MEMORANDUM

DISCUSSION:

The Food and Nutrition Services (FNS) of the United States Department of Agriculture (USDA) has determined that frequent electronic benefit transfer (EBT) card replacement requests may be an indicator of fraudulent activities.

In our ongoing efforts to promote Food Stamp program integrity a second report of four or more card replacements in the 6 months between October 2012 and March 2013 has been obtained from FIS/eFunds, the EBT card vendor. This report compared to the last report introduced in IM Memorandum IM-#107, dated December 26, 2012 FOUR PLUS EBT CARD REPLACEMENT REQUESTS IN TWELVE CALENDAR MONTHS shows 117 individuals on both reports continue to request replacement cards.

Emails will be sent to each county with an individual listed on both of the reports. Take the following actions:

• Send a request for contact to each individual to schedule an interview to determine why they continue to request replacement cards.
• Provide the individual with the IM-4EBT pamphlet and the IMPORTANT INFORMATION ABOUT ELECTONIC BENEFIT TRANSFER (EBT) TRANSACTIONS (IM-3EBT) form.
• Obtain an IM-3EBT signed by the individual that was interviewed because of frequent replacement requests. Put a copy in the case file and provide a copy to the individual.
• After interviewing the individual determine if they have a legitimate reason for replacements or if there is indication of fraudulent activity.

  EXAMPLE: Individual did not understand their card stays active and can be used each month regardless of the EBT account balance. This would be a legitimate reason for requesting replacements and the individual should be given the correct information regarding their EBT card.

• Record a comment on the Eligibility Unit Member Role (EUMEMROL/FM3Z) screen in FAMIS regarding the interview and information provided to the individual.
• If there is indication of fraudulent activities make a referral to the Welfare Investigation Unit by completing the Referral for Investigation (DOI-1) form and scanning it to DLS.ReportFraud@dss.mo.gov.
• Complete the spreadsheet sent with the email and return to ColeFSPolicy@dss.mo.gov.

FSD will be mailing letters to the remaining participants named on the report informing them that their EBT account will be monitored for replacement requests and if they continue to request replacement cards their case may be investigated to ensure the card is not being used in fraudulent activities. The letter lists violations of the Food Stamp program.

The FSD will monitor the impact of the letters by comparing the four plus EBT card replacement request report for the period ending March 2013 with the report that will be requested for the period ending September 2013.

The letters will be mailed in May 2013. These letters may cause the participants to contact the FSD INFO Center or the local FSD offices for more information. The FSD must protect vulnerable populations such as frail elderly, homeless, or disabled individuals who may lose their cards repeatedly but are not committing fraud.

The FSD staff must not deny replacement card requests from individuals that have received the letter. Share information with participants on proper use of the EBT card and offer an IM-4EBT and IM-3EBT when the contact is in-person. Record a comment from the Eligibility Unit Member Role (EUMEMROL/FM3Z) screen in FAMIS documenting the reason for and response to the participant contact.

If FSD staff receives reports of Food Stamp participant fraud, record the participant's name if known, the store name, address, telephone number, and details about the incident on the Referral for Investigation (DOI-1) form. Scan the information to the Welfare Investigation Unit at DLS.ReportFraud@dss.mo.gov and record a comment on the Eligibility Unit Member Role (EUMEMROL/FM3Z) screen in FAMIS.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

ATTACHMENTS:

• FOUR PLUS EBT CARD REPLACEMENT REQUESTS LETTER
• Referral for Investigation (DOI-1) form
• WIU REGIONAL MAP

AC/cb