FISCAL NOTE
Date Requested: January 22, 2024
Time Requested: 01:31 PM |
| Agency: |
Human Services, WV Department of |
|---|
| CBD Number: |
Version: |
Bill Number: |
Resolution Number: |
| 1913 |
Comm. Sub. |
SB450 |
|
|---|
| CBD Subject: |
Human Services |
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|
FUND(S):
0403 - DIV OF HUMAN SERVICES GENERAL ADMINISTRATION FUND, 8722 - CONS FEDERAL FUNDS DIV HUMAN SERVICES GEN ADMN FD
Sources of Revenue:
General Fund Federal
Legislation creates:
Fiscal Note Summary
Effect this measure will have on costs and revenues of state government.
The purpose of this bill is to require photo EBT cards to be used beginning July 1, 2024.
The bill indicates photos shall be provided by the Division of Motor Vehicles. Therefore the cost for photos is not included in this fiscal note.
Implementation of a State EBT Photo ID requires development of an extensive and detailed plan under Federal rule 7 CFR 274.8(f)(14)(iii) and submission of the plan to FNS for approval before beginning an EBT photo ID process. Without FNS approval, EBT photo ID cannot be implemented without possible loss of grant funds.
The Department estimates additional costs related to this legislation would be $14,620,405 ($7,030,711 state) for FY2025 and $8,953,112 ($4,197,065 state) for future years.
Fiscal Note Detail
| Effect of Proposal |
Fiscal Year |
2024
Increase/Decrease
(use"-") |
2025
Increase/Decrease
(use"-") |
Fiscal Year
(Upon Full
Implementation) |
| 1. Estmated Total Cost |
0 |
14,620,405 |
8,953,112 |
| Personal Services |
0 |
2,858,312 |
2,858,312 |
| Current Expenses |
0 |
11,725,805 |
6,094,800 |
| Repairs and Alterations |
0 |
0 |
0 |
| Assets |
0 |
36,288 |
0 |
| Other |
0 |
0 |
0 |
| 2. Estimated Total Revenues |
0 |
0 |
0 |
Explanation of above estimates (including long-range effect):
With a change of this magnitude, a pilot is recommended to assess impact to retailers and clients before rolling out to everyone. Therefore costs indicated include estimates from EBT vendor for pilot rollout and statewide rollout in regards to testing and analysis at initial pilot and full rollout.
Expenses totaling $14,620,405 include:
a) the development of hours for the design and development of a photo ID card by the EBT vendor ($90 hour x 5,277 hours) = $474,930.
b) mass replacement/issuance of new/existing EBT cards at $6 per card for all EBT cards (1,225,000 cards) = $7,350,000.
c) creation of photo ID Summer EBT cards for the new summer student benefit at $12 per card (224,000 cards) = $2,688,000.
d) destruction of cards replaced at $35 per 1,000 (1,225,000 cards) = $42,875.
e) communication to retailers estimated at $86,400 (estimate from EBT vendor)
f) pilot for photo ID at $86,400 (estimate from EBT vendor)
g) statewide ID rollout at $288,000 (estimate from EBT vendor)
h) FIS call center initial cost $32,400 (estimate from EBT vendor)
i) FIS call center monthly fee $288,000 ($24,000 mo x 12 mo)
j) Administrative Service Assistant 2 for EBT banking services $63,399 (average salary $46,962 + 35% EB of $16,437)
k) Install photography equipment for 54 DHHR offices with secured location for photography system for mass replacement as well as monthly card issuances = $36,288 ($672 x 54 offices)
l) Picture transmission = $216,000 (from contractor)
m) Picture storage = $172,800 ($14,400 x 12 mo)
n) Economic Service Worker for 54 DHHR offices $2,794,913 (average salary $38,339 + 35% EB of $13,419 x 54)
Future year expenses totaling $8,913,592 include:
a) Replacement/issuance of new EBT cards at $6 per card for all EBT cards (455,000 cards) = $2,730,000.
b) Replacement/issuance of photo ID Summer EBT cards for the new summer student benefit at $12 per card (224,000 cards) = $2,688,000.
c) FIS call center monthly fee $288,000 ($24,000 mo x 12 mo)
d) Administrative Service Assistant 2 for EBT banking services $63,399 (average salary $46,962 + 35% EB of $16,437)
e) Picture transmission = $216,000 (from contractor)
f) Picture storage = $172,800 ($14,400 x 12 mo)
g) Economic Service Worker for 54 DHHR offices $2,794,913 (average salary $38,339 + 35% EB of $13,419 x 54)
The Department anticipates the need for an Interface between the eligibility system and the EBT system that can't be quantified until it is determined how these systems will work together.
Memorandum
Photo IDs would put an undue burden on retailers, possibly discouraging them from participating in SNAP redemption. Since all relatives must be able to use the SNAP card to purchase groceries on behalf of the primary/beneficiary, state must have procedures in place for eligible members of the household to use the SNAP benefits. The solution for this access for all eligible members could would be difficult and would add more cost.
EBT card expenses are supported by federal SNAP grant funds approved by the USDA Food and Nutrition Service for SNAP. Benefits for SNAP clients are 100% federally funded. Prior to implementation, the state would need to satisfy 7 CFR 274.8(f)(14)(iii) which requires an implementation plan to include a description of the proposed procedures for opting into a voluntary photo EBT card policy and documenting that a household voluntarily chose to have a photo on its EBT card. Specifically, the plan will need to show how the opt-in process will protect clients’ right to not have a photo on the card in voluntary programs.
Implementation of photo ID for EBT cards requires mass change for over 1,225,000 new cards. There are no revenues associated with this project and expenses to the state, if approved by FNS would at least require the state to pay 50% of administrative costs for SNAP and 100% of costs for WV WORKS. This initiative will not provide any additional food or cash benefits to clients.
In addition, Supplemental Nutrition Assistance Program (SNAP) benefits are designed to be used by all members of the household. About 1/3 of SNAP caseloads are elderly or disabled individuals who can appoint a caregiver who does not live in the household but can buy food with the EBT card. A single photo would not represent all legitimate users of the card. Federal regulation prohibits retailers from treating SNAP customers differently from other customers; retailers would be required to ask for photo ID for all customers which could result in customer complaints and clerk liabilities for not checking IDs for all customers. The USDA reports that the main type of SNAP trafficking involves colluding retailers trading cash for false SNAP-related transactions in which a photo ID would not make a difference.
Per FIS, a photo ID card would require 18 months of development after the state receive approval from FNS.
Person submitting Fiscal Note: Cynthia A. Persily, Cabinet Secretary
Email Address: dhhrbudgetoffice@wv.gov