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Question of the Month ~ February 2014


Q. Can states require a photo ID on the electronic benefit transfer (EBT) cards used by individuals who receive food stamps?

Under federal law, states can require that EBT cards for the Supplemental Nutrition Assistance Program (SNAP) include photos of the beneficiaries or that customers show photo ID to use the cards.
Massachusetts is the only state that currently has such a law.
SNAP is federally funded, but administrative costs are shared by states and the federal government. The photo ID requirement on SNAP cards aims to stop “trafficking” — trading food benefits to others for cash. According to the U.S. Department of Agriculture, the rate of trafficked benefits is about 1.3 percent, which would equal about $970 million in fiscal year 2012. The rate of trafficking, the USDA says, is down from 4 percent roughly 15 years ago. That’s in part because modern electronic cards and personal identification numbers offer increased security and allow purchases to be more closely monitored.
A 2012 study in Pennsylvania estimated the cost of putting photos on SNAP cards at $8 per card (versus 23 cents for cards without photos). Missouri stopped such a program in 2001 due to a lack of significant cost savings. Massachusetts had abandoned the use of photos on EBT cards in 2004, citing high administrative costs in relation to success in deterring fraud. But under a law passed last year, the state has 12 months to replace EBT cards with versions that include photos.
When a state passes legislation requiring photo ID to use SNAP benefit cards, it must then comply with several federal requirements.
One such rule is that relatives must be able to use the SNAP card to purchase groceries on behalf of a beneficiary. Therefore, if states require photos on EBT cards, they must have procedures in place for eligible members of the household to use the card. Critics point out that this process could be unwieldy, and they have raised concerns that it would be difficult and costly — if not impossible — to keep track of this information.
Under federal rules, too, SNAP beneficiaries cannot be treated differently than other shoppers; so, in states that implement the photo ID provision, SNAP retailers must ask all customers for photo identification.
These requirements, some say, would place an undue burden on retailers, discouraging them from participating in SNAP. Federal rules also stipulate that state-issued SNAP cards be usable in other states.
Critics of the photo ID requirement say that most “trafficking” requires participation by a dishonest retailer, and that a photo ID would not curb this type of fraud. Such a requirement could also compel beneficiaries to visit a state office and get a photo taken.
Bills to add photos to SNAP cards have been introduced in at least three Midwestern states (Illinois, Michigan and Minnesota) over the past three years. Last year, separate bills in Illinois would have required photos on all EBT cards (HB 1235) or on all new cards (SB 1531).


Article written by Kate Tormey, staff liaison to the Midwestern Legislative Conference Health & Human Services Committee. Deb Miller, director of health policy for CSG, contributed to this article. Question of the Month highlights an inquiry received by CSG Midwest; to request assistance, please contact us at csgm@csg.org or 630.925.1922.