FISCAL NOTE
Date Requested: January 22, 2019
Time Requested: 01:08 PM |
| Agency: |
Health and Human Resources, WV Department of |
|---|
| CBD Number: |
Version: |
Bill Number: |
Resolution Number: |
| 2620 |
Introduced |
HB2581 |
|
|---|
| CBD Subject: |
Governmental Agencies, Health |
|---|
|
FUND(S):
0403 - Division of Human Services Gen Admin Fund, 8722 - Cons Fed Funds Div Human Services Gen Admin Fund
Sources of Revenue:
Other Fund General & Federal
Legislation creates:
Creates New Expense
Fiscal Note Summary
Effect this measure will have on costs and revenues of state government.
The purpose of this bill is to require recipients of Supplemental Nutrition Assistance Program be issued a photo identification card that must be used when making program purchases. The bill establishes penalties for misuse. The bill also requires rule-making.
The Department estimates the cost for this legislation to be $874,600 for FY2020 and $45,000 going forward.
Fiscal Note Detail
| Effect of Proposal |
Fiscal Year |
2019
Increase/Decrease
(use"-") |
2020
Increase/Decrease
(use"-") |
Fiscal Year
(Upon Full
Implementation) |
| 1. Estmated Total Cost |
0 |
874,600 |
45,000 |
| Personal Services |
0 |
0 |
0 |
| Current Expenses |
0 |
485,800 |
45,000 |
| Repairs and Alterations |
0 |
0 |
0 |
| Assets |
0 |
0 |
0 |
| Other |
0 |
388,800 |
0 |
| 2. Estimated Total Revenues |
0 |
0 |
0 |
Explanation of above estimates (including long-range effect):
Expenses include a) the development hours from the EBT vendor estimated at 3,958 hours at $100/hour ($395,800), b) photographic equipment for 54 locations at $7,200 per unit ($388,800), c) retailer enablement and pilot implementation costs ($45,000) and statewide rollout ($45,000).
Memorandum
SNAP and WV Works benefits are issued on the Mountain State EBT card. Each case can have one or multiple cards, based on the number of eligible members plus any authorized representatives assigned to the case - with each eligible member having their own individual card. The authorized representatives frequently change, requiring issuance of a card to the new authorized representative. EBT cards are ordered by the Local DHHR Office and mailed to the client in 7-10 days. The process for adding photo IDs would involve a) submitting a comprehensive implementation plan to FNS for approval, b) development, quality control, user testing, system certification by the vendor, c) implementation decision - voluntary or mandated photos on cards, which determines how cards will be replaced and whether the current card will remain active until replaced, d) destruction of the cards that are replaced, e) procurement of photography equipment for 54 local offices and securing a location for housing the photography system, f) development of a system for transmitting pictures to the card vendor for creating the cards that are mailed to the cardholder, g) procurement of a picture storage solution, h) implementation personnel as well as permanently assigned staff to take photos, i) development and procurement of technology required for system interface, j) on-going maintenance and materials for daily processes, and k) implementation, training and development needed for retailer participation.
Due to the vague language of the bill the following charges are difficult to quantify: a) destruction of cards at $35.00 per thousand, b) on-going production of cards with photograph at $0.60 per card. Unable to quantify as the total required is unknown.
Food Nutrition Services amended the SNAP regulations at 7 CFR parts 271, 272, 273, 274 and 278 to codify and expand guidance that was issued December 29, 2014, requiring State agencies that intended to implement the photo EBT card option under Section 7(h)(9) of the Act, 7 U.S.C. 2016(h)(9) to submit a Comprehensive Implementation Plan to ensure state implementation is consistent with federal requirements and that program access is protected for participating households. The Supplemental Nutrition Assistance Program: Photo Electronic Benefit Transfer (EBT) Card Implementation Requirements rule, which clarifies the SNAP regulations, became effective on January 12, 2017.
State agencies are prohibited from having photo EBT card requirements that affect the household's eligibility or the certification process.
All household members and any other individual permitted by the household have the right to use the EBT card to purchase food or meals on behalf of the household, regardless of whether their photo is on the card.
Retailers cannot require an ID from an EBT cardholder.
Households have the right to permit other individuals to use the household's EBT card on an ad hoc basis for the purpose of attaining assistance with purchasing food, whether or not the State has a photo EBT requirement.
Anyone with a valid PIN may use the card even if he/she is not pictured on the card.
Equal treatment as provided in program regulations at 7 CFR 278.2(b) and 274.7(f).
Retailers would have to require IDs from anyone using a credit card for tender to require an ID from an EBT cardholder.
Federal regulations must be adhered to in order for federal funding not to be jeopardized.
Person submitting Fiscal Note: Bill J. Crouch
Email Address: Bill.J.Crouch@wv.gov