.
San Mateo County is not scheduled to roll out EBT until February 2003
and it is not certain whether they will be distributing CAPI benefits
through the EBT system.
Advocates in Alameda County
have been concerned about the CAPI population who tend to be limited English
proficient (LEP) and are elderly or disabled. Because San Mateo County
administers the program, advocates in Alameda County have had little success
getting information about if and how EBT will be administered for CAPI.
As a result, little is known about the kind of special consideration that
may be needed to assist this population during and after EBT roll-out.
Suggestions for Advocates
- Find out early whether your
county administers CAPI for recipients in your county. If your county
does not administer the program, find out which county does and determine
whether that county has chosen cash EBT for CAPI recipients and when
it will roll out EBT.
- If your county is one that
administers the program for other counties, find out which counties
and consider contacting immigrant advocates in those other counties.
- Find out how many CAPI recipients
reside in your county and what their primary languages are.
- Meet with immigrant advocates
and the CAPI administrator (either in your county or in the administering
county) to discuss whether CAPI will be included in cash EBT or not,
and to propose special consideration and procedures, such as "opt-in"
for the elderly and disabled, before roll-out.
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